Products Regulation 7 th June2017 Dr. Jeremy Hodge Chief Executive - - PowerPoint PPT Presentation

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Products Regulation 7 th June2017 Dr. Jeremy Hodge Chief Executive - - PowerPoint PPT Presentation

Reaction to Fire Requirements for Cables under the Construction Products Regulation 7 th June2017 Dr. Jeremy Hodge Chief Executive Summary New fire requirements applied to all permanently installed cables Cables will be CE marked to


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Reaction to Fire Requirements for Cables under the Construction Products Regulation

  • Dr. Jeremy Hodge

Chief Executive 7th June2017

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Summary

  • New fire requirements applied to all permanently

installed cables

  • Cables will be CE marked to the CPR
  • Labelled, and supported by Declaration of Performance
  • New fire performance information will be available for

many cables

  • Requirements apply to those supplying cables, not to

users

  • Complex and potentially expensive testing and

classification process for manufacturers and suppliers

  • Common approach across Europe
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The Construction Products Regulation (CPR)

  • EU Regulation 305/2011 - harmonised conditions for the

marketing of construction products Applicable for all building products, including cables, made available or offered to the market place for permanent installation in buildings and civil engineering projects

  • Domestic dwellings
  • Industrial buildings – Factories, warehousing
  • Offices
  • Shops and out of town outlets
  • Hospitals and care homes
  • Entertainment and sports facilities/stadia
  • Common approach for testing and certification of all

construction products

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Scope of CPR for Cables – EN 50575+A1

New requirement for cables across EU and applicable to all power, control and communication cables Fire performance – for Reaction to Fire only at this stage

  • Cables with declared ‘Fire resistance’ / circuit integrity are

not eligible for classification under the Reaction to Fire CPR

  • Provides a consistent process to quantify Reaction to Fire

characteristics:

  • heat release
  • flame spread
  • smoke and acid gas emission
  • UK – only affects selling of cables, not use
  • Allows end-users to make better informed cable choices
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SLIDE 5

Launch of CPR for Cables

  • Date of Applicability was 10 June 2016
  • Declaration of Performance and CE marking become optional
  • Cables manufactured before this date could not be CE marked
  • End of co-existence period is 1 July 2017
  • Declaration of Performance and CE marking become mandatory
  • CE marked cables will be available to the market before this date and

should be stocked

  • Limited time to obtain CE marking - shortage of testing capacity
  • Implementation will vary by Member State
  • National standards and requirements will be replaced by CPR
  • No UK regulatory requirements for particular classes but cables shall be

CE marked.

  • Likely to be driven by specifiers and insurers
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Manufacturer / Supplier Responsibilities

  • Decide upon cables/ranges for evaluation and anticipated class
  • Commission Notified Body work as appropriate

CE marking and labeling Publication of Declaration of Performance and retention of data for 10 years

  • Technical documentation

Factory production control

  • Factory sample testing including annual fire testing

Traceability requirements Safety / installation instructions in local language of use

  • Records of complaints and recalls – retention etc.

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Distributor/Importer Responsibilities

Only compliant product to be placed on the market

  • Ensure AVCP undertaken, technical documentation and

Declaration of Performance have been prepared by the manufacturer Check product is CE marked Recall product where relevant, record of complaints Safety info / contact details of importer supplied with product Local language of use Storage and transportation without degradation Co-operate with national authorities

  • Importers shall undertake routine testing

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Supply Chain

‘Making available on the market’ means offer or supply No get-out for OEM cables supplier to user Economic operators (manufacturers, authorised representatives, importers, distributors) are obliged to tell market surveillance authorities:

Where they have obtained supply of product from To whom they have supplied product

Applies for 10 year period No distinction between distributor and wholesaler

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End-user’s Responsibilities

No formal responsibilities under CPR Shall comply with National Regulation and/or local codes Comply with all Health & Safety requirements

  • Have realistic expectation for cable performance

Purchase CE marked cables with traceable provenance Co-operate with national authorities

  • Sample testing

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Manufacturer Duties of Importers / Distributors

If using own trade name or trademark on the cable then the Importer/Distributor assumes the responsibilities of the manufacturer Modifications to product will require the distributor to assume manufacturer responsibilities, for example:

Overjacketing / oversheathing / overbraiding Additional marking / metre marking Repackaging – reeling, coiling, cut-to-length – information flow still needed by economic operator

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SLIDE 11

Simplified Procedures

A ‘manufacturer’ may use the results of obtained by another manufacturer (OEM) for their Declaration providing:

The ‘manufacturer’ obtains permission from the OEM to use the data The OEM remains responsible for the accuracy, reliability and stability of the results

OEM data can be used to generate Distributor Classification Reports to support Distributor DoP

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Outline route to CE marking for CPR

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Notified TL tests samples & issues classification report

3 (D & E) 1+ (A, B1, B2, C)

Manufacturer creates DoP & maintains for 10yr. Applies CE mark Notified CB issues Cert. of Constancy of Performance Mfr. chooses range for compliance AVCP system

  • Mfr. selects

samples Mfr. Approaches Notified CB. Notified CB selects samples & undertakes FPC

  • Mfr. Chooses

intended class. Mfr. approaches Notified TL Notified TL tests samples & issues classification report

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Test Requirements

X = required; # = optional

Class EN ISO 1716 EN 50399 EN 60332-1-2 EN 61034-2 EN 60754-2 Aca X B1ca X X # # B2ca X X # # Cca X X # # Dca X X # # Eca X Fca X

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CPR Test Methods

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EN 50399 Test

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EN 60332-1-2 Single Cable Vertical Flame Propagation Test

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AVCP System Requirements

Responsibility AVCP System 1+ AVCP System 3 AVCP System 4 Aca, B1ca, B2ca, Cca Dca, Eca Fca

Manufacturer Factory production control Routine production testing of samples Annual fire testing Factory production control Routine production testing of samples Annual fire testing Factory production control Type testing Notified Body Notified Certification Body tasks Issuance of Certificate of Constancy

  • f Performance

Determination of type test sample. Sample selection from stock Initial inspection of plant and factory production control Commissioning type testing Continuing surveillance, assessment and evaluation of factory production control (2x per year) Audit-testing of samples (once every 3 years) Notified Test Laboratory task Determines product-type on the basis of type testing etc. Sampling undertaken by the manufacturer

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EN 13501-6 Classification Table

Class Test Method(s) Classification criteria Classification criteria Aca

EN ISO 1716 PCS ≤ 2,0 MJ/kg (1)

B1ca

EN 50399 (30 kW flame source) and FS ≤ 1.75 m and THR1200s ≤ 10 MJ and Peak HRR ≤ 20 kW and FIGRA ≤ 120 Ws-1 Smoke production (2, 5) and Flaming droplets/particles (3) and Acidity (pH and conductivity) (4) EN 60332-1-2 H ≤ 425 mm

B2ca

EN 50399 (20.5 kW flame source) and FS ≤ 1.5 m and THR1200s ≤ 15 MJ and Peak HRR ≤ 30 kW and FIGRA ≤ 150 Ws-1 Smoke production (2, 6) and Flaming droplets/particles (3) and Acidity (pH and conductivity) (4) EN 60332-1-2 H ≤ 425 mm

Cca

EN 50399 (20.5 kW flame source) and FS ≤ 2.0 m and THR1200s ≤ 30 MJ and Peak HRR ≤ 60 kW and FIGRA ≤ 300 Ws-1 Smoke production (2, 6) and Flaming droplets/particles (3) and Acidity (pH and conductivity) (4) EN 60332-1-2 H ≤ 425 mm

Dca

EN 50399 (20.5 kW flame source) and THR1200s ≤ 70 MJ and Peak HRR ≤ 400 kW and FIGRA ≤ 1300 Ws-1 Smoke production (2, 6) and Flaming droplets/particles (3) and Acidity (pH and conductivity) (4) EN 60332-1-2 H ≤ 425 mm

Eca

EN 60332-1-2 H ≤ 425 mm

Fca

EN 60332-1-2 H ˃ 425 mm

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SLIDE 19

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EN 13501-6 Classification Table Notes

(1) For the product as a whole, excluding metallic materials, and for any external component (i.e. sheath)

  • f the product.

(2) s1 = TSP1200 ≤ 50 m2 and Peak SPR ≤ 0.25 m2/s s1a = s1 and transmittance in accordance with EN 61034-2 ≥ 80% s1b = s1 and transmittance in accordance with EN 61034-2 ≥ 60% < 80% s2 = TSP1200 ≤ 400 m2 and Peak SPR ≤ 1.5 m2/s s3 = not s1 or s2 (3) d0 = No flaming droplets/particles within 1200 s; d1 = No flaming droplets/particles persisting longer than 10 s within 1200 s; d2 = not d0 or d1. (4) EN 60754-2: a1 = conductivity < 2.5 μS/mm and pH > 4.3; a2 = conductivity < 10 μS/mm and pH > 4.3; a3 = not a1 or a2. (5) The smoke class declared for class B1ca cables must originate from the EN 50399 test (30 kW flame source). (6) The smoke class declared for class B2ca, Cca, Dca cables must originate from the EN 50399 test (20.5 kW flame source).

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Class Predictions

  • Class Aca – Very few cables with this classification (glass

tape/mineral insulated)

  • Class B1ca – Highest performing cables only (limited requirement)
  • Class B2ca – Commonly used class for many LSHF cables
  • Class Cca – Commonly used class for many LSHF cables
  • Class Dca – Lower performing LSHF cables/higher performing PVC

– System 3 so less costly

  • Class Eca – Many common PVC and other cables which have no

additional claims of fire or smoke performance - Entry-level test

  • Class Fca – Cables not usable in many applications
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Application of CPR

  • Usage requirements by will vary by European country
  • National standards and requirements will be replaced by CPR
  • No UK regulatory requirements for particular classes. Likely to be driven by

specifiers and insurers

Transport for London S1085 – Fire safety performance of materials

Stations and tunnel infrastructure - Cca-s1a,d0,a3

Commission Regulation 1303/2014 – Safety of railways in tunnels

Tunnels >1km – B2ca-s1a,a1

  • Risk based approach to performance
  • High risk (lots of people or impaired means of escape for example hospitals,

concert halls, high rise buildings) = Class B2ca

  • Medium risk (lower number of people or large open areas for example

industrial or low rise buildings) = Class Cca/Dca

  • Low risk (for example domestic dwellings) = Eca

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Observations

  • Manufacturers are being over optimistic of cable’s performance
  • Bundled cable arrays performing less well than single spaced

arrays

  • Performance within a defined family can vary widely
  • Significant increase in Class Eca testing as 1st July 2017

approaches

  • Significant lack of awareness and understanding over regulation,

end user expectation and cable performance available

  • Applicability of ‘permanent installation’ for utility supply cables?
  • Penetration length into buildings and structures
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Frequently asked questions

  • Will there be an extention to the Period of Co-existence
  • What cables are included in the CPR
  • What is a ‘building’
  • What is meant by ‘permanently installed’
  • Indoor/outdoor cables
  • What is meant by placing ‘on the market’ and at what point does it become ‘on

the market’

  • Role of Authorised Representatives
  • Sale of old stock
  • Retrospective CE marking
  • Distributors can declare different performance from OEM so long as the type

testing/Classification Report supports this

  • Dual sourcing
  • Do labels have to be applied to every cut length
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BASEC’s Role

  • Independent cable certification body / test laboratory
  • Operational for over 40 years
  • UKAS Accredited specialist cable fire laboratory
  • BASEC is a Notified Body (No. 2661) for:
  • Product Certification Body (AVCP System 1+)
  • Factory Production Control Certification Body (AVCP System 1+)
  • Testing Laboratory (AVCP System 3)
  • Active member of Group of Notified Bodies committee SH02

WG10 – Cables

  • Provider of CPR training
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Contact details

BASEC Presley House, Presley Way Milton Keynes MK8 0ES, UK Tel: +44-(0)1908-267300 Fax: +44-(0)1908-267255 Email: mail@basec.org.uk / technical@basec.org.uk Web: www.basec.org.uk

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