So, here I am in darkest Northamptonshire, arguably one of the best places to be if you want to go somewhere else!
Although I have made progress with my licence applications, I've had a very interesting response from Northants finest that the rest of you guys might be interested in seeing.
In April this year, I submitted the forms for an A&K for BP and an AO for fireworks and, after several phone calls, a Firearms Enquiry Officer was assigned as my case officer. After speaking to him on the phone, he admitted that he knew nothing about explosives or fireworks and was only comfortable with firearms. He was, however, comfortable with BP due to it's firearms application.
Eventually, he visited me in August and decided that I was an OK person and the upshot was that I had my A&K for BP delivered on November 5th, couldn't have been a better date as far as I'm concerned but there was no AO.
Talking to the FEO, he told me that he had been advised by the ELO for Northants that the A&K for BP was all that I needed so I, diplomatically, pointed out that my understanding gleaned mostly from the Society and many hours of reading through ER2014 and other documents was very different and I was sure that a certificate was needed and he said that he'd refer it back to the ELO.
I've now heard back and the ELO is saying that I don't need an explosives certificate for fireworks but, if I want to make them, I need an manufacturing licence from the HS&E so I should talk to them. In other words, they haven't refused me one on legal grounds just think that it's unnecessary.
So far, my response to them has been to:
Point them at the Society's Good Practice Guide, especially the section on legislation. They've responded that it wasn't helpful as they didn't understand it! Sorry Wayne.
I've copied them with a verbatim quote of Regulation 6, 1 and 2a of ER2014 to try and explained the manufacturing exemption, as best I can, and why I don't need a licence to manufacture provide that I stick tom the restrictions in the above regulation.
I've copied them with the definition of BP on p5 and asked them if, given the precise definition of BP in terms of components, I add other components or replace all or part of the potassium nitrate with another nitrate then is it still BP because, if it isn't then my A&K isn't valid. I've also pointed out that many fireworks do not contain BP or any of it's components so my A&K won't cover them either.
Finally, I've copied them with the definition an "explosive substance" and "fireworks" on p 7 of ER2014, the "explosive substance" being, in my opinion more of an exact description of a pyrotechnic substance than an explosive, and "fireworks" being defined as "explosive articles" and therefore, requiring a certificate. However, nowhere in ER2014 can I see a black and white phrase that defines a pyrotechnic substance as an explosive that requires a certificate. That may just be my tired old eyes though!
I'm waiting for a response but, in the meantime I thought I'd ask if anyone can point me towards something simple, in black and white that states that a certificate is required for possession of fireworks outside of the permitted four occasions every year or indeed any other legal "ammunition" that may help.