Getting a license fireworks

[Mumbles]

Table 555.224 of the orange book sets out tables of distances for display fireworks. Tables 555.222-223 set out tables of distances regarding processing buildings and other buildings, magazines, highways, etc.

 

It is my impression from reading the orange book that display fireworks have different setbacks than generic low explosives. It seems unlike the government to allow us to "pick and choose" what best suits us. It helps us for larger quantities, but hurts us for quantities 50lbs and under. The range of 0-1000lbs is regulated the same.

 

Subpart K 555.201(d) The regulations set forth in §§ 555.221 through 555.224 pertain to the storage of display fireworks, pyrotechnic compositions, and explosive materials used in assembling fireworks and articles pyrotechnic.

 

Subpart K 555.206( Outdoor magazines in which low explosives are stored must be located no closer to inhibited buildings, passenger railways, public highways, or other magazines in which explosive materials are stored, than the minimum distances specified in the table of distances for storage of low explosives in §555.219, except that the table of distances in § 555.224 shall apply to the storage of display fireworks. The distances shown in §555.219 may not be reduced by the presence of barricades

 

The above specifically mentions outdoor magazines, so I'm not sure if an indoor type 4 is somehow different.

[jordanm]

Does anyone have a good excel document for keeping track of records of what is stored in a magazine? I think I recall magazines needed to be inspected personally weekly as well. Also I assume you don't need to keep a record for when the magazine is empty correct? I finished my type 4 magazine and have it installed in my shed. I sent in my application and just waiting on the inspector.

[lloyd]

Jordan,

 

Two things... I have a nice form I use for keeping records. However, under recent rulings by the Director of ATF (about five years ago), one cannot keep records on a computer, unless the program makes the records completely 'unchangable'... that is, the only way you're permitted to correct an improper entry is by entering a 'correcting transaction'... the original errored figure or transactions must remain unscathed.

 

It used to be that was on the 'honor system', in that the record-keeper was responsible for that sort of action. Now, they want the software used to mandate that it be done that way.

 

That said, for low numbers of transactions, keeping a paper log is the simplest way to make them happy.

For empty magazines -- Technically you don't have to do regular inspections on an empty magazine. In truth, if ATF finds a magazine has gone empty and un-inspected, they may presume that it is 'abandoned', and ask you to retire it. Now... an empty magazine is NOT 'abandoned' if it's still inspected regularly, and the inspections are entered into your log.

 

To that end (and because of the nature of work I do, my magazine is often empty), I still inspect on the same regular schedule - and record those inspections - so that I've shown my intent to keep it in use. You don't have to perform a 'formal' inspection more often than once or twice a year (I don't remember which), but because of the way my records are set up, I do one monthly, anyway.

 

Maybe these will help:

Lloyd

Fire extinquisher inspection log-generic.doc

Daily Magazine Blank NEW #1.doc

Daily Manufacturing Log Blank generic #1.doc

Edited September 4, 2017 by lloyd

[jordanm]

Thank you. That is kind of what i am looking for and yes i would be printing them off and having them hard copied by the magazine and stored in a folder. By quantity placed in magazine do you mean shell size and quantity or mass? Where my magazine is located i usually visit once a month so that should not be a problem, however i most likely will not be storing anything in it until i get closer to the fourth. What is the minimum an occupied magazine must be inspected?

 

Also what types of things are you looking for when you perform an inspection? Just an inspection of integrity and evidence of being tampered with?

[lloyd]

Jordan,

Shell numbers are not an acceptable entry, because magazine quantities are determined by EXPLOSIVE WEIGHT.

 

To determine the explosive weight of shells, ATFE has determined that a person may take 50% of the gross weight of aerial shells to be their explosive weight. So, if you put 10lb of shells in, you should record the count (as your own part of the record, in the 'comments' area), but record the weight as 5lb explosive weight.

 

Because ATFE isn't concerned with dribs and drabs, round to the nearest 1lb increment. Just be sure that you do the same upon removal, and that all your rounding for a 'lot' ends up being the same total that went in to begin with.

 

My inspections consist of (as you mentioned) integrity and evidence of tampering. But also, cleanliness, evidence of water leaks, and visible or odoriferous signs of deterioration of product that might present a safety hazard. In my area, ATFE also requires a fire extinguisher to be IN every magazine (although I'll be DAMNED if I'm going to run INTO a burning magazine to put out a fire!). So I also inspect that for proper charge and date of inspection. Further, I include in my (small quantity) inspections a verification that the numbers in the magazine match the numbers in my records. Doing that is aided by clearly labeling each container (or even each individual large shell) with a weight label. (and be sure you UPDATE that label if you take out a small portion from a bucket or box!!! (BTDT))

 

I THINK a magazine only requires a 'formal' recorded inspection once a year, but it may be twice a year. Since I do it monthly, I've not spent the time to refresh that particular memory of the Orange Book. It's in there. But, since they may come at any time and do their own inspection, it behooves the license-holder to always be sure the quantities recorded match the quantities actually stored.

 

Lloyd

[jordanm]

Thank you. Do the boxes typically state the weight on them or do you manually weight the box of shells to determine this?

[lloyd]

You pretty-much have to weigh everything, Jordan. I wouldn't trust any Chinese product to be properly weighed, anyway. OTOH, if I bought a 5lb bottle of Green Dot, I'd accept the weight marked on it.

 

It's also important (for consistency, yes, but also for inspections), that you use the same scale for everything, and that you provide that scale to ATFE, if they wish to weigh boxes to confirm your weights.

 

Lloyd

[OldMarine]

I've got me a job box for an indoor magazine but right now I don't have the separation for my manufacturing area. I figure half a measure is better than none for now and once I get it all moved to the barn I'll have everything Kosher. I've got a shed 225' from the barn on the closest corner that will serve nicely.

[starxplor]

Does an indoor (type 4) require such distances? I thought there were basically no separation requirements beyond 'not attached' when dealing with the low capacity type 4?

[lloyd]

There are no stated tables of distances for indoor type 4 magazines. They cannot be in a dwelling, but other than that, I don't think there are any distance issues, at all.

 

I know from prior interactions with another pyro that you cannot just build a 'shell' building around a large type 4 and call it an 'indoor' magazine. Apparently, ATFE already knows about that ploy, and won't permit it.

 

Lloyd

[OldMarine]

I was going by what Ned stated in his article on the indoor type 4 magazine. I looked up the current distances and it's changed somewhat to the better.

https://atf-eregs.18f.gov/555-222/2015-25190#555-222-p1

I was also referring to my manufacturing area rather than the distance from the house.

Edited September 6, 2017 by OldMarine

[Mumbles]

This would be a question for the ATF or someone who has a permit/licence with one of those types of magazines.

 

Given that the tables in question (555.222 through 224) have values as low as 0lbs, it seems like they'd be applicable even for a low capacity type 4. My interpretation would be that these distances could be enforced for a type 2 or a type 4 magazine.

[starxplor]

There are no stated tables of distances for indoor type 4 magazines. They cannot be in a dwelling, but other than that, I don't think there are any distance issues, at all.

 

I know from prior interactions with another pyro that you cannot just build a 'shell' building around a large type 4 and call it an 'indoor' magazine. Apparently, ATFE already knows about that ploy, and won't permit it.

 

Lloyd

 

I already have a shed, but it had a tree fall on it before I bought the place. I am looking in to buying/building a new one in the next couple of years and was planing to make sure it had space for a job box style type 4. Right now, I only build up north, so being able to prep stuff like BP down-state to take up north means I would have more time for shell building once up there, meaning more shells to build.

 

On a related note to the earlier conversation about inspection: In the winter, my property is covered in snow, making the current shed's doors un-openable (magazine would be empty all winter). How often do they do inspections in the dead of winter?

Edited September 7, 2017 by starxplor

[lloyd]

Star,

They usually call before inspection, unless you've had compliance problems in the past. One way to help ensure that they'll call is to list your site access times (on your license application) as "by appointment". When/if they call, you can tell them that the magazine has been empty (since such & such date), and is presently "snowed in".

 

They'll probably defer until a later date. However, IF they come, you must make the magazine accessible for inspection, even if you have to shovel snow for two hours to get the door open.

 

The new breed of ATF investigators consists of more reasonable and reasoning people than the last couple of generations. If your record has been 'clean' until such an event, they'll work with you. Keep in mind that they're people, too; just people doing a job. They don't want to be made physically uncomfortable or to be endangered any more than you do.

 

Lloyd

Edited September 7, 2017 by lloyd

[starxplor]

I had this amusing idea of having them show up unexpected, asked to see the magazine, i say sure, pull out my snowshoes and ask where theirs are... I wonder if the inspectors that cover the UP actually do have a set in their vehicles, heh.

[pyrofly]

So, I had this idea on this subject. Would a remotely inspectable door seal that gets destroyed any time the doors are opened along with surveillance cameras to inspect for larger breaches/disturbances be sufficient for the weekly inspection? The A copy of the magazine books, and surveillance logs could be kept offsite in a location where the weekly inspections were performed from.

 

That weekly inspection is mainly to make sure the magazine hasn't been tampered with as I understand it which should be possible to do remotely. A satellite internet or cell connection could easily support a system like this. I can think of a few situations where storage at some remote locations would be useful where the magazine contents might be used or added to every few months, but where the ease of access and lack of on site personnel on a regular basis would make a weekly inspection in person difficult.

[lloyd]

Fly,

ONE of the purposes of regular inspections is to check for tampering. That's hardly all... one needs to check for a number of conditions -- leaks being high on that list.

 

Weekly is more-often than required.

 

Lloyd

[NtzPrinter]

Thanks for all of the input. I'm just a hobbyist. I have no interest whatsoever in going commercial. I'm 59 years old and just love "sky art" but I also make it very clear that safety is my first concern.

I would love to have a valid ATF license as well as any permits required by the State Fire Marshall. But all I'm really concerned with is building and shooting aerial shells.

 

My grandkids also love fireworks and of course, we fire them (legal consumer products) safely for their amazement and enjoyment!

[jordanm]

Here is my How to make a cheap Indoor ATF Type 4 (IV) Storage Magazine for Display Fireworks video.

Hopefully it will help some people out and i hope it will pass, what do you think Lloyd?

[dave321]

surely it would be better to line it with 18mm plywood, rather than just paint it.

 

the 18mm will give added protection from heat if a fire occurred in the shed / barn .

 

that's why in the uk blackpowder is required to be stored in an 18mm ply box with 6mm ply inside for the separate

partitions, and it also requires an intumescent strip on the lid area.

[jordanm]

It is not just paint. It is bedliner that is used on truck beds. In the USA it needs to be spark free and this meets that criteria. If you have a fire next to a storage container i don't think that plywood is going to last very long before it combust and starts fire on the inside. The purpose of the liner is not as an insulator its to create a layer that does not promote sparks that would ignite the containers contents,

[lloyd]

That should work fine. If the investigator balks at the bed liner, you can cite the fact that others have had such approved.

 

He might (legitimately) require that there be some means of ensuring goods don't rest against the outside walls. We use 1x4 strapping in conex boxes (lined with plywood or particleboard, yes. It's cheaper than bed-liner on that big of a box! <grin>)

 

Lloyd

[jordanm]

I contacted the ATF contact when i was filling out my application and specifically asked if bedliner could be used as a spark free liner and she stated that it is completely acceptable.

 

Obviously i will be moving the propane tanks at the end o the video when i am storing items in the box as well.

[lloyd]

Jordan,

That's as I surmised. They aren't particularly critical of HOW you achieve spark-resistance, so long as you take measures to do so (and it works).

 

Bed liner is expensive, but fine for a small box like that. It would be prohibitively-expensive for a large container.

 

Lloyd

[jordanm]

Lloyd,

 

Would you expect this container to be suitable as an outdoor storage container or does it need to be more weather proof then this?

 

I only ask in case i want a little more weight in the container and want to move outside of the 50lb limits. Im sure this container would be capable of holding more than 50lbs. I know i would have to do more securing it so that it could not be removed but is the container itself acceptable?