The following are some of the responses we have received from the online questionairre. Please use the MSER forum for any comments on these or other matters relating to MSER
| Regulation/Question | Topic | Comments |
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| Reg 11 | Refusal to register | The regulations deal with "unsuitable" premises or "unfit" persons. If LAs refuse on other grounds (eg anti-firework lobby) what is the procedure from there on in? ACoP should specify refusal can only occur where distances cannot be met |
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| Reg 13 | Consultation Zones | There should be an additional requirement for "reasonable steps" to notify persons in the zone. An "approved" system (letter drops, ads etc) will need to be developed.
It also appears there is no cap on fees charged by the Local Authority and this should not exceed the costs reasonably incurred. Furthermore these should be forfeited if the LA fails to comply with the procedures in the specified time period. |
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| Reg 14 | HSE licences | Does 14(4)(b)(i) imply that HSE can place security provisions on buildings as part of the licence? |
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| Articles Pyrotechnic vs Fireworks | There is a need to clearly discriminate (or draw an equivalence) between these two sets of explosives. This is particularly the case where "articles pyrotechnic" are stored in theatres etc relying on the old "14 Day rule".
If hazard is the determining factor then 1.4G articles pyrotechnic should be treated exactly the same as 1.4G fireworks. |
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| HSE Q13 | Supply of fireworks | Fireworks should only be supplied to a licenced company/person |
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| HSE Q3 | Revocation/Refusal of licences | I feel that there is not sufficient clarification as to why someone could have their licence revoked or refused. I think situations could occur where the site could be 100% suitable for fireworks storage and the local authority will find excuses not to have an explosives site in their area. I do think that this position could possibly be abused in certain circumstances. On the other hand, if it were to rid the fireworks industry of the "cowboy" element by some form of filtering process then this can only be a good idea. I do think there is a very fine line between yes and no on this subject. |
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| HSE Q28 |
I think that this is a very complex issue and is very difficult if not an impossible task to classify into one section. Each individual site has it's own case. For example. Say the site is large enough to have several stores on it and is also large enough to enable these stores to have a long enough distance from each other to allow seperation distances between each store. Why should the aggregate storage total be an issue if each store has its own seperation distance. |
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