A review of the process for classification of fireworks by default
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A review of the process for classification of fireworks by default. for Explosives Classification Group Meeting 21 January 2010 Dave Adams, HSE Explosives Inspectorate. Contents. Scope What has been done Audit of 2008/9 applications Approach used by other Competent Authorities Findings

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A review of the process for classification of fireworks by default

A review of the process for classification of fireworks by default

for

Explosives Classification Group Meeting

21 January 2010

Dave Adams, HSE Explosives Inspectorate


Contents default

  • 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


Scope default

  • 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


Audit analysis of data
Audit & Analysis of data default

  • 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



Altered classifications
Altered classifications default

  • 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


Summary from audit
Summary from Audit default

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


Benchmarking approach of other competent authorities
Benchmarking - Approach of other Competent Authorities default

Conducted in 2 Stages

General approach

Specific queries

Email survey for both

Sent to 14 CA’s


Approach of other competent authorities general approach
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


Approach of other competent authorities specific aspects
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)


Summary benchmark with other ca s
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


Next steps what we intend to do
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


Next steps what we intend to do 2
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


Next steps longer term
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


Before general discussion
Before General Discussion

Handover to Allen Webb to update us

on progress regarding these aspects



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