Construction Products - Assessment of release of dangerous substances - Use of harmonised horizontal assessment methods
|Publication Date:||1 October 2013|
|ICS Code (Construction materials in general):||91.100.01|
The Construction Products Directive 89/106/EEC (CPD) contained six essential requirements for works that gave rise to a number of 'essential characteristics' for products that had to be covered by European Technical Specifications (ETS) for construction products (harmonised European Standards (CEN) and European Technical Approvals (EOTA)). As derogation from this rule, essential requirement No 3 "Hygiene, health and the environment" (ER3) was dealt with via a convention in the ETS which did not take it directly into account, mainly due to the absence of European harmonised test methods. In order to solve this problem, the European Commission gave CEN, the European Committee for Standardization, a mandate (M/366) in 2005 to develop European harmonised test methods for the assessment of release or emission of dangerous substances from construction products.
From July 2013 the CPD has been replaced by the Construction Products Regulation (Regulation (EU) No 305/2011, CPR). The fundamental principles of the CPR are the same as for the CPD. The CPR now refers to basic requirements for construction works (BRCWs) instead of ERs, but the same six functional requirements as for the CPD are still there, supplemented by a seventh, the "Sustainable use of natural resources", and BRCW 3 is extended to the construction and demolition phase. However, it is expected that the work in CEN/TC 351 according to mandate M/366 will be carried out under the terms and conditions of the CPD with a focus on release and emission in the use phase of construction works.
Mandate M/366 requires that CEN develops horizontal test methods that, as far as possible, are based on existing test methods. This means that European harmonised test methods will not be developed for each construction product separately. The methods should be preferably applicable to all constructions products as defined in the CPR as far as they are covered by BRCW 3. The intention is to avoid the unnecessary and onerous development of product specific test standards for a multitude of construction products and to minimise the amount of costly testing. The horizontal approach is described in detail in CEN/TR 16098.
Furthermore, according to the guidance of the EC (Decision 192, CEN/TC 351 meeting in Berlin on 2013-02-11/12), CEN/TC 351 is asked to provide horizontal methods reflecting the state of the art. Different test methods or testing options can be considered by CEN/TC 351 when technically justified because of different conditions of use, different end uses or product characteristics, but not because of differences in regulations.
In order to apply the horizontal test methods correctly to individual construction products, some product specific additions remain necessary. For example, aspects such as pre-treatment and preconditioning of test specimens cannot be completely specified horizontally but require product specific additions. The necessary product specific additions to the horizontal test standards must be included in the harmonised product standards for the implementation of BRCW 3.
The European Commission has recently amended ten and is currently amending some further existing construction product mandates issued to CEN to include detailed requirements for BRCW 3. The updated mandates include the requirements for each harmonised product standard. For each hEN or mandated prEN, the relevant release/emission scenarios and the relevant regulated dangerous substances1) are listed. The CEN product TCs are obliged to amend their product standards using the mandate amendments as a checklist for including BRCW 3-related requirements.
This Technical Report (TR4 of mandate M/366) gives instructions on which aspects related to the horizontal test methods are important to address when amending product standards. The report is intended as guidance for CEN product TCs for the revision of product standards in regard to possibilities to avoid testing through the use of e.g. descriptive elements like positive or negative lists in product standards are not covered by this report. With respect to this issue, the product TCs may consult the guidance given by the European Commission including the amended product mandates.
The examples described in Annex A and Annex B show how the guidance given in this Technical Report can be adopted in a product standard. They illustrate a possible way to implement the horizontal test standards of CEN/TC 351 into product standards by product TCs. The examples are inspired by work in progress on existing harmonised product standards. Their intention is to provide generic, non-product specific assistance; they are not the only possible solution confirmed by the powers that be.
1) The term regulated dangerous substances refers to dangerous substances for which performance criteria have been defined in notified regulations in the EEA.