Help the Fireworks Industry Comment this weekend

[displayfireworks1]

I am posting this information to link into a video I making. Please read and comment using the link to the CPSC website. Please do not post an aggressive type comment. I think we can approach this reasonably. Please feel free to use parts of the letter in your comment.
.
CPSC HAS PROPOSED A RULE THAT WILL EFFECTIVELY BAN MOST AERIAL FIREWORKS CONSUMER DEVICES CURRENTLY ON THE MARKET!!!
WHAT YOU NEED TO KNOW:
CPSC is accepting public comment on their rule by the end of the day on Monday, July 17, 2017. Please make your voice heard. Feel free to use these notes to draft your own comments and tell CPSC why you oppose the proposed rule. You can post your comments at https://www.regulations.gov/comment?D=CPSC-2006-0034-0014. Your input is critical!
WHAT THE RULE DOES
CPSC’s rule bans all powdered metals from aerial consumer fireworks devices. These metals are commonly found in aerial consumer fireworks, so they will fail the new test and be banned. Not only that, but the rule will be enforced using unreliable, error-prone, and expensive testing procedures, including XRF and ICP-OES. CPSC plans to use XRF to test for aluminum and ICP-OES to test for magnesium and titanium. XRF testing, although highly useful for other purposes such as screening solid materials, is totally unreliable and inaccurate when testing powders such as fireworks compositions. ICP-OES is expensive and not readily accessible to most small importers and fireworks business owners.
WHY THE RULE IS BAD
A solution in search of a problem that doesn’t exist!
CPSC has not identified any reason why the amount of powdered metal present in consumer fireworks currently on the market is dangerous. While the goal of making fireworks safer is a noble one, it should focus on actual dangers. CPSC has not provided any evidence that consumer aerial fireworks with powdered metals are any more likely to cause injury than other
consumer aerial fireworks. Instead of recognizing that fireworks injuries are caused mostly by
misuse, CPSC assumes that by drastically decreasing fireworks’ performance (by removing all
powdered metals), fireworks will become safer. To the contrary – if fireworks do not perform,
many consumers will stop buying them and resort to trying to make their own at home – which
is known to be extremely dangerous. This rule could result in more fireworks injuries – not
fewer.
CPSC admits that the proposed rule will ban 84% of the consumer aerial fireworks devices
presently on the market.
CPSC has conducted testing under the proposed rule and found that 84% of the fireworks
tested have failed. Many of the products that consumers love the most will be taken off the
market and made illegal. Sales will plummet and the industry will suffer dramatically. The rule
will drive people in the industry out of business.
Regulatory Over-reach
 CPSC has not followed their own rule-making procedure which is mandated by federal
law.
 The law requires CPSC to identify a product which poses an unreasonable risk of harm
and identify injuries resulting from the products’ design.
 CPSC has not identified a product or injuries.
XRF testing is unreliable and inaccurate
 XRF (x-ray gun) testing is great for testing things like solid metals but does not work well
when testing powders – like fireworks compositions.
 Powders are not homogeneous – meaning their contents aren’t mixed up evenly. Even
a small amount of metal powder could be concentrated in only the part of a sample
being tested. When this happens, the device will fail because the test will show much
higher levels than are actually present.
 XRF cannot be reliably used to test devices in China because moisture will drastically
affect results. Fireworks are made in outdoor facilities in China in a humid climate.
When they are tested prior to transport they can be moist resulting in a low powdered
metal reading. The fireworks often dry out during shipping resulting in a much higher
test result upon arrival. Fireworks that pass in China may not pass when they arrive.
 The powder samples are tested in a container with a mylar (clear plastic) sheet between
the XRF gun and the fireworks composition sample. This is problematic because the
mylar is statically charged. The static causes the plastic to attract only the powdered
metals in the sample. The result is a higher concentration of metals near the surface
which makes the test show a higher percentage of powdered metal than is actually
present.
 The air pockets around the grains that make up powder cause inaccurate test results.
XRF technology was not designed to test powders but rather solids.
ICP-OES (“wet chemistry”) testing is expensive and time consuming.
 Chinese manufacturers will have a tough time testing for magnesium and titanium
because ICP-OES testing must be done in a laboratory and is time consuming and
expensive.
 This will result in unreliable products that may not pass inspection when tested in the
US.
HELP STOP THIS THREAT TO THE AMERICAN FIREWORKS INDUSTRY!
Submit comment online no later than Monday, July 17, 2017, at
https://www.regulations.gov/comment?D=CPSC-2006-0034-0014.
Your input is critical!

[fatcat]

Glad you posted this Dave, I just received an e-mail from one of my local suppliers with this info and was wondering if this was an every year item or what since i didn't see any of your advertisers posting about this. For what it is worth I intend to send a comment .

[displayfireworks1]

You will not see them post about it. They are too smart for that. I just released this on my YouTube channel
.

https://www.youtube.com/watch?v=M6HyuV1zhZo

[BhadDawg]

Just finished Posting, used mostly my own words and used all of the characters allowed in the response. So, either copy and paste Daves post or write your own, doesn't matter, Just please comment!

[BhadDawg]

Glad you posted this Dave, I just received an e-mail from one of my local suppliers with this info and was wondering if this was an every year item or what since i didn't see any of your advertisers posting about this. For what it is worth I intend to send a comment .

Kind of wondering the same thing, is this an every year thing or something new. Strange that I have not heard from any of my suppliers on this, I am in the customer base of several.

[bigmike79]

I commented on this just a few minutes ago

[vegassalute]

I'm doing it now, this is totally unacceptable and will destroy the consumer segment of the industry. And shortly thereafter they most certainly be emboldened to come after 1.3 compositions! We are living through the gold age of fireworks right now, they've never performed better, more economical, more diverse, and they've never been more safe! We need to get the word out, only a few short days!

[Mattp]

I did this immediately, stated my opinions and kept it polite..i will share this link to everyone i know and ask them to do the same

[fatcat]

Just wondering if after responding to the CPSC, if sending a polite message to the local congressman/woman especially in the fireworks friendly states would help. Opinions please

[rkmcdon]

Commented. Hope this goes away

[kingsixx]

I commented and I used part of the OPs post in my comment. Seems that as of my post here, there were only 33 comments on the page and some of them were in favor of the legislation.

[Zippster]

Commented, kept it simple and straight forward with no swearing or name calling. :o If their looking for the cause of injuries, look no farther then youtube. You cant fix or regulate stupidity.

[Forti1bs]

I just let an entire club know in Michigan... So I hope it helps! The youtube video was great Dave! Thank you for your work on this.

[PyroMike79]

Below is the comment I posted-I hope like hell that these comments are of some actual use. Something about how this is being done is very fishy. I cannot help but wonder if a decision has already been made and this is just the dog and pony show to calm the masses and make us think we have an actual say. Be nice to be wrong on this one.




There is an inherent risk in the use of fireworks, be they consumer of professional. As a user of consumer fireworks I am aware of those risks and 100% in favor of efforts to increase the safety and reliability of pyrotechnic products. Things like consumer education, better product labeling and the removal of bootleg products from the consumer market, will help to increase safety for everyone. I am not anti-regulation-but regulation with reason, logic and just cause.

The removal of powdered metals from fireworks is essentially the removal of fireworks themselves. It is the powdered metals that make the fireworks function as fireworks in the first place. It has been widely reported that this will eliminate 84% of all aerial fireworks from the consumer market. I have serious doubts as to whether the industry can survive such an action. There are many thousands of people across the country whose livelihoods will be adversely impacted or out right eliminated by this policy-if so enacted. One may point out that other-non aerial-fireworks will remain available, however they will certainly increase dramatically in cost as manufacturers and distributers try to recoup the lost revenue this will cause. In addition, one must consider if many importers will consider it worthwhile to go through the costly testing and regulations to import smaller, lower profit margin products.

I have not seen any evidence that the amount of metals in a firework has any impact on the safety of said device. This is a regulation which would do nothing for safety but would certainly do a lot to destroy an industry for importers, wholesalers, retailers and millions of consumers. The safety of consumer fireworks-when responsibly used-has never been better and will continue to improve. Progress has been made. Please do not respond to that progress by putting an end to a great American tradition.

Thank you for your time and consideration.

[MontanaMike]

I just submitted my comment. Thanks to all for commenting, and thanks Dave for giving us the heads up on this. Hope it doesn't go through.

[pistolus]

I gave them my two cents.. I can't help but wonder if the latest legalization of consumer fireworks in many states in the last few years has fireworks haters at the federal level clamoring to stick a cork in the leaking barrel.. It's clear the vast majority of Americans want consumer fireworks, this seems like a sneaky way to pull the wool over the American people's eyes.

[MtnViewPyro]

I commented. I used most of the info you provided Dave and closed with the following paragraph:

If this proposal becomes law, you will not only ruin a family tradition to celebrate the independence of this country, but you will do the same to countless other families. We are a country that celebrates our freedoms and this proposal goes against these longstanding traditions. It is going to be a truly sad day when this country regulates an industry out of business that plays a big role in the celebration of independence from an overreaching government!!!

[TexasPyro110]

I Submitted my comment hopefully we can stop this. I would hate to see all the progress we've made with consumer fireworks over the years be destroyed overnight. Anyone that hasn't already submitted a comment, please do just keep it polite any comment helps.

[Rick_In_Tampa]

Thanks for bringing this nonsense to our attention Dave. I commented. Since more people die from bee stings than fireworks each year, I told them they need to work on the "bee assault" and leave fireworks alone. In typical government fashion they crafted a "solution" that's now in search of a problem. Utter nonsense....

[hawkeye0323]

I voiced my opinion also. They should focus on real problems and not crap like this.

[Stormcrow]

So glad I joined this forum. Thanks for the heads up Dave. I commented.

[vegassalute]

Thanks for bringing this nonsense to our attention Dave. I commented. Since more people die from bee stings than fireworks each year, I told them they need to work on the "bee assault" and leave fireworks alone. In typical government fashion they crafted a "solution" that's now in search of a problem. Utter nonsense....

Your point is perfect Rick. We need to call out the comparisons, like bee stings, peanut allergies, prison deaths, pedestrians hit by cars, people that fall of ladders on their property, etc as compared to injuries sustained by pyros when properly using fireworks. This should not be worth one second of the governments time, they have much bigger fish to fry. Total BS! I'm beside myself with this nonsense! They tried to "sneak" this through!!

[chriskrc]

Just posted my comments not supporting the test and why. Lets hope we can stop this.

[hillbilly]

sent reply we need to stay on this don,t let them sneek his thru heads up

[ras1986]

This is going to make a lot more 54 holders if it passes..... also the black market is small now but it's going to be huge if it passes as well.

[PyroJoeNEPA]

Sent my comment in. Here is a copy. Feel free to cut & paste and/or modify if you need a starting point.

I am writing to you IN OPPOSITION to CPSC’s proposed rule banning powdered metals in consumer fireworks break charges. While I am in favor of making fireworks safer, CPSC’s rule will not accomplish that in any way. Most consumer grade fireworks injuries are caused by misuse – and stupidity--not powdered metals in break charges. CPSC has not produced any studies showing that powdered metals make consumer fireworks more dangerous. No injuries resulting from powdered metals have been identified. So why has legislation been proposed to deal with a "ghost issue"? Don’t let this rule be another example of unnecessary government regulation.

Furthermore, the testing methods proposed by the rule are inappropriate. XRF is not reliably accurate when testing fireworks compositions [Xrays are designed to detect SOLID metals---not the fine powders in pyrotechnic compositions and ICP-OES is expensive and time-consuming making it difficult for use in compliance testing in China. ICP=OES is based on a sampling on mylar film which would not be an accurate sampling of metals distributed through a batch of composition. Depending on the mix technique-as well as humidity issues-an accurate sampling of metal particles would not be 100% definitive! This legislation--if allowed to pass-will result in an unreliable supply of products which will drive up prices hurting American fireworks businesses and consumers.

[misfmr]

Submitted my opposition to the CPSC proposed rule change.

Tracking number 1k1-8xj9-l5ru

Frank Rodriguez
misfmr

[displayfireworks1]

Thank you all for your response on this critical issue.

Here is a copy of a official response sent by by one of my YouTube subscribers. I'll post it here on the forums. Its exciting to see the social media response on this. We are giving it the good fight.
.
.
.
.
.
.
.

I hope you don't think the patriotic Americans that celebrate our American history with fireworks are not going to take another regulation on our rights.

There is way to much to much infringement on our day to day lives.

If you really want to take one of the true joys away from the American citizen it will be not taken in vain.

just think of all the good that comes out of these fireworks,
it brings people together, brightens a day with happiness, fascinates children and makes the American citizen believe in the American dream again.

Think about what you will take away by doing this.

This country was founded upon freedoms and limited government.

The government policies and over regulation is ruining the America that the founding fathers dreamed it would be
This is why we elected a president thats wants to cut regulation.
The American people have spoken about this over regulation so as representatives of the people of the united states do not over regulate us.
We have spoken in the last election and we do not want this over regulation like this.

So ask yourself are you willing to take that dream away and not abide by what the American people want

I hope not

In these times any product that brings the American people together and gives then joy should not be taken away because it is needed in these trying times

Please don't take the joy away from children to old.

To many Americans fireworks mean America

Are you taking America away..

I hope not

Concerned disabled citizen

[fatcat]

that should be sent to the president and every member of congress

[jLk_pyro]

Commented. Thanks for the info Dave!

[esgrillo]

just some basic information to show that the claim of improving safety is simply a thinly veiled lie to cover the true intent which must be a fireworks ban. Now I am not remotely inferring that any injury from fireworks use is not a serious issue especially to those directly or indirectly affected. This is simply some statistics that the CPSC uses and CDC info. There are about 30,000,000 non fatal injuries that require ER visits each year. Approx 7000 are fireworks related. That is 0.023%. Any person that has been involved with safety analysis or process improvement knows what the pareto principle is and this legislation violates everything about the principle and basic improvement techniques. Improving safety is a good idea in any industry however targeting fireworks as a method for overall reduction of non fatal ER accidents is statistically absurd. You eliminate all these injuries and you still have essentially 30,000,000 non fatal ER visits. Plus if you look at the details on the recent data for the 10 yearly deaths, almost all of them involve misuse and or the user being impaired.

[Rick_In_Tampa]

The only problem with your analysis Ed is it relies on hard facts and stats. Even a little math. Unfortunately, the Feds don't use any of that to make decisions these days. Today it's all about "feelings" and special interest money.

[ras1986]

The only problem with your analysis Ed is it relies on hard facts and stats. Even a little math. Unfortunately, the Feds don't use any of that to make decisions these days. Today it's all about "feelings" and special interest money.

Lol Rick. This is the truth.

[esgrillo]

Lol Rick. This is the truth.

right RAS.... This legislation sounds about the same and makes about as much sense when you hear anyone making the argument we need to ban AR-15s in order to reduce gun deaths. Of course they dont know that AR's are on average used in about 50 of the 30,000 guns deaths each year (murder and suicide combined)

[chriskrc]

right RAS.... This legislation sounds about the same and makes about as much sense when you hear anyone making the argument we need to ban AR-15s in order to reduce gun deaths. Of course they dont know that AR's are on average used in about 50 of the 30,000 guns deaths each year (murder and suicide combined)

Now if only the government would be this attentive to statistics and pay better attention to the real truth we wouldn't be in these predicaments.

[displayfireworks1]

Todd A. Stevenson
Office of the Secretary
Consumer Product Safety Commission
Room 820 4330 East-West Highway
Bethesda, MD 20814

RE: Comments on Proposed Fireworks Amendment, 82 Fed. Reg. 9012

Dear Mr. Stevenson,

I support the National Fireworks Association’s comments urging the CPSC to refrain from dramatically altering the rules for consumer fireworks in a way that is likely to hurt NFA’s members, and the entire fireworks industry, without any demonstrable benefits to consumer safety. Specially, I strongly oppose the proposed “metals test,” which, according to CPSC’s own data, would effectively ban most of the aerial devices that have been widely sold on the market for decades. This ban includes all aerial devices, including reloadable shells, single shot shells, cake shots, and stick rocket payloads, so long as there is any powdered metals in their burst charges.

For many Americans, fireworks play an important role in celebrating holidays, special events, neighborhood block parties, and picnics. Like other popular products—such as snow skis, trampolines, and countless others—there is some risk associated with them. But there is no data to suggest that the risks associated with aerial devices containing powdered metals in their burst charges is so severe that they must be banned entirely from commerce. To the contrary, when used properly, aerial devices have an outstanding safety record.

Similarly, there is no reasoned basis for imposing an across-the-board prohibition on all metallic powder regardless of the size of the burst charge. To illustrate, under the CPSC’s proposed “metals test,” a device with a 1 gram burst charge consisting of 99% black powder and 1% powdered aluminum would be banned, but a 10 gram burst charge with pure black powder would be allowed although it has nearly 1000% greater explosive force than the outlawed 1 gram burst charge. If the goal of the proposed rule is to address explosivity, it fails.

Further, because the proposed “metals test” bans aerial devices with burst charges containing any powdered metal, devices are likely to fail simply because of minor contamination that has no effect on the total explosivity of the device. Contamination can occur in many ways, including that from clays and stars that are used to manufacture the devices. In addition to failing because of contamination, the proposed testing methodology is unproven, expensive, and prone to error.

Critically, there has been no consideration of the grave risk that the “metals test” poses to the American fireworks industry. There has been no analysis of the costs associated with manufacturing devices with sufficient purity to pass the proposed stringent standard, and there has been no analysis of the costs to American businesses from decreased sales attributable to a reformulation of popular consumer products.

In sum, I strongly oppose the “metals test” because the harm to American businesses and fireworks supporters far outweighs the speculative benefits to safety.

Thank you for your consideration.

Sincerely,

[Hartman]

Replied....

[pfm1700]

White House petition. Sign and confirm the email you receive. Please spread this on your social media as well. We need the signatures!


https://petitions.whitehouse.gov/petiti ... -fireworks

[Pyro Paul]

replied :D

[esgrillo]

Why have we not seen this post on the home page of every online fireworks retailer and wholesaler??

[Zippster]

Why have we not seen this post on the home page of every online fireworks retailer and wholesaler??

For some reason people dont bother to pay attention or react until it affects them and is usually too late...

[BhadDawg]

One of the comments I saw on the regulations page from an anonymous source. I find it strange and somewhat confusing that a Chinese exporter would comment in this way, Maybe an imposter? If not an imposter, it really chaps my a$$ when someone hides behind a keyboard and make post like this.
Comments on Amendments to Fireworks Regulations
CPSC-2006-0034-0014

Our company is an exporter of consumer fireworks from China to the USA.

The APA Standard 87-1 is the most important document for the fireworks industry since its inception. It is important for the fireworks industry to have only one set of standards for fireworks for sake of clarity for all shippers and manufacturer of fireworks. Therefore we strongly support CPSC's proposed amendments to fireworks regulations to be in line with current and future APA Standard 87-1 requirements.

As a manufacturer and exporter of fireworks, our company and its related factories have for years followed APA/DOT requirements. Thus, CPSC's proposed ruling will have little effect on our company.

We strongly support CPSC's adoption of existing APA Standard 87-1's total composition limits and ratios for mine and shell, reloadables, firecrackers, torches, wheels and chasers.

We also strongly support CPSC's replacement of their current "sound test" with APA/DOT's ban on fine metal powders in burst charge. However, there is one key concern we have of CPSC's proposal, and that is CPSC's burst charge contamination allowance of fine metal powder smaller than 149 microns at only 1%. During the production process, fine metals from paper, clay, and stars may contaminate the burst charge, creating a higher level of contamination. We feel that an increased acceptable allowance of 2% of fine metal powder contamination should be allowed. Based on testing data by industry and CPSC, 2% will not pose any significant dangers to consumers.

We believe CPSC's NPR will provide more clarity and consistency between APA and CPSC Standards, creating more level playing field in the fireworks industry.

So why are people in the industry behind this? I have heard many explanations and it sounds like there are some manufacturers trying to use this to shut out smaller competitors.

[WithReport]

CDC 2016 Fireworks Annual Report - June 2017
https://www.cpsc.gov/s3fs-public/Fireworks_Report_2016.pdf?t.YHKjE9bFiabmirA.4NJJST .5SUWIQJ

Highlights:
* Average of 7.1 reports of fireworks-related deaths per year between 2001 and 2016.
* 11,100 injuries treated in U.S. hospital emergency departments during 2016.
* The estimated rate of emergency department-related injuries is 3.4 per 100,000.
* 92 percent were treated at the hospital emergency department and released.
* There is not a statistically significant trend in estimated emergency department-treated, fireworks-related injuries from 2001 to 2016
* According to injury investigation reports, most victims recovered from their injuries or were expected to recover completely.

If you read the 2016 fireworks related non-occupational deaths they are all due to stupidity - even the one categorized as malfunctioned.

1) Someone attempting to manufacture fireworks in his garage (Since it states "attempting," I'm assuming this was someone without proper knowledge - maybe others on this forum have more details on this death)
2) “Malfunctioning” fireworks in a PVC mortar - don’t use PVC (I'm assuming a HDPE tube would not have been deadly)
3) Upside down fireworks in a mortar placed on the victim's head (really? - this is just natural selection)
4) A mortar device exploded in the victim's hand and he “fell of the roof.” (again - natural selection)


I could not find a similar report on Holiday Decorations, but there is a Morbidity and Mortality Weekly Report (MMWR) from the CDC in 2004 that has some sobering statistics for a 2000-2003 study..

Over three years, an estimated 17,465 persons were treated in U.S. hospital emergency departments for the holidays decorating.

Overall injury rate was 8.1 per 100,000

If we follow the over regulating trend of the government, maybe Christmas lights and decorations should be banned too.

Or if we want to just look at ladders in general. The fatalities due to falls are more than 100/year. Perhaps we should ban ladders.

Or we can continue to acknowledge that the injuries and deaths from Christmas decorations and ladder falls are due to misuse, incompetence, and stupidity.



I've commented on the proposed rule

[Rick_In_Tampa]

Of course they dont know that AR's are on average used in about 50 of the 30,000 guns deaths each year (murder and suicide combined)

According to the CDC "In a typical year, nearly 100 American deaths are caused by bee stings." So bees are twice as deadly to Americans as AR-15's. Oddly enough, I don't hear anyone clamoring for more common sense bee laws though.

[Zippster]

Big corporation rule what happens, just look at alcohol , more killed and injured then can be ever imagined. If the big players in the fireworks industry dont lobby and spend $$, us little guys dont matter at all what we think or say.

[PyroManiacs]

Big corporation rule what happens, just look at alcohol , more killed and injured then can be ever imagined. If the big players in the fireworks industry dont lobby and spend $$, us little guys dont matter at all what we think or say.

Cant argue with that.

[chriskrc]

Big corporation rule what happens, just look at alcohol , more killed and injured then can be ever imagined. If the big players in the fireworks industry dont lobby and spend $$, us little guys dont matter at all what we think or say.

Let's hope phantom and the others are in there helping us out.

[BhadDawg]

Let's hope phantom and the others are in there helping us out.

Not sure we are going to get any help from the big boys, I have found out the stance of one of big guys and they are not opposed to it.

[PGH_Pyro]

if Trump is so rah rah about the N.R.A., he should step in and stop this bullshit...

[esgrillo]

Not sure we are going to get any help from the big boys, I have found out the stance of one of big guys and they are not opposed to it.

Why, really does not make a lot of sense? If all of a sudden all their product sucks, don't they think people are going to stop buying. I for one will not spend thousands of $'s on product that looks terrible.

[esgrillo]

Well looks like '76 is trying to get some action mobilized. 2520

[chriskrc]

Not sure we are going to get any help from the big boys, I have found out the stance of one of big guys and they are not opposed to it.

That's probably tnt since they love safe and sane anyway. And as esgrillo said if there products really start to suck no is going to buy them so why wouldn't tjey stand against this.

[chriskrc]

Well looks like '76 is trying to get some action mobilized. 2520

That's awesome thank you for sure SO76. Lets hope others are joining you.

[BhadDawg]

You can look at the PGI vendor roster and figure out who the big boys are that are supporting this.

[displayfireworks1]

Here is the PGI response from the email list. The true count of comments on the website may not be know for some time because comments have to be reviewed and approved.
.

July 17, 2017

Todd A. Stevenson
Office of the Secretary
Consumer Product Safety Commission
Room 820
4330 East-West Highway
Bethesda, MD 20814

RE: Comments on Docket No. CPSC-2006-0034

Dear Secretary Todd A. Stevenson,
The Pyrotechnics Guild International, Incorporated is a not-for-profit 501c(6) educational association for fireworks enthusiasts and professionals alike. We have both professionals and hobbyists as members. We engage in both display and consumer fireworks activities. We represent over 2300 members across the United States.
We are not opposed to the proposed regulation regarding the presence of metals in consumer fireworks in principle, but, we are opposed to the proposed regulation as it currently stands on the following grounds:
1) X-ray fluorescence/energy dispersive spectroscopy detects the presence of elements-atomic species- but is not the proper test methodology to determine particle size or the chemical composition of dry powders pyrotechnic compositions. Metals are useful in many pyrotechnic compositions, but, it is only the finely powdered metals of less than 100 mesh size that are used to make explosive salute powders.
2) Members of the consumer fireworks industry have recently purchased XRF technology and retained a consultant to examine fireworks samples obtained from the leading importers and wholesalers in the United States. Using XRF technology, looking merely for the presence/absence of metal at a less than 2% presence (aluminum, primarily), up to 90% of fireworks from known, lawful and compliant importers failed the testing. Any test methodology that fails 90% of known, safe products is clearly flawed.
3) Metals require great energy to be released from their ores. This energy is then available when they are oxidized in pyrotechnic compositions. The purpose of this energy may be to produce an audible effect- a salute OR the intended effect may be to provide effective dispersion in the sky of the display effects. In the latter incidence, the fact that sound is produced is an unintended byproduct and not the intention with/for which the metal is incorporated into the pyrotechnic formula.
The PGI is adamantly opposed to the sale of illegal, overloaded, and salute-containing consumer fireworks. We are taking very serious steps to ensure that such materials are never a part of our annual events. Yet, even the major wholesalers we have contracted to provide consumer fireworks for our members at our 2017 convention would have devices that would fail under the proposed rule.
We respectfully oppose the adoption of the proposed rule. We feel that with further time more testing and more data will allow a more appropriate rule to be devised the meets the goals of protecting the safety of the consumer and not inappropriately impeding a lawful business. We specifically feel that three things must be resolved before any such rule is adopted:
1) Establishing what percentage of metal is acceptable in burst and or lift charges and an empirical method of testing that gives accurate, repeatable, analysis of the percentage of metal.
2) Identifying metal powder particle size which is ignored by the current rule and critical to determining whether the metal is permissible.
3) Identifying the oxidation state of the metal to determine whether or not it is a fuel, in its reduced or elemental state or oxidized and present in clays and many inert compounds of no explosive potential.
4) Understanding that burst charges designed to distribute ignited pyrotechnic effects in the sky may produce an audible effect that is NOT intended, but, rather, a necessary and unavoidable byproduct of the burst function.
On behalf of our over two thousand members, we ask that the rule NOT be adopted in its present form and NOT be adopted at this time.

Yours truly,

Paul Smith, B.A. in Chemistry
President, PGII

John Steinberg, MD (BS in Biochemistry)
First Vice-president, PGII

[displayfireworks1]

The response was great, prior to this weekend there were 35 comments , the comment count is now over 2,300. Now we wait to see the next move. Thank you to everyone that posted a comment
.

https://www.youtube.com/watch?v=bmqetac66fk
.
https://www.regulations.gov/docket?D=CPSC-2006-0034
It appears as comments are approved they are posted.
.

[displayfireworks1]

I received some CPSC reports of failed Consumer Fireworks as a result of their testing procedures. My anonymous source has allowed me to summarize the data but not to post the reports. I will summarize in a future video. it will give us a great inside look at what goes into testing Consumer Fireworks. Just glancing through some of the reports I think you may have experienced some of these failures over the years yourself.

[aerialpyro]

Displayfireworks1, why is the first video you posted unavailable?

[displayfireworks1]

You missed the school bus this weekend. The comment period is closed. Now we wait.

[displayfireworks1]

Please see the attached document for the response from Phantom fireworks in regards to this proposed CPSC change. You may have to sign into your account to see the document. Phantom Fireworks is one of my advertisers and they are of course entitled to an opinion on this issue the same as we are. I am posting pieces of information from significant players as I find it, in the interest of us having a better understanding on the scope of the issue. Phantom did not give me this document.

[displayfireworks1]

This is part of a document from the Consumer Product Safety Commission given to me from one of my sources. I can only show you parts of the document. The unlisted video below, is a clip from the performance of the product I found on the internet.
The product in question is a 5 inch canister artillery shell. As you watch the performance, does it appear to be any different than any other canister artillery shell on the market? They appear to be applying the current language intended to product an audible report, to products that are intended to produce a color break and have a report like quality in the process. I am not 100% on this but it appears they are loosely applying the current language in this fashion. Note the section on mesh size. This analysis is multiple pages and appears very extensive. It is written like a lab crime report. I think now we can see why the push is on for simple x-ray type test that can be done right at the importation port.
.

https://www.youtube.com/watch?v=Dzyr0YJvgxo
.
http://www.pyrotalk.com/bulletin/attachment.php?attachmentid=2626&stc=1
.
http://www.pyrotalk.com/bulletin/attachment.php?attachmentid=2627&stc=1
.
http://www.pyrotalk.com/bulletin/attachment.php?attachmentid=2628&stc=1

[PyroManiacs]

They all looked the same to me.

[jamisonlm3]

I think that's the thing. I bet those are just your everyday 60g canister shells. Since they do make an audible effect and have more then 130mg of flash in them, they're saying they're overloaded.

[displayfireworks1]

I guess the question is, is the shell designed to produce a color effect or an audible effect. The push is for that X-ray testing method. You can see how burdensome this lab analysis testing is. Plus considering the amount of product that enters the country, the current method is not very efficient. It would be interesting to see how or who pays for testing of product and/or how is a product selected for testing.

[chriskrc]

They all looked the same and yeah a 60g can has an audible effect but that doesn't mean it's overloaded

[cherrybomb1]

I guess the question is, is the shell designed to produce a color effect or an audible effect. The push is for that X-ray testing method. You can see how burdensome this lab analysis testing is. Plus considering the amount of product that enters the country, the current method is not very efficient. It would be interesting to see how or who pays for testing of product and/or how is a product selected for testing.

The consumers will pay for it in the long run!

[displayfireworks1]

Here is a copy and paste of a meeting. Note the "Ear Test"
.
.
.
Page 1 of 3
Meeting with U.S. Small Business Administration (SBA) and Consumer Product Safety Commission (CPSC) Staff
Re: Notice of Proposed Rulemaking: Amendments to Fireworks Regulations, Docket CPSC-2006-0034 and Provisions Regarding Devices Intended to Product Audible Effects
Date: May 25, 2017
Location: CPSC Laboratory, 5 Research Place, Rockville, MD
ATTENDEES: (See sign-in sheet)
Mark Bailey (CPSC) Lindsay Abate (SBA)
Meridith Kelsch (CPSC) Stephanie Fekete (SBA)
Shelby Mathis (CPSC) Bruce Lundegren (SBA)
Jason Ng (CPSC) Michael McManus (SBA)
Aaron Orland (CPSC) Prianka Sharma (SBA)
Matt Roemer (CPSC)
Andrew Stadnik (CPSC)
Rodney Valliere (CPSC)
SUMMARY:
-SBA would like to better understand how CPSC now tests for compliance with 16 CFR 1500.17(a)(3) and how testing would occur under the proposed revision to the that section
.
-Currently, the first step is field testing in which a trained technician sets off devices and listens for a distinct sound—it is the quality of the sound, not loudness that is of note. Metal powder creates a sharp crack, whereas black powder creates a sound that is loud but has a broad sound wave. CPSC staff played a video demonstrating the 2 distinct sound types. If the technician detects the sharp crack, then the second step is to determine weight to see if the device exceeds the limit in 1500.17(a)(3). (Note that listening for the distinct sound is only an indicator to measure content, it is not in itself a failure to comply with any requirement.)
.
-Under the proposed method, staff opens a device and separates the contents and then uses the XRF to screen for content and amount.
-The hazard at issue is the energy the device produces (how much energy and how quickly it is created), which impacts consumer safety when the device functions near a person—the hazard is not related to hearing or loudness. The greater the energy, the greater the possibility and severity of injury when it fires near a person. It may fire near a person because devices don’t always function at the apex of flight.
-The proposed requirement is intended to diminish the hazard—cannot entirely eliminate the explosive risks associated with fireworks.
-The regulation was written as it is because at the time it was adopted, devices on the market could be assessed for this by using that test. Designs and content of devices have changed since
Page 2 of 3
then. As a result, while some devices clearly either make the sharp crack or do not, some (e.g., hybrids) can be less clear; there can also be variation among devices of the same kind.
-There are EU requirements that address the loudness of devices (limit sound level), but these are largely aimed at noise control, not hearing damage.
-CPSC staff looked at the possibility of metallic fuel in effects (e.g., visual effects, stars) contaminating the break charge and found that does not seem to occur.
-APA Standard 87-1, on which the proposed requirement is based, is used internationally and by the U.S. Department of Transportation—as a result, the proposed requirement would harmonize with these rather than creating a new standard.
-The AFSL standard also prohibits metallic powder and has tried other test methods, which are not as effective as the one proposed.
-There are very few U.S. manufacturers of consumer fireworks—most are in China.
-Because of the limits of detection of instruments, CPSC proposed to include a window of flexibility in the form of enforcement discretion—the limit proposed is based on the corresponding increase in energy.
-The proposed requirement would impact U.S. importers, which are largely small businesses. Manufacturers/importers could conduct the proposed testing themselves or pay a testing lab to do so.
-The proposed requirement would not affect the colors in the visual effects (i.e., it does not apply to metals in visual effects). For one, visual effects are not in break charges. Also, the proposed requirement only deals with the smallest/finest powder (i.e., 100 mesh). The break charge has fine powder, but the metals in effects are too large to go through the 100 mesh sieve.
-To the extent that there is selling value in the sound the device creates, most people would not distinguish the difference in sound.
-It is difficult to determine how many devices on the market comply with the standard because CPSC focuses compliance testing on those likely to fail (based on resources, etc.). CPSC tests a small percentage of the U.S. market.
-Some industry groups test devices in China, but they do not necessarily use CPSC’s current or proposed test method. Importers must certify that the devices were tested.
-Importers generally store no more than 1 year worth of inventory.
-If CPSC finds that a device fails to comply with fireworks requirements, the Compliance division considers various factors, such as how much over the weight limit the device is, compliance history, and the volume of devices. (Note that when CPSC finds devices to be overloaded, they are generally very over the limit.) For minor violations, CPSC may just ask the company to fix future products. For egregious violations, CPSC may have the company destroy the lot. In that case, the company submits a destruction plan to CPSC, gets various approvals, and bears the cost of disposal. However, other cures are possible if the company seeks approval, such as reclassifying the devices as non-consumer and then selling them for professional displays (ATF, PHMSA, OSHA then have jurisdiction), using them for training purposes, or fixing the non-compliant feature (e.g., trim fuse length).
-States and local jurisdictions control what devices may be sold to consumers and this varies greatly.
-CPSC staff gave SBA staff a tour of the lab, showing sample fireworks, 100 mesh sieve, XRF equipment and ICP equipment, and demonstrated XRF testing. The device shown included pellet-sized black balls in the visual effects, course gravel-like black powder in the lift charge, and fine black powder in the brake charge.
Page 3 of 3
-ICP equipment costs approximately between $80,000 and $100,000; it cannot be used in the field. XRF equipment is easy and safe to use, can be used in the field, is quick (1-2 min to screen a sample) and costs approximately $30,000 to $35,000. (With respect to testing sound levels, not only is that not a hazard we are targeting, but basic sound meters could not accurately assess it because it needs to measure more than loudness—a device sophisticated enough to assess sound accurately would be approximately $10,000 to $20,000 and would take more time to test accurately than an XRF).
-CPSC publishes an annual injury report regarding fireworks, many of which are very serious.
-The thickness of a device’s shell affects the length of time before it bursts and can impact sound, but would not affect the proposed test method.
-Under the proposed requirement, because of variability, manufacturers need to strive for 0 metallic content in break charges and the proposed enforcement discretion would generally cover minor variations; but the 3-5% allowance that industry members have recommended is far above levels of variation—levels would only be that high if metallic powder were added intentionally.

[displayfireworks1]

I spoke with the Consumer Product Safety Commission today.
.
Unlisted Video

https://www.youtube.com/watch?v=NBSqVUmEgYs
.
.
https://www.regulations.gov/docket?D=CPSC-2006-0034

[jamisonlm3]

I know there are smaller than 60g canister shells on the market. Those are the 1.5" shells I think. Personally, I think they're on the market to fill a niche between the smaller shells and 1.75" canister shells. They're smaller than the 60g canister shells, contain less composition, but still hit pretty hard, look nice and are a good bit cheaper.

[Kenny East]

Glad to hear there are some good people over at the cpsc. I'm curious to know how China is taking the news that a lot of their products could be black listed with the proposed regulation changes. That could cost them a lot of money, especially if it gets rejected at our ports. Some one is going to have to foot the bill to ship it back, if it fails testing. Keep us posted, and thank you for being the consumers voice on this issue.

[vegassalute]

Very informative. Great investigative work.

[yoshisbar]

Dave I bet it was those blow up boys! LOL Lighting the Monday boom!!

[countryboy7978]

Those shells in the above video are definitely overloaded according to standards simply because they use flash powder as a break charge instead of BP or other non-metallic mixes. While I find nothing wrong with the shells and don't think they are any more dangerous when used correctly as ones made with non-metallic charges, they are the classic definition of an overload. I sure hope that they still get in, and I assume they will. That's how a feel a consumer shell should break not PUFF.

[countryboy7978]

The 100 mesh screen does mean 100 openings per square inch of screen. Screening the break charge through a 100 mesh screen and collecting everything that fell though and calling it flash powder is BS! Even 300 mesh metals will not make a good flash powder. Most flash grade aluminum is -325 or less, usually much less.

60 grams is the total weight allowed. 40 has always been the break and stars. The other 20 is for the lift charge.

[jamisonlm3]

How much flash powder is usually used as the break charge in a 60g canister shell? That is one thing I'd like to know.

[displayfireworks1]

From what the CPSC is doing is, if a shell sounds like a salute , even if it is color , the weight of the powder is then compared against the 130 mg ruling. It does not necessarily have to be flash powder. Thus they call a color break a "intended to produce an audible report". That is my interpretation.

[yoshisbar]

So if what you imply is what they intend, the break charge is supposed to be in the 130mg ruling? 130mg won't break a shell for XXXX. If they are going to start categorizing each separate component and I would think the Chinese would say "make them yourself" we don't want the hassle, or charge such a price it would double the cost of current items..
1 example I have. I got some dominator whistle ball shells (ball shells 1.75") few years ago these were straight powder in a ball shell with lift and the whistle insert. This year same product, tore one open, NOW it is a INSERT (like a cake) and the ball shell part is just for show. 1 small tube that goes from the lift to the top and plugged to make it louder, and probably so you can't pour out the contents and fill it with flash powder (lol) like on youtube..

But another thought is what about the items that have an "audible report", but do to the fact, that to get around some of the 60 gram limitations, they manufacturer wraps and packs the crap out of it (ALOT of canister shells do this) to make a thump out of the gun and a boom in the sky..

[countryboy7978]

Ok so in order for me to explain this and it make sense you have to go back to 1977 when the current CPSC flash powder limits came into play.
Firecrackers were limited to 50mg as we all know. The reason for this 50mg limit was to limit firecrackers to only ladyfingers and ban all firecrackers of larger size. By virtue of their design a ladyfinger measuring 7/8" x 1/6" could only contain 50-60 mg when loaded to the max. In contrast a standard paper 1.5" x 1/4" firecracker was designed to hold 130mg or 2 grain (as you hear collectors refer to full load firecrackers like daisy TB, duck brand, anchor brand by). So again the spirit of the law was to ban 1.5" firecrackers and only keep 7/8" ladyfingers. So ladyfingers 50mg, and 1.5" firecrackers 2 grain/130mg, that's where the amounts came from.

Now for those of us that go back to the DOT era and remember the items that were available for sale in the late 70's and 1980's that contained "reports" very frequently used full sized Chinese firecrackers for those reports. Sky Rockets and Missiles had loose firecrackers in the header to act like reports. Some used ladyfingers while others used full load firecrackers. B3 Bombers had full 130mg crackers under their wings, tube items like United's Rainbow and Thunder or Sky Racket had a bundle of 1.5" firecrackers as the reports, Happiness Fountains used firecrackers in the mine portion of their fountains, 36 shot Happy cakes used firecrackers inside of a paper sleeve as the insert and shells like Phantom Cannon Ball had firecrackers in the payload of the shell. The break charges on most all aerials were black powder. This is why most DOT aerial items with the exception of the period overloaded items like Flashing Thunder, Firing Squad, Multi Barrel Launcher, and DS1 Temple shells were boring and dull. It was easy at that time to figure out what was overloaded and what was not because an overloaded item was almost always a salute. The items the CPSC targeted during that time were typically firecrackers and aerial salutes like 3 and 9 shot US made tube devices.

In the late 1990's when cakes and shells became the mainstays of the fireworks industry, the industry started to muddy the waters by introducing heavier break charges that made the relatively small inserts of a cake and the relatively small shells allowed for consumer use to look more and more impressive and more like display fireworks. One could hide behind the idea that these new break charges were only being used for aesthetic effects rather than audible (or reports). So the ear test came about to test whether a break was flash powder based (in the eyes of the CPSC flash is always meant to produce an audible effect) or "other" which could be considered break charge vs report, even if a byproduct of the break was a loud report. This is where we are now. So you guys are right that 130mg of flash won't do anything as a break. 130mg of flash was NEVER intended to be used as a break either on it's own or as a boost for an organic break charge. This isn't about overloads either. It's about whether otherwise compliant break charges can contain metals and still be considered break and not report.

[countryboy7978]

From what the CPSC is doing is, if a shell sounds like a salute , even if it is color , the weight of the powder is then compared against the 130 mg ruling. It does not necessarily have to be flash powder. Thus they call a color break a "intended to produce an audible report". That is my interpretation.

The way I interpret it is that it can contain as much of the organic powders as will fit in the insert as long as they are not flash or metallic based, and as long as their are effects to expel. If the insert was purely BP or H3 or loose whistle mix, it would be considered to be for audible effect. This is what I heard happened to the Lightning Bolt brand black powder salutes that used to be sold in the early 2000's. Even though they were nothing like a flash powder salute, the CPSC considered them to be audible devices because the only stars they contained were seed pods that would drop all over you after the shell broke.

The CPSC considers flash or metal powders less than 100 mesh particle size to be used for audible effects only. All other break charges are just that, break charge. Therefore they don't fail items containing these organic charges despite how much is present. But if they find over 130mg of metallic composition, they would typically have to fail the item.

I personally like flash based break charges. I think the white flash enhances the aesthetics of the break despite that some purists say it detracts from it.

[Rick_In_Tampa]

If they are going to start categorizing each separate component and I would think the Chinese would say "make them yourself" we don't want the hassle, or charge such a price it would double the cost of current items.

My friend, you have just described how to regulate something out of existence without coming right out and making it illegal.

While the rest of us sit around and try to make sense out of the nonsensical, organizations like the CPSC don't care because the end game is the same for them. They win when we won't/can't buy it, and the industry goes away.

[chriskrc]

My friend, you have just described how to regulate something out of existence without coming right out and making it illegal.

While the rest of us sit around and try to make sense out of the nonsensical, organizations like the CPSC don't care because the end game is the same for them. They win when we won't/can't buy it, and the industry goes away.

Let's hope this doesn't happen. But you sir are correct, but the time we figure this all-out the damage is usually already done.

[countryboy7978]

I think we are thinking way to much gloom and doom. The industry isn't going anywhere. There is too much money at stake. Consumer fireworks are a huge business, the manufacturers will make whatever it is that the importers tell them to as long as they get paid for it. There is a ton of money at stake here in the US in the form of sales revenue, taxes, fees, advertising, fine revenue, you name it. Consumer fireworks are not going anywhere.

[PGH_Pyro]

lets hope trump doesnt put these high trade tariffs on everything coming in from china...
will price fireworks out of most peoples' budgets, for good...
that is if he isn't impeached before that...

[countryboy7978]

Actually Trump and his pro-business and anti regulation agenda are our only saving grace.

[Rick_In_Tampa]

lets hope trump doesnt put these high trade tariffs on everything coming in from china...
will price fireworks out of most peoples' budgets, for good...
that is if he isn't impeached before that...

Lol... Ah yes. Comedy. I love it.

[PGH_Pyro]

anti-regulation, my ass.
he was talking of tariffs on everything coming in from china.
that of course, includes fireworks.
dump trump.

[Rick_In_Tampa]

anti-regulation, my ass.
he was talking of tariffs on everything coming in from china.
that of course, includes fireworks.
dump trump.

And your solution to correct the massive trade imbalance and China's currency manipulation so fireworks stay cheap is what again??

[countryboy7978]

anti-regulation, my ass.
he was talking of tariffs on everything coming in from china.
that of course, includes fireworks.
dump trump.

Regulation and tariffs are completely different things! Trump is anti-regulation and pro-business period. Pro US business.
Would you like to have a job or cheaper fireworks? I know I love fireworks but I love having a home, car, family, and food more!

[PGH_Pyro]

worst president in history, so far.
lowest approval rating, ever.
he's about to get us into World War 3 .
his one and only term, I guarantee that.
the least he could do is provide us with cheaper fireworks...

[RalphieJ]

Hillary lost.

[PGH_Pyro]

ralphie gee, that's great that you can read the news. congrats on that but hilary won more votes than he did.
the electoral college and it's outdated math ratio elected trump.
otherwise, she won by lots of votes. hopefully, you're intelligent enough to comprehend that.
as well, hilary lost because james comey interfered at the last second for no good reason and also because trump made
the masses think he's all for them when he is not.
the ballcap on and the whole thing.
he pulled quite a maneuver.

as far countryboy's post, i'm all for small businesses thriving. i'm all for having food on the table and etc but
trump is a business guy. you cannot run this country like it were a business.

[RalphieJ]

Trump won 31 states, Hillary 19. The adults are back in charge. Just sit back and settle in for the next 7 1/2 years. BTW, my investments are up 15% since election day. How are yours?

[PGH_Pyro]

Hilary won a huge difference of popular votes. Like at least, a couple million, I believe.
Note that i'm a registered libertarian and not the Hilary fan-boy that you assume I am but Hilary was/is qualified to be President. Trump had and still basically has no experience in that role. You don't hire a dentist who never went to Dental school and trained for years. You hire a real dentist.
Trump is anything but an adult. He's mentally ill, clearly and perhaps has alzheimers disease.
He won't win another election after this disaster. Don't be silly .
Nor will Pence win if he ran. He's even worse and more out of touch .

[MtnViewPyro]

I must be lost!!! I thought pyrotalk.com was a place for firework enthusiasts to come and talk about their love and knowledge of fireworks. I have learned so much from many of these guys on here. I hope we don't ruin a great thing for many because of politics. If I understand this thread correctly this organization in place has been trying to do this for many years and will continue to do it for many years to come. However, one thing that will keep it from happening is a united firework family. Just because you two disagree about who is flying the plane, you should both agree that we want the plane to land.

You can go on Facebook right now and watch people fight about politics under a thread about Hurricane Irma. Instead of being concerned about those life's that are about to be drastically changed, people are fighting about what old fart signs the bills. Truly a sad thing to watch. I for one, hope that this doesn't continue on here. This is one, of the very few, sanctuaries I have from the political discourse we find ourselves in.

My name is MtnViewPyro and I approve this message :D

[bakerCRZ]

ralphie gee, that's great that you can read the news. congrats on that but hilary won more votes than he did.
the electoral college and it's outdated math ratio elected trump.
otherwise, she won by lots of votes. hopefully, you're intelligent enough to comprehend that.
as well, hilary lost because james comey interfered at the last second for no good reason and also because trump made
the masses think he's all for them when he is not.
the ballcap on and the whole thing.
he pulled quite a maneuver.

as far countryboy's post, i'm all for small businesses thriving. i'm all for having food on the table and etc but
trump is a business guy. you cannot run this country like it were a business.

I did not, do not, and will not endorse either candidate from this past election. I think they both were the worst candidate from each party. That said, I think that the hatred of our electoral college is due to a lack of education on why the electoral college was created in the first place.

America was founded to be a constitutional republic not a pure democracy. The electoral college is not "outdated" and still performs as the founding fathers originally intended. Its purpose is to protect and give voice to the "fly-over" states and rural America. If the electoral college did not exist, presidential candidates could could/would campaign in the nation's biggest cities (NY, LA, Houston, Chicago, etc) and avoid campaigning in all the spaces in between. The people in low-population states would be ignored all together; there aren't people in them to be worthwhile. People outside of cities would be forgotten. Our founding fathers sought to prevent this.

Like it or not, the system is fair, and either party can take advantage of it. If Hillary would have spent more time campaigning in rural America, she could have won. You have to win in cities AND rural America to become president. We should not forget this. Do some research before condemning the system that our founding fathers worked so hard to create. The amount of time they spent designing this system should not be disregarded.

[PGH_Pyro]

it's out-dated and furthermore, life is vastly different in a big city than it is in "flyover areas" as you describe. i'm convinced they need their own leadership and should secede. people in butt-f**k america should not be in any position to vote in politicians for people in higher population/urban areas. things are just way too different. things were very different, back when that electoral b.s. was set up.
it's a much different America/World now and we must adapt and change.

[bakerCRZ]

it's out-dated and furthermore, life is vastly different in a big city than it is in "flyover areas" as you describe. i'm convinced they need their own leadership and should secede. people in butt-f**k america should not be in any position to vote in politicians for people in higher population/urban areas. things are just way too different. things were very different, back when that electoral b.s. was set up.
it's a much different America/World now and we must adapt and change.

You can hand-wave and call it "outdated" as much as you would like, but until you provide evidence that the system is not working as the founding fathers intended, your claim is unfounded.

Well the last time "butt-f*** america" as you called it tried to succeed, they were invaded and pillaged by the Union Army for trying to leave.

Regardless, I think insulting people and claiming they are not in a position to vote for their president is exactly the type of 'holier/better than thou' thinking that lost the Democrats election. Maybe you (and others with views left of center) should try getting along and reaching out rather than demeaning the other side.

The words and behaviors in your posts in this thread perfectly exhibit the problem with our country at the moment: We would rather insult those we disagree with rather than trying to get along.

[bakerCRZ]

You can hand-wave and call it "outdated" as much as you would like, but until you provide evidence that the system is not working as the founding fathers intended, your claim is unfounded.

Well the last time "butt-f*** america" as you called it tried to succeed, they were invaded and pillaged by the Union Army for trying to leave.

Regardless, I think insulting people and claiming they are not in a position to vote for their president is exactly the type of 'holier/better than thou' thinking that lost the Democrats election. Maybe you (and others with views left of center) should try getting along and reaching out rather than demeaning the other side.

The words and behaviors in your posts in this thread perfectly exhibit the problem with our country at the moment: We would rather insult those we disagree with rather than trying to get along.

*secede ..... auto-correct sucks.....

[MtnViewPyro]

it's out-dated and furthermore, life is vastly different in a big city than it is in "flyover areas" as you describe. i'm convinced they need their own leadership and should secede. people in butt-f**k america should not be in any position to vote in politicians for people in higher population/urban areas. things are just way too different. things were very different, back when that electoral b.s. was set up.
it's a much different America/World now and we must adapt and change.

I'm from a town with a population of a little under 3k. I'm a very proud American and it's rather insulting you believe us little town folk should secede. What standard of measurement does one use to come to this conclusion? From your previous post, I believe you and I voted for the same person. So why should I lose my right and you keep yours? Oh because you live somewhere that's better or "smarter" to vote for the right person. You should leave PA, they went against you. Better yet, write your representative and ask that he/she introduce a bill for PA to secede because they voted for Trump and they clearly have now reason to be trusted anymore. Come on man.

[displayfireworks1]

OK I think its about time to close the thread. The never ending political debate can go on forever. The original subject was helping the fireworks industry and commenting on the CPSC website and over 2500 people did.