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A&K Application problems review...


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#91 exat808

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Posted 09 December 2016 - 11:57 AM

Gareth,

We thought long and hard about the format of the pyro substance manufacture process. After taking advice re using assigned UN numbers we created the UNMAN2 concept.

The argument was that for absolute correctness any of the UN numbers with an NOS designation must also have a Technical Name shown on the certificate - for example "UN0476 Substance Explosive NOS, Flash Composition RD283"

On the face of it NOS appears to be a catch all listing but when used properly as UN model regulations and ADR etc state the full technical name must be shown.

The use of NOS has been problematic in explosives licencing with many administrators not grasping the need to include a Technical Name. An example has been for model rocket motors falling under UN0349 Articles Explosive NOS - without a technical name on the certificate the holder could lawfully acquire a vast range of explosive articles other than the model rocket motors he had originally had the certificate granted for. 

 

An additional problem is that of assigning a HD or in storage an ER2014 HT. Assigned UN numbers all have an HD whereas our UNMAN2 is not HD or therefore HT specific.

 

Hope this answers your question. 


Edited by exat808, 09 December 2016 - 11:57 AM.


#92 digger

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Posted 09 December 2016 - 12:57 PM

OK,

 

So here is the quandary for me. I have space, and have sited a 50kg HT1 store (all power and cabling for Redcare alarm in), a 500kg HT3 store and a 500kg HT4 store on the land behind my house I also have a 2000kg HT1 store elsewhere exclusively for UN0333 to UN0337. The plan is to get an explosives certificate so I can play with experimental pyrotechnics again. I want to be able to manufacture 100 grams and store it most likely in the HT1 store (lowest risk policy to decide everything is HT1) and do this multiple times so that I can test the compositions/articles at a time of my choosing.

 

This will make it easier on anyone within earshot as I would be able to do my testing on an infrequent basis at noisy times of day rather than testing one or two items every night.

 

As technically UN numbers are related to classification for transport, we will not be classifying anything for transport. I guess truly assigning any UN number is not actually possible.

 

So an explosives manufacturing company may well require a HSE explosives manufacturing licence, however I guess they still need an explosives certificate for non exempted explosives. How do they put this down on their certificate especially when they are doing research into new materials and storing them? 

 

So to the question does the UNMAN2 cover me to do this with A&K rather than AO as the whole thing is pretty pointless to me unless I can store the acquired explosive. This may not be true of everyone, but we are all different.

 

If the UNMAN2 does not cover me to store once "acquired" how do you suggest I get my explosives certificate structured so that I can?


Edited by digger, 09 December 2016 - 01:01 PM.

Phew that was close.

#93 martyn

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Posted 09 December 2016 - 02:28 PM

Very interesting.

Topics like this often go off forum and onto PM's.

As long as it stays on general principles rather than personal specifics, could I ask that you keep it on here if possible.

This is exactly the sort of detail that may be relevant to other people now or in the future.

Cheers.



#94 exat808

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Posted 09 December 2016 - 02:29 PM

The UNMAN2 concept was designed primarily to allow possession of unclassified pyro substances created as part of the unlicensed manufacturing criteria at ER2014 Reg(6)(2)(a). The guidance given to the ELO's is that anything manufactured under UNMAN2 should be tested, analysed etc immediately after the process of manufacture has been completed. It is acknowledged that some manufacturing may be lengthy as there are drying processes etc to be considered before the substance can be said to be finally made.

So, following your scenario above - in my opinion you may keep unfinished pyro substances whilst they are drying or curing etc but must then test, analyse etc as per (6)(2)(a).

 

The keeping of any unclassified explosive should follow the principles of safe storage demonstrated in HSE Guidance to ER2014 L150. A main element of the process would be the segregation of classified from unclassified - 2 stores.

 

Other pitfalls - trying to persuade the licensing authority that the HT you have assigned to your pyro substance is appropriate. Of course calling everything HT1 would deal with that but you are then into Separation Distance territory and everything that goes with it.

Other main pitfall for the small scale manufacturer is that there is nothing in ER2014 Reg 7(2)(a)  - the unlicensed keeping provisions which will allow even the smallest amount of a pyro substance (classified or not) to be kept without a licence. Immediately you are into a costly environment.  



#95 wayne

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Posted 09 December 2016 - 02:33 PM

I guess is depends why you want to store the acquired explosive.  For experimental pyro, your wouldn't want to actually store anything.  Ie, you manufacture the explosive/article and then test it...no storage required.  Whilst any composition is still in a drying state or an article is still in a production stage, this isn't technically storage as its still in a state of manufacture.  

 

AFAIK, the reason for the AO of MAN2 is so you can manufacture a substance/article (including all production stages of drying, assembling etc) but not be able to store the finished substance/device unnecessarily.  That's not to say that any substance/article should be left lying around during a manufacturing stage, it should be stored appropriately.

 

Hope that makes sense and I'm sure Danny will correct me on any points if necessary.



#96 wayne

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Posted 09 December 2016 - 02:37 PM

I was keying the above while Danny was keying his reply - Good to see i'm on the same page!  B)



#97 exat808

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Posted 09 December 2016 - 03:04 PM

Just a few more comments following on from Gareths posts above.

 

An HSE site licence will contain textual detail about what may be present in any building or store at any one time and will also be prescriptive about permitted manufacturing activities in any location on the site - none of this detail can be applied to unlicensed manufacture.  UKPS has covered all of the required duties in its Guidance document.

I think that the thread may be in danger of going off topic a bit as we are discussing a wider compliance issue here.

Happy to discuss the wider issues of licensing in another thread.

 

Gareth sounds like he has the ability to store his manufactured substance. He will have to convince his ELO that his storage licence can accommodate unclassified substances. I am sure that HT's can be demonstrated by analogy to existing classifications - it may take some work with the ELO as we dont go into a lot of depth on classifications on the ELO course.



#98 digger

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Posted 09 December 2016 - 03:42 PM

Gareth sounds like he has the ability to store his manufactured substance. He will have to convince his ELO that his storage licence can accommodate unclassified substances. I am sure that HT's can be demonstrated by analogy to existing classifications - it may take some work with the ELO as we dont go into a lot of depth on classifications on the ELO course.

 

I sure do, I can easily satisfy the safety distances required in MSER 2014 even without relying on reduced distances for low population densities (which I can also satisfy).

 

I am not worried about HT's as I only intend to use my HT3 and HT4 stores for CAT4 and the HT1 for everything else. I have cabling installed for a monitored alarm system so security is not an issue (all stores a genuine H&G's in difficult to access locations for anyone but me). I just need to know what should go on the certificate / storage licence for the pyrotecnic substance to be stored.

 

Mod's feel free to split this off into separate thread.


Phew that was close.

#99 exat808

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Posted 09 December 2016 - 04:10 PM

Gareth in my opinion you should try the following:

 

A&K certificate with UN numbers for all your commercially sourced pyro substances and other explosives listed (flash, BP etc) plus UNMAN2 for your manufactured pyro substances.

 

Licence application for the HT1 store to be done by HT rather UN number - the Form ER2 allows for either so dont be pressured to supply UN numbers. If you are using an analogous assumption of HT1 be prepared to evidence the analogy. "HT1 Pyrotechnic Substances" should in my view be sufficient.

 

Have a good plough through L150 - look at some of the principles of safe storage especially segregation of products.

 

Happy to review your application and provide supporting info outside of the forum.  



#100 digger

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Posted 09 December 2016 - 06:41 PM

Thanks

 

I may well take you up on your offer.

 

Let's see how it goes, watch this space...............................................................


Phew that was close.

#101 wayne

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Posted 12 December 2016 - 04:13 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

 

Hi Rod,

 

I'm just PM'd you regarding a response I've finally received from your ELO.

 

Cheers,

Wayne.



#102 David G

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Posted 12 December 2016 - 05:01 PM

Hi Rod,
 
I'm just PM'd you regarding a response I've finally received from your ELO.
 
Cheers,

Wayne.

Could you please send me the information you have.

Regards




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