77 replies to this topic

[martyn]

To be fair, there is not too much to discuss.

The legislation is what it is - it's not up for discussion.

The interpretation may be however, and that is guided by Wayne's document and the various other approved documents.

No matter which way you try and tweak it, it 'only' (and I don't mean that in any way ungratefully) gives us the ability to do small scale genuine experiments - not to manufacture enough pyro for a November spectacular, once you grasp that it all seems clearer.

Perhaps now is the time for doing not talking - still feel the need to look over my shoulder though.

[Arthur Brown]

While the ELR committee was in session it was bad form to overtly publish things that you had done, lest the publication may skew the outcome of the review. 

Now the review is finalised and the results published it really is up to us to use the new regs correctly, and to use the guidelines correctly and publish the results of our experiments (on here).

[digger]

To be fair, there is not too much to discuss.

The legislation is what it is - it's not up for discussion.

The interpretation may be however, and that is guided by Wayne's document and the various other approved documents.

No matter which way you try and tweak it, it 'only' (and I don't mean that in any way ungratefully) gives us the ability to do small scale genuine experiments - not to manufacture enough pyro for a November spectacular, once you grasp that it all seems clearer.

Perhaps now is the time for doing not talking - still feel the need to look over my shoulder though.

 

Not necessarily so, yes you can't build 8" shells, but you should be able to build a good selection of 100 gram devices that would put much of the commercial CAT 3 stuff to shame. 

[martyn]

I suppose you could make a very sparse 8" :-)

Launched by a separate experimental device.

[MrDan]

There is one question that I still have outstanding with the HSE regarding schedule 2 and that is, "fireworks" of all classifications are not present in the list.  Schedule 1 of COER included "fireworks" of all classifications.  In theory, because of this it would appear that an explosives certificate IS required to obtain fireworks.  Of course, this can't be the case but up to press I can't seem to find any other exemption!  I'm still waiting for the HSE to clarify so a bonus point for anyone who can! 

 
Are they not classed as pyrotechnic articles and so covered under 5(3)(b )?
 
 

(3) Paragraphs (1) and (2) do not apply to —
(a) the explosives as referred to in Schedule 2;
(b ) pyrotechnic articles apart from those as referred to in Schedule 3; or
(c ) ammunition the acquisition of which is regulated or prohibited by virtue of the Firearms
Acts 1968 to 1997(a).

Edited by MrDan, 30 September 2014 - 08:44 PM.

[digger]

 
Are they not classed as pyrotechnic articles and so covered under 5(3)(b )?
 
 

I don't think so, as pyrotechnic articles has traditionally covered items such as paintball maroons and smokes amongst other things. Anyway the paragraph limits them to 1 kg NEQ which is fine for CAT3, but would rule out a great deal of CAT4. Not great for most of the display operators.

[MrDan]

From the guidance doc (emphasis mine):
 
http://www.hse.gov.u.../books/l151.htm
 

pyrotechnic articles articles that contain explosives substances or an explosive mixture of substances designed to produce heat, light, sound, gas or smoke or a combination of such effects through self-sustained exothermic chemical reactions. They include fireworks plus other items such as flares, smoke signals and flash cartridges. Pyrotechnic articles will also include all such articles that have been characterised as such by a notified body under the provisions of Directive 2007/23/EC, pyrotechnic articles that are equipment falling within the scope of Directive 96/98/EC and percussion caps intended specifically for toys falling within the scope of Council Directive 88/378/EEC. Pyrotechnic articles will also include those articles that have identified as such by Directive 2004/57/EC.

[wayne]

No matter which way you try and tweak it, it 'only' (and I don't mean that in any way ungratefully) gives us the ability to do small scale genuine experiments - not to manufacture enough pyro for a November spectacular, once you grasp that it all seems clearer.

Perhaps now is the time for doing not talking - still feel the need to look over my shoulder though.

 

I'm afraid the reg 6(2)(a) is based around experimentation and as such it is not designed for anything related to a display in the terms you mention.  If you want to manufacture a large haul of pyro for nov 5th, you can and have always been able to do so....with a full manufacturing licence!

 

In time who knows if we could increase limits, but for now, we'll have to be happy with 100g!  As Digger points out, there are plenty of decent things to manufacture within the 100g limit.

 

As for looking over your shoulder, if you follow the guidance and regulations, there's nothing to worry about.

[martyn]

I'm afraid the reg 6(2)(a) is based around experimentation and as such it is not designed for anything related to a display in the terms you mention.  If you want to manufacture a large haul of pyro for nov 5th, you can and have always been able to do so....with a full manufacturing licence!...........

I'm sorry if it didn't come across very clearly Wayne, that was exactly my point.

We can now legally make sub 100g experimental devices and enjoy doing so.

I phrased it as I did because I have heard offline of some people desperately trying to interpret the regs so as to convince themselves it's ok to make a stash for Nov.

Once you grasp that this is not the intention or the spirit or the letter of the regs, it seems fairly straight forward.

[wayne]

Quite right Martyn, once its understood that the regulation (6(2)(a)) is all based around "lab analysis, experimentation, demonstration and testing", then the its limitations can be understood.

 

Yes, the main exciting thing with all this even taking into account its limitations is that and 100g or comp of device can be legally manufactured!  

 

I'm sure when people have got to grips with the requirements and appropriately licensed/certified themselves, the forum will start to come back to life with postings of experiments.

 

Come on all, lets see those experiments   

[Gareth]

You guys are real experts, to someone just trying to get to grips with this and can't roll off regs and paragraph and subsection numbers etc. I have a very basic question.

 

"experimental manufacturing process buildings"

 

I am taking this to mean that we have to have a dedicated building in our back gardens to do this stuff?

Not sure how a standard shed can be kept "dry and clean" though, they tend to always be a bit damp and dusty to me?

So this limits the hobby to those with large enough 'back gardens' that can support a fully weather tight workshop?

Such a workshop cannot be used for anything else / storing anything else, as the risk of contamination or reaction is great.  Fair enough.

Further a second facility to store manufactured items is required even ones that are simply drying ready to be used later - so this would be a second building in the garden or some kind of storage container?

You're gonna need a large 'garden' - I am guessing most people on this forum are land owners then :-)

 

Its a great document and certainly is causing me to think quite a bit.  Right now, to someone just getting started (and started excited and eager) I am now erring on the side of "I don't think I can do this, I don't think I have a facility big enough to support this hobby".

 

What might be a great annex document would be "a typical example" - i.e. Joe is mad on fireworks and has joined the ukps to learn some hobby pyro.  He lives on a council estate in a mid-terrace.  He has a narrow but long garden separating him from his neighbours etc. etc. Such an example would go on to explain how Joe proceeds, who he contacts, what buildings he needs, what storage and equipment he might need to start and where he can get info on basic experiments to begin with.

BTW this isn't exactly my situation but it's that not far off.

[maxman]

I take it to mean not to have a leaky roof with rain pouring in and to be tidy with a clear clean bench to do work on and not for storage of other things like the lawnmoor, petrol cans and paint tins and clutter. I think a shed should be fine if it can be like that.

 

Rod

[wayne]

Hi Gareth, just take its a step at a time and things will fall into place.

 

In regards to process building (and with all the application of the regulations), it just takes a little common sense.  A dedicated building would be ideal, but not an actual necessity - it depends what else you do in there.  For example, it could be a shed that is used just to store your shovel and spade, it would say that would be fine.  If your shed stores a mower, fuel and you also use it as an occasional office, I wouldn't say that was suitable.

 

Most sheds would be dry and clean if maintained properly, so a shed is perfectly acceptable as long as it has a roof that works!

 

Storing items away from process building is just common sense, who in there right mind would make an explosive composition in a room where other devices and substances are stored!

 

Its inevitable that not everyone will have access to the required space, for example, if you live in a 1 bedroom flat without any outside space then its a non starter.  That said, most normal sized gardens would be perfectly adequate.  Again, its all common sense.

 

Unfortunately, the guidance document cannot be prescriptive and therefore providing a "typical example" wouldn't be possible.  I understand how this could be useful but we have to be careful on stating exactly how things could be done.  We have to leave the responsibility to the individual to use their judgement.  That's not to say though that it could be discussed here! 

[wayne]

I take it to mean not to have a leaky roof with rain pouring in and to be tidy with a clear clean bench to do work on and not for storage of other things like the lawnmoor, petrol cans and paint tins and clutter. I think a shed should be fine if it can be like that.

 

Rod

 

Spot on Rod!

[Gareth]

Fair enough about the paints and flammables in the shed.

My shed doesn't leak, it has new felt and everything :-) but you do get a lot of condensation in a shed especially in winter time.  That was really my thing about 'damp'.

Of course the problem is the shed itself, they tend to burn readily and most people have their sheds next to a fence - my fence is also wooden so that's a further risk too to consider.

What kind of storage do we think would be suitable for manufactured / drying / awaiting assembly items?

And of course what storage for the base chemicals?