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ER 2014 - Good practice guidance feedback and discussion


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#31 rocketpro

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Posted 29 September 2014 - 03:04 PM

The more I read about all this the messier it seems to get. :(


Who tests the tester.


#32 wayne

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Posted 29 September 2014 - 03:21 PM

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

 

Not sure where you get that from?  Schedule 1 was COER, ER 2014 is schedule 2, explosives not requiring an explosives certificate.

 

ER 2014, Reg 7 states:

 

no more than 5 kilograms of—
(aa) shooters’ powder; or
(bb) any hazard type 3 or 4 explosive, or desensitised explosive, which is not a
relevant explosive, or a combination of hazard type 3 or 4 explosives, or
desensitised explosives, which are not relevant explosives; or
(cc) a combination of shooters’ powder and any hazard type 3 or 4 explosives, or
desensitised explosives, which are not relevant explosives;
 
Flash would be HT1 and excluded from the above?

Edited by wayne, 29 September 2014 - 03:21 PM.


#33 maxman

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Posted 29 September 2014 - 03:37 PM

Isn't there two types of flash? 0305 and 0094 from memory? one is 1.1g and one 1.3g? or is it the same and packaged different?

 

Rod



#34 wayne

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Posted 29 September 2014 - 03:52 PM

Isn't there two types of flash? 0305 and 0094 from memory? one is 1.1g and one 1.3g? or is it the same and packaged different?

 

Rod

 

Hhmmm, UN 0305 would appear to be listed as 1.3g, but I'm not sure I'd want to argue which flash is pyro flash.  When in doubt, for me its HT1.

 

In any case, anyone who wants to store more that 100g of flash really does need their head seeing to!  Its only takes minutes to make, why store?



#35 wayne

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Posted 29 September 2014 - 05:10 PM

Found this:

 

"Flash powder is assigned to Division 1.1G unless evidence can be produced that it 
belongs to Division 1.3G."
 
Its Australian, but I would tend to agree...
 


#36 digger

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Posted 29 September 2014 - 06:45 PM

Hi Wayne

 

I was working from my former knowledge of MSER 2005, I will have good dig through MSER 2014 to make sure it has not changed (which I guess it may have). Page 116 of the old ACOP says that 5kg of schedule 1 explosives can be held without a licence indefinitely.

 

I will trawl through the legislation to check it has not changed, but you are closer to it than me at the moment..

 

Cheers

 

Gareth


Phew that was close.

#37 digger

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Posted 29 September 2014 - 06:49 PM

I guess I may have made a mistake, as I assume that flash powder will be removed from schedule 1 on the 1st of October. Is this correct Wayne?


Phew that was close.

#38 wayne

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Posted 29 September 2014 - 07:32 PM

I guess I may have made a mistake, as I assume that flash powder will be removed from schedule 1 on the 1st of October. Is this correct Wayne?

 

No problem, the transition into ER 2014 is confusing.  Yes that's correct, ER 2014 schedule 2 doesn't include flash powder:

 

http://www.legislati...schedule/2/made

 

whereas, schedule 1 of COER did include flash powder:

 

http://www.hse.gov.u.../schedule-1.htm

 

ER 2014 supersedes and incorporates COER. 

 

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!  :)


Edited by wayne, 29 September 2014 - 07:41 PM.


#39 maxman

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Posted 29 September 2014 - 07:47 PM

I spotted that too Wayne re "fireworks" I thought I must of missed something though. Seems odd. But while we are talking about "fireworks" I see that in the guidance explosive article storage process I see you refer to items as "fireworks" and not pyrotechnic articles. I thought fireworks were ONLY items that were allocated with their specific UN numbers?? Do we therefore have the 5Kg unlimited time storage for these items?

 

Rod



#40 wayne

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Posted 29 September 2014 - 08:12 PM

I spotted that too Wayne re "fireworks" I thought I must of missed something though. Seems odd. But while we are talking about "fireworks" I see that in the guidance explosive article storage process I see you refer to items as "fireworks" and not pyrotechnic articles. I thought fireworks were ONLY items that were allocated with their specific UN numbers?? Do we therefore have the 5Kg unlimited time storage for these items?

 

Rod

 

If your "fireworks" are classed as HT 3 or 4, then yes!  I may include that in the process map at some point but because I expected most manufactured devices may default to HT1 (unclassified) and its generally undesirable to store fireworks without proper storage (even 5kgs!), I left it out.



#41 digger

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Posted 29 September 2014 - 08:50 PM

I don't see why we should over classify any devices, just for the sake of being on the safe side. With small articles it should be easy to justify HT3 / HT4 with appropriate boxing up. It should also be a simple matter to do experimentation to justify the classification without going to full 6 series testing.


Phew that was close.

#42 Arthur Brown

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Posted 29 September 2014 - 09:46 PM

Assuming that the constructor knows the content of a device the default tables could always produce some classification guidance.


http://www.movember.com/uk/home/

Keep mannequins and watermelons away from fireworks..they always get hurt..

#43 wayne

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Posted 30 September 2014 - 06:07 AM

I don't see why we should over classify any devices, just for the sake of being on the safe side. With small articles it should be easy to justify HT3 / HT4 with appropriate boxing up. It should also be a simple matter to do experimentation to justify the classification without going to full 6 series testing.

 

Agreed, unfortunately the guidance can't possibly get into the classification of devices so its up to the individual to make the judgement and HT1 is the general "if in any doubt" option.



#44 digger

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Posted 30 September 2014 - 08:03 AM

Fair comment, I just wanted to point out that the gudance is not saying everthing made should be HT1, otherwise we are back to the point at which the rules become overbearingly restrictive and make it vitually impossible to do anything other than a single experiment at a time.

 

In fact I can only think of one item at 100g that should be classed as HT1 and then I have seen packing for transport in the past that has passed 6c testing to make that device 1.3 / 1.4. So with some common sense and care we should be able to store pretty much anything that we could make under the regulations indefinitley.


Edited by digger, 30 September 2014 - 08:06 AM.

Phew that was close.

#45 maxman

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Posted 30 September 2014 - 08:05 AM

The UN list is very helpful here and well worth downloading and studying.  For example a gerb/fountain less than 1KG NEQ is 1.4G and over 1KG 1.3G

 

Rockets with less than 20g substance BP burst charge and less than 0.13g flash comp per report and less than 1g total is 1.4G

More than 20g pyrotechnic substance and flash less than 25% 1.3G

Flash composition more than 25% of the pyrotechnic substance 1.1G

Flash composition effects only 1.1G

 

It lists pretty much everything we might make and the download link is in the guidance

 

Rod






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