Happy New Year

I hope that you had a fantastic Christmas and a Happy New Year. Well, 2015 turned out to be a very busy year for the BPA, what with legislative changes, guidance documents, a competition and plenty of meetings. Think of this edition’s column as an update...

Thank you to Jonathan Denney for this photograph taken during the Montreal International Pyromusical Competition

First of all I’d like to say a big congratulations to Chris, Andy and the team at Jubilee Fireworks on winning the Gold Jupiter at the L'International des Feux Loto-Québec also known as the Montréal
International Pyromusical Competition. This really is a fantastic and very well deserved achievement.

Next, own use and the question, ‘do professional fireworks imported by a UK firework display company for use in their own firework displays (and not for sale to any members of the trade),
need to be CE marked’? In my last column I told you BIS had written to the European Commission seeking clarification on this and that we were awaiting their response. That response has now
been received, but at first sight it wasn’t good news. I say at first sight because the initial reading of their letter paints a sorry picture in terms of their view. However, when you then read the letter that
BIS wrote to the Commission, you realise that unfortunately BIS didn’t ask the correct questions, and if you don’t ask the right questions you don’t get the right answers. There were some positive
areas of agreement found. BIS still fully supports the industry and proposed going back to the Commission with a new letter addressing points from the Commissions’ initial response, and asking some new questions with scenarios. I wrote a detailed paper on behalf of the BPA stating our position, the legal points as we understand things, the safety implications of our position (of which we see none), and the impact on the UK industry, all of whom are SME’s and all of whom one would expect the Commission to
wish to protect.

My paper and others are now being considered by BIS and the Pyrotechnic Articles Liaison Group
(PALG) and will be used as the basis for the new approach to the Commission, likely to take place
in Q1 2016. In our approach we are asking for a meeting with the Commission and for industry representatives to be sent to that meeting. So although some in our industry have been scare-mongering saying that own-use products would be banned and HSE would be getting new powers to seize non-CE stock, this just isn’t the case currently. The resolve of the group is very strong, I for one do not intend to sit back and allow Europe to steam roll over the issue when in my opinion their interpretation of the law is very clearly wrong.

In September last year I attended a meeting of the Explosives Industry Forum hosted by HM ChiefInspector of Explosives, Dr Richard Daniels at HSE in Bootle. We covered much ground in the daylong meeting, but particularly relevant to our industry stood two things. Firstly, that Dr Daniels was taking a fresh approach to his predecessors, and was keen to improve departmental performance in all sectors. He provided a range of statistics to demonstrate improvements he had already made, and spoke of how he planned to continue on this tack. One telling example was how member of the classifications team had said to him fairly recently how quiet they were. His replywas along the lines of that they were actually just as busy as they had been the previous year, it’s just that through stream-lining the department and the efficiencies they had made, had resulted in less time being taken processing each application. I can certainly vouch for that - I had a classification application completed by HSE in just 19 days last summer. The second topic of interest was the five-year expiry for firework classifications. I laboured the
point about how problematic this had become for some parts of industry. I gave an example of where a company that holds a classification goes out of business, whilst their products are still in stock with other companies. HSE said they would take a sympathetic view of this situation and would try to find individual solutions where this occurred. However, more significantly, Dr Daniels tasked Principal Inspector Martyn Sime with examining HSE’s need for the five-year expiry - was it necessary, could the same be achieved another way, was five a magic number or could it be something else? No promises, but I am happy that this is being looked at properly and that Martyn
Sime will consider it from all angles and consult with industry.

You may recall that last year The Event Services Association (TESA) introduced some of the most sweeping changes ever to the British Firework Championships. They listened to the unhappy industry and set about making improvements to the competition. They changed the scoring, the judging system, the role of the adjudicator and many other things, including adding an industry observer to watch over formalities and help ensure ‘fair-play’. TESA invited the BPA to provide an observer in 2015, and after a discussion at a BPA meeting as to who should do the role, I was the person we put forward.

So, what can I tell you? Well, firstly, I walked a lot - 8 miles on the Tuesday and 8.2 miles on the Wednesday, and on the Wednesday got so wet that even waterproofs couldn’t keep up! I watched set-up from around 7am until early evening each day, and then headed over to observe the judges scoring each team in the evening. Early on, I was pleased to be able to assist the adjudicator with a technical breach that an experienced eye was needed for. If some teams were doing a particular aspect of their show one way and others another, and one was correct and the other wasn’t that wouldn’t be right. Fair play is all about everyone being treated on a level field. Potential rules breaches in the new competition are flagged up to the judges who then take a view on whether to penalise or not. I do think the adjudication team needs someone on it who has spent a number of years setting up firework displays.

It was also clear the adjudicator has a very tough job. One of the comments that came through loud and clear was a terrible disparity in the standard of risk assessments from different companies. Some companies provided thorough, professional assessments considering all of the
risks, others apparently contained a lack of information, not enough in some instances for a proper assessment to be made.
Putting the competition to one side, how can you say if it’s safe to fire a firework or not if you’ve not considered its performance characteristics in a range of weather conditions? We see this time and time again, and I give you some Christmas lights ceremonies as a perfect example. On occasion people don’t assess the risks properly and then people are put in danger, firing fireworks from
rooftops that are not suitable for use in those specific circumstances.

At our Autumn BPA meeting we resolved to make risk assessment a key topic for the Association. The standard of risk assessment in some parts of the UK professional fireworks display industry really needs to improve. I say ‘some,’ because for many companies H&S comes naturally, is taken very seriously and their assessments are first class. Back to Plymouth and I have to say that for the set-up phase, fair play did prevail and although day 2 teams had appalling weather conditions to contend with, it was a pretty level playing field in terms of compliance with the rules, certainly no massive issues to report.

So, I headed over to the judging. This is probably one of the first reports to ever be published about what happens over at the judging for Plymouth. First of all, I’ll make clear my role. My role was to observe and not get involved, and that is exactly what I did, I watched and listened and nothing more. We started by having a buffet dinner upstairs in the restaurant/bar area of the RoyalPlymouth Corinthian Yacht Club, followed by a briefing in the judges scoring room, a small private room on the lower level of the club, which had a large window overlooking Plymouth Sound and a side door leading out onto a balcony which was large enough for a dozen or so people. The judges sat around a large table in the centre of the room. TESA briefed the judges with a pre-agreed script, and Head Judge Len, sorry, Charles Smith (I’ve been watching too much Strictly!) then had a few words.

The process that followed was that the judges would go out onto the balcony two minutes or so before each show, watch the show, then return to the judges room and write their scores and any comments. This was then repeated. The whole process was very solemn and to my surprise was conducted in silence. I don’t know what I was expecting, but there was no conferring, the whole process was very quiet. At the end, the judges had an opportunity to review their scores for all competitors (the idea after all was to pick the winner in their opinion), and the papers were collected in. The expert judges then had an opportunity to consider any rule breaches and one option was to take no action, another could result in up to 10 points being deducted overall per team.

I watched the scores being totalled and then attended the presentation. Congratulations to Fantastic Fireworks on their win, I know what it feels like to win at Plymouth and they did a fantastic (!) show.

So, at the end of everything, was the competition fair? Well yes, it was in my opinion. Fair play did prevail and I think the result came about from proper consideration by the judges. That’s what counts at the end of the day - it absolutely has to be a level-playing field for all, without fear or favour, affection or ill will.

I observed a few strange things that day, hiccups if anything, and certainly nothing that affected the result, but overall, I would recommend the British Fireworks Championship to everyone. TESA I know are planning a second round of consultations with industry, which is great. I think my biggest observations are the need for an experienced ‘fireworker’ on the adjudication team (that’s with no criticism to the current team, it’s just an enhancement that I think would benefit the competition), and I would like to see expert judges who are experts in fireworks rather than from the explosives sectors as a whole. I’m not sure that a defence explosives company would want me to judge their entry in a defence industry competition? These people are extremely welcome on the judging team, but but as lay judges, not as ‘experts’ in our field.

BPAAndy HubbleMay 21, 2018New Years Fireworks, Firework Legislation, Fireworks Risk Assesment, BPA, TESA