October 23, 2009
Liuyang, China
Statement of the American Pyrotechnics Association
By Julie L. Heckman, Executive Director
Dear distinguished colleagues, on behalf of the American Pyrotechnics Association, let me extend my congratulations and sincere appreciation to the IFA for convening this very important transportation safety forum. And let me express my deep regret that I could not join you in person to discuss and exchange ideas as transportation safety is one of APA¡¯s highest priorities.
I applaud the participation of the Ministry of Transportation as well as the officials from BAM, TNO, CIQ and the port authorities in this important conference. We have experienced improvement in the safety and transportation of fireworks during recent years and each of us should be commended for our role and participation in this positive progress.
While transportation and safety is improving, we still have much to do. Members of the fireworks industry, working along side with the relevant government officials, must remain vigilant to ensure that fireworks are properly classified and declared before they are offered for export.
We are pleased to learn from the Shanghai Maritime Safety Administration that an alternate port will handle fireworks and other dangerous goods during the Shanghai World Expo in 2010. It is extremely critical that China provide enough ports for fireworks exports to ensure smooth trade world wide and to help reduce number of mis-declared goods. When transport restrictions are too severe, and there are not enough ocean carriers willing to accept fireworks, there is too much incentive for factories to cheat and improperly declare goods.
An on-going area of concern to the APA and its members, both China manufacturers and U.S. importers, is that currently China does not accept the U.S. Department of Transportation classifications for fireworks. Under the United Nations, the U.S. DOT is recognized as a Competent Authority and EX approvals issued by the U.S. DOT are respected and recognized by the UN community.
The U.S. allows for aerial shells, 8 inch and 10 inch in diameter, to be classified and approved at 1.3G fireworks, UN 0335, because the US approvals process and chemical restrictions, pyrotechnic chemical formulas are far more restrictive than the UN classification scheme. However, the China ports and CIQ do not accept the U.S. DOT classifications and EX approvals which hinders trade and encourages factories to misdeclare fireworks which is not good for the China export port, the ocean carriers, or the U.S. receiving port. We respectfully request that the U.S. classifications and EX Approvals for fireworks intended to be exported to the U.S. be accepted by the ports and CIQ. This will greatly enhance transport safety, by ensuring that exports are properly declared.
Additionally, the U.S. DOT has de-regulated certain novelty devices for the purpose of transportation. Certain sparklers, snappers, party poppers and similar devices, which contain nominal amounts of pyrotechnic composition are not regulated as 1.4G fireworks in the U.S. and these devices may be transported as general merchandise. China currently treats these devices as 1.4 G fireworks, which creates much confusion for the U.S. receiving report. Again, we strongly encourage China MOT, CIQ and port officials to accept the U.S. Competent Authority Approval for products destined to the U.S.
Once again, I sincerely hope that you will appreciate the efforts of the APA to improve transport safety.
We stand with you, our colleagues in safety, to do our part to help ensure the world wide transport of fireworks so that we all can celebrate the beauty of fireworks in the skies for many years to come.
In closing, I extent my best wishes and warmest regards to the IFA for a successful conference.
Sincerely,
Julie L. Heckman
Executive Director
American Pyrotechnics Association
