In response to a disturbing finding of the industry practice of transporting aerial shells alone, and without reloadable tubes, the Pipeline and Hazardous Materials Safety Administration (PHMSA) recently issued a formal guidance on the requirements for transporting an aerial shell kit with a reloadable tube as UN0336, 1.4G. Aerial shell kits are designed to operate…
[First and foremost, this article is dedicated to the memory of Dotty Drewes] In the December 2012 edition of the ATF Explosives Industry Newsletter, the ATF released a list of the six most frequently-cited violations during the 5-year period of 2006-2011. These six violations represent, in the aggregate, over fifty percent (50%) of the total…
The war on terrorism is being fought on many fronts. Unfortunately, the lumping of an entertainment activity such as display fireworks together with the commercial explosives industry puts the display fireworks industry on one of those fronts. To avoid becoming a victim of that war, the display fireworks industry must battle to separate itself from…
Just when you thought it could not get any worse on the regulatory front, on the eve of the New Year, PHMSA released another clarification on its fireworks approval policy. In the process, it appears that PHMSA has both upended and compromised certain accepted industry practices of businesses located in the United States and, at…
