This is the second of two articles discussing some of the fine points of drafting legislation. In last month’s article, I discussed general concepts regarding drafting legislation; in this month’s article, I will examine the art of drafting legislation that either amends or repeals an existing statute. It is rare for a legislative proposal to…
The Pipeline and Hazardous Materials Safety Administration has recently issued a clarification of the prevailing fireworks policy regarding approvals or certifications for specialty devices. [Docket No. PHMSA-2013-0206; Notice No. 13-15; dated October 2, 2013]. Interestingly, this Agency may have deliberately elected to issue a clarification to bypass seeking public comment; PHMSA routinely seeks public comment…
Two months after issuing a ruling benefiting industry practices relating to pick bins of fireworks shells, ATF has followed up with a separate ruling relating to approval of wood-only floors for Type 4 storage magazines. Specifically, ATF Ruling 2012-5 sets forth an alternate basis for approval of Type 4 storage magazines constructed of wood-only floors….
Dallas, Texas, was the site of the American Pyrotechnics Association’s (APA) 59th annual convention; billed as the Red River Shootout. The Convention was scheduled around daytime seminars and a trade show, while many nights were punctuated by a reception culminating in a fireworks display. The fact that the convention coincided with the Texas State Fair…
