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
Safety Consulting Engineers, Inc WHO ARE WE
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
Fireworks Certification Agencies (FCA) WHAT ARE THEY
Fireworks Certification Agencies FCAs are new FCA110 identifies SCE Issued by the US DOT 49 CFR 107.402(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
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
Governing Documents 49CFR The law 49CFR 173.65 Exceptions for Division 1.4G Consumer Fireworks APA 87 1 Incorporated by Reference in 49CFR 171.7 Lays out specifics
Fireworks Certification Agencies WHAT ARTICLES QUALIFY FOR FCA EXAMINATION
What articles qualify For an FCA only certain articles from APA 87 1 1.4G Consumer fireworks ONLY However Can still apply to DOT for paperwork review of all allowable articles in APA 87 1
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
FC Approvals HOW ARE THEY DIFFERENT
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
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
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
FC Numbers Approvals valid for shipment FC XXX YYYYYY ZZZZ XXX = 110 for SCE YYYYYY = YYYYMM 201409 ZZZZ = sequential number
Applying for an FC approval THE PROCESS
The way(s) forward
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.
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
Path 1 Submit to DOT Send application to DOT DOT approval EX Number You can ship!
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)
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
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
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
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)
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.
Path 2 Success! FCA response If CERTIFIED Ship with FC number IMMEDIATELY If REJECT or DENY notified why SCE written response in email (pdf) SCE quick turnaround for errors and omissions
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 www.sceinc.com
What can be tested Virtually anything Component (substance) Article It s a longer journey Contact lab Coordinate sample delivery Testing Report DOT Review / approval
It s a journey
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
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
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
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
Single package test success APA Conference Miami, FL October 2014 Safety Consulting Engineers, Inc. A DEKRA Company
Single package test fail
External fire results 1.1 1.2 1.3 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
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
Path 3 success! Lab generates report You submit report to DOT Receive EX letter You can ship!
The bottom line IN SUMMARY
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
Questions? Please Contact US! Thaddeus Speed Technical Director Thaddeus.speed@dekra.com Graham Walsh Senior Explosives Engineer Graham.walsh@dekra.com fca@sceinc.com