FIREWORKS CERTIFICATION AGENCIES

Transcription

1 Thaddeus Speed Technical Director Graham Walsh, Ph.D. Senior Explosives Engineer Bernadette Reyes Operations Manager and Sr. Engineer Jim Dahn, Professional Engineer FIREWORKS CERTIFICATION AGENCIES

2 Safety Consulting Engineers, Inc WHO ARE WE

3 Intro SCE DOT authorized lab for Explosive Testing Fireworks Certification Dust explosion Flammable solid / liquid Mat l characterization UN and other standards PHA / PSM audits analysis and training

4 Fireworks Certification Agencies (FCA) WHAT ARE THEY

5 Fireworks Certification Agencies FCAs are new FCA110 identifies SCE Issued by the US DOT 49 CFR (d) SCE Staff 4 employees certified to carry out Firework Certification reviews SCE is experienced Approved as FCA March 2014 Founded in 1972 Fireworks Explosives Energetics

6 Fireworks Certification Agencies Allow for an alternate path for applicants FCAs can approve fireworks for shipment New numbering system FC #s rather than EX #s Total 2,881 fireworks applications in process (September 2014) with PHMSA

7 Governing Documents 49CFR The law 49CFR Exceptions for Division 1.4G Consumer Fireworks APA 87 1 Incorporated by Reference in 49CFR Lays out specifics

8 Fireworks Certification Agencies WHAT ARTICLES QUALIFY FOR FCA EXAMINATION

9 What articles qualify For an FCA only certain articles from APA G Consumer fireworks ONLY However Can still apply to DOT for paperwork review of all allowable articles in APA 87 1

10 APA 87 1 Section 3.1 Ground and hand held sparking devices Cylindrical fountain Conical fountain Illuminating torch Wheel Ground Spinner Flitter Sparkler Toy Smoke Device Wire sparkler / dipped stick Aerial devices Sky and Bottle rocket Missile type rocket Helicopter/aerial spinner Roman candle Mines and shells Reloadable aerial shell kits Audible ground devices Firecracker Chaser

11 FC Approvals HOW ARE THEY DIFFERENT

12 FC vs EX Approvals You apply to an FCA instead of the DOT Usually much faster approval Can ship with either FC number instead of EX number Learning curve

13 FC vs EX Approvals Main differences Time Cost Files Limitations FC Approvals are for Consumer Fireworks of 1.4G ONLY Cannot submit to both FCA and DOT for same firework Required Records Certifications Must Be Keep on File Manufacturer Importer and/or Shipper for 5 years after last shipment (import). Manufacturer must provide copy of FC to importers and Shippers

14 FC Numbers REGARDLESS of application outcome An FC Number is Created Approvals You get Written Certification and can ship immediately Rejections For DOT Tracking Denials For DOT Tracking All are reported to DOT

15 FC Numbers Approvals valid for shipment FC XXX YYYYYY ZZZZ XXX = 110 for SCE YYYYYY = YYYYMM ZZZZ = sequential number

16 Applying for an FC approval THE PROCESS

17 The way(s) forward

18 Three Scenarios 1. Display firework 4 red to blue peony Non metallic break 2. Consumer firework Cylindrical fountain 74 g pyro comp, produces shower of sparks 3. You re special You know who you are.

19 Path 1 APA 87 1 Compliant Non Consumer Firework An FCA can t help You can apply to the DOT Same as it ever was Not a consumer firework

20 Path 1 Submit to DOT Send application to DOT DOT approval EX Number You can ship!

21 Path 2 APA 87 1 Compliant 1.4G Consumer Fireworks Two options Apply to the DOT Apply to an FCA An FCA can review & certify your device Consumer Firework Conforms to APA 87 1 Three true outcomes Certification (ship!) Reject (revise) Deny (it s not APA Compliant)

22 Applying for an FC Approval Contact an FCA We re all new We re all different But we all have the same requirements from the DOT Develop a packet Communication with FCA Response from FCA

23 Our Responsibilities Electronic reporting Certified Not Certified (Denied) Modified Provide Chemical composition Diagram Statement that the application is not a duplicate and info is true Thermal stability test

24 Responsibilities FCA Assigns FC number Regardless of outcome FCA sends customer notice of certification / denial FCA must maintain a copy of all documents for 5 years Manufacturer and importer maintain docs for 5 years after last import

25 Getting A Fireworks Certification (FC) Initial contact with SCE Set up as customer Allow us to call you with questions Response from SCE Checklist Fillable forms SCE Review 21 days (typical) 5 days (expedited)

26 Getting A Fireworks Certification (FC) Packet requirements Name, address, telephone and fax manufacturer and U.S. Agent, if applicable; A detailed diagram A complete list of the chemical compositions, formulations, and quantities Thermal stability test results A signed certification declaring conforms to the APA Standard 87 1, that the descriptions technical information contained is complete and accurate no duplicate applications submitted to PHMSA.

27 Path 2 Success! FCA response If CERTIFIED Ship with FC number IMMEDIATELY If REJECT or DENY notified why SCE written response in (pdf) SCE quick turnaround for errors and omissions

28 Path 3 Something Different! Not APA 87 1 Compliant APA 87 1 doesn t cover your article You re an innovator! Neither an FCA nor DOT can approve via paperwork You have to test Contact a DOT Explosives lab SCE

29 What can be tested Virtually anything Component (substance) Article It s a longer journey Contact lab Coordinate sample delivery Testing Report DOT Review / approval

30 It s a journey

31 Boiled down For a substance UN Series 3 Impact sensitivity Friction sensitivity Thermal stability Small scale burn UN Series 6 Single package test External fire test For an article UN Series 4 Thermal stability 12 m drop test UN Series 6 Single package test External fire test

32 UN Series 3 Small scale sensitivity tests Is the substance thermally stable Is the substance forbidden for shipment IN THE FORM TESTED Substance required 330 g typically Tests Impact sensitivity Friction sensitivity Both vs. a threshold Thermal stability Can t ignite Small scale burn Can t detonate

33 UN Series 4 Determine if article is stable enough for transport Thermal stability test 75C for 48 hours Same as self test, but required to be witnessed 12 m drop test Article cannot ignite NOT a test of packaging or article integrity

34 UN Series 6 Assigns article to division 1.1, 1.2, 1.3, 1.4 or 1.4S Single package test Test for mass detonation Screening test for 1.1 External fire test Assigns division

35 Single package test success APA Conference Miami, FL October 2014 Safety Consulting Engineers, Inc. A DEKRA Company

36 Single package test fail

37 External fire results Mass detonation Projections greater than 20 J Fireball greater than 4 m Fiery projections further than 15 m 1.4 Fireball greater than 1 m Fiery projections greater than 5 m Projections greater than 8 J 1.4S Nothing much happens *Remember, these results are for an article / packaging system

38 Other tests There are other test series Examiners will work with you to determine proper tests Can test substances as well as articles Full up or subcomponents For things that fall outside of APA 87 1

39 Path 3 success! Lab generates report You submit report to DOT Receive EX letter You can ship!

40 The bottom line IN SUMMARY

41 The bottom line You have options when it comes to obtaining shipping approval SCE is here to help Discuss best path forward If you want to ship it, there s a way forward for you US DOT Approved FCA (since 2014) US DOT Approved Explosives Lab (since 1999) DOT Always an option if APA 87 1 compliant Free FCA Option for 1.4G APA 87 1 Compliant Lower volume quicker turn around Explosives lab Sometimes the only option Much more costly

42 Questions? Please Contact US! Thaddeus Speed Technical Director Graham Walsh Senior Explosives Engineer