Proposals are being put forward to revise the Construction Products Directive (CPD). A conference was held in Luxembourg earlier this year which reviewed the CPD’s impact on fire safety products and considered the way forward. A summary of the findings of the conference are given here.
Representatives from four sectors of the passive fire protection industry gave their views. Active fire protection products, which are also covered by the CPD, were not considered.
Mike Wood of Pilkington expressed the view that the process established under the CPD was too complex and centralised. He posed the question: “What is a product under the CPD?” Using the example of glass he pointed out that fire safety depended on thinking about systems. A consequence of this, he said, was that importance should be paid to the quality of installation, but this was not addressed in the CPD.
Birgitte Messerschmidt from Rockwool International A/S explained that CE marking of thermal insulation products had been made possible since 2002. At that time there was limited experience in using the new SBI (Single Burning Item) test and the reaction to fire Euroclassification system. This provided challenges in two areas:
– The field of application of test results. This was influenced by product parameters and end use application parameters and is important, as grouping products together results in lower testing costs. Later, guidance on direct and extended application of test results was provided in CEN TS 15117.
– Mounting and fixing test specimens in fire tests. The influence of this on fire test results came as a surprise to many; this had not been foreseen and no guidance was given in product standards. Initially, not all Notified Bodies were aware of this issue, but CEN technical committee TC 88 and the GNB Fire Sector Group (FSG) developed guidelines. To be fully effective, however, the guidance needs to be followed by all Notified Bodies.
She concluded that reaction-to-fire testing for CE marking was not a simple task, and that the field of application of the test results still needed to be addressed by manufacturers.
Fire doors cannot yet be CE marked because the necessary harmonised standards have not yet been published, said Werner Hrdy of Domoferm International GmbH. He pointed out that manufacturers were testing doors to EN 1634-1, but there were some drawbacks:
– Mutual recognition of test reports is not yet working satisfactorily, due to lack of acceptance by some national authorities
– Test results on identical fire doors are showing wide variability in different laboratories (up to 25%)
– Although standards covering extended application of test results were in preparation, the standardisation process was being slowed down by endless comments and negative voting
– Classification of fire doors to EN 13501-2 was still not accepted in some Member States
– There is no mutual recognition of audit reports between Member States.
Technical approvals
Stefaan Van Haute of Promat International NV described CE marking of protective board products against the guidelines for European technical approvals (ETAG/ETA). Some technical specifications are covered by ETAG, from which a European Technical Approval (ETA) would be prepared by a national Approvals Body. In addition to addressing performance against the Essential Requirements of the CPD, these approvals would also address durability and serviceability.
Under the CPD, an ETA is a technical specification against which products could be CE marked. However recent thinking by the EC was that compliance with an ETA was voluntary, and this was causing some confusion within the industry. EAPFP members were urging the EC to clarify the position of ETAGs in its revision of the CPD.
The passive fire protection industry’s views were followed by a Notified Body perspective. Dr Le Tallec, from Yannick Le Tallec in France, emphasised that the Essential Requirements of the CPD covered construction works – but only products could be CE marked. Bodies were notified to the EC by their Member States. She was concerned, however, that criteria for notification were different across Member States and rules for verification were not defined. The Notified Bodies used harmonised standards in their tasks but some of these did not provide sufficient details for common interpretation, she added. EC Guidance Papers were useful but they had no legal status.
Simplification not dilution
In a paper written by Karlheinz Zachmann of the European Council of Civil Engineers, it was stated that civil engineers did not want the revision of the CPD to dilute any of the essentials of the existing text. What was required was the strengthening of links to Eurocodes and the mandating of other codes linked to health and safety and energy saving.
Giancarlo Bedotti of EC DG Enterprise reminded delegates that Euroclassification systems had been developed for reaction-to-fire, fire resistance, and external fire performance of roofs, and that these systems had now been adopted in all Member States.
Turning to the CPD revision process his colleague, Vicente Leoz Arguelles, said simplification was needed. The existing Directive would be replaced by a Regulation, this would make its implementation mandatory in all Member States, he added. Direct implementation of a Regulation would save on bureaucracy and enable national regulators to express their national requirements in the same language, which would also be taken up by users, designers, architects and others. Specific terminology would be defined in the CPR, while accreditation of Notified Bodies and market surveillance would also be addressed. He considered accreditation of Notified Bodies should be compulsory to give more credibility to the system.
The question of whether additional marks might disappear with the increased acceptance of CE marks was posed by Eric Winnepennickx of BBRI Belgium. The credibility of CE marks depended on a combination of effort from the Notified Bodies and market surveillance. While CE marking provided market access, he said, other marks provided market acceptance.
In conclusion he considered that unless the revised CPD covered more than just regulatory requirements, there was always the potential for a manufacturer’s and/or user’s need for additional marks.
The conference in Luxembourg was organised by EGOLF, the European organisation representing fire testing bodies, and EAPFP, the European passive fire protection association. Our thanks to Ruth Boughey of the EGOLF secretariat on whose full report this is based. To see the full report visit: www.egolf.org.uk
