I would suggest to the NFA that a more effective approach would be to send an "Expert" to the UN. I believe this would require the acceptance of the Expert by the USA government as their representative to the
Committee of Experts on the Transport of Dangerous Goods
and on the Globally Harmonized System of Classification
and Labelling of Chemicals
Sub-Committee of Experts on the Transport of Dangerous Goods
The committee accepts presentations for modification of the table.
The information that would need to be presented are UN series 6 tests on all of the fireworks designs in question. The case for allowing the USA fireworks designs would have to be effectively presented by the "Expert" sent to the subcommittee.
When the UN default fireworks classification table was developed and implemented in 2004 there was an American Expert involved who did not effectively make the case for American 1.4G fireworks designs. During the development of the table I followed the input from all the "Experts" involved and in my opinion he did not effectively present the case for American fireworks designs. My impression of his input was mostly disagreement with the committee and very little presentation of technical information. He was of advanced age and passed away not long after so this may have been a contributing factor to his lack effective presentation for the case of American fireworks designs. Had an effective presentation of USA fireworks designs been made at that time it is possible the current problem would not exist now.
