11 replies to this topic

[maxman]

Assuming some of us ever get a COER I just spotted the below link from HSE and wondered if I am correct in thinking this will apply to us? and if this in someway is a change from what was previously required pre April 5th 2015? Anyone know anything about it? I guess it's no hardship to keep records anyway and under the guise of an experiment we will need to keep records and data from our experiments.

 

Basically seems to be saying that " Relevant and civil explosives don't need a record to be kept of their acquisition and use if you are a private individual using for your own personal use not in connection with your work!?

http://www.hse.gov.u...ord-keeping.htm

Rod

[digger]

I would not worry about it too much Rod. You have hit the nail on the head.

 

You are a private individual. All of the explosives you manufacture will start and end their life with you. You won't be transferring them to anyone else.

 

Of course you should keep good records as a matter of course so that you can track everything that you have done / used, even if it is just used as an aid memoir / justification for purchase of precursors. Batch numbers etc are a matter for personal choice in this instance.

 

D

[Arthur Brown]

IMO the law does not require you to keep records, BUT

 

1/ If you do keep records accurately then it starts to justify the use of the "Home Pyrotechnic Experimentation" permissions.

2/ If you do keep records and there is a real incident on ANOTHER day/time then it shows it wasn't you.

 

Think of the Chemistry Practical books of school years, you develop a theory, research the details, do the experiment and determine the results and write it all up. That's what the Home pyrotechnic experimentation permits. -skip the theory and it could be seen less nicely as "making bangs" 

[wayne]

As I always say, please read the guidance document...its all there.

 

The regs don't necessarily require you to keep records for "personal use" but you still need to maintain a simple record system to report any loss (I know we're only talking 100g but you only have to add a line to a spreadsheet so no big deal):

 

"Private individuals acquiring relevant explosives for their own use

135 As noted above, private individuals who acquire and keep explosives other

than in connection with their work and solely for their own personal use are not

required to keep a record of the relevant explosives. They should however have

systems in place to retain sufficient information to be able to report losses under

regulation 37."

Edited by wayne, 27 April 2015 - 03:18 PM.

[maxman]

Quite! I also think recording times of testing and video documentation would be a good idea. If anyone makes a complaint then I will have evidence of what was tested and how long the testing took at what time etc and a video of the results to back it up. Besides videos of tests are great to share and can be useful when played frame by frame to see if all your stars light for example. I just wondered if that link referring to April 5th was something new that it was no longer required to keep those records.

 

I have made the mistake in the past of doing something then in an attempt to replicate at a later date forgot how I did it  Anyway law or not I will be keeping records of everything.

 

Rod

[wayne]

Definately!  Nothing wrong with keeping records, it doesn't do any harm.

 

Again, see the guidance document, there's a good example of a experiment log sheet template...

[maxman]

Wayne, that clears up for me at least re records on explosives and pyrotechnic articles. Now I have read the guidance but what about records of chemicals? The guidance says

 name of substance
 date purchased
 quantity purchased
 where purchased
 quantity used
 storage location

and also

All chemical records should be accompanied with its associated MSDS (Material Safety Data Sheet). The supplier of the chemical should always be able to supply the relevant MSDS for the chemical purchased.

 

Now some of my chemicals were given to me and date back to 2003  for instance a big bag of mixed TI, Magnalium  and strontium nitrate etc. Other chems such as red gum, sparkler grade iron filings barium sulphate came from skylighter when they shipped to UK 

 

Some of these items I have no idea of dates and they don't have data sheets.

 

I also think I read something about keeping chems in original packing but I'm looking to reorganise all my chems and store them in small plastic storage buckets with a separate scoop in each one (to avoid cross contamination)  Is this OK? and what about labels when they are on the original jar or had non in the first instance? Do I have to weigh everything I have now aswell?

 

Is this LAW or just good practice?

 

Rod

[wayne]

I'm in much the same position as you, have various containers with chemical from various sources over time.  I'm sure there's a regulation somewhere (digger?) that defines chemical storage, but in our case, I think as long as you take appropriate common sense steps to safely store your chemicals, that should be enough.  What you're proposing is exactly what I'm going to do, so as you say, just good practice.

 

MSDS sheets can be downloaded, so if you feel the need you can alway get them.

 

P.S, you can alway retrospectively create records for your chemicals.  If you can't remember the exact date purchased or the source, just estimate it.  It doesn't really matter, but will start you on the process.  Just good house keeping really.

Edited by wayne, 27 April 2015 - 04:32 PM.

[digger]

I'm in much the same position as you, have various containers with chemical from various sources over time.  I'm sure there's a regulation somewhere (digger?) that defines chemical storage, but in our case, I think as long as you take appropriate common sense steps to safely store your chemicals, that should be enough.  What you're proposing is exactly what I'm going to do, so as you say, just good practice.

 

MSDS sheets can be downloaded, so if you feel the need you can alway get them.

 

P.S, you can alway retrospectively create records for your chemicals.  If you can't remember the exact date purchased or the source, just estimate it.  It doesn't really matter, but will start you on the process.  Just good house keeping really.

 

Yep there are regulations on chemical storage. However they do not really apply to the quantities that we are dealing with to individuals.

 

A sensible approach to risk assessment should cover everything that you need to prove "due diligence".

 

Disposal also needs to be thought about carefully!

[digger]

p.s. rod.

 

As far as I am aware the labeling requirements only apply in the case of the placing on the market of chemicals except for the case of controlled chemicals which must be marked and stored as such.

[maxman]

Gareth when you say controlled chemicals do you mean those on the epp list? Or something else?

Rod

[digger]

Gareth when you say controlled chemicals do you mean those on the epp list? Or something else?

Rod

 

I would have to check the exact regulation for the wording, but I remember that there needs to be labeling on the chemicals with respect to the EPP list to say that they controlled.

 

I don't believe that scheduled poisons need to labeled as controlled, however it is wise to ensure that the nature of the chemical is displayed on the label.

 

When we used to sell chemicals we always ensured the labels conformed with the legal requirements. However in my opinion that was not always that helpful to the end user, as we only had to list the codes and appropriate hazard labels as defined under REACH along with a few other bits and bobs. I think a good descriptive label goes a long way, but that is just my opinion.

Edited by digger, 27 April 2015 - 08:14 PM.