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<Contruction Products: EPF considering options on EU approach to assessing the fire performance of facades

Regulation (EU) N° 305/2011 (the Construction Products Regulation, 'CPR') enables the free movement of construction products by providing the framework for the harmonisation of national standards and CE marking. Under this framework, 450 harmonised standards have so far been agreed. But the CPR does not aim to harmonise national building codes - each member state is free to set its own requirements on the performance of building works and, therefore, of construction products when in use, which is still a major cost factor for pan-European construction products manufacturers.

EPF's historic view has been that the owner/investor pays for a building, not for its building materials, and so should not take part in this highly technical standardisation work. Let's see if that mantra applies to this new situation:

The member states themselves, in their Standing Committee of Construction (SCC) asked the Commission to provide national regulators with a means to regulate the fire performance of facade systems based on a European approach. Is this something EPF can be equally distant from given owner/landlord liability when fires occur, something which is much in the news these days following recent high mortality events in countries where fire performance was inadequate? Also, as increasing regulation of fire performance will surely impact building owners' bottom line much more than the cost of one or other individual construction product, is there not a vested interest for owners in leveraging EU harmonisation to get the safest and cheapest solutions?

You would think that all parties would share that vested interest, but a study undertaken for the Commission and published last week reveals in its Appendix I ('I' as in H, I, J) that the main concern of some member states is to change their own systems as little as possible, making any common solution heavier, with multiple testing, and more costly. The study offers two options:

  • an approach preferred by the European Commission called "proposed test method" which basically consists of adopting a British test (BS8414) and a German test (DIN 4102 part 20) (Appendix E)
  • and an alternative test method developed during the project (Appendix G)*
    * "However, the proposed test method [the one above that the Commission prefers] will lead to a considerable number of tests for one product to be sold throughout Europe because of the optional character of additional requirements for certain Member States, especially when the product is to be used in Member States who have additional requirements not covered by DIN 4102-20 or BS 8414. That was the reason to propose an alternative test method (Appendix G) which combines as many options as possible in one test method." Study, p. 11, par. 3

Fire Safe Europe, a lobby of diverse interests including firefighters and NGOs with an interest in fire prevention, produced a position paper that favours the alternative test method because, in their view:

  • the UK/German method will create market distortion favouring British and German manufacturers;
  • keeping both methods and consequently a complex classification system will increase costs for new approvals and make it difficult for users to understand;
  • the UK/German approach won't guarantee an adequate level of fire safety;
  • under the alternative approach, only one test will be needed for a specific system to achieve a clasification that can be used across the Union.

In Appendix I, Eurima, the insulation manufacturers' lobby, sees this as an opportunity to introduce a single high quality test method that will reflect the real safety risks related to facades, including those seen during real fire incidents. The Danish, Finnish and Swedish governments, Finnish Industries and the Swedish National Board of Housing, Building and Planning all seem to be pushing in the same single test direction.

Full report under epf18-62 of 01.10.2018