Does anyone know the specific DOT regulation which forbids transporting ematched product?
It's my understanding that it's currently being done under a variance the APA lobbied for.
I believe this is the one but I'm hoping someone more familiar with DOT regs can help me out.
§ 173.54 Forbidden explosives.
Unless otherwise provided in this subchapter, the following explosives shall not be offered for transportation or transported:
(a) An explosive that has not been approved in accordance with § 173.56 of this subpart.
(b) An explosive mixture or device containing a chlorate and also containing:
(1) An ammonium salt, including a substituted ammonium or quaternary ammonium salt; or
(2) An acidic substance, including a salt of a weak base and a strong acid.
(c) A leaking or damaged package or article containing an explosive.
(d) Propellants that are unstable, condemned or deteriorated.
(e) Nitroglycerin, diethylene glycol dinitrate, or any other liquid explosives not specifically authorized by this subchapter.
(f) A loaded firearm (except as provided in 49 CFR 1544.219).
(g) Fireworks that combine an explosive and a detonator.
(h) Fireworks containing yellow or white phosphorus.
(i) A toy torpedo, the maximum outside dimension of which exceeds 23 mm (0.906 inch), or a toy torpedo containing a mixture of potassium chlorate, black antimony (antimony sulfide), and sulfur, if the weight of the explosive material in the device exceeds 0.26 g (0.01 ounce).
(j) Explosives specifically forbidden in the § 172.101 table of this subchapter.
(k) Explosives not meeting the acceptance criteria specified in § 173.57 of this subchapter.
(l) An explosive article with its means of initiation or ignition installed, unless approved in accordance with § 173.56.
[Amdt. 173-224, 55 FR 52617 Dec. 21, 1990, as amended at 56 FR 66267, Dec. 20, 1991; Amdt. 173-236, 58 FR 50236, Sept. 24, 1993; 67 FR 61013, Sept. 27, 2002; 68 FR 48569, Aug. 14, 2003]
Yes, that is the rule that the APA variance exempts it from. I believe that another area close by prohibits having an "means of ignition" stored near or with "explosives", but it is not as clear as the section you listed. Many of the codes were written for high explosives originally, meaning basically no blasting cap with the dynamite, but were given new meaning now that fireworks are considered as "explosives", not a separate category.
proximate pyro effects nearly always come with their own igniter installed
The DOT rules mostly cover 1.1, 1.2, and 1.3 as "high explosives", which are the ones limited by the DOT rules listed in 173.54. Most close prox products are 1.4 fireworks, which have much easier rules, which only apply to over 1000 pounds. There are far fewer limitations for 1.4 fireworks. That is one reason that doing all 1.4 shows is a great solution in many cases. As mentioned elsewhere, many 1.4 products are very good now, the purchasing, storage, and transport are all much simpler, and if you can get 1.4 pro items, they add a lot of products and effects normally found only in 1.3.