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Working within UN MAN2

UN MAN2 A.O.

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#1 samboradford

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Posted 16 August 2015 - 08:23 AM

The availability of the UN MAN2 designation is a further step forwards in my opinion, but there are some gaps I was hoping other members might clarify their thoughts on.

 

The UN MAN2 classification is applicable to Acquire Only and covers the 100g rule for pyrotechnic compositions for our purposes, however, there are some relatively fundamental and fairly basic processes which I can't see would be covered. I'll give the following examples

 

1.

If I make a 100g batch of a dextrin bound composition e.g. blonde streamer and I allow this to dry for several days, I then prime with granulated BP ( stored with a BP A + K ), would I have breached - firstly because the composition which is now 100g + prime is over the 100g limit and secondly because I have "stored" that composition whilst drying for several days

 

2.

If I roll a total of 100g of a composition - drying each layer for 24 hours before applying the next and final layer of prime ( say over 4 or 5 days ) - have I breached - again because they have been stored for several days whilst drying

 

3.

Does a similar breach occur whilst assembling the device. E.g. a small 2 inch shell of NEQ < 100g - again  because whilst pasting / assembling it has been "stored".

 

4.

If granulate and roll some small starter cores e.g. gorski red and "store" these for rolling at a later date, even if the amount of composition is 100g, have I breached - again because I have "stored" a composition not covered by my BP only A + K

 

Essentially, it would seem as though a good next step and first solution to this problem ( assuming this is an issue ) would be to allow the UN MAN2 designation for A + K which will allow for all of the above ?

 

Thanks for listening.

Sam.



#2 maxman

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Posted 16 August 2015 - 09:36 AM

Sam, as I see it.

 

1: Stars drying are NOT in storage but adding prime to an already 100g batch would take it over yes. So make 100g and burn some off or make less in the first place.

 

2: Drying is in manufacture not storage.

 

3: You are pasting a pyrotechnic article which is now not a relevant explosive and is exempt from the rules of the explosive certificate. You will need the default UN list to know if you have made a 1.1G 1.3G or 1.4G article and store as per storage rules.

 

4: When the cores are ready for the next rolling stage you should then do this and as soon as dry/ready make up the pyrotechnic article.

 

Please feel to correct me if you disagree as this is just y understanding.

 

Rod



#3 exat808

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Posted 17 August 2015 - 10:50 AM

The availability of the UN MAN2 designation is a further step forwards in my opinion, but there are some gaps I was hoping other members might clarify their thoughts on.

 

The UN MAN2 classification is applicable to Acquire Only and covers the 100g rule for pyrotechnic compositions for our purposes, however, there are some relatively fundamental and fairly basic processes which I can't see would be covered. I'll give the following examples

 

1.

If I make a 100g batch of a dextrin bound composition e.g. blonde streamer and I allow this to dry for several days, I then prime with granulated BP ( stored with a BP A + K ), would I have breached - firstly because the composition which is now 100g + prime is over the 100g limit and secondly because I have "stored" that composition whilst drying for several days

 

Your manufacture finishes when the process of manufacture is concluded - at the end of the drying process. At that point you have then acquired a pyro substance. The process of testing using lawfully kept BP does not add to the acquired 100g 

 

2.

If I roll a total of 100g of a composition - drying each layer for 24 hours before applying the next and final layer of prime ( say over 4 or 5 days ) - have I breached - again because they have been stored for several days whilst drying

 

As above. If the process of manufacture to achieve a completed pyro substance involves a number of days drying then the substance is only manufactured when drying is complete. At that point the acquisition is made.

 

3.

Does a similar breach occur whilst assembling the device. E.g. a small 2 inch shell of NEQ < 100g - again  because whilst pasting / assembling it has been "stored".

 

If your pyro substance is immediately placed into another process of manufacture once it has been manufactured (ie - making 100g of comp into 2 small shells each <100g)  then there is no keeping provided that the shells are used for test/experimentation etc at the end of their manufacture ( even if their manufacture includes a drying time for pasting etc)   

 

4.

If granulate and roll some small starter cores e.g. gorski red and "store" these for rolling at a later date, even if the amount of composition is 100g, have I breached - again because I have "stored" a composition not covered by my BP only A + K

 

Yes. If you manufacture a pyro composition and keep it, regardless of the fact that it is <100g then you are in breach.

 

 

 

Essentially, it would seem as though a good next step and first solution to this problem ( assuming this is an issue ) would be to allow the UN MAN2 designation for A + K which will allow for all of the above ?

 

No. The keeping of unclassified pyro comp is not catered for in ER2014. It poses many issues for the enforcing authorities in terms of whether or not a licence would be needed and may also negate any separation distance exemptions for your BP.

 

 

 

Hope the above helps a bit.



#4 samboradford

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Posted 17 August 2015 - 03:39 PM

Thank you, enormously, that is actually very helpful.  Perhaps we need an F.A.Q.  of some sort - I would be happy to trawl through and put one together if there is space somewhere to allocate for it ?

 

I think it's clear to me what is possible within these regulations as it is laid out, sometimes I must admit I think I have cracked it and then I haven't !  The principle is to grasp what ER2014 is really for and designed to cover.  There is a lot that can be done within this scope and I'm happy to work within this.  I can see as time progresses and in my natural evolution looking to formally apply for a manufacturing license - do such things exist within the hobby community ? Does anyone have any personal experience on this process or know where I might obtain this help with time to come ?

 

Thanks again.



#5 exat808

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Posted 17 August 2015 - 04:03 PM

A manufacturing licence for a site to permit experimentation beyond the ER2014 Reg6(2) exemption should be as achievable for the non-work applicant as it would be for a commercial applicant.

Cost is a big thing  - £635 for the licence plus around £150/hour for the HSE Inspectors visits. The plus side is that a licence is not time limited you only need to renew your certificate every 5 years.

Lots of work to do to get a compliant laboratory but as I said its still achievable. Happy to consult in the future!!!! Its what we do @Skewenergetics    



#6 samboradford

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Posted 17 August 2015 - 07:40 PM

Ok. On the face of it that seems like a lot but over the course of many years a sound investment.  Sounds like it would be worth starting the process and seeing where it ends up.  I'll email you.  Thanks.



#7 samboradford

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Posted 21 August 2015 - 08:42 PM

Danny,

 

could you also give your view on the helpful post made by Rod, is this line correct :

 

3: You are pasting a pyrotechnic article which is now not a relevant explosive and is exempt from the rules of the explosive certificate. You will need the default UN list to know if you have made a 1.1G 1.3G or 1.4G article and store as per storage rules.
 
That's to say, if I paste a small 2 inch shell < 100g I can store for up to 5 days ( as long as total HT4 is < 50Kg ) as per my storage rules as assuming I would classify HT3 ( or assuming 1.3G )

Edited by samboradford, 21 August 2015 - 08:51 PM.


#8 exat808

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Posted 22 August 2015 - 12:39 PM

Sam, as I see it.

 

 

 

3: You are pasting a pyrotechnic article which is now not a relevant explosive and is exempt from the rules of the explosive certificate. You will need the default UN list to know if you have made a 1.1G 1.3G or 1.4G article and store as per storage rules.

 

The issue here is one of classification. If your manufactured articles were going to be transported and placed on the market they would have to be submitted for classification and testing in approved packaging. At this time you could refer to analogous classification to determine a HD.

In the scenarios most likely to be encountered by UKPS members manufacturing <100g articles for test etc then classification under UN will not happen, and a reliance must be made on the manufacturers assessment of HT in accordance with ER2014. Whilst this is feasible there is the potential of conflicts and non-compliance with the Guidance to ER2014  - HSE document L150 particularly in relation to the storage of unclassified explosives.

 

My view is that the ethos of the Reg 6 exemption relies on testing and demonstration as soon as manufacturing has ceased. Storage of unclassified explosives irrespective of quantity would not sit comfortably with HSE.


Edited by exat808, 22 August 2015 - 12:39 PM.


#9 maxman

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Posted 22 August 2015 - 03:51 PM

Sorry I didn't wish to mislead anyone. It was my understanding that storage was allowed based upon page 19 of our guidance document http://www.pyrosocie...evision-1.2.pdf Maybe I have misunderstood this? Or perhaps it might be a good idea to change this ASAP in case it is interpreted as I did.

 

Thanks

 

Rod



#10 samboradford

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Posted 22 August 2015 - 08:06 PM

Thanks,

 

that's what I suspected. Rod, this would make the guidance, sadly, rather incorrect ?



#11 fruitfulsteve

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Posted 22 August 2015 - 09:48 PM

How does this work with say waiting until it's dark or indeed if 'testing' has to be delayed due to weather conditions ?


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#12 Sparky

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Posted 13 September 2015 - 10:03 PM

A manufacturing licence for a site to permit experimentation beyond the ER2014 Reg6(2) exemption should be as achievable for the non-work applicant as it would be for a commercial applicant.

Cost is a big thing  - £635 for the licence plus around £150/hour for the HSE Inspectors visits. The plus side is that a licence is not time limited you only need to renew your certificate every 5 years.

Lots of work to do to get a compliant laboratory but as I said its still achievable. Happy to consult in the future!!!! Its what we do @Skewenergetics    

Exat (sorry I don't know what else you go by as you don't use a sig)

It seems to me that if we (hobbyists) are really to do anything within the law that we know we all do then we would need this type of set up. All these posts seem to be pussy footing around the real problem and trying to find loopholes in the law to allow us to do the experimentation we want to.

It is all very well us getting EPP and even A&K but realistically for us to make anything worth our while we need a manufacturing license for a site to perform experimentation. We would need premises, a lab and a lot of red tape, rubber stamping from HSE but given the will and the financial backing there is no reason why someone could not set up a lab, manufacturing for experimentation premises?

The legal hoop jumping seems similar in some ways to the obstacles you would have to overcome to set up your own firework display company with a store, insurance, separation distances, BPA training etc etc. Although I imagine there would be a few more hoops to jump through.

Surely there are businesses still making pyrotechnics in the UK but possibly in more specialist areas and not in Fireworks?

I am one for fantasising but you don't know until you ask right...and there is no such thing as a stupid question.

If availability of money, people's time, suitable premises and enthusiasm were all there is it even feasible to imagine a body (business) that existed only to experiment with pyrotechnics and that the people running that business would be part-time and the purpose would be to sell on potential discoveries to other pyro businesses.

There must be many small businesses out there that start up this way and who provide special effects etc. They need labs and the ability to test and experiment. Are there regulations that would make it impossible for amateurs?

Apologies for the rambling line of questioning!



#13 digger

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Posted 14 September 2015 - 10:53 AM

It is entirely possible to set up an explosives manufacturing company on a small scale. The legislation is prescriptive, so if you follow the rules the HSE will have to issue a licence.

 

The problem comes when the process gets to assent. In theory the council should assess the health and safety issues associated with the application along with any planning issues. But unfortunately, they do not follow prescriptive rules in quite the same way, so it can be very likely to fail due to opinion of the councillors on the committee. If you need change of use of the land for the application it is a very easy way for the application to be kiboshed.

 

However it has been achieved by people in the past. One such company is Dean fireworks, I am not sure if they are still trading, but there was a great article in Fireworks magazine a number of years ago which is well worth reading.


Phew that was close.

#14 wayne

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Posted 14 September 2015 - 01:23 PM

Yep, its all possible given enough initiative, money and patience but largely unrealistic for most.  This is why the 100g experimental avenue was pursued.  Yes there's limitations, but its also easily achieve able for most.

 

As for a society run manufacturing facility, that idea has been around for quite a while and was pursued until the usual barriers of funds, geographic location, members willingness to get involved all kicked in.

 

As it stands, the only practical solution for most is experimentation under ER2014 reg 6(2)(a).



#15 maxman

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Posted 14 September 2015 - 01:58 PM

I take it one still needs to be in possession of an explosive certificate regardless of manufacturing licence or not? Or would this be easier to come by under those circumstances? If so why?

Rod





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