APA Advisory - Implementation of Revised APA Std. 87-1

January 27, 2021

SUBJECT: Markings of Finished Fireworks Devices

As announced in a November 25, 2020 Advisory the revisions to APA Standard 87-1 became effective on December 28, 2020.

One of the new requirements in the 2018 APA Standard 87-1 A, B, and C, is the requirement for a Finished Firework Device to be marked with the EX Number (or FC Number) on the device, or packaging if the device is too small.  Any device manufactured prior to October 1, 2018 is not required to be marked with the EX Number.

Below are the specific page references in the Standards:

APA 87-1 A         see pg 9
APA 87-1 B         see pg 8
APA 87-1 C         see pg 8

The Pipeline and Hazardous Materials Safety Administration (PHMSA) which issues EX Approvals and enforces requirements of the APA Standard has asked the APA to remind fireworks manufacturers and importers of the EX / FC Number marking requirement and urge you to immediately begin marking devices (or packaging if the device is too small) with the EX / FC number. Foreign manufacturers should begin marking the EX or FC Numbers on the devices prior to shipment to the U.S.

PHMSA will delay compliance until November 1, 2021, however, urges manufacturers to begin marking devices now so that importers will not end up with surplus inventory requiring marking just prior to the November 2021 compliance date. 

The APA is aware that U.S. display companies may currently have a lot of inventory manufactured after October 1, 2018, in storage magazines that would be subject to this marking requirement and has advised PHMSA that requiring such existing inventory (each aerial shell or device) to be labeled with the EX number would present an extreme safety hazard. The volume of existing inventory requiring these new markings will be dependent upon whether the display industry has a season (sporting events, concerts, festivals, Independence Day celebrations, etc.)  Accordingly, PHMSA would like to know how big of a problem this is for APA members and approximately how much inventory companies have on hand that would require marking. We will survey the display membership post-virtual Winter Conference.

In the interim, please instruct your manufacturers to immediately begin marking all finished fireworks devices with the EX or FC Number.

Advisory #2021-03