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ER 2014 - Good practice guidance feedback and discussion


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#16 Rip Rap

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Posted 29 September 2014 - 10:38 AM

Generally a bare medium sized rocket motor would be classed as 1.3 - small motors would be 1.4

 

Obviously that could change depending on headings.

 

As it stands, up to 10KG of loose B.P. can be stored indefinitely without a storage licence, but The Good Practice Guide under Explosive substance storage process map states -

 

"Black powder and flash powder will generally be expected to behave as hazard type 1. Hazard types for all other unclassified pyrotechnics substances should have their hazard type determined on a case-by-case basis but pyrotechnic substances will generally be expected to behave as hazard type 1 "

 

The article storage flow chart states that anything hazard type 1 or 2 can be stored for a maximum of 24 hours.

 

So if I take my loose B.P. (which I can store indefinitely) and compress it into a tube, I am creating a HT 1 article which I can only store for 24 hours without a storage licence?

 

 


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#17 rocketpro

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Posted 29 September 2014 - 10:45 AM

Well it wont be a HT1 article when manufactured,  it will become a HT3 article but you are right about the 24hr storage for HT1

 

But for HT3 it says you can store for maximum of 5 days in their place of intended use under ER 2014 Exemption Reg 7(2)(d)(i)

Edited by rocketpro, 29 September 2014 - 10:59 AM.

Who tests the tester.


#18 Rip Rap

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Posted 29 September 2014 - 11:16 AM

 

Well it wont be a HT1 article when manufactured,  it will become a HT3 article but you are right about the 24hr storage for HT1

 

But for HT3 it says you can store for maximum of 5 days in their place of intended use under ER 2014 Exemption Reg 7(2)(d)(i)

 

 

Thanks for the reply and I agree that a rocket motor (without a header) should be HT3 (no mass explosion or projectile hazard).

 

But why does the guidance document state -

 

"Black powder and flash powder will generally be expected to behave as hazard type 1. Pyrotechnic substances will generally be expected to behave as hazard type 1 (HT1), especially when confined"

 

This seems to imply that any device should be classed as HT1, which obviously affects storage.


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#19 rocketpro

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Posted 29 September 2014 - 11:31 AM

Yes I agree, but it does state "generally" 

 

A pile of BP would have a mass explosion hazard, but press the same into a tube then it has a controlled burn so now it has no mass explosion hazard.


Who tests the tester.


#20 digger

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Posted 29 September 2014 - 12:10 PM

Hazard type should be determined based on the behaviour of the device when stored. So as you all know

 

HT1 mass explosion hazard

HT2 projection/projectile hazard (no mass explosion) (think missiles)

HT3 Minor explosion or minor projectile hazard

HT4 slight explosion or fire hazard with only local effects (should not get out of the box)

 

So your rocket motor could be either HT3 or HT4 depending on how it was being stored. If it was in a strong, double or tripple walled box then it would most likely be HT4 as it would not get out of its box. If it was in a plastic packet it would be HT3 as it would wizz about if ignited. It is up to the user to determine hazard type based upon storage conditions. However it is probably wise to use the HSE default classification list for some pointers.

 

Your loose BP would always be HT1 by definition and anyway if it was loose in a bottle it would perform very differently from from your pressed rocket motor.

 

Hope this helps


Phew that was close.

#21 digger

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Posted 29 September 2014 - 12:11 PM

P.S. the guidance you quote says pyrotechnic substances and not pyrotechnic articles


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#22 Rip Rap

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Posted 29 September 2014 - 12:21 PM

P.S. the guidance you quote says pyrotechnic substances and not pyrotechnic articles

 

Hi Digger,

 

I realised that the guidance I quoted is for substances, but it was where it said "especially when confined" that I was unsure. Because by placing a composition into a tube etc it is "confining" it.

 

Thanks for the clarification about the types of storage and condition of storage affecting the hazard type.


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#23 rocketpro

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Posted 29 September 2014 - 12:23 PM

 There`s a useful hazard list here (scroll down).....

 

http://www.hse.gov.u...e-fireworks.htm


Edited by rocketpro, 29 September 2014 - 12:27 PM.

Who tests the tester.


#24 digger

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Posted 29 September 2014 - 12:45 PM

Yep that is the default list. Be aware however this relates to transport of goods, hence the 1.4 and not HT4. So how you store them can affect the hazard type. For instance if you have a few UN cartons of waterfalls at 1.4g if you take them out of the boxes and store them on the shelf then they would most likely be HT3 and could even become HT1 (see BAM testing).

 

Hi Rip Rap, I think that this relates to the storage of loose powders in containers rather than finished items, as clearly loose powders have faster burning speed than stars etc.


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#25 wayne

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Posted 29 September 2014 - 01:06 PM

Spot on Digger.  The guidance leaves classification of the substance or article to the individual.  Unfortunately, storage is a complex area so if there is any doubt, assume HT1.

 

Being that we are discussing experimental pyrotechnics here, there should be very little storage required.  Whilst the regulations will allow storage, its recommended that any substance or article manufactured should be stored only if really required for the experiment.  Any storage should be justifiable from an experimentation point of view.  For example, stock piling substances and devices without any experimental justification would not be viewed as acceptable within the regulations, but a batch of BP for later inclusion in a device would be acceptable (as long as it isn't stored indefinitely!).  Its all common sense!  

 

Also, guidance is exactly that, guidance and not a prescriptive instruction manual.  It is always up to the individual to make choices and decisions as they see fit within the regulations.  Sometimes, there isn't an exact right and wrong way to do things!



#26 wayne

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Posted 29 September 2014 - 01:12 PM

Very interesting. Thanks to Wayne and all others involved for getting us this far.

 

Can I ask re: Loose pyrotechnic compositions. Compositions in a loose powder state should only be stored if required  for further processing or testing, and in ALL cases in quantities not more than 100g

 

Whereas in VII.C  explosive substance storage process map asks if the substance manufactured is black powder then less than 10kg is allowed??

 

Does this mean we can make 100g 60.30.10 then when this is dry and stored 100g 44.44.9 then again when dry 75.15.10 meal then 100g 75.15.10 granulated? This of course is only 400g but is ALL blackpowder. So this would facilitate in making say a core burning rocket which might only use 20g in total but be made of various types of BP without making lots of very small quantities of individual types of BP

 

Thanks

 

Rod

 

Don't confuse the manufacturing regulation (reg 6) with the storage regulation (reg 7).

 

From an experimental standpoint, you can only manufacture up to 100g at any one time.  From a storage point of view, you can store whatever you are allowed to dependent on your storage facilities.

 

Again, any stored articles or substances should all be justifiable from an experimental point of view.



#27 wayne

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Posted 29 September 2014 - 01:23 PM

 

This bit seems confusing....
 
 when the amount of explosive to be stored is less or equal to 100g In accordance with ER 2014 
regulation 27(3)(a).
 
 when the explosive is black powder and is stored in accordance with Appendix 7 of L150 (see regulation 
27 (3) © & (d).
 
It seems to infer that you can only keep 100g max- But as Rod mentioned in VLL.C it says <10kg is allowed.
 
Regarding manufactured articles I assume more than one item with less than 100g of comp can be stored. Is that correct??

 

 

This is stating that separation distances aren't required for substances <= 100g, ie, no licensed store required.  Over 100g, separation and storage must be considered unless you have a certified shooter powder stored (wooden box).

 

Don't forget, an explosives certificate is required in either case!



#28 maxman

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Posted 29 September 2014 - 01:57 PM

OK just had a visit from my ELO who was very nice. Apparently I am the first in my area and with all this being very new he wanted to know what my intentions are. We had a lengthy discussion and he has raised a few questions that he needs to clear up one of which is should I apply for two certs? due to the fact that flash is acquire only and cant go on an acquire and  keep. Anyway I don't want to talk to much about my individual case at the moment but suffice to say that this is all new to him also so he needs to get his head around it all and understand what can and can't be done.

 

With regards to BP his criteria is that the box needs to be secure. He has advised that a built in wardrobe is OK (in my case) to house it and would prefer a lock on the door so as to stop any other family members gaining access (who don't have a cert) also an alarm on the building (house) is essential!

 

Rod 



#29 wayne

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Posted 29 September 2014 - 02:28 PM

OK just had a visit from my ELO who was very nice. Apparently I am the first in my area and with all this being very new he wanted to know what my intentions are. We had a lengthy discussion and he has raised a few questions that he needs to clear up one of which is should I apply for two certs? due to the fact that flash is acquire only and cant go on an acquire and  keep. Anyway I don't want to talk to much about my individual case at the moment but suffice to say that this is all new to him also so he needs to get his head around it all and understand what can and can't be done.

 

With regards to BP his criteria is that the box needs to be secure. He has advised that a built in wardrobe is OK (in my case) to house it and would prefer a lock on the door so as to stop any other family members gaining access (who don't have a cert) also an alarm on the building (house) is essential!

 

Rod 

 

Please bear with the ELO as they are in catch up with the regulations and our type of application.  I've been told there is be additional training for the ELO's but I don't know if this has been completed yet.  Its also worth noting that each regional police authority may have their own individual requirements when it comes to storage.  My box is stored in a similar fashion, behind a locked door.

 

Good question regarding 1 or 2 certificates but leave that to your ELO, its up them if they can put both on one certificate or if it will require two.

 

I guess its understandable regarding flash as the BP box if for exactly that, BP and other shooters powders.  If you need to store flash in quantities > 100g then a HT1 store is the only way forward - not that is recommended in any way for experimental pyro!


Edited by wayne, 29 September 2014 - 02:31 PM.


#30 digger

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Posted 29 September 2014 - 02:48 PM

I guess its understandable regarding flash as the BP box if for exactly that, BP and other shooters powders.  If you need to store flash in quantities > 100g then a HT1 store is the only way forward - not that is recommended in any way for experimental pyro!

 

However as it is now a regulated explosive (schedule 1), you can store upto 5kg indefinitely without the need for a storage licence!


Phew that was close.




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