What is the new CE Directive for pyrotechnics and the T1 and T2 categories?

From July 4th 2013 the CE Directive for theatrical pyrotechnics requires that product supplied throughout Europe be CE certified and labelled accordingly.

There has, until now, been an exemption in place that meant certain products could still be supplied until July 4th 2017 without this CE authorisation but that date has now passed.

This means that all pyrotechnic articles supplied must comply with the directive and be labelled with the relevant CE information.

The directive categorises products into T1 or T2 according to their type of use, their purpose, and level of hazard:

Category T1: pyrotechnic articles for stage use which present a low hazard. Some T1 articles are restricted for outdoor use only and will be labelled as T1 ‘for outdoor use only’ accordingly. These items remain available to the general public.

The minimum age limit for the supply of category T1 theatrical pyrotechnic articles is 18 years.

Category T2: pyrotechnic articles for stage use which are intended for use only by persons with specialist knowledge. The term stage use includes film and television productions, live events and similar theatrical use.

To qualify as a ‘person with specialist knowledge’ (and therefore be able to purchase T2 products) the purchaser must demonstrate to the satisfaction of the supplier that they have:

Undertaken training recognised in the theatrical profession, in relation to the type of category T2 theatrical pyrotechnic articles to be supplied;
Previously used category T2 theatrical pyrotechnical articles;
Valid public liability insurance covering use of category T2 theatrical pyrotechnic articles (may be in the name of the individual or the employer of the individual).

A person of specialist knowledge also includes:

Any person whose full time trade or business (or significant part of that trade or business) is the supply of category T2 theatrical pyrotechnic articles, for the purpose of supplying them in accordance with the regulations.

This means that distributors can buy and supply T2 products but must ensure that anyone purchasing them is a ‘person with specialist knowledge ‘as defined above (therefore, qualifying them as a T2 user).

T2 training
(Persons with specialist knowledge - PWSK)
The Department for Business, Energy and Industrial Strategy (BEIS) guidance states that “the concept of training recognised in the business, industry or profession does not mean that BEIS will be recognising particular training. It is for the supplier to make such judgement as to whether the training in question is sufficient and provided by a person or body with a sufficient reputation in that sector”.

Training is however, recognised by, but not limited to, the Association of Stage Pyrotechnicians (www.stage-pyro.org.uk) and offered regularly by a variety of different hosts, suppliers and venues across the UK. Most recent of available courses can usually be found at www.stage-pyro.org.uk/training. The ASP also provides the repository for members competency in recording other aspects of appropriate training ie: fire fighting, first aid, working at height, electrical safety as well as specific T2 product training and advanced study.

Le Maitre T2 products
All of Le Maitre products are category T1 apart from the following:

Flash Reports
Plastic Maroons
1 x 50 Fountains (Gerbs)
Cascades
Saxons
Starbursts (including those on harnesses)
Mortar Hit Loud Report

NOTES

If a customer cannot prove that they are trained and have valid insurance they cannot purchase T2 products. The supplier will be in breach of the regulations and can be liable if they are in breach of this.
A person with specialist knowledge (T2 user) can handle and/or use articles labelled T1 or T1 'for outdoor use only' in a different manner to that prescribed on the label or within the instructions for use, provided that they have taken due consideration of the hazards and risks that any deviations they make might have. A person with specialist knowledge is expected to have the knowledge to make use of T1 products in a different manner to those prescribed on the label or the instructions.

For example: a T1 'for outdoor use only' product could be used indoors, in an appropriately sized venue/space by a person with specialist knowledge if, with suitable risk assessment and preparation, they can demonstrate it safe to do so. (ref: BSI Standard Note EN 16256 Part 2 sec 4.3 Cat T2)

Le Maitre Limited have established and apply a quality management system, and the requirements for the quality control according to Module E, Annex II of the European Directive 2013/29/EU have been fulfilled.