Examination of CPR based harmonised product standards with a view of identifying the classes and threshold levels included in them

Transcription

1 Ref. Ares(2018) /01/2018 MetSta Hanna Järvenpää Examination of CPR based harmonised product standards with a view of identifying the classes and threshold levels included in them Executive summary Part I and II 1

2 Content 1. Background 2. Scope of the examination 3. Definitions 3.1 Definitions in the CPR 3.2 Definitions in the Guidance Paper E 3.3 Definitions used in this examination 4. Threshold levels, technical classes and pass/fail criteria in 443 hens 4.1 CEN TCs involved 4.2 Summary of the results 5. Most frequent use of pass/fail criteria in hens 6. Analysis of the excel sheet 2

3 1. Background Construction Products Regulation (305/2011/EU; the CPR) replaced Construction Products Directive (89/106/EEC; the CPD) on 1 July CPD explicitly recognized regulatory classes which were decided upon by the Commission after the consultation and the support of Member States. Regulatory classes have been adopted only for some fire characteristics. In general, it was left to the CEN Technical Committees (CEN TC) to agree in the harmonised product standards (hen) on threshold levels, technical classes and pass/fail criteria. Member States had to use regulatory classes when giving requirement levels for the characteristics of construction products but for threshold levels and technical classes the same obligation was not formally acknowledged. Guidance how to use threshold levels and technical classes in hens was given in Commission Guidance Paper E Levels and classes in the Construction Product Directive. No specific guidance was given how to use pass/fail criteria in hens, but the necessity to use them was recognized by most of the CEN TCs preparing hens for construction products. CPR does not recognize the difference between regulatory classes and technical classes. According to its Article 27, classes of performance in relation to essential characteristics may be adopted by delegated acts or on the basis of revised mandates. Threshold levels in relation to essential characteristics may be established by delegated acts or by CEN TCs in hens when provided for in the mandates. Existing harmonised product standards (443 hens in place) most of which were mandated under the CPD include a lot of threshold levels, technical classes and pass/fail criteria for essential characteristics. These are commonly used to declare the performance of the construction product in the declaration of performance (the DoP) and when affixing the CE-marking. The current hens are used also under the CPR, but obviously would need certain adjustments to become fully adapted to the new system. In this context, one area of further consideration is constituted by the use of threshold levels, classes and pass/fail criteria. In order to enable discussions and further elaborations with stakeholders on this matter, it is important to know how frequently these instruments have been used in hens, and to analyse these situations more specifically. 2. Scope of the examination This examination covers 443 hen for construction products which are prepared by CEN TCs 33, 46, 50, 51, 67, 72, 88, 99, 104, 112, 121, 124, 125, 128, 129, 130, 132, 133, 134, 135, 154, 156, 163, 165, 166, 167, 175, 177, 178, 180, 185, 189, 191, 192, 193, 203, 208, 217, 226, 227, 229, 236, 241, 246, 249, 254, 265, 266, 277, 295, 297, 298, 303, 336, 340, 349, 357, 361, 393 and ECISS TC 103, 105, 110, 111 and CENELEC TC 20. hens cited in the OJEU and thus currently to be used for the DoP and the CE-marking have been analysed. Excel sheets have been prepared for each CEN TC, including for each hen the essential characteristics and the results of the following analysis concerning each characteristic: 3

4 1) Existence of threshold levels and performance values or other criteria indicating these levels 2) Existence of regulatory classes 3) Existence of technical classes and performance values or other criteria indicating these classes 4) Existence of pass/fail criteria which are declared in the DoP and the CE-marking and indicating criteria for these pass/fail criteria 5) Existence of pass/fail criteria which are not declared in the DoP and the CE-marking and indicating criteria for these pass/fail criteria 6) Existence of other classifications given in the DoP. In addition, those products and product families have been identified, for which pass/fails criteria are used in a significant fashion. Excel sheets including this analysis are presented in the attached file. 3. Definitions 3.1 Definitions in the CPR According to Article 2 (points 5 to 8) performance of a construction product, level, class and threshold level are defined as follows: 5. performance of a construction product means the performance related to the relevant essential characteristics, expressed by level or class, or in a description; 6. level means the result of the assessment of the performance of a construction product in relation to its essential characteristics, expressed as a numerical value; 7. class means a range of levels, delimited by a minimum and a maximum value, of performance of a construction product; 8. threshold level means a minimum or maximum performance level of an essential characteristic of a construction product. 3.2 Definitions in Guidance Paper E Commission Guidance Paper E Levels and classes in the Construction Product Directive clarified the differences between regulatory and technical classes in the following clauses: 4.3 Regulatory classes [ ] shall be established according to the procedure foreseen by Article 20(2) of the CPD. The range of levels covered by these classes depends upon the existing and justified levels encountered in the Member States. The provisions of Article 6(3) of the CPD apply to regulatory classes, obliging Member States to use them if specifying performance levels to be observed on their territory. 4.4 Technical classes, often referred to as classes of convenience, are classes of product performance established as a means of convenience [ ] where justified differences specified in Article 3(2) of the CPD have not been identified or where a classification of product performance has not been identified as the means of 4

5 expressing the range of requirement levels of the works. They are intended to make it easier to use the technical specification to relate a product s performance to its intended use. Where necessary, specification writers may establish such classes themselves, keeping the Commission and the Standing Committee informed. They are not classes according to Article 3(2) of the CPD and Article 6(3) does not apply (i.e. Member States are not obliged to refer to technical classes when setting performance levels to be observed on their territory, but may do so if they see fit). In clause 4.11 of GP E for example the following guidance was given for technical specification writers when they established technical classes: - there must be a real and demonstrable, technical or regulatory need for classes - technical classes must be compatible with the existing national provisions of all of the Member States ( ); - the classification must not be used to exclude existing products that are already legally placed on the European market; 3.3 Definitions used in this examination CEN TCs are not using the terms threshold levels, technical classes and pass/fail criteria consistently. In this examination a consistent approach is used which may contradict the terms used in some individual hens. Following principles are used which supplement the definitions in clauses 3.1 and 3.2: 1) Threshold levels A threshold level has been set when the hen contains for an essential characteristic a limiting value (lower or upper limit) restricting a given allowed performance. In practice a minimum (lower) limit presents the lowest allowed performance in relation to a given characteristic of the product, whereas a maximum (upper) level indicates the highest allowed performance. One should not exclude situations where some products fall under the scope of the hen, but their performance does not come up to these threshold levels. In theory, such products could even have been commercialized before the application of the hen in question and would thus already remain on the market: turning to these thresholds would result in the exclusion of such products from the market. An alternative for construing a legal justification for this outcome would be not to treat these products as construction products in the meaning of the CPR, since (at least for given intended uses) they would not appear to fulfil appropriately the technical requirements set for construction works. In fact, one seems to arrive to the same end result when treating such products as construction products which do not come up to the obligatory requirements for placing them on the market for given intended uses. Of course this underlines the necessity to take utmost care when determining such threshold levels, so as to avoid any inappropriate exclusion of products from the market. This goes for threshold levels set both in hens and through the application of Article 3(3) of the CPR. 5

6 2) Limits for dimensional tolerances Part of the threshold levels are setting limits for dimensional tolerances (marked yellow in the Excel sheets). Dimensional tolerances define the limits to the variation of the product dimensions (e.g. the length shall be 100 mm ± 2 mm i.e. the length of all tested products shall be between 98 mm and 102 mm). Dimensional tolerances are treated separately since their role as threshold levels merits further consideration. 3) Regulatory classes According to clause 4.3 in GP E (see clause 3.2). 4) Technical classes Examination also covers classifications which the hens in question are not calling classes. Instead hens are also using other terms e.g. category, type or exposure classes, which actually are technical classes in most of the cases but in some other cases may be considered something else (e.g. intended use categories). In any case they are covered since they are declared in the DoP and in the CE-marking. 5) Pass/fail criteria For pass/fail criteria especially concerning durability aspects, the hen frequently comprises a testing sequence for essential characteristics in question, without any explicitly given limiting value. In some cases, (e.g. for water tightness), one single testing round is considered sufficient. Occasionally the hens contain even requirements for the general construction of the product (e.g. solid fuel heating appliance). In all these situations the products are simply expected to fulfil such a requirement, without allowing the manufacturer to declare a better performance. Of course, this pre-empts the discretion of Member States to regulate in any other manner, too. Pass/fail criteria are partly declared in the DoP and in the CE-marking, but this is not always the case. 6) Other classifications Examination also covers a examples of classifications which in the respective hens have been expected to be declared in the context of the CE-marking (currently also the DoP), but which are not directly related to essential characteristics (i.e. other classifications). Example on this is Category I and II in masonry units hens prepared by TC 125. They are mainly used to inform on the AVCP-system (2+ for Cat I and 4 for Cat II) applicable for the product, as chosen by the manufacturer. Another example is constituted by exposure classes (used in TC 125, TC 177, TC 229 and TC 277 hens), use classes (included in TC 112 and TC 175 hens) and service classes (included in TC 124 hens), which are declared classes for durability but appear mainly to indicate the appropriate intended uses of the products in question. 6

7 4. Threshold levels, technical classes and pass/fail criteria in 443 hens 4.1 CEN TCs involved Examination covers the hens developed by following 64 CEN Technical Committees (TC): CEN/TC 33 - Doors, windows, shutters, building hardware and curtain walling CEN/TC 46 - Oil stoves CEN/TC 50 - Lighting columns and spigots CEN/TC 51 - Cement and building limes CEN/TC 67 - Ceramic tiles CEN/TC 72 - Automatic fire detection systems CEN/TC 88 - Thermal insulating materials and products CEN/TC 99 - Wallcoverings CEN/TC Concrete and related products CEN/TC Wood-based panels CEN/TC Welding CEN/TC Timber structures CEN/TC Masonry CEN/TC Roof covering products for discontinuous laying and products for wall cladding CEN/TC Glass in building CEN/TC Space heating appliances without integral heat sources CEN/TC Aluminium and aluminium alloy CEN/TC Copper and copper alloys CEN/TC Resilient, textile and laminate floor coverings CEN/TC Execution of steel structures and aluminium structures CEN/TC Aggregates CEN/TC Ventilation for buildings CEN/TC Sanitary appliances CEN/TC Waste water engineering CEN/TC Chimneys CEN/TC Structural bearings CEN/TC Round and sawn timber CEN/TC Prefabricated reinforced components of autoclaved aerated concrete or light-weight aggregate concrete with open structure CEN/TC Paving units and kerbs CEN/TC Decentralized gas heating CEN/TC Fasteners CEN/TC Geosynthetics CEN/TC Fixed firefighting systems CEN/TC Fire service equipment CEN/TC Adhesives CEN/TC Cast iron pipes, fittings and their joints CEN/TC Elastomeric seals for joints in pipework and pipelines CEN/TC Surfaces for sports areas CEN/TC Road equipment CEN/TC Road materials CEN/TC Precast concrete products CEN/TC Non-industrial manually operated shut-off valves for gas and particular combinations valves CEN/TC Gypsum and gypsum based products CEN/TC Natural stones CEN/TC Plastics 7

8 CEN/TC Flexible sheets for waterproofing CEN/TC Metallic tanks for the storage of liquids CEN/TC Thermoplastic static tanks CEN/TC Suspended ceilings CEN/TC Residential solid fuel burning appliances CEN/TC Free-standing industrial chimneys CEN/TC Pigments and extenders CEN/TC Floor screeds and in-situ floorings in buildings CEN/TC Bituminous binders CEN/TC Anti-seismic devices CEN/TC Sealants for joints in building construction CEN/TC Project Committee - Stretched ceilings CEN/TC Polymer modified bituminous thick coatings for waterproofing - Definitions/requirements and test methods CEN/TC Equipment for storage tanks and for filling stations ECISS/TC Structural steels other than reinforcements ECISS/TC Steels for heat treatment, alloy steels, free-cutting steels and stainless steels ECISS/TC Steel tubes and iron and steel fittings ECISS/TC Steel castings and forging CENELEC/TC 20 - Electric cables 8

9 4.2 Summary of the results Table 1: Number of threshold levels, technical classes and pass/fail criteria in 443 hens CEN TC Number of hens Number of threshold levels Number of regulatory classes Number of technical classes Number of pass/fail declared Number of pass/fail not declared Number of other classification TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC

10 TC TC TC TC TC TC TC TC TC TC TC ECISS ECISS ECISS ECISS CLC Total

11 Table 2: Number of hens containing threshold levels, technical classes and pass/fail criteria from 443 hens CEN TC Number of hens hens threshold + pass/fail total hens with threshold levels hens with regulatory classes hens with technical classes hens pass/ fail total hens with pass/fail declared hens with pass/fail not declared TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC hens with other classification

12 TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC ECISS ECISS ECISS ECISS CLC Total Total/ % 65 % 54 % 48 % 45 % 28 % 20 % 11 % Observations - Numbers in Tables 1 and 2 include threshold levels, technical classes and pass/fail criteria for each essential characteristic in each hen. The same threshold level, technical class or pass/fail criterion may be included more than once in the numbers, because more than one characteristic or more than one hen may use the same threshold level, technical class or pass/fail criterion, often emanating from the same supporting EN. - Regulatory classes for fire characteristics: - reaction to fire - resistance to fire - external fire performance These three regulatory fire classifications are the same in all hens. Their content is not examined or commented further within this executive summary. Pursuant to respective Commission Decisions on classification without (further) testing, a part of the hens include only part of the regulatory classes. - Total number of thresholds is the greatest i.e in 443 hens meaning 2,3 thresholds as an average in each hen. There are also a lot of technical classes i.e. 738 in 443 hens meaning 1,7 technical classes as an average in each hen. - Threshold levels are partly declared in the DoP and in the CE-marking (sometimes declaring just pass ) and partly not at all. It remains unclear whether some of the hens instruct the 12

13 manufacturers to declare the threshold level only, or whether the manufacturers are allowed to declare a better performance. - Some hens (i.e. TC 33 hens, TC 154 hens, TC 177 hens, TC 277 hen, EN prepared by TC 125 and EN prepared by TC 124) include technical classes, but also allow the manufacturer to declare the performance using levels as alternatives to classes. - In some cases (e.g. TC 154) technical classes include a class declared, allowing manufacturers to declare any levels as classes, and another for No Requirements. In some other cases (e.g. EN prepared by TC 33), No performance determined is presented as an optional class, even when threshold levels are set for some characteristics. - For some essential characteristics, European harmonized test methods do not exist yet. That is why those characteristics are still verified using methods valid in the place of use (this is the phrase to be used by standards writers). This examination does not cover possible national classifications used in Member States for these characteristics. 5. Most frequent use of pass/fail criteria in hens Following CEN TCs are using a lot of pass/fail criteria per hen: 1) CEN TC Anti-seismic devices has prepared 1 hen having 17 pass/fails declared 2) CEN/TC Residential solid fuel burning appliances has prepared 7 hens having 7,57 pass/fails as an average per each hen most of them are not declared 3) CEN/TC Sanitary appliances has prepared 11 hens having 5,18 pass/fails declared as an average per each hen 4) CEN/TC Copper and copper alloys has prepared 1 hen having 5 pass/fails declared 5) CEN/TC Ventilation for buildings has prepared 1 hen having 5 pass/fails declared 6) CEN/TC Non-industrial manually operated shut-off valves for gas and particular combinations valves has prepared 2 hens having 5 pass/fails declared as an average per each hen 7) CEN/TC Road equipment has prepared 11 hens having 3,36 pass/fails declared as an average per each hen 8) CEN/TC Thermoplastic static tanks has prepared 1 hen having 3 pass/fails declared 9) CEN/TC Sealants for joints in building construction has prepared 4 hens having 3 pass/fails as an average per each hen 10) CEN/TC Polymer modified bituminous thick coatings for waterproofing - Definitions/requirements and test methods has prepared 1 hen having 3 pass/fails declared. Also following CEN TCs are using a lot of pass/fail criteria even the average number of pass/fails per hen is not so great as in the above list: 1) CEN TC 33 - Doors, windows, shutters, building hardware and curtain walling: 14 hens having 36 pass/fails 2) CEN TC 72 - Automatic fire detection systems: 17 hens having 48 pass/fails 3) CEN TC Roof covering products for discontinuous laying and products for wall cladding: 20 hens having 51 pass/fails 4) CEN TC Waste water engineering: 26 hens having 71 pass/fails 5) CEN TC Decentralized gas heating: 9 hens having 26 pass/fails not declared 6) CEN TC Fixed firefighting systems: 27 hens having 61 pass/fails 7) CEN TC Flexible sheets for waterproofing: 11 hens having 25 pass/fails declared. More detailed analysis on the frequent use of pass/fail criteria is given in Table 3. Table 3: Number of pass/fails declared and not declared per number of CEN TC hens 13

14 CEN TC Number of hens Number of pass/fail declared per hens Number of pass/fail not declared per hens Total pass/fail per hens TC ,21 2,36 2,57 TC ,00 1,00 1,00 TC ,00 0,00 0,00 TC ,00 0,25 0,25 TC ,00 0,00 1,00 TC ,71 2,12 2,82 TC ,00 0,00 0,00 TC ,00 0,00 0,00 TC ,75 0,44 1,19 TC ,00 0,00 0,00 TC ,00 0,00 0,00 TC ,00 0,13 0,13 TC ,00 0,00 0,00 TC ,35 1,20 2,55 TC ,00 0,00 0,00 TC ,00 0,00 0,00 TC ,00 0,00 5,00 TC ,00 0,00 1,00 TC ,00 0,00 2,00 TC ,00 0,00 0,00 TC ,13 0,25 0,38 TC ,00 0,00 5,00 TC ,18 0,00 5,18 TC ,35 0,38 2,73 TC ,81 0,19 1,00 TC ,50 0,67 1,17 TC ,00 0,00 0,00 TC ,00 0,00 0,00 TC ,00 0,00 0,00 TC ,00 2,89 2,89 TC ,00 0,00 0,00 TC ,00 0,00 1,00 TC ,89 1,44 2,33 TC ,00 2,00 2,00 TC ,25 1,25 1,50 TC ,33 0,00 2,33 TC ,00 0,00 0,00 TC ,00 0,00 0,00 TC ,36 0,00 3,36 TC ,15 0,00 0,15 TC ,00 0,00 0,00 TC ,00 0,00 5,00 TC ,15 0,00 0,15 TC ,00 0,00 0,00 TC ,00 0,00 1,00 TC ,27 0,00 2,27 TC ,00 0,00 2,00 TC ,00 0,00 3,00 TC ,00 0,00 0,00 TC ,71 4,86 7,57 TC ,50 0,00 0,50 TC ,00 0,00 0,00 14

15 TC ,00 0,00 0,00 TC ,00 0,00 0,00 TC ,00 0,00 17,00 TC ,50 1,50 3,00 TC ,00 0,00 2,00 TC ,00 0,00 3,00 TC ,67 0,33 1,00 ECISS ,00 0,00 0,00 ECISS ,00 0,00 0,00 ECISS ,25 0,00 1,25 ECISS ,00 0,00 0,00 CLC ,00 0,00 0,00 Total average 443 0,89 0,54 6. Analysis of the excel sheet The following special features are recognized in 64 CEN Technical Committees analysed: 1) CEN/TC 33 Doors, windows, shutters, building hardware and curtain walling hens include many pass/fail criteria (33) which are not declared. hens for building hardware include a lot of threshold levels (18 26 per hen) which are given for proxy characteristics supplementing the essential characteristics. In curtain walling EN 13830, No performance determined is presented as an optional class, even when threshold levels are set for some characteristics. 2) CEN/TC 46 - Oil stoves Characteristic mechanical resistance has no reference clause in Table ZA.1 of EN 1. 3) CEN/TC 50 - Lighting columns and spigots Methods 1, 2 and 3 are used in EN ) CEN/TC 51 Cement and building limes hens include a lot of threshold levels which are not declared especially for the composition of constituent materials. National methods valid in the place of use are used for durability. 5) CEN/TC 67 Ceramic tiles hen for ceramic tiles (EN 14411) includes a classification ( Grouping of the ceramic tiles ) which forms the base for all requirements set in the hen, including also voluntary characteristics. All these declared values and classes are presented only concerning given Groups. This hen declares for ceramic tiles intended for internal uses pass for durability without testing. 15

16 The other two hens include threshold levels which are declared. 6) CEN/TC 72 - Automatic fire detection systems hens include a lot of thresholds and pass/fails not declared. Some characteristics are declared as pass even they are thresholds. 7) CEN/TC 88 Thermal insulating materials and products hens include a lot of threshold levels and very detailed technical classes. A lot of so called proxy characteristics are used to supplement essential characteristics. National methods valid in the place of use are used for the characteristic continuous glowing combustion. Designation code is used in the CE-marking for declaring essential characteristics. 8) CEN/TC 99 - Wallcoverings One hen having 3 thresholds and reaction to fire regulatory classes. 9) CEN/TC 104 Concrete and related products hens include a lot of threshold levels not declared especially for the composition of constituent materials. National methods valid in the place of use are used for the characteristic durability of fly ash (EN 450-1) and blast furnace slag (EN ) and for the characteristic corrosion behaviour of concrete injection (EN ). Common requirements for admixtures of concrete, mortar and grout are given in EN referred to in hens for these products (EN 934-2, -3, -4, -5). 10) CEN/TC 112 Wood-based panels One umbrella hen (EN 13986) is covering different wood-based panels. It does not contain any threshold levels. Different technical classes for the same characteristics have been included in material standards referred to in EN These different material classes are not counted within the statistics compiled. Material standards are covering plywood, solid wood panel, oriented strand board, particleboard, cement-bonded particleboard, hardboard, medium board, soft board, MDF and LVL as wood based panels. Technical classes have been set for the release of formaldehyde and for the content of pentachlorophenol. Use classes have been set for durability of plywood, solid wood panels and LVL. 16

17 11) CEN/TC Welding One hen having technical classes given in referred standards for welding consumable. 12) CEN/TC 124 Timber structures Most of the strength characteristics (i.e. compressive strength, bending strength, shear strength, etc.) are covered by the same technical strength classes. For natural durability the hens use natural durability classes 1, 2, 3, 4, 5 (EN table 2) Technical classes have been set in hens for glulam (EN 14080) and for LVL (EN 14374) for release of dangerous substances concerning formaldehyde emission. hen for glulam (EN 14080) allows the manufacturer to declare the performance also using levels as alternatives to strength classes. For durability of treated wood the hen for wood poles (EN 14229) requires use class 4. hen for connectors and fasteners (EN and EN 14592) service classes have been set for durability. 13) CEN/TC 125 Masonry Durability of freeze-thaw is determined according to the methods valid in the place of use for clay masonry units (EN 771-1), aggregate concrete masonry units (EN 771-3), AAC masonry units (EN 771-4), for manufactured stone masonry units (EN 771-5) and for rendering mortars except one coat (EN 998-1). hen for clay masonry units (EN 771-1) includes the class any value for dimensional tolerances and for density tolerances. Following other classifications is declared in the context of the DoP and the CE-marking: - Category I or II for the AVCP-system used coming from the mandate for masonry units - Determination model P1, P2, P3 or P4 for the characteristic thermal resistance (conductivity) for masonry, which explains the method used when determining the thermal resistance, i.e. is the declared value based on testing of cubes, units or test walls. - Material/coating reference L1 L21 determined for ties, tension traps, hangers, brackets, lintels and bed joint reinforcement used in masonry. For clay masonry HD-units (EN 771-1) exposure classes have been set for durability. 14) CEN/TC 128 Roof covering products for discontinuous laying and products for wall cladding hens include many threshold levels and regulatory classes. For some characteristics in the hens it is allowed to declare pass using visual inspection. hen for clay roofing tiles (EN 1304) refers for the characteristic durability to EN which includes 4 national alternative test methods. 17

18 15) CEN/TC Glass in building hens include regulatory classes and technical classes. Current method in the country is allowed if pren is not applicable in almost all hens. 16) CEN/TC Space heating appliances without integral heat sources Surface temperature is determined indirectly based on inlet water temperature. 17) CEN/TC Aluminium and aluminium alloy In addition of the declaration of essential characteristics description of the product is given in accordance the aluminium grade. 18) CEN/TC Copper and copper alloys One hen having 4 thresholds and regulatory classes for reaction to fire. Some characteristics are declared as pass even they are thresholds. Resistance to high temperature (for heating networks) is claimed to be a threshold even it is not. 19) CEN/TC Resilient, textile and laminate floor coverings One hen having 2 thresholds, regulatory classes for reaction to fire and 2 pass fails declared. 20) CEN/TC Execution of steel structures and aluminium structures Scope of EN A1 is covering different kind of structural steel and aluminium products and kits. scope is very unclear. Execution classes declared for 2 essential characteristics. 21) CEN/TC 154 Aggregates hens include a lot of very detailed technical classes. The classification also includes class declared and class No Requirements. A lot of so called proxy characteristics are used to supplement essential characteristics. National methods valid in the place of use are used for durability against alkali-silica reactivity in hen for concrete aggregate (EN A1) and in hen for mortar aggregate less than 4 mm (EN 13239). 22) CEN/TC Ventilation for buildings Different regulatory resistance to fire classes. 18

19 Some characteristics are declared as pass even they are thresholds. 23) CEN/TC Sanitary appliances A lot of pass/fails not declared. 24) CEN/TC Waste water engineering A lot of thresholds and pass/fails declared. Some characteristics are declared as pass even they are thresholds. Loadbearing capacity/structural behaviour is declared based on national methods in EN A1 and EN A1. In EN 1916 and EN 1917 any complementary national characteristic may be allowed to be required in addition to the essential characteristics listed in Table ZA.1. See Foreword of these hens. 25) CEN/TC 166 Chimneys The highest temperature class of the chimney hens is T600, which means that the chimney is tested with the 700 C flue gas temperature and if having soot fire resistance class G also with 0,5 hour 1000 C flue gas temperature. This cannot be considered an upper threshold level since it does not indicate a limit for highest performance for any chimney products, albeit restricts the manufacturer from declaring a higher performance than T600. National methods valid in the place of use are used for the essential characteristic resistance to fire external to external in hen for concrete flue blocks (EN 1858+A1), in hen for concrete outer wall elements (EN 12446) and in hen for flue and air supply ducts for room sealed appliances with metal chimney (EN ). National methods valid in the place of use are used for fire resistance in hens for system chimneys with clay/ceramic flue liners with soot fire resistance (EN ), under wet conditions (EN ) and for air flue system chimneys (EN ). Designation code is used in the CE-marking for declaring part of the essential characteristics. 26) CEN/TC Structural bearings A lot of references to the supporting standard EN ) CEN/TC 175 Round and sawn timber hens (EN A1 and EN 14915) do not include any threshold levels. Technical classes are given for release of dangerous substances and durability. Use classes have been set for durability. 19

20 28) CEN/TC 177 Prefabricated reinforced components of autoclaved aerated concrete or lightweight aggregate concrete with open structure hens cover different kind of LAC and AAC components. hen allows the manufacturer to declare levels as alternatives to compressive strength and density classes. Exposure classes have been set for durability. hens include structural design annexes comparable with the Eurocodes. In EN three different corrosion resistance test methods are given with one reference method. 29) CEN/TC 178 Paving units and kerbs National methods valid in the place of use are used for the characteristics skid resistance, freeze-thaw resistance with de-icing salt and polishing in use in hens for natural stone paving products (EN 1341, EN 1342 and EN 1343). 30) CEN/TC Decentralized gas heating Table ZB is for the CPR. Seems to include mistakes. E.g. no reference is given to any clause for resistance to fire in EN 778. Tables ZB.1 of different hens inform that two essential characteristics are not applicable to the products in accordance with these hens. Some characteristics are declared as pass even they are thresholds. 31) CEN/TC 185 Fasteners Product grade (e.g. C/B/A) covers tolerances on dimensions and shape for bolts, nuts and washers in EN ) CEN/TC 189 Geosynthetics One pass/fails declared in all hens. 33) CEN/TC Fixed firefighting systems A lot of pass/fails declared and not declared. Also thresholds are declared as pass. 34) CEN/TC Fire service equipment A number of thresholds. References to national requirements in EN

21 35) CEN/TC 193 Adhesives Pass/fails not declared in hens. Some characteristics are declared as pass even they are thresholds. 36) CEN/TC Cast iron pipes, fittings and their joints Thresholds and pass/fails declared in hens. Some characteristics are declared as pass even they are thresholds. 37) CEN/TC Elastomeric seals for joints in pipework and pipelines A number of thresholds and hardness categories as other classification. 38) CEN/TC Surfaces for sports areas A number of thresholds in one hen. 39) CEN/TC Road equipment A lot of thresholds and technical classes. Also pass/fails declared. Reference to ETA. Safety factors for loads shall be in accordance with Table 6. Table 6 Partial safety factors for Classes PAF 1 and PAF 2 in EN ) CEN/TC Road materials A lot of thresholds and technical classes. hens include different product trypes. For binder content Table ZA.1 of EN does not make reference to any clause. Durability is declared as pass, but reference is made to national provisions for protective coating in EN ) CEN/TC 229 Precast concrete products Common rules for precast concrete products are given in EN referred to in hens for these products. Exposure classes are used in most hens when declaring durability. National methods valid in the place of use are used for the characteristics durability (freezethaw resistance) in hen for concrete shuttering blocks (EN 15435). 42) CEN/TC Non-industrial manually operated shut-off valves for gas and particular combinations valves A lot of thresholds in hens. 21

22 43) CEN/TC 241 Gypsum and gypsum based products Characteristics impact resistance, direct airborne sound insulation and sound absorption are considered as system characteristics which cannot be declared in the context of the DoP or the CE-marking of the product. 44) CEN/TC 246 Natural stones Few regulatory classes and technical classes are used in hens. 45) CEN/TC Plastics A number of technical classes in 2 hens. 46) CEN/TC 254 Flexible sheets for waterproofing Few regulatory classes and technical classes are used in hens. Instead they contain more pass/fail criteria which are declared in the DoP and in the CE-marking. For some essential characteristics (e.g. for water tightness) pass/fail criteria allows to choose from 2 alternative test methods. In Table ZA.1 of some hens it is indicated that water tightness has a threshold value which actually is a pass/fail criterion. In Table ZA.1 of part of the hens the characteristic water tightness is explained to be a threshold value although pass/fail declared criterion is in question. 47) CEN/TC Metallic tanks for the storage of liquids Few thresholds, regulatory classes, technical classes and pass/fails declared in 1 hen. 48) CEN/TC Thermoplastic static tanks A lot of thresholds in one hen having different product types. Some characteristics are declared as pass even they are thresholds. 49) CEN/TC 277 Suspended ceilings hen includes technical class any value for the characteristics flexural tensile strength and loadbearing capacity. Technical classes have been set in the hen for release of dangerous substances concerning formaldehyde emissions. Tables ZA.1.1 and ZA.1.4 in the hen indicate that classes E1 and E2 for release of formaldehyde are mandated regulatory classes, which is not correct. Exposure classes have been set in the hen for durability. 50) CEN/TC 295 Residential solid fuel burning appliances 22

23 hens include a lot of threshold levels and pass/fail criteria which are not declared in the DoP and in the CE-marking. Many of pass/fail criteria are giving requirements for the general construction of the appliance. For different characteristics same requirement clauses in the hens are referred to. 51) CEN/TC Free-standing industrial chimneys Soot fire resistance classes based on EN For gas tightness in EN it is explained that the state of the art has shown, that gas tightness may not be required. 52) CEN/TC Pigments and extenders One hen including technical classes. Some characteristics are declared as pass even they are thresholds. 53) CEN/TC 303 Floor screeds and in-situ floorings in buildings Both two hens include threshold levels for strength properties and durability. hen for screed material (EN 13813) includes very detailed technical classes. For some essential characteristics alternative test methods are given. 54) CEN/TC Bituminous binders Five hens including a lot of technical classes. 55) CEN/TC Anti-seismic devices One hen including different product types. A lot of pass/fails declared. 56) CEN/TC 349 Sealants for joints in building construction Four hens including threshold levels, a lot of technical classes and some pass/fail criteria. Technical classes are constituted by combining the performance of the product in relation to essential characteristics. Moreover, some threshold levels are presented in this context. However, this classification is not contained to be declared in the context of the CE-marking. 57) CEN/TC Project Committee - Stretched ceilings Four hens including thresholds and technical classes. 58) CEN/TC Polymer modified bituminous thick coatings for waterproofing - Definitions/requirements and test methods One hen with 2 thresholds and 2 pass/fails declared. 23

24 59) CEN/TC Equipment for storage tanks and for filling stations Three hen including few thresholds, regulatory classes, technical classes and pass/fails. Classes of leak detection systems I, II, III, IV, IV A, IV B, V to be given in EN Overfill prevention device Type A or B to be given in EN ) ECISS/TC Structural steels other than reinforcements Three hens including a lot of thresholds. 61) ECISS/TC Steels for heat treatment, alloy steels, free-cutting steels and stainless steels Three hens including a lot of thresholds. 62) ECISS/TC Steel tubes and iron and steel fittings Four hens including few thresholds, regulatory classes and pass/fails declared. 63) ECISS/TC Steel castings and forging A lot of thresholds in one hen. 64) CENELEC/TC 20 - Electric cables One hen having just one characteristic reaction to fire with regulatory classes. 24