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Put To The Test

15 January 2009

The European Construction Products Directive which brings CE standardization to construction products across Europe has implications for fire alarms systems from 1 August 2009 as Keith Minster explains.

THERE CONTINUES TO BE A CONSIDERABLE LACK OF awareness throughout the fire safety equipment supply chain around the application of the European Construction Products Directive (CPD) and what is required for compliance. This has not been helped by the fact that the UK government, along with Ireland, has taken a somewhat different view from other EU member states to certain aspects of its implementation.

The CPD, which came into effect in 2003, is described by the British Standards Institution (BSI) as one of the ‘New Approach’ directives that aims to create a single European market by removing the technical barriers to trade between member states through the use of harmonised standards and approvals.

The Directive ‘applies to all construction products that are produced for, or incorporated in, building and civil engineering construction works. It harmonises all construction products subject to regulatory controls for CE marking purposes,’ and includes all fire alarm products fitted to buildings. Parts of the fire alarm system such as smoke detectors (EN54 Pts 7 and 12), heat detectors (EN 54 Pt 5) and sounders (EN54 Pt 3) have already completed the transition process and standards have become harmonised – and thus commonly regulated - throughout the EU. This means that:

● The CPD does apply to all fire alarm products

● The standard which applies to fire control panels (EN54 Pt 2) and power supply (EN54 Pt 4) comes into effect on 1 August 2009

● When the standard becomes harmonised on that date, the relevant fire safety products must have had independent third party testing and approval

Fire alarm control panels and power supply equipment (EN54 Pts 2 and 4 respectively), are currently completing the transition phase, when both the BS standard and existing local standards may both apply. However, the present period of co-existence is due to come to an end in August 2009, when all products will have to conform to the new standard.

Independent testing
For those businesses affected by parallel regulations such as the Electromagnetic Compatibility Directive (EMC) or the Low Voltage Directive (LVD), there is an important difference in the way the CPD works. In the case of the EMC and LVD, though compliance with the standard is similarly obligatory, the method by which this is achieved depends on the size of the individual manufacturer and their impact on the market.

In the case of large players, this will continue to require independent testing to prove compliance. For smaller competitors with only a marginal or niche impact, by contrast, the objective is to ensure that approval is not disproportionately onerous or costly: as a result, the concept of due diligence puts a lesser burden on compliance. Here, evidence of adherence to current best practice thinking - within a Technical Construction File which describes how the product was approved (through self-testing, for example) - may be perfectly adequate.

In the case of the CPD, however, regulation places an obligation on all manufacturers to seek independent third-party testing and approval for all products, in ensuring they meet the relevant European standard. The reason for the unusual requirement of compulsory testing in this case is that construction products are directly linked to issues of life safety, where failure could put the lives of many people at risk. As a result, the regulatory authorities have taken the view that the risk is too high to rely on the normal rules of free trade, competition and the law courts to determine successful products.

The European regulatory landscape is constantly evolving and the move to implementing EN54 Pts 2 and 4 has been further complicated by more recent amendments and detailed ‘options with requirements’ – classifications within each standard which may or may not be adopted by individual member states.

This means that, despite the overall move towards harmonisation, a manufacturer will still need to identify the relevant options with requirements for those EU countries in which they wish to distribute fire alarm products. And in response modify the product specification where necessary to comply in each case.

For fire alarm panels (EN54 Pt 2), many of the modifications required to meet the new standard are essentially documentary in nature. However, the changes necessary in the case of power supply equipment (EN54 Pt 4) are more significant, with new functional requirements causing manufacturers to modify hardware components of their products.

As in the case of other standards, products are becoming more reliable and robust in response to a general tightening up of security and safety provisions within fire alarm equipment regulation. Of key concern in the area of power supply equipment, for example, has been that of back-up power supplies for fire alarm panels. One characteristic of lead acid batteries is that they deteriorate over time, something which would typically be dealt with by routine maintenance and replacement. Under previous regulations, which specifically addressed issues around measuring voltage, any deterioration might not be picked up, potentially resulting in insufficient energy in the back-up battery if called on in an emergency.

In response, under the latest regulation periodic measurement of the internal resistance of the battery will also be required, in order to test for physical deterioration. Further, a number of manufacturers have developed monitoring functionality within their products which provides early alerts of any significant battery deterioration.

There has been an almost complete lack of awareness or understanding of theses changes, their timing and their impact in the market, in part caused by the UK and Irish governments interpreting the CPD somewhat differently from other member states.

For example, in the case of CE marking – a product’s ‘technical passport’ enabling entry into signatory European states – it is not a requirement in the UK and Ireland to CE mark products as confirmation of CPD compliance. As a result, some manufacturers have taken this interpretation further, to mean that independent third party testing is not obligatory. And with the transition dates already having been extended by two years to 2009 – in order to align fire alarm panels with power supply equipment - the resulting picture is far from clear or satisfactory.

The issue of CE marking within the UK market might be perceived as of limited concern, as a local, technical issue. Much more important, however, is the fact that the current period of coexistence will end on 1 August 2009 – with no further extension anticipated. This means that all manufacturers must have completed third party testing on all fire alarm panel and power supply equipment products by that date. This will present a problem for some manufacturers, as testing capacity is severely restricted. Put simply, unless they already have development work well underway and have applied to have their products tested, it is unlikely that they will secure the necessary laboratory time - and so they will fail to be compliant by 1 August 2009.

So, in light of this, what should an end-user be asking of their fire safety equipment provider? In short, they should be seeking an assurance that there are plans in place to ensure certification by 1 August 2009, so that the core elements of their fire safety solution – the fire safety panel and power supply equipment - are fully compliant with the CPD.

This should take the form of a declaration of conformity from the manufacturer backed up by suitably-qualified third party approvals from organisations such as LPCB. These are not simply technicalities, but reflect a growing regulatory shift toward stronger safety provision supported by independent verification and testing, moves backed by both the manufacturers’ main trade body and the Chief Fire Officers Association.

● Keith Minster (left) is sales manager UK & Ireland, Morley-IAS by Honeywell

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