The Construction Products Directive and Fire Safety
Category: Specialist Fire Protection
As a founder member of the EAPFP, the UK Association for Specialist Fire Protection (ASFP) played a major part in the Conference.
The programme over two days firstly looked at how the CPD was influencing individual product sectors and then whether the provision of Fire Safe Products ensured fire safety in building works. The overall question of fire safety in buildings was looked at through the eyes of fire fighters, insurers and indeed the whole "Fire Community" in an attempt to see a wider picture. As all products will in future be required to have a CE mark as a cross border "passport" the mechanism and timetable for obtaining the mark was also examined in detail before the final session looked at probable developments for the future including a review of the whole picture by Mr Vincente Leoz-Arguillez, the Head of the Construction Unit in The Enterprise Directorate.
Fire Safety Products and the CPD
The first session asked the question "How will the CPD influence the design of Products and Buildings?" and individual papers looked firstly at the overall picture for Building Products before glazing, firesealing materials, mineral wool, and fire doors were looked at in detail. The final paper examined how all PFP products are actually installed in buildings and the challenges that this set for the industry.
Overall it was concluded that whilst implementation of the CPD by CE marking of products will start in early 2002, the manufacturing industry will retain existing products although many of these will require new test evidence to adapt them to the new harmonised European system. This reality presented us all with some problems, not least of which was the load the retesting of existing products will place both on industry, as a cost, and on the laboratories as workload.
Products such as modern fire resistant glass allow the designer great freedom of concept and the materials are well capable of passing any of the tests that are required provided that they are installed correctly, a recurring comment that followed every session of the conference. Firesealing both around glazed screens and throughout the building can be done with a rapidly developing range of foam and sealing products that have already been designed to pass the new tests where these are known but delays in the completion of European Technical Agreements (ETAs) are holding up the process of development in some areas as all the characteristics required by such products have not yet been agreed. This delay will hold up the CE marking process and could slow development until details are known.
The affixing of the CE mark by manufacturers is a result of Directives and these can come in several forms. Most PFP products will have to follow this route as a result of the CPD but certain products such as fire doors and shutter mechanisms will also have to follow the Machinery Directive that covers the actual installation of the device in a building and as this often includes a variety of equipment some confusion exists as things currently stand. Once again the point was forcibly made that the CE mark as required by the CPD will be fixed as the product leaves the factory but the mechanism may well fail under fire conditions if the machinery is not installed correctly and the quality of installation of products was agreed as the main challenge facing all PFP manufacturers.
Living with the CPD
Given the requirement that all construction products should have a CE mark and that this mark shall show the level of "safety in case of fire" the conference showed just how this mark is to be obtained. All products will be covered either by a Product Standard (for established product groups) or a European Technical Agreement (for novel products) that will allow the manufacturers to affix the mark based on the "Fire Classification". The standards and the testing on which the system is based have been up to 15 years in the making.
The core of the system will be the "Notified Bodies" through which manufacturers will confirm that that a CE mark can be affixed. This is a complex system and the delegates expressed considerable concern at either the willingness of certain National Governments to accept products tested and appraised outside their national borders, or at the comparative skills and knowledge of the Notified Bodies in all countries. The detailed requirements of National Building Regulations are within the competence of the member states and it was felt that these could still be a barrier to trade unless some Europe wide policy in this area is established.
It is clear that some products will have the CE mark within a few months and that most construction products are likely to be involved within 2 to 3 years with existing National Standards withdrawn at that time.
The initial performance testing having been undertaken within this system, responsibility for market surveillance in the continued performance of the products in use becomes the responsibility of the member state. Industry is concerned that a distortion of the market will occur if the implementation of the system is uneven and there needs to be a willingness to work in a transparent manner to avoid this. Any higher costs in the short term should be offset by lower long-term costs because of the fact that one test or group of tests will cover many countries. This should open the market up to smaller companies that previously worked within National boundaries.
"Does the CPD improve safety in case of fire?"
Whilst all products, active or passive, have their role to play in the fire safety of structures they are interdependent and can never be looked at in isolation. This fact was very clearly demonstrated in a paper that put the view from the fire fighters perspective in a dramatic manner. The fact is that whilst we have clear rules for the provision of fire safe construction products we have not yet found a way of imposing rules on the fire itself! Two illustrations were given of the fact that fire is totally unpredictable and we underestimate it at our peril, and in particular, at the peril of the fire fighter.
The CPD is simply a way of opening up the European market to any product from whatever source that meets agreed test standards. Fire safety in buildings can only be improved by the proper use of products that have a known performance in fire and the CPD was never intended to improve performance, merely to provide sound, agreed standards. The delegates were invited to consider that the question of fire safety in buildings needs to be reviewed in the light of EC legislation as more than one Directorate is involved. A proposal was accepted by those present that a Conference should be organised encompassing all the European groups with an involvement in fire and the EAPFP will work to set up such a Conference. The purpose would be to consider the future direction of European fire safety policy.
The conference was reviewed by Mr Leoz with clear statements that the EC saw the CE mark as a passport for the free movement of goods and that no other barriers can be put in the way of such trade. It is a clear indication of the fitness for purpose of the product but should not be seen as any sort of barrier to higher quality and improved performance. The use of the mark is compulsory and the Commission will reject any proposal that a member state can work without it. Similarly firm action will be taken to ensure that all states cease the acceptance of products tested only to National Standards when the system is in use. The market should be even and open to all across all borders and this will be watched very closely by the EC.
Whilst it is perhaps true to say that the CPD does not 'per-se' improve safety in case of fire it does ensure that only products with a known performance in fire can be sold and so, in practice standards can and should improve. The next step is some aligning of National Building Codes together with the performance based regulation and in this respect the proposals from the conference for further discussion of this point across the whole of the "stake holder" group is particularly pertinent.