China rule regarding U.S. 1.4G Consumer Fireworks multi-shot “Cakes”
As you have all been hearing there is a significant obstacle facing the manufacture and export of traditional UN0336, 1.4G consumer fireworks made for America.
At issue is the application of a certain part of the United Nations “Recommendations on the Transport of Dangerous Goods, Model Regulation, Volume 1, Twenty-first revised edition”1, incorporated by reference which contains “Table 2.1.3.5.5 – Default fireworks classification table”1that describes “This table contains a list of fireworks classifications that may be used in the absence of Test Series 6 data (see 2.1.3.5.2)”1. Under the guidelines presented in the UN table, any multiple tube device (cake) containing tubes with an inside diameter greater than 30mm or 1.2” would be classed as 1.3G fireworks unless they were subjected to UN Series 6 testing and were subsequently determined to be 1.4G. Should such conditions prevail and be fully implemented by the Chinese Government it would have a profoundly negative effect on the manufacture and importation of many 500gram cakes regularly available in the U.S. market today.
The National Fireworks Association (NFA) has been following this issue as it has been morphing into being over the past two months. Many rumors have abounded, and many people are promulgating ideas being discussed as though they are final solutions to the problem. As of this time there is no final, absolute conclusion on the current situation. Before we tackle the various topics, let us provide some background and perspective on this issue as we here at the NFA understand it.
Historically the country of China has recognized that fireworks being shipped to the United States can be manufactured, classed and transported under the conditions by which the United States categorizes such items. The United States PHMSA/DOT has prescribed construction requirements for fireworks being exported to and imported by American importers which are in place to enhance safety for the manufacturers, transporters, sellers and end users of such products. It is the opinion of the National Fireworks Association (NFA) that U.S. Consumer, 1.4G, UN0336 Fireworks products are the safest in the world.
In December of 2019 a terrible accident happened in China at an unlicensed factory in China that was manufacturing NON U.S. compliant 1.4G fireworks. The result was an accident that led to a significant death toll of workers at the factory, a real tragedy. Understandably, the Chinese government swiftly investigated the accident and prosecuted those responsible for the tragedy. Since then there have been a number of changes that China CIQ/Customs (the entity that governs fireworks exports) has implemented to bolster safety protocols.
Unfortunately, we believe that their application of the UN recommended standards are being misapplied to U.S. 1.4G consumer fireworks because our U.S. requirements are actually a higher standard and this has been commonly accepted over many past decades. The UN recommendations do not address construction methods and specific chemical usage, rather they reference only tube size and individual tube pyrotechnic content.
For example, in the U.S. when multiple tube devices, commonly referred to as “cakes” exceed a gross pyrotechnic weight of 200grams, there must be a minimum tube spacing of 12.8mm between all tubes in all directions from each other. This limits the propagation effect of an “explosion” in one tube to continue to the next. This is a significant component of safety. Further, U.S. cakes are commonly constructed to a limit of 500grams of pyrotechnic composition. The UN recommendations do not address these specific construction and gross pyrotechnic device weight issues, rather they define classification based on tube size and pyrotechnic composition per tube alone. The UN recommendations would allow for a cake with inside tube diameters ≤ 30mm where each tube contains a maximum ≤ 25grams per tube of pyrotechnic composition to be manufactured with 100 tubes having no tube spacing. Such a device would be classed as a 1.4G device using the UN table referenced earlier, but it could contain up to 2,500grams of pyrotechnic composition and have no tube spacing. It is the experience of the NFA that such a device would be more dangerous than a 1.4G 9 shot 2.25” 500gram cake manufactured for the U.S. market under U.S. construction requirements. The distinct difference in construction methods and their positive effect on device safety is where we see the crux of the issue.
In addressing the various solutions to the issue that have been discussed to date we will go through them and highlight their status.
Discussed “quick” solutions and status:
1) Grace Period allowing items with inside tube diameters >30mm up to 50mm to be manufactured before November 30th, 2020.
a. This has happened. The cakes must be “topped” with a 9mm thick board after they have been placed in the shipping carton before it is sealed. Under these requirements the items will still be considered UN0336 1.4G. This is good news for now, but it is only temporary.
2) Steel “cages” placed around items not conforming to the ≤ 30mm rule in the UN Table. a. This is not a final solution. This was only discussed as “possible” action to reach a possible solution. Currently the Netherlands requires such cages on their product which could include very large cakes – think coffee table size that have no tube spacing – these are not comparable to U.S. 1.4G products. The NFA strongly disagrees with this steel cage approach. The cost in terms of both time and money is wasteful, inappropriate and unneeded because of how U.S. 1.4G consumer products are built and what they are built with. Also, it appears that the reasoning behind having the steel cage is based off of an incorrect application of a 15 meter specification that is being applied to the inserts (shells) and stars of consumer fireworks cakes, rather than debris or “shrapnel” (think left over parts) following a large singular “explosion”. This requirement was established in the testing protocols to apply to fragmenting grenades not consumer fireworks. The proper way to do this test is to put up “shadow plates” around the devices and then measure the dent depths to determine if it passes, but in China they are not interpreting it as such and instead are just saying that if the cake is placed in a burn pit and expels a star or shell (the insert) more than 15 meters outward it fails. With this interpretation virtually ALL cakes would fail – even those with tubes under 30mm such as small 200gram cakes that are automatically granted 1.4G status. Clearly this application of the test needs to be addressed. In preloaded tubes the inserts are designed with an intended function to expel more than 15m out of the device. Using an intended function of the device to disqualify it is wholly inappropriate and causes the UN rules to be in immediate conflict with themselves. The thinking behind the cage is that it would limit star or shell expulsion should a cake catch fire and begin to rapidly burn – in essence meeting a requirement that doesn’t actually exist under U.S. interpretation of the UN standard. While this is bad
enough, the NFA also feels that by constricting the item in a cage it could actually lead to a more rapid and more dangerous deflagration scenario than what our U.S. 1.4G products are presently built and designed to prevent. The difference between deflagration and detonation are very important to understand. A deflagration is a rapid burning of pyrotechnic effects where the flame front moves through the material below the speed of sound, but faster than convective burning. A detonation is a nearly singular “all at once” consumption of all explosive material where the flame front moves through the material faster than the speed of sound. Deflagration is what consumer fireworks and many professional fireworks do. Detonation is what dynamite or military grade explosives do. They are vastly different, and while terms are often “generally” misapplied, it is an important distinction we must make when discussing anything classed as an explosive. Specifically, at no time that we are aware of, has any compliant U.S. manufactured 1.4G consumer fireworks fire resulted in a detonation class “explosion” or loss of life. This is due to the chemicals being used in the devices as well as the tube spacing that prevents a mass, sequentially timed “detonation” event because the propagation of an initial explosion into another is severely limited by the air space or void between tubes. Rather, the devices just burn and discharge over time, allowing for the fire to be contained and the preservation of life to be accomplished. U.S. consumer fireworks already have the safety features built into them for safe handling and transportation, above and beyond what the UN recommendations are. Steel cages will just add unnecessary expense, time and problems to the process. Further, if we just “accept” steel cages we would, in essence, be agreeing that our U.S. 1.4G fireworks are actually dangerous enough to need the cages. That could/would have potentially far broader negative implications than any of us in the consumer fireworks business could stand.
3) Placing dual placards on shipping cartons – cases for purposes of this discussion. a. This a non-starter. Specifically, it was discussed in general terms that a 1.3G placard would be placed on the box in addition to the 1.4G placard. The thought was that the 1.3G would be used only while it was being transported in China, and then once it departed on the ship from the port the 1.4G placard would take over. But, you cannot do this, the confusion that would prevail would be too much. It would also lend itself to abuses. Remember, once an item enters the 1.3G realm everything changes. The NFA believes such a process would ruin the integrity of the safety of the U.S. 1.4G Consumer fireworks products as it would be much easier for people to “smuggle” in illegal fireworks by U.S. standards. How could U.S. Customs Border Protection (CBP) and PHMSA/DOT ever be expected to track such merchandise? Also, keep in mind that in the U.S. when it comes to handling 1.3G versus 1.4G explosives, the rules are vastly different as far as warehousing/storage, authorities having jurisdiction (AHJ’s). In some other countries the differences in handling are not near what they are here, so a 1.3G/1.4G placarding system is not practical or really even possible. As we said before, this is a non-starter as an option, for far too many reasons. Last, our existing EX/FC numbers are granted for 1.4G items, we can’t put EX/FC #’s for 1.4G items on 1.3G boxes.
4) Handling and shipping products from China as 1.3G and then remarking the cases once they arrive in the U.S. as 1.4G.
a. This is also a non-starter. Aside from the same potential abuse problems in exporting fireworks to the U.S. and the EX/FC # problems, there is simply no cargo space to do this. The space for shipping 1.4G containers is already nearly maxed out and the space allowed for 1.3G containers is a fraction of what is allowed for 1.4G containers. Put simply you cannot pour the contents of a gallon of milk into a shot glass. It simply won’t fit.
Now that we have addressed some of the more “talked about” rumors or solutions, let’s turn to what the NFA is and has been working on.
The NFA has reached out to PHMSA/USDOT and have requested their assistance in working with China on this issue. This is an international trade issue and we at the NFA are also discussing with our Washington, DC lobbyists the involvement of the U.S. State Department and the U.S. Trade Representative to assist with the diplomatic side of this issue. This needs to happen. The decision that has been made was made by the Chinese export authority in Changsha which, at the end of the day, holds the power over fireworks movement in China. This is a Chinese Government ruling, so we need our U.S. Government counterparts to act on our behalf to assist us in Beijing so that further clarity can be passed on to the Changsha authority. This is an international trade issue and the NFA believes this issue could or will have implications even outside our industry in terms of international trade if left unchecked. For decades, US consumer fireworks have been manufactured to in China to meet our specifications and criteria because they are being sent here to the U.S. for sale and use. We believe this was justified especially since we believe our regulations encompass and represent “a higher standard” than that of the UN model regulations because of the chemicals allowed, overall pyrotechnic weights and construction requirements discussed earlier. Applying a U.N. recommendation or a country of manufacture standard for goods that are destined for export to another country with different rules is not appropriate, especially in this instance where we believe our construction standards result in the production of a safer device. As an additional thought on this issue, it was pointed out to me in a previous conversation that refrigerators manufactured in China for export to the U.S. are built to meet our standards – 110V for instance, so they will work here. Refrigerators manufactured in China for use in China are built to meet their standards – 220V for instance because that is what will work there. Although fireworks and refrigerators are vastly different items the premise remains the same – you manufacture the item so that it meets the laws and standards required by the country in which the products are ultimately destined for use. This is where we need to get to with China on the issue of our U.S. 1.4G consumer fireworks.
The NFA is conducting some independent testing to check on the possible compliance of alternatives and we are communicating with manufacturers and group associations in China to aide in the development of solutions for both sides. Unfortunately, travel restrictions are preventing in person meetings and the timeline is short, so communications are only of an electronic nature, phone and email.
All of these considerations are a transportation and storage safety issue and are not an intended function issue. At no time during transportation or storage that we are aware of, have properly constructed, classed and finished 1.4G fireworks bound for the United States ever resulted in a singular mass explosion incident or performed in a way in such a scenario that was outside of the expected intended function of the fireworks either here or abroad. This is a critical point and it is well documented throughout the past decades following incidents of fire involving large quantities of stored U.S. 1.4G UN0336 fireworks product imported from China. None of these incidents resulted in deaths or mass explosion incidents. The product is well manufactured and safe from mass explosion hazards.
Rather than focusing too much on tube size, what is needed is a better mutual (China/US) understanding of:
a) What really presents a mass explosion hazard in transportation and storage
b) What really causes a mass explosion hazard in transportation and storage
c) How to prevent a mass explosion hazard in transportation and storage
d) The subjectivity of interpretation by independent countries of the UN Recommended Model Regulations and UN testing procedures and how those recommended model regulations are sometimes at odds with themselves
e) How to properly construct legal documentation so that business and commerce can continue between international countries and the safety concerns of everyone can be achieved.
What can you do at this time?
1) We have been getting notifications that Chinese brokers are calling people that have a few containers with them that they must pay for the steel cages in order for their exports to be shipped because it is the only option. The NFA strongly recommends AGAINST this practice for reasons outlined in point #2 above. We believe this is a knee jerk reaction/pressure tactic. There has been no ruling that we are aware of that this is an actual requirement by Chinese CIQ. To just accept it as a such and make it a “new normal” is an unnecessary economic burden and would likely have very serious negative effects on possible future demands regarding shipments. You need to reject this.
2) Forward any rumors that you may be hearing to me at shouser@nationalfireworks.com so that the NFA can address them, either through verification or through debunking them.
Together we will get through this latest issue. It is a significant one for sure and that is why communication and information exchanges are so important. I look forward to communications with our members and await the arrival of any further information you may have.
Stephen W. Houser
President
National Fireworks Association
At issue is the application of a certain part of the United Nations “Recommendations on the Transport of Dangerous Goods, Model Regulation, Volume 1, Twenty-first revised edition”1, incorporated by reference which contains “Table 2.1.3.5.5 – Default fireworks classification table”1that describes “This table contains a list of fireworks classifications that may be used in the absence of Test Series 6 data (see 2.1.3.5.2)”1. Under the guidelines presented in the UN table, any multiple tube device (cake) containing tubes with an inside diameter greater than 30mm or 1.2” would be classed as 1.3G fireworks unless they were subjected to UN Series 6 testing and were subsequently determined to be 1.4G. Should such conditions prevail and be fully implemented by the Chinese Government it would have a profoundly negative effect on the manufacture and importation of many 500gram cakes regularly available in the U.S. market today.
The National Fireworks Association (NFA) has been following this issue as it has been morphing into being over the past two months. Many rumors have abounded, and many people are promulgating ideas being discussed as though they are final solutions to the problem. As of this time there is no final, absolute conclusion on the current situation. Before we tackle the various topics, let us provide some background and perspective on this issue as we here at the NFA understand it.
Historically the country of China has recognized that fireworks being shipped to the United States can be manufactured, classed and transported under the conditions by which the United States categorizes such items. The United States PHMSA/DOT has prescribed construction requirements for fireworks being exported to and imported by American importers which are in place to enhance safety for the manufacturers, transporters, sellers and end users of such products. It is the opinion of the National Fireworks Association (NFA) that U.S. Consumer, 1.4G, UN0336 Fireworks products are the safest in the world.
In December of 2019 a terrible accident happened in China at an unlicensed factory in China that was manufacturing NON U.S. compliant 1.4G fireworks. The result was an accident that led to a significant death toll of workers at the factory, a real tragedy. Understandably, the Chinese government swiftly investigated the accident and prosecuted those responsible for the tragedy. Since then there have been a number of changes that China CIQ/Customs (the entity that governs fireworks exports) has implemented to bolster safety protocols.
Unfortunately, we believe that their application of the UN recommended standards are being misapplied to U.S. 1.4G consumer fireworks because our U.S. requirements are actually a higher standard and this has been commonly accepted over many past decades. The UN recommendations do not address construction methods and specific chemical usage, rather they reference only tube size and individual tube pyrotechnic content.
For example, in the U.S. when multiple tube devices, commonly referred to as “cakes” exceed a gross pyrotechnic weight of 200grams, there must be a minimum tube spacing of 12.8mm between all tubes in all directions from each other. This limits the propagation effect of an “explosion” in one tube to continue to the next. This is a significant component of safety. Further, U.S. cakes are commonly constructed to a limit of 500grams of pyrotechnic composition. The UN recommendations do not address these specific construction and gross pyrotechnic device weight issues, rather they define classification based on tube size and pyrotechnic composition per tube alone. The UN recommendations would allow for a cake with inside tube diameters ≤ 30mm where each tube contains a maximum ≤ 25grams per tube of pyrotechnic composition to be manufactured with 100 tubes having no tube spacing. Such a device would be classed as a 1.4G device using the UN table referenced earlier, but it could contain up to 2,500grams of pyrotechnic composition and have no tube spacing. It is the experience of the NFA that such a device would be more dangerous than a 1.4G 9 shot 2.25” 500gram cake manufactured for the U.S. market under U.S. construction requirements. The distinct difference in construction methods and their positive effect on device safety is where we see the crux of the issue.
In addressing the various solutions to the issue that have been discussed to date we will go through them and highlight their status.
Discussed “quick” solutions and status:
1) Grace Period allowing items with inside tube diameters >30mm up to 50mm to be manufactured before November 30th, 2020.
a. This has happened. The cakes must be “topped” with a 9mm thick board after they have been placed in the shipping carton before it is sealed. Under these requirements the items will still be considered UN0336 1.4G. This is good news for now, but it is only temporary.
2) Steel “cages” placed around items not conforming to the ≤ 30mm rule in the UN Table. a. This is not a final solution. This was only discussed as “possible” action to reach a possible solution. Currently the Netherlands requires such cages on their product which could include very large cakes – think coffee table size that have no tube spacing – these are not comparable to U.S. 1.4G products. The NFA strongly disagrees with this steel cage approach. The cost in terms of both time and money is wasteful, inappropriate and unneeded because of how U.S. 1.4G consumer products are built and what they are built with. Also, it appears that the reasoning behind having the steel cage is based off of an incorrect application of a 15 meter specification that is being applied to the inserts (shells) and stars of consumer fireworks cakes, rather than debris or “shrapnel” (think left over parts) following a large singular “explosion”. This requirement was established in the testing protocols to apply to fragmenting grenades not consumer fireworks. The proper way to do this test is to put up “shadow plates” around the devices and then measure the dent depths to determine if it passes, but in China they are not interpreting it as such and instead are just saying that if the cake is placed in a burn pit and expels a star or shell (the insert) more than 15 meters outward it fails. With this interpretation virtually ALL cakes would fail – even those with tubes under 30mm such as small 200gram cakes that are automatically granted 1.4G status. Clearly this application of the test needs to be addressed. In preloaded tubes the inserts are designed with an intended function to expel more than 15m out of the device. Using an intended function of the device to disqualify it is wholly inappropriate and causes the UN rules to be in immediate conflict with themselves. The thinking behind the cage is that it would limit star or shell expulsion should a cake catch fire and begin to rapidly burn – in essence meeting a requirement that doesn’t actually exist under U.S. interpretation of the UN standard. While this is bad
enough, the NFA also feels that by constricting the item in a cage it could actually lead to a more rapid and more dangerous deflagration scenario than what our U.S. 1.4G products are presently built and designed to prevent. The difference between deflagration and detonation are very important to understand. A deflagration is a rapid burning of pyrotechnic effects where the flame front moves through the material below the speed of sound, but faster than convective burning. A detonation is a nearly singular “all at once” consumption of all explosive material where the flame front moves through the material faster than the speed of sound. Deflagration is what consumer fireworks and many professional fireworks do. Detonation is what dynamite or military grade explosives do. They are vastly different, and while terms are often “generally” misapplied, it is an important distinction we must make when discussing anything classed as an explosive. Specifically, at no time that we are aware of, has any compliant U.S. manufactured 1.4G consumer fireworks fire resulted in a detonation class “explosion” or loss of life. This is due to the chemicals being used in the devices as well as the tube spacing that prevents a mass, sequentially timed “detonation” event because the propagation of an initial explosion into another is severely limited by the air space or void between tubes. Rather, the devices just burn and discharge over time, allowing for the fire to be contained and the preservation of life to be accomplished. U.S. consumer fireworks already have the safety features built into them for safe handling and transportation, above and beyond what the UN recommendations are. Steel cages will just add unnecessary expense, time and problems to the process. Further, if we just “accept” steel cages we would, in essence, be agreeing that our U.S. 1.4G fireworks are actually dangerous enough to need the cages. That could/would have potentially far broader negative implications than any of us in the consumer fireworks business could stand.
3) Placing dual placards on shipping cartons – cases for purposes of this discussion. a. This a non-starter. Specifically, it was discussed in general terms that a 1.3G placard would be placed on the box in addition to the 1.4G placard. The thought was that the 1.3G would be used only while it was being transported in China, and then once it departed on the ship from the port the 1.4G placard would take over. But, you cannot do this, the confusion that would prevail would be too much. It would also lend itself to abuses. Remember, once an item enters the 1.3G realm everything changes. The NFA believes such a process would ruin the integrity of the safety of the U.S. 1.4G Consumer fireworks products as it would be much easier for people to “smuggle” in illegal fireworks by U.S. standards. How could U.S. Customs Border Protection (CBP) and PHMSA/DOT ever be expected to track such merchandise? Also, keep in mind that in the U.S. when it comes to handling 1.3G versus 1.4G explosives, the rules are vastly different as far as warehousing/storage, authorities having jurisdiction (AHJ’s). In some other countries the differences in handling are not near what they are here, so a 1.3G/1.4G placarding system is not practical or really even possible. As we said before, this is a non-starter as an option, for far too many reasons. Last, our existing EX/FC numbers are granted for 1.4G items, we can’t put EX/FC #’s for 1.4G items on 1.3G boxes.
4) Handling and shipping products from China as 1.3G and then remarking the cases once they arrive in the U.S. as 1.4G.
a. This is also a non-starter. Aside from the same potential abuse problems in exporting fireworks to the U.S. and the EX/FC # problems, there is simply no cargo space to do this. The space for shipping 1.4G containers is already nearly maxed out and the space allowed for 1.3G containers is a fraction of what is allowed for 1.4G containers. Put simply you cannot pour the contents of a gallon of milk into a shot glass. It simply won’t fit.
Now that we have addressed some of the more “talked about” rumors or solutions, let’s turn to what the NFA is and has been working on.
The NFA has reached out to PHMSA/USDOT and have requested their assistance in working with China on this issue. This is an international trade issue and we at the NFA are also discussing with our Washington, DC lobbyists the involvement of the U.S. State Department and the U.S. Trade Representative to assist with the diplomatic side of this issue. This needs to happen. The decision that has been made was made by the Chinese export authority in Changsha which, at the end of the day, holds the power over fireworks movement in China. This is a Chinese Government ruling, so we need our U.S. Government counterparts to act on our behalf to assist us in Beijing so that further clarity can be passed on to the Changsha authority. This is an international trade issue and the NFA believes this issue could or will have implications even outside our industry in terms of international trade if left unchecked. For decades, US consumer fireworks have been manufactured to in China to meet our specifications and criteria because they are being sent here to the U.S. for sale and use. We believe this was justified especially since we believe our regulations encompass and represent “a higher standard” than that of the UN model regulations because of the chemicals allowed, overall pyrotechnic weights and construction requirements discussed earlier. Applying a U.N. recommendation or a country of manufacture standard for goods that are destined for export to another country with different rules is not appropriate, especially in this instance where we believe our construction standards result in the production of a safer device. As an additional thought on this issue, it was pointed out to me in a previous conversation that refrigerators manufactured in China for export to the U.S. are built to meet our standards – 110V for instance, so they will work here. Refrigerators manufactured in China for use in China are built to meet their standards – 220V for instance because that is what will work there. Although fireworks and refrigerators are vastly different items the premise remains the same – you manufacture the item so that it meets the laws and standards required by the country in which the products are ultimately destined for use. This is where we need to get to with China on the issue of our U.S. 1.4G consumer fireworks.
The NFA is conducting some independent testing to check on the possible compliance of alternatives and we are communicating with manufacturers and group associations in China to aide in the development of solutions for both sides. Unfortunately, travel restrictions are preventing in person meetings and the timeline is short, so communications are only of an electronic nature, phone and email.
All of these considerations are a transportation and storage safety issue and are not an intended function issue. At no time during transportation or storage that we are aware of, have properly constructed, classed and finished 1.4G fireworks bound for the United States ever resulted in a singular mass explosion incident or performed in a way in such a scenario that was outside of the expected intended function of the fireworks either here or abroad. This is a critical point and it is well documented throughout the past decades following incidents of fire involving large quantities of stored U.S. 1.4G UN0336 fireworks product imported from China. None of these incidents resulted in deaths or mass explosion incidents. The product is well manufactured and safe from mass explosion hazards.
Rather than focusing too much on tube size, what is needed is a better mutual (China/US) understanding of:
a) What really presents a mass explosion hazard in transportation and storage
b) What really causes a mass explosion hazard in transportation and storage
c) How to prevent a mass explosion hazard in transportation and storage
d) The subjectivity of interpretation by independent countries of the UN Recommended Model Regulations and UN testing procedures and how those recommended model regulations are sometimes at odds with themselves
e) How to properly construct legal documentation so that business and commerce can continue between international countries and the safety concerns of everyone can be achieved.
What can you do at this time?
1) We have been getting notifications that Chinese brokers are calling people that have a few containers with them that they must pay for the steel cages in order for their exports to be shipped because it is the only option. The NFA strongly recommends AGAINST this practice for reasons outlined in point #2 above. We believe this is a knee jerk reaction/pressure tactic. There has been no ruling that we are aware of that this is an actual requirement by Chinese CIQ. To just accept it as a such and make it a “new normal” is an unnecessary economic burden and would likely have very serious negative effects on possible future demands regarding shipments. You need to reject this.
2) Forward any rumors that you may be hearing to me at shouser@nationalfireworks.com so that the NFA can address them, either through verification or through debunking them.
Together we will get through this latest issue. It is a significant one for sure and that is why communication and information exchanges are so important. I look forward to communications with our members and await the arrival of any further information you may have.
Stephen W. Houser
President
National Fireworks Association