A review of the process for classification of fireworks by default

1. A review of the process for classification of fireworks by default for Explosives Classification Group Meeting 21 January 2010 Dave Adams, HSE Explosives Inspectorate

2. Contents • Scope • What has been done • Audit of 2008/9 applications • Approach used by other Competent Authorities • Findings • What we plan to do & when • Allen Webb update on progress • Discussion

3. Scope • To undertake a fundamental review of the process for the classification of fireworks using the UN default list • Wide-ranging • Tools, process steps, interfaces etc • Exclusion • Not a review of the legislation

4. Audit & Analysis of data • 2008/9 • 112 applications for classification by default • One third of files reviewed • Selected on a random basis • Time analysis of the process • Effect – changes to classification • Record any other issues identified

5. Audit – Breakdown of process steps

6. Altered classifications • Circa 1890 articles in files reviewed • 36 changes to classification (~ 2%) • 22 went from 1.4 to 1.3 • 8 went from 1.3 to 1.4 • 2 went from 1.3 to 1.1 • 2 went from 1.4 to 1.1 • 2 went from 1.4S to 1.4G

7. Summary from Audit Multiple exchanges of information is common during process Major effect on time taken Requesting information Waiting for response Time in in-tray But does lead to changes in classification Some issues with Part B of the form Some issues re: selection pack requirements Exchanges of information can be avoided Applicants provided excess information

8. Benchmarking - Approach of other Competent Authorities Conducted in 2 Stages General approach Specific queries Email survey for both Sent to 14 CA’s

9. Approach of other Competent Authorities – General Approach A ‘set’ of six approaches drafted 7 out of 9 – responded as follows; ‘The competent authority checks each article against the default list, with complete details of firework candidate article (firework drawings, compositional details etc) as supplied by the importer/manufacturer. The competent authority amends any classifications found to be incorrect before issuing a competent authority document.’ The general UK approach appears (if anything) less rigorous than other CA’s Some more rigorous – items checked None responded indicating less rigour

10. Approach of other Competent Authorities – Specific Aspects Email survey – in progress Specific queries regarding approach Domestically manufactured vs imported Use of other CA CAD’s Grouping Close too but outside default criteria Responses from 6 CA’s to date (sent to same 14)

11. Summary – Benchmark with other CA’s Range of approaches to specific issues apparent Responses to date indicate; General approach same for imports Other CA CAD’s are used but no responses to date indicate universal acceptance Grouping – added benefit? UN criteria – all responses to date except one (Sweden) indicate strict appliance

12. Next steps – what we intend to do Review [1] Complete evaluation of other CA’s responses to specific aspects – mid Feb Classification Process [1] Minimize the need for further information during the process Specify and make available the information requirements for each firework category/sub category in the UN default list – end March Clarify and make available the information requirements re: selection boxes – already completed Clarify the quality standard for drawings – end Feb

13. Next steps – what we intend to do [2] Classification Process (contd) [2] Progress minor fixes to Part B form – tbc [3] Review guidance on ‘How to complete the application form’ following clarification on the information requirements at [1] Existing and new – end March [4] Define and clarify the approach relating to: grouping, the use of other CA CAD’s and application of the default criteria – end March

14. Next steps – Longer term [1] Revamp / design of Part B form Need? Added benefit? Timescale? [2] Review effectiveness of the new information requirements and guidance Audit number of requests for clarification / further information Time taken for the process 12 months time

15. Before General Discussion Handover to Allen Webb to update us on progress regarding these aspects

16. Discussion