Kracklin' Kirks Fireworks

1 week ago

THE FIREWORKS INDUSTRY IS UNDER ATTACK.
WE NEED YOUR HELP NOW!!!!!!!!

Kracklin Kirks encourages YOU to help

Under a proposed CPSC rule, 84% of consumer aerial fireworks currently on the market will be BANNED, replaced by lower-performing devices without the spectacular visual effects of today’s cake shots, reloadable shells, and stick rocket payloads!

This proposed rule will hurt American businesses and take away some of the most popular consumer aerial products on the market that Americans use to celebrate our Nation’s birth, local sporting events, and other occasions we celebrate.

THE CPSC HAS NO SAFETY JUSTIFICATION FOR THIS RULE – IT JUST THINKS AERIAL FIREWORKS TODAY ARE “TOO DANGEROUS” FOR PEOPLE! But weakening the performance of aerial fireworks can increase the risk of injury if stars fall while still ignited or pieces of the device don’t break apart enough in the sky!!!!!!

HELP DEFEAT THIS ATTACK BY FILING YOUR COMMENTS HERE: www.regulations.gov/comment?D=CPSC-2006-0034-0014


If you are a customer who loves fireworks, tell the CPSC:
• How important aerial fireworks are to you as an American;
• Why you think the aerial devices you buy now are safe when used correctly; and
• Why you DON’T want the Government to make aerial devices perform poorly!

**YOU CAN FILE YOUR COMMENTS ANONYMOUSLY IF YOU LIKE**

GET YOUR FRIENDS AND BUSINESS ASSOCIATES TO FILE COMMENTS OPPOSING THIS RULE!!!!!

There are two sample comment letters included. However, don't be afraid to add how this rule will hurt your business and the enjoyment of fireworks!

Another sample letter from an American:
To Whom It May Concern at my government:

Upon reading the CPSC proposed regulations regarding consumer use fireworks, I feel that you are overstepping your bounds. You are attempting to regulate a product that is only in use a small fraction of the year, with far-reaching statements that sound, as if, they are made by someone who has never used any of these products you are trying to ban. Not to mention, since they are already highly regulated as to when and where they can be used, any usage is considered newsworthy. This is why most public fireworks shows are widely broadcast so the public can participate in the rare yearly viewing. This is why when they are used in neighborhoods, many neighbors run to their yards and porches while calling for others to come see the beauty and freedom in their very own sky. Unfortunately this is also why, when there is an accident, usually caused by misuse, bad behavior, or wanton abandonment of any law, not just fireworks usage, it is made to be such a ridiculous spectacle. If fireworks were allowed to be used year round many of the minor incidents that are sensationalized by the media would be unheard. As a mother, of now teenage children who have been shooting fireworks since they were small, I feel completely comfortable and safe in allowing them to use these fireworks, but I am the same mother who allows my children to eat grapes and hotdogs, which are known worldwide as “choking hazards”. My family and I also swim and boat, in deep waters of pools, lakes, and oceans. Bicycles are often ridden in our neighborhood in streets without supervision. In my day, this was called growing, learning and self-regulating. Most people are smart, rule following Americans, who are tired of people trying to regulate, under the guise of protectionism, to the point where there is no life, no freedom, no fun. Mistakes can and will be made in every aspect of life, no matter how safe you try make it. Please do not take away this freedom which has represented our freedom for hundreds of years.

Thank you for your consideration,

A concerned, NOT fearful mother

Please take the time TODAY to comment on this proposal.

www.regulations.gov/comment?D=CPSC-2006-0034-0014

Sample Comment Letter

July 2017


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, ... See MoreSee Less

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