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National Fireworks Association Executive Director Nancy Blogin 8224 NW Bradford Court | Kansas City, MO 64151 Phone: 816-505-3589 | nlblogin@gmail.com September 24, 2018 Consumer Product Safety Commission 4330 East-West Highway Bethesda, MD 20814 RE: Amendments to Fireworks Regulations, Docket No. CPSC-2006-0034 To the Commission, The National Fireworks Association (NFA) respectfully submits the enclosed test report in relation to the Amendments to Fireworks Regulations, Docket No. CPSC-2006-0034. The test report is relevant to assessing the percentage of powdered metals that should be permitted in burst charges. As demonstrated by the test report, there is no rational basis for any proposal that prohibits less than 12.5% powdered metals in burst charges because hybrid formulations (which don’t have powdered metals) produce greater explosive energy than those with 12.5% powdered metals.1 NFA commissioned Safety Management Services (SMS) – a DOT-approved Explosive Test Lab – to compare the relative energy output of two burst charges that are understood to be used in consumer aerial fireworks: one with no metals (the “hybrid” powder)2 and the other with 12.5% powdered aluminum (the “metals” powder). The test method employed by SMS, which was developed in conjunction with DOT for the purpose of evaluating burst charge powders, involves placing burst charge formulations in steel tubes with various vent sizes at the top. Samples of burst charges are placed inside the steel tubes and ignited, thereby simulating the performance of a burst charge within a consumer fireworks shell. The vent size at the top of the steel tube is measured in 1 mm increments, with a maximum opening size of 22 mm in diameter. The relative energetics of different burst charges is determined by observing the vent size opening at which the steel tube is ruptured by the ignition of the burst charge. A rupture at a smaller vent size (e.g., 10 mm) indicates less explosive energy than a rupture at a larger vent size (e.g., 20 mm). 1

In its prior written submissions, NFA has provided multiple reasons for why a 15% powdered metals limit should be adopted. Although those reasons are still valid, NFA will not oppose a lower powdered metals limit of 12.5% as it believes that this lower level of powdered metals is sufficient to produce the necessary amount of energetics for the safe and proper functioning of consumer aerial fireworks. 2

Since the issuance of the formal proposal to ban metals in the burst charges of consumer aerial fireworks, NFA understands that some manufacturers have been switching to various whistle mixes, including the one tested by SMS, in anticipation of the proposal possibly taking effect. This change in burst charge formulations would explain the discrepancies between CPSC’s and NFA’s testing in the United States (which showed most devices would fail under a metals ban), and AFSL/APA’s testing in China (which showed a significant percentage of tested devices would pass). Many companies, however, do not want to switch to hybrid powders because they are more expensive and more susceptible to ignition by shock or impact than metal powders.


Consumer Product Safety Commission September 24, 2018 Page 2 The test report shows that the metals powder ruptured the steel tube with a 15 mm vent hole, whereas the hybrid powder ruptured the steel tube with an 18 mm vent hole.3 This demonstrates that the hybrid powder (without any powdered metal) is more energetic than the metals powder with 12.5% powdered aluminum.4 As mentioned, the burst charges tested are not hypothetical formulations; they are used in consumer aerial fireworks today.5 A prohibition on less than 12.5% powdered metals would thus arbitrarily ban less energetic devices than those it would allow. NFA maintains its position that there is no justification for the proposed amendments to fireworks regulations because there is zero evidence that they will reduce the risk or likelihood of injury. Still, if the Commission moves forward on a proposal to regulate burst charges based on their chemical formulations, instead of their actual performance,6 a powdered metals limit below 12.5% is unjustifiable as the results of this testing procedure prove. We appreciate your consideration of these materials as you evaluate the proposed amendments. Sincerely,

Nancy Blogin Executive Director National Fireworks Association Enclosure

3

By comparison, flash powder (which was used in the M-80s, cherry bombs, and other powerfully explosive devices that were the focus of the audible effects standard that has been law for more than half a century), could not be measured by the test because it ruptured the tube with the vent completely open at 22 mm. 4

Powdered aluminum is the most commonly found powdered metal in the burst charge of consumer aerial fireworks. 5

Metal or hybrid powders are necessary components of consumer aerial fireworks. As established on the record, black powder alone does not generate the heat or pressure necessary for breaking apart shells, dispersing fragments, igniting stars, and other functions essential for the safe and proper performance of aerial fireworks. A 12.5% powdered metals allowance would provide sufficient energetics for the safe and proper functioning of consumer aerial fireworks while prohibiting unnecessarily over-energetic formulations such as flash powders. 6

A performance test, such as that used by SMS, would of course be superior to chemical restrictions because it would allow for flexibility in manufacturing while preventing overly explosive burst charges made with permissible chemicals.


TEST REPORT

BURST CHARGE POWDERS EQUIVALENCY TESTING

SEPTEMBER 13, 2018 SMS-5278-R1, REV 0

PREPARED FOR NATIONAL FIREWORKS ASSOCIATION 8224 NW BRADFORD CT KANSAS CITY, MO 64151

KIRT N. SASSER JASON FORD

SAFETY MANAGEMENT SERVICES, INC. 1847 WEST 9000 SOUTH, SUITE 205 WEST JORDAN, UTAH 84088

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Test Report

Burst Charge Powder Equivalency Testing

September 13, 2018 SMS-5278-R1, Rev 0

Prepared For National Fireworks Association 8224 NW Bradford Ct Kansas City, MO 64151

________________________________ Kirt N. Sasser

________________________________ Jason Ford

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TABLE OF CONTENTS I.

OBJECTIVE........................................................................................................................ 4

II.

SUMMARY AND CONCLUSIONS .......................................................................................... 4

III.

SAMPLE DESCRIPTION ....................................................................................................... 4

IV.

TEST DESCRIPTIONS AND RESULTS ...................................................................................... 6

A.

Burst Charge Powder Equivalency Test ................................................................................ 6

V.

APPENDIX .......................................................................................................................13

A.

Test Method Background ..................................................................................................13

LIST OF TABLES Table 1: Burst Charge Powder Equivalency Test Results ................................................................ 4 Table 2: Burst Charge Samples Tested............................................................................................ 4 Table 3: Burst Charge Powder Equivalency Test Results – Electric Match Ignition Source ......... 10

LIST OF PHOTOS Photo 1: Burst Comp Containing Metal (12.5% Al) ........................................................................... 5 Photo 2: Whistle Comp (70/10/20) ................................................................................................ 5 Photo 3: Flash Composition .......................................................................................................... 6 Photo 4: Koenen Tubes and Orifices............................................................................................... 7 Photo 5: Tube/Orifice Assembled ................................................................................................. 7 Photo 6: Protective Fixture for Electric Match Ignition ..................................................................... 8 Photo 7: Protective Fixture for Electric Match Ignition ..................................................................... 8 Photo 8: Ignition Source – Electric Match ....................................................................................... 9 Photo 9: Burst Charge Containing Metal – 15 mm Orifice - PASS ......................................................10 Photo 10: Burst Charge Containing Metal – 12 mm Orifice - FAIL ......................................................11 Photo 11: Whistle Composition – 18 mm Orifice - PASS ...................................................................11 Photo 12: Whistle Composition – 12 mm Orifice – FAIL ...................................................................12

REFERENCES 1. United Nations (UN) Recommendations on the Transport of Dangerous Goods, Manual of Tests and Criteria, Sixth revised edition, 2015

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OBJECTIVE The National Fireworks Association (NFA) requested that Safety Management Service, Inc. (SMS) perform testing of some standard burst charge formulations using a new test method developed to help distinguish the reaction behavior of burst powders for aerial fireworks shells. Three samples were examined in the new test method. I.

SUMMARY AND CONCLUSIONS The test results are summarized in Table 1. The Burst Charge Containing Metal (12.5% Al) and the Whistle Composition had Equivalency Levels of 15 mm and 18 mm respectively. The Flash Composition’s Equivalency Levels exceeded the limits of the test (i.e. > 22 mm). II.

Table 1: Burst Charge Powder Equivalency Test Results Burst Charge Equivalency Level Burst Charge Containing Metal (12.5% Al) 15 mm Whistle Composition 18 mm Flash Composition > 22 mm SAMPLE DESCRIPTION Three samples were compared in this testing: (1) a Burst Charge Containing Metal; (2) a Whistle Composition; and (3) a Flash Composition as seen in Table 2. A picture of each sample is provided in Photos 1-3 III.

Table 2: Burst Charge Samples Tested Burst Powders

Burst Charge Containing Metal

Chemical Constituent Potassium Perchlorate Aluminum, Indian Blackhead (< 53Âľm) Charcoal Sulfur Total

Whistle Composition

Potassium Perchlorate Sodium Benzoate Corn Starch Total

Flash Composition

Unavailable

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Weight Percentage (%) 68.5 12.5 11.4 7.6 100% 70 10 20 100% NA


Burst Charge Equivalency Testing National Fireworks Association

SMS-5278-R1, Rev 0 September 13, 2018

Photo 1: Burst Comp Containing Metal (12.5% Al)

Photo 2: Whistle Comp (70/10/20)

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Burst Charge Equivalency Testing National Fireworks Association

SMS-5278-R1, Rev 0 September 13, 2018

Photo 3: Flash Composition

IV.

TEST DESCRIPTIONS AND RESULTS

A.

Burst Charge Powder Equivalency Test

1.

Test Description

This test is used to compare the relative energy output of burst (or break) charge powders as compared to each other. 2.

Apparatus and Materials

The apparatus consists of a Koenen non-reusable steel tube (UN Series 1b), which is equipped with a closing plate with an orifice (Photos 5 & 6) and installed in a protective fixture. Upon ignition of the sample using an electric match, the decomposition gases escape through the orifice. If the orifice is not of sufficient size, the gases rupture, burst, or fragment the tube. The closing plate with the orifice is made of heat-resisting chrome steel with venting hole diameters from 2.0 to 22.0 mm. A steel threaded collar and nut hold the orifice in place during the test. The dimensions of the tubes are provided in Figure 1.

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Burst Charge Equivalency Testing National Fireworks Association

Photo 4: Koenen Tubes and Orifices

SMS-5278-R1, Rev 0 September 13, 2018

Photo 5: Tube/Orifice Assembled

The overall concept for this test is that substances that are more energetic and have burn rates that are relatively fast will require orifices that are much larger than substances that have slower burn rates. If the venting or orifice hole is sufficiently large, then the material will burn within the Koenen tube and vent out the specified orifice hole. If the venting or orifice hole is insufficient, then the Koenen tube will rupture (fragment or burst). Equivalency levels (which correlate to a vent size) are established when three trials at a given orifice size are performed with no tube rupture or fragmentation. In general, substances that require a larger orifice size such that the Koenen tube does not rupture, have a much faster burn rate than those substances that do not rupture with smaller orifice diameters. The assembled test unit is placed in a protective fixture. Photos 7 and 8 are representative photos of the protective test fixture used with the Koenen tube and collar/orifice assembly.

Figure 1: Koenen Tube (mm)

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Burst Charge Equivalency Testing National Fireworks Association

SMS-5278-R1, Rev 0 September 13, 2018

Photo 6: Protective Fixture for Electric Match Ignition

Photo 7: Protective Fixture for Electric Match Ignition

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Burst Charge Equivalency Testing National Fireworks Association 3.

SMS-5278-R1, Rev 0 September 13, 2018

Procedure

Five (5) grams of the test substance are weighed out and placed in the bottom of the test tube. A vent size is selected, and the orifice, collar, and nut are assembled, and the test assembly positioned in the protective fixture. The fixture is positioned such that the operator approaches from the back side for safety purposes. The operator then positions an electric match (Photo 9) through the vent hole and down into the powder. The electric match is functioned, and the test tube is examined for damage. If the tube does not rupture, the vent size is decreased and the process repeated until a rupture occurs. If the tube ruptures, the vent size is increased and the process repeated until a rupture does not occur. The test is then repeated until 3 trials are performed at the smallest vent size without rupture occurring. This is then determined to be the Equivalency Level for this powder and can be compared to other powders performed using this same method. Additional details of the electric matches function in this system are presented in the Appendix.

Photo 8: Ignition Source â&#x20AC;&#x201C; Electric Match 4.

Test Configuration

Three samples were compared in this testing; a burst charge containing metal, a whistle composition, and a flash composition (see Table 1). Trials were performed with these substances using 5 grams per trial. A new tube is used for each trial. Five (5) grams of the test substance are weighed out and placed in the bottom of the test tube. A vent size is selected, and the orifice, collar, and nut are assembled, and the test assembly positioned in the protective fixture. 5.

Test Results

The results of the tests are shown in Table 3. The Burst Charge Containing Metal (12.5%) had an Equivalency Level of 15 mm. The Whistle Compositionâ&#x20AC;&#x2122;s Equivalency had an Equivalency Level of 18 mm. The Flash Compositionâ&#x20AC;&#x2122;s Equivalency Level exceed the limits of the test (i.e. > 22 mm).

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Burst Charge Equivalency Testing National Fireworks Association

SMS-5278-R1, Rev 0 September 13, 2018

Table 3: Burst Charge Powder Equivalency Test Results â&#x20AC;&#x201C; Electric Match Ignition Source Orifice Size Burst Charge Trial Results Pass/Fail (mm)

Burst Charge Containing Metal

Whistle Composition

Flash Composition

15

1

Tube undamaged

Pass

8

1

Tube ruptured

Fail

10

1

Tube undamaged

Pass

10

2

Tube ruptured

Fail

12

1

Tube ruptured

Fail

15

2

Tube undamaged

Pass

15

3

Tube undamaged

Pass

22

1

Tube undamaged

Pass

20

1

Tube undamaged

Pass

18

1

Tube undamaged

Pass

12

1

Tube ruptured

Fail

15

1

Tube ruptured

Fail

18

2

Tube undamaged

Pass

18

3

Tube undamaged

Pass

22

1

Tube ruptured

Fail

Photos 10-13 show typical results of undamaged tubes and ruptured tubes.

Photo 9: Burst Charge Containing Metal â&#x20AC;&#x201C; 15 mm Orifice - PASS

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Burst Charge Equivalency Testing National Fireworks Association

SMS-5278-R1, Rev 0 September 13, 2018

Photo 10: Burst Charge Containing Metal â&#x20AC;&#x201C; 12 mm Orifice - FAIL

Photo 11: Whistle Composition â&#x20AC;&#x201C; 18 mm Orifice - PASS

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Burst Charge Equivalency Testing National Fireworks Association

SMS-5278-R1, Rev 0 September 13, 2018

Photo 12: Whistle Composition – 12 mm Orifice – FAIL

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Burst Charge Equivalency Testing National Fireworks Association V.

APPENDIX

A.

Test Method Background

SMS-5278-R1, Rev 0 September 13, 2018

As previously mentioned, this test method was developed to help compare the relative energy outputs of burst charge powders for aerial fireworks shells. The use of an electric match and the consequences to the desired objective were evaluated in the development of the test method. Two obvious details with the use of the e-match are the reduction of vent area from the e-match leads and the energy released by the match head. A short discussion of these details is provided in the following: 1.

Vent reduction by e-match lead wires

As the objective of this test method is to give a relative comparison of the energy output of the burst powders, the reduction of vent area due to the electric match leads is inconsequential as the reduction is constant. The area taken up by the leads is small enough such that the effective vent area is always larger as the orifice diameters increase. The cross-sectional area of the electric match lead wires occupies a lesser percentage of the vent hole as the diameter of the vent hole increases. For example, the insulation on the lead wires of the Daveyfire SA 2001 A/N 28Br electric matches used in this study each have a diameter of 1.25 mm, or a cross-sectional area of 1.23 mm2. The paired, or â&#x20AC;&#x153;zippedâ&#x20AC;? wires have a combined area of 2.46 mm2. The cross-sectional area of the 22 mm orifice is 380 mm2. The percentage of the vent area occupied by the lead wires is then, (2.46 mm2 / 380 mm2) x 100% = 0.65% The area percentage occupied by the lead wires for the 18 mm and 15 mm orifices is 0.97 and 1.4 %, respectively. These reductions in area are considered insignificant as the system is the same for all powders being evaluated. 2.

Energetic contribution of the electric match to the energy released by the burst charge sample

The pyrotechnic composition in a Daveyfire A/N 28Br electric match head has a mass of 80 mg and a heat of explosion comparable to those of the three burst charges tested. Thus, the energy contribution from the electric match head to the burning of 5g (5,000 mg) of a burst charge sample equates to approximately, (80 mg / 5,000 mg) x 100% = 1.6% This is also judged to be insignificant, having little effect on the test results as once again, this value is constant, and the results are comparative in nature from sample to sample. Page 13 of 13

NFA Consumer Fireworks Burst Charge Testing  
NFA Consumer Fireworks Burst Charge Testing