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#1 spectrum

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Posted 28 September 2015 - 10:16 PM

Some years ago I proposed this and I will do so again now.

 

It is clear to me that much of what occurs oin this forum is simply not in conformance with the law. You can argue your case but I don't write the law and cannot be blamed for simply pointing that out.

 

Experimentation simply does not allow an individual to make a device - please correct me if I've got that wrong. To put together a firework or device you need a manufacturing license (as well as other permits) and as such, the experimentation that takes place simply should not, at least when the resulting composition is manipulated into stars for example and then assembled into a shell take place.

 

No matter what specification you build your garden shed to, it will not become an

assembly building / process shed / laboratory  until you successfully license it - whether you are operating for private research or not!!

 

For the experienced and well qualified out there, a nosey neighbour will, with the involvement of the authorities, outwit you and prove this point. The red face will be the least of your worries!

 

I originally proposed that the society should collectively establish a factory, share the costs and use it for both private R&D as well as agreed commercial activities, I know there will be many ready to correct me with complaints of cost etc. The biggest cost - apart from land - will be licensing. I will take this opportunity to confirm here and now that I am prepared to write the license draft for anyone wishing to make the move and at no charge. Dismiss it if you want but I know that certain of my contemporaries would do the same for a fee stretching into 5 figures - and they do already. I have 32 years experience in this business, licensed (and amended several times) my own factory as well as others in the business. The offer is more than an idle brag.

 

The position we face now is more prohibitive than it has ever been at any time - you face more obstacles and red tape than your predecessors ever did (and having researched then directly I am able to make that statement quite definitively!)

 

There are real advantages to getting together and making this work - with the new CE regs coming into play sooner than you think, classification being what it is and the effect that lot is having on the trade - which I predict will diminish substantially when the deadlines hit - unity is strength. You lot have that and a deal of passion driving you.

 

In practical terms, here is what I would propose:

 

1. Establish the availability of land at points about the UK within reach of all members, i.e. places in the south, midlands and north. 

 

2. Establish a generic (or close) license footprint - I will produce it.

 

3. Agree what you want to make - portfires, painball smokes, shells if you dare try!

 

4. Establish a membership forum which would cover all costs.

 

The last bit will be a sticking point, after years in this business I can safely say there are more talkers than doers. but.....

 

5. If you have reasonable prospects for commercial sales, say for example you decide to include Portfires in a society portfolio, then approve them - for production at all three sites - and sell them. The trade uses them so supply them.

 

Don't respond with objections listing difficulties please, 20 years ago I did this with a dole cheque and created the Paintball and Airsoft market in pyrotechnics from scratch. It can be done.

 

Start thinking about it - to the extent you can't sleep! One or two of the individuals who once worked for me tried and succeeded in copying what I did, believe me they were far from bright and did not compare to the talent I see contributing to these forums - technically speaking. It really is possible.

 

When I made a similar proposal some years back another contributor rebuked me - he has since disappeared unsurprisingly for me. If he hadn't you could have had something up and running by now.

 

Paul M.

 


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#2 wayne

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Posted 29 September 2015 - 08:35 AM

Hi Paul,

 

Yes, I know its difficult to believe but it is perfectly lawful to build experimental articles.  We've spent nearly 8 years working with the HSE and the Home office to get clarification and exemption.  This isn't without limitation, but its legal as longs as:

  • The article is <= 100g NEQ
  • The article is made for experimentation of demonstration only - no practical use.
  • You are in possession of a A&K or A0 certificate for the above.

For full details see: http://www.pyrosocie...ctise-guidance/

 

Quite rightly, if you want to build articles outside the restrictions above, you would need a full manufacturing licence.

 

A fully licensed manufacturing shared facility would be great and an idea that has been investigated many times over the years.  I hope it could be a reality one day.

 

Cheers,

Wayne.



#3 Rip Rap

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Posted 29 September 2015 - 08:48 AM

Hi Paul,

 

Yes, I know its difficult to believe but it is perfectly lawful to build experimental articles.  We've spent nearly 8 years working with the HSE and the Home office to get clarification and exemption.  This isn't without limitation, but its legal as longs as:

  • The article is <= 100g NEQ
  • The article is made for experimentation of demonstration only - no practical use.
  • You are in possession of a A&K or A0 certificate for the above.

For full details see: http://www.pyrosocie...ctise-guidance/

 

Quite rightly, if you want to build articles outside the restrictions above, you would need a full manufacturing licence.

 

A fully licensed manufacturing shared facility would be great and an idea that has been investigated many times over the years.  I hope it could be a reality one day.

 

Cheers,

Wayne.

Thank goodness for this reply! - For an awful couple of seconds as I read Spectrums post, I thought that I had totally misinterpreted everything that I had read about ER2014!


"Choose a job that you love & you will never do a days work in your life!"

#4 wayne

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Posted 29 September 2015 - 01:35 PM

Thank goodness for this reply! - For an awful couple of seconds as I read Spectrums post, I thought that I had totally misinterpreted everything that I had read about ER2014!

 

That's why I thought I should reply ASAP! ER2014 reg 6(2)(a) is still law  :D



#5 samboradford

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Posted 29 September 2015 - 03:42 PM

Thanks Wayne for some reassurance.

 

I think what Paul is saying is a really powerful vision for how the future should, possibly could, be.  As we have had shared experiences in terms of A+K  for BP or A.O under UN MAN2 the next level might be to do the same for licensing manufacturing facilities and offers such as Paul's need to be snapped up and run with.



#6 spectrum

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Posted 29 September 2015 - 09:28 PM

Appreciate the correction Wayne and I'm sorry if I startled anyone. I would stand by the spirit of the original post though insofar as compliance with the law will obviate any interpretation of the law which challenges yours. I was reading the "no practical use" in the literal sense - that is, the manufacture of an article would manifestly result in a "practical use" situation.

 

If you have cleared this with the powers that be then I apologise for not knowing and for causing any alarm, this was absolutely not my intention.

 

I still maintain a lawfully licensed, properly managed production facility is the best way to achieve the aims of the numerous contributors on this forum. I can vouch for the difficulties in observing weight limits and in my case, these limits have always been way in excess of 100g!






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