National Fireworks Associationubmission form



The National Fireworks Association commissioned a third-party US Department of Transportation approved explosives testing facility to conduct tests of various burst charge compounds containing powdered aluminum and collected data on the explosive force of those burst charges. The study compared a compound containing 12.5% powdered aluminum (the metals powder) against another with zero powdered metals (the hybrid powder). The results showed that the energy output (explosive force) of the hybrid powder exceeded that of the metals powder. Since the proposed rule would allow the more explosive non-metallic hybrid powder but ban the less explosive metallic powder, it seems that the proposed rule does not increase the safety of devices as it was intended. To read the full study from the NFA, please contact us.

Click to Download SMS-5278-R1 Rev 0

The United States Small Business Administration (SBA) also offered their unsolicited opinion on the proposed rule by the CPSC. SBA became concerned the CPSC proposed this regulation without factual basis and cited the significant impact it would have on small businesses. It even suggested steps for the CPSC to take to make the rule less damaging to small businesses. To read the full opinion from the SBA, please contact us. 

Click to Download Advocacy Fireworks Comment Letter

Comments filed on Commission’s proposed interpretation of the phrase intended to produce and audible effect.  This was an attempt by the CPSC to rewrite the existing fireworks regulation without doing a formal rule making. 

Click to Download 2016.10.04 - NFA Comments Interpretive Rule

Comments filed by the NFA on the CPSC proposal to change the existing fireworks regulations.  Eliminating the ear ready for a new test. 

Click to Download 2017.07.17 - NFA Comments NPR 82 Fed Reg 9012

Testimony of NFA Counsel Spence’s Elg on the CPSC proposed fireworks rule.  

Click to Download 2018.03.07 Oral Presentation (Elg)

Testimony of Steve Houser, Secretary of the NFA, on the CPSC proposed fireworks rule. 

Click to Download 2018.03.07 Oral Presentation (Houser)

NFA comments pertaining to the proposed metals ban and how it fails to measure explosivity. 

Click to Download 2018.03.14 NFA Comments on Fireworks NPR

NFA comments highlighting incorrect, misleading, and unsubstantiated statements in the 9/26/2018, CPSC staff briefing package. 

Click to Download 2019.03.20 NFA Letter to CPSC

NFA comments on the CPSC budget process requesting that nothing proceed without a permissible metals allowance in the burst charge between 10% and 15%.  

Click to Download 2019.04.17 NFA Letter Re CPSC 2020-2021

On July 1, 2019, Congressmen Dusty Johnson (R-SD), Paul Gosar (R-AZ), Doug LaMalfa (R-CA) and Tim Burchett (R-TN) wrote a letter to Consumer Product Safety Commission (CPSC) Acting Chairwoman Ann Marie Buerkle about their concerns of the agency’s proposed rulemaking around fireworks and their concerns that it will have on small businesses.

Click to Download Western Caucus Letter