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A&K Application problems review...


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#76 BlackCat

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Posted 28 November 2016 - 04:13 PM

I've spent several hours on the internet looking for UN MAN2 but have not been able to locate the document.

 

Would some kind, knowledgeable person please post a link to it for me?

 

Thanks.



#77 wayne

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Posted 28 November 2016 - 05:00 PM

I'm afraid its not yet documented online (AFAIK), but its apparently been sent as a memo through the ELO intranet so they should be all aware.  I have included the definition though for MAN2 in the above posting.  Its defined as: "Any pyrotechnic substance or article subject to these regulations that is within the meaning of explosive contained within regulation 2".



#78 BlackCat

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Posted 29 November 2016 - 07:02 PM

Thanks for that Wayne, I presume that that's Reg 2 of ER2014? I'll pass the info on to them and hope that they can find it on their Intranet.

 

Nothing back from then so far but, it is still very early days.


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#79 exat808

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Posted 02 December 2016 - 09:40 PM

Just diving back in.

I created UN MAN2 for the Police National Firearms Licensing Management System (NFLMS) a few years ago. You will not find any reference directly to it on the internet. Its intent and purpose have been well described in the forum by Wayne, Digger, Samboradford and others.

Wayne can you advise me outside of the forum about any ongoing issues. We are running some ELO continuation training next year and will consider more pyro related input? 


Edited by exat808, 02 December 2016 - 09:59 PM.


#80 wayne

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Posted 06 December 2016 - 07:48 PM

Hi Danny, 

 

Apologies for the slow reply.

 

I'll drop you a line shortly and hopefully we can assist the ELO's in understanding our type of application.

 

As always, thanks once again for your continued support!



#81 exat808

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Posted 06 December 2016 - 10:43 PM

We have been discussing ELO continuation training today. Perhaps this might be an appropriate occasion for a UKPS member to come and present your side of things? It wont guarantee exposure to every ELO but it may help.

I will update Wayne by emails with dates etc. Venue is not far from where he lives!!!  



#82 wayne

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Posted 07 December 2016 - 10:27 PM

Absolutely, it would be great to be involved.  I'll be in touch once I know more.

 

Also, just for every bodies reference, I've updated the good practise guidance to include UN MAN2 in explosive certificate applications:

 

http://www.pyrosocie...ctise-guidance/



#83 BlackCat

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Posted 08 December 2016 - 02:43 PM

I received the following E-mail from the Police yesterday regarding my AO application:

 

"I have now discussed this matter further with A.Jamieson and also our regional explosives person R.Grey.

 

Mr Grey confirms that we have issued the correct certificate. He has advised that licences to manufacture pyrotechnics are issued by the HSE and do not come under the remit of Firearms Licencing. He did say that in the small quantities involved where you are concerned they may consider that you are not a manufacturer but they will advise you on this when they visit.

 

Mr.Grey suggested I refer you to p17 of the explosives act for further information.

 

Regards

 

Dave"

 

P17 of ER2014 is essentially Reg 6 to which I referred them in the first place so we've gone around in a complete circle!

 

So, apart from referring them to Reg 6.2.(a) and explaining to them how this is interpreted as an exemption from a HSE manufacturing licence, I have also:

  • Sent them a link to the UKPS Good Practice Guide.
  • Passed on the information in the above posts concerning UN MAN2.
  • Sent them a link to the discussion thread "Working with UN MAN 2" in our forums.
  • Sent them a link to a HSE Guidance Note that states clearly that pyrotechnic substances are a relevant substance under ER2014 and so an explosives certificate is required.
  • Pointed them at several definitions in ER2014 that seem to cover pyrotechnic substances.
  • Sent them a list of Police Forces that do not have a problem with issuing an AO for UN MAN2 or pyrotechnic substances, gleaned from this thread, and suggested that they talk to other ELO's.

The certificate that they've issued, referred to in the E-mail is an A&K for BP only so, obviously, doesn't cover me for anything else. I have asked them what their interpretation of Reg 6.2(a) actually is and why they do not consider a pyrotechnic substance a relevant substance under ER2014. It remains to be seen whether or not I get a reply.

 

I really am at a loss to see how I can move forward with my application so any advice, help or suggestions will be gratefully received.



#84 BlackCat

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Posted 08 December 2016 - 04:12 PM

Since posting the above, I've had a further E-mail from Andi Jamieson, who is the ELO for Northants, and copied to the enquiry officer handling my application. In it, he says that having seen my E-mail responding to their E-mail copied in my previous post and having a look at the updated UKPS Good Practice Guide via the link that I sent them, he now believes that the Police are responsible for issuing licences for pyrotechnics. Consequently, he's advised my case officer to go ahead and issue me with an appropriate certificate.

 

It seems that re-sending them the link to the GPG has done the trick and broken the stalemate so is, perhaps, something that future applicants should include with their application covering letter.

 

I'm not going to celebrate until I have the piece of paper in my hand but, a big thanks to all of you that posted advice and support for my endeavours and a special thanks to Wayne.

 

I'll let you know when it arrives.



#85 wayne

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Posted 08 December 2016 - 05:43 PM

Brilliant news, another example of a successful application!  Glad you got there in the end!  Its difficult for all the ELO's to know all the regs for all the different types of application,  especially since our type of application must be rare.  Hats off to them for taking the time to consider the information you were giving them and finally issue your certificate.

 

Well done on your persistence!  I look forward to seeing some experimentation posts when you've everything in place!

 

Now go and have a beer and celebrate!  :D



#86 maxman

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Posted 08 December 2016 - 05:54 PM

I'm very pleased for you blackcat hope all goes well.

 

I dare say this is a silly question but about 6 months ago Wayne made contact with the GMP ELO and promised us regular updates even if nothing had happened, even these have not been forthcoming! So any news?

 

I wish I didn't live in a black hole.

 

Rod



#87 wayne

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Posted 08 December 2016 - 06:01 PM

Hi Rod,

 

I'm afraid I hit a brick wall with your ELO.  I am still trying to get feedback from him, but up to press, its difficult to move things forward when communication is one sided.

 

I gave him proposals to cover all his concerns and he did say he would consider them.  Unfortunately, I still have had nothing back.

 

I feel for you Rod, but as a society we can only do so much.

 

I will keep trying but its quite evident that things don't move quickly with your ELO.

 

Cheers,

Wayne.

 

PS.  I've just nudged him once more...I'll set a time in my diary for next week to call him again If I hear nothing back...



#88 BlackCat

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Posted 08 December 2016 - 06:55 PM

Thanks guys, for the record, I am the first to apply for pyro licencing in Northants so it isn't too surprising that it's taken 8 months to get there. Hopefully, the next person will have an easier ride than I've had but, it's a good place to be.

 

You know, I may just change my mind about celebrating and have that beer...............



#89 exat808

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Posted 09 December 2016 - 09:58 AM

Some further words re Pyrotechnic Substances and their status in ER2014:

ER2014 Regulation 5(3) is a good start point to make a determination with regard to those explosives that are not treated as "Relevant" explosives - ie must be shown on a certificate.

5(3)(b ) and (c ) make no mention of "Pyrotechnic Substances" and a careful study of the entire reference at 5(3)(a) reveals only 1 mention of "Pyrotechnic Substance" being exempted from certification in very specific circumstances which does not capture the activities of UKPS members or the wider pyro research community. It can be concluded therefore that "Pyrotechnic Substances" will be treated as "Relevant" explosives and must be included on a certificate to allow lawful acquisition.

Moving now to UNMAN2. Part of the concept of explosives certificates is that "Relevant" explosives are identified by UN numbers. This is fine for anything that has been tested and subjected to classification and has a UN number assigned. For the pyro researcher who is never going to submit their manufactured substance for classification there needed to be a mechanism to permit unclassified pyrotechnic substances to be included on a certificate and out of this need UNMAN2 was created. We also created a UNMAN1 for explosive substances. In essence UNMAN2 is a catch all that permits lawful acquisition of any manufactured pyro substance.

Finally, on to manufacture. I can see from earlier posts that there has been confusion in the enforcement sector about lawful manufacture. The start point is ER2014 Reg(6) which states that all manufacture must be subject to a licence and later in ER2014 we see that any manufacture is licensed by the HSE. However, ER2014 Reg(6)(2) provides a list of specific circumstances where a manufacturing licence is not required.Reg(6)(2)(a) is the element that permits unlicensed manufacture of a pyrotechnic substance.


Edited by exat808, 09 December 2016 - 09:59 AM.


#90 digger

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Posted 09 December 2016 - 11:18 AM

Danny, a quick question.

 

Why can't we use a combination of UN 0476, UN 0478 and UN 0485 as a cover all for pyrotechnic substances not otherwise specified, as anything we produce will fall under one of these?

 

In fact I guess taking the worst possible case everything could fall under UN 0476?


Phew that was close.




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