View Full Version : type 54 permit
crackerbomb
01-10-2012, 09:38 PM
If a person is transporting over 1000lbs of consumer fireworks. Does a type 54 permit cover him to transport them or must he have a HAZ-MAT endorsement on a CDL?
indianahx
01-15-2012, 01:17 PM
I'm surprised no one has given you an answer on this yet. All I can offer is that consumer fireworks has absolutely nothing to do with the type 54 or any other user license the ATF can give to you. The BATFE has no regulation when it comes to consumer fireworks. Consumer fireworks are governed by the CPSC.
Secondly, from everything that i've read regarding transportation, the "1000lbs" you talk of is in regards to the actual pyrotechnic compound weight only. I dont believe it includes weight of the cardboard or paper tubes or anything else involved in the construction of the actual "firework"....only the powder weight.
Finally, I'm not quite sure about the whole HAZ-MAT or CDL issue. Maybe it would fall under the whole idea of "commerce" or "not in commerce" issue. I know that for the retailer I worked at for 11 years, every single truck that brought us our inventory was placarded with the D.O.T 1.4g explosive orange diamond stickers. As for a normal citizen going to a warehouse or wholesaler and loading up their 5th wheel to the brim, I'm not sure if that would require placards or not???? I would suggest calling the store you plan to visit (or make a face to face trip to discuss with them you plan on buying a large volume) and ask them beforehand if there's any kind of regulation for literally loading up on as much as you can get with or without placards. Good luck. Wish I could be in your shoes to have 1000lbs of 'works on my hands!
jknepp1954
01-15-2012, 07:30 PM
I'm surprised no one has given you an answer on this yet. All I can offer is that consumer fireworks has absolutely nothing to do with the type 54 or any other user license the ATF can give to you. The BATFE has no regulation when it comes to consumer fireworks. Consumer fireworks are governed by the CPSC.
Secondly, from everything that i've read regarding transportation, the "1000lbs" you talk of is in regards to the actual pyrotechnic compound weight only. I dont believe it includes weight of the cardboard or paper tubes or anything else involved in the construction of the actual "firework"....only the powder weight.
Finally, I'm not quite sure about the whole HAZ-MAT or CDL issue. Maybe it would fall under the whole idea of "commerce" or "not in commerce" issue. I know that for the retailer I worked at for 11 years, every single truck that brought us our inventory was placarded with the D.O.T 1.4g explosive orange diamond stickers. As for a normal citizen going to a warehouse or wholesaler and loading up their 5th wheel to the brim, I'm not sure if that would require placards or not???? I would suggest calling the store you plan to visit (or make a face to face trip to discuss with them you plan on buying a large volume) and ask them beforehand if there's any kind of regulation for literally loading up on as much as you can get with or without placards. Good luck. Wish I could be in your shoes to have 1000lbs of 'works on my hands!
First of all - a type 54 has nothing to do with consumer fireworks even in transportation.
Second of all - 1000# is not the pyro comp - but rather the total GROSS WEIGHT - say like for example - you are transporting 13 cases of excals (each one weighing about 75 or 80# each) you are over 1000#.
bottom line, if you are transporting either consumer or display fireworks for your own personal pleasure, then you are NOT in commerce and can do so without being in violation of DOT regs.
BUT if you are in commerce, then a whole diff ball game - placards, hazmat endorsement, etc prevails.
Perhaps this thread needs moved to the legal and laws section???
indianahx
01-15-2012, 07:47 PM
bottom line, if you are transporting either consumer or display fireworks for your own personal pleasure, then you are NOT in commerce and can do so without being in violation of DOT regs.
BUT if you are in commerce, then a whole diff ball game - placards, mat endorsement, etc prevails.
I knew someone would chime in. I'd listen to Joyce, something tells me she knows what she's talking about.
jknepp1954
01-15-2012, 07:58 PM
i MUST ADMIT - I don't really know all the ins and outs, but these are the basics...
Pyro Nation
01-15-2012, 09:45 PM
i MUST ADMIT - I don't really know all the ins and outs, but these are the basics...
Well, seeing how ya run a Fireworks Resale company. We should go with you on it..lol
crackerbomb
01-15-2012, 11:57 PM
First of all - a type 54 has nothing to do with consumer fireworks even in transportation.
Second of all - 1000# is not the pyro comp - but rather the total GROSS WEIGHT - say like for example - you are transporting 13 cases of excals (each one weighing about 75 or 80# each) you are over 1000#.
bottom line, if you are transporting either consumer or display fireworks for your own personal pleasure, then you are NOT in commerce and can do so without being in violation of DOT regs.
BUT if you are in commerce, then a whole diff ball game - placards, hazmat endorsement, etc prevails.
Perhaps this thread needs moved to the legal and laws section???
thankls for all the feedback. I was told that no matter what if you are transporting of 1000lbs of fireworks (1.4 or 1.3) you must have a HAZ-MAT endorsment on your CDL. Even if they are for your personal use. I don't know, thats why I asked you guys, THE PRO'S.
Pyro Nation
01-16-2012, 12:46 AM
thankls for all the feedback. I was told that no matter what if you are transporting of 1000lbs of fireworks (1.4 or 1.3) you must have a HAZ-MAT endorsment on your CDL. Even if they are for your personal use. I don't know, thats why I asked you guys, THE PRO'S.
Thats exactly what was told to me once when i got a shipment in... i wonder if it was the limit on the company I was getting it shipped from because it is commerce still for them in that respect
jknepp1954
01-16-2012, 06:47 AM
thankls for all the feedback. I was told that no matter what if you are transporting of 1000lbs of fireworks (1.4 or 1.3) you must have a HAZ-MAT endorsment on your CDL. Even if they are for your personal use. I don't know, thats why I asked you guys, THE PRO'S.
That has been a really highly debatable subject. I am not up on hazmat issues to really be totally knowledgeable on that. But as long as you are not in commerce (buying works for your own personal use and not getting any monetary compensation for it), I don't see a problem. Otherwise most all folks who buy fireworks would need to be placards/hazmat cert drivers and that is not going to happen.
jknepp1954
01-16-2012, 07:00 AM
Thats exactly what was told to me once when i got a shipment in... i wonder if it was the limit on the company I was getting it shipped from because it is commerce still for them in that respect
I remember when you told me about that - i don't really think this is the issue with them. I think they were just being weird, cause most other shippers are not like that.
I was told by my logistics company that Roadway would ship - so I called our local Roadway in Altoona area - NOT - no way would they ship fireworks - other hazmats yes, but not fireworks.
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