Safety Flooring and Matting - Current European requirements and new regulations to be implemented in 2013 [Sep 2010]
Published: 01st Sep 2010
Jackie Glasspool, of SATRA Technology Centre, looks at current and forthcoming European legislation and standards associated with safety flooring and matting.
Construction Products Directive (CPD)
Flooring materials are considered as permanent fixtures within a building and as such are one of the many products included within the scope of the Construction Products Directive (CPD) (89/106/EEC). Along with other European directives the CPD is intended to provide a mechanism that allows free movement of goods within the member states of the European Economic Area (EEA), and includes ‘essential requirements’ (listed within Annex I of the directive).
In order to CE mark and market a product it must be shown that it meets those essential requirements applicable to its nature and application. In common with other directives, in order to cover the wide range of different products included within the scope of the directive, the list of essential requirements is very generic and does not provide specific criteria that a product must meet.
There are six areas covered by the essential requirements:
- Mechanical resistance and safety
- Safety in case of fire
- Hygiene, health and the environment
- Safety in use
- Protection against noise
- Energy economy and heat retention
In order to provide a mechanism for setting product specific requirements and, indeed, methods for assessing such properties, the European Parliament set in place a programme of standard development. Once published in the Official Journal of the European Union (OJ), these documents (hENs) provide a means of assessing whether materials/products meet the necessary characteristics/specifications in order to be CE marked.
One significant difference with the CPD to other directives is that it is not possible to CE mark a product against the directive until the relevant standards (hENs) have been developed and published in the OJ. These standards have a presumption of conformity and an informative annex (annex ZA) at the back of the standard provides details of how the standard applies in relation to the directive, and also the route to be followed in order to CE mark the product.
However, it can often take a number of years for a standard to be developed and published, and even then it may not always cover some of the more novel or specialised products.
To overcome this problem CEN allows two further types of documents:
European Technical Approvals (ETAs) and European Technical Agreements (ETAGs). ETAs are granted under any of the following conditions:
- Where no relevant hEN exists
- Where no mandate for such a standard has been given
- Where the European Commission considers that a standard can not be developed within a suitable time frame
Once granted, an ETA is valid for five years and allows the product to be CE marked. ETAGs are similar in nature except that they are granted to an individual manufacturer for a specific product.
It should be remembered that a directive itself has no legal or regulatory status. Each member state is required to put in place its own national laws and regulations that enforce the contents and requirements of the directive. This, coupled with the decision that the published standards needed to be available before a product could be CE marked, made the CPD implementation difficult and inconsistent across the various member states.
Since its publication in 1989, considerable work has been undertaken by both national and European committees and there are now a number of standards that have been developed and published by the European standards body (CEN). Despite this, some countries fail to fully implement the directive and the national standards remain in place, making it difficult to market goods freely within the EU. As the original intention of the directive and others like it was to ensure free movement of goods within the member states of the EU, and to make the CE marking process simple, and equally implemented and policed across all parts of the EU, a decision was taken under the Lisbon strategy in 2005 to review and simplify the CPD. This process has resulted in the decision being taken to not only revise the contents of the directive but to change it to a EU regulation.
This effectively means that once published in the OJ it will automatically have status as European law and there will not be a requirement for member states to copy it into their own national laws for it to be implemented. It is hoped that this, along with changes to the contents, will rationalise the requirements made upon those products considered as construction products, and allow the free movement of goods within member states.
It has taken a number of years for agreement to be reached on the contents of this new regulation but at a meeting held on May 25, 2010, the Construction Products Regulation was put to a vote at the EU Council of Ministers, and passed with a large majority. This now secures Council Political Agreement on the Regulation.
The Council is expected to meet again in the autumn of 2010 to agree a common position, following translation of the text. As the regulation is subject to co-decision, the next step will be for the council to negotiate with the European Parliament to obtain a second reading at the end 2010/start of 2011. If the regulation is adopted and published in early 2011, then a transition period of up to two years is anticipated, giving 2013 as a final deadline by which time a product must comply. Unlike the directive, the regulation will apply directly as European law and will not require any further implementation.
Attestation of conformity
As mentioned earlier, there are a number of routes that can be followed for a product to achieve the CE mark. In fact there are six different routes depending on the type of product, its intended end use and also the degree of risk associated with it. These routes are known as Attestation of Conformity, or AOC systems. These detail not only the requirements and procedures, but also which parts are the responsibility of the manufacturer and which parts which need to be undertaken by a member state-approved third party organisation, known as a notified body.
SATRA is a notified body for the testing of a range of flooring materials and also as a certification body for those materials covered by EN 14041.
All of the possible routes require the manufacturer to set up and to maintain a system for factory production control. Although not a mandatory requirement, an ISO 9000 quality system certified by an approved certification body that covers the products in question would be a good way of addressing this requirement. If requested by the competent body, then the manufacturer would need to be able to show not only that a factory production control system is in place, but that it covers the specific requirements for the product - the product standard (hEN) will include information of any additional or specific requirements that the factory production control needs to cover, and this should be read to ensure that a general company policy addresses these points, and that it is audited and maintained on a regular basis.
Where AOC system 1+ and 1 and 2+ and 2 are applicable then the manufacturer will also need to have a system in place that provides evidence that further testing of samples taken from the site of manufacture is being carried out in accordance with a test plan.
The degree of involvement of the notified body depends on the AOC system and may be as much as initial type testing of the product, inspection of the factory production control system and ongoing surveillance, along with certification of the product and the factory production control, to no involvement at all where system 4 is used.
The annex ZA in the standard relating to the product states the route that must be followed for the different products, and the standard itself will provide information on the specific requirements for all aspects of the CE marking process.
CE marking of flooring
A number of what can be considered primary standards exist for the different flooring types. Essentially, these provide a check list of the criteria that need to be met in order to comply with the requirements of the directive and for the CE mark to be applied.
For instance, EN 14041 covers resilient, textile and laminate materials (EN 14041: 2004 incorporating corrigenda Nos 1 and 2. - Resilient, textile and laminate floor coverings - Essential characteristics). EN 14041 addresses the requirements for textile, laminate and resilient flooring materials. The scope of the standard states that loose mats and rugs are not covered by the contents of the standard.
The reason for this is that the construction products directive covers those products that are permanent features of a building and, while flooring is included, mats and rugs are removable and can be considered as temporary and, as such, are outside the scope of the directive and also the various standards.
The allowed AOC routes given in annex ZA of EN 14041 are based on the claims made and results from the reaction to fire testing (shown in table 2).
System 1 applies to the classes listed above and, in addition, to those manufacturing processes where there is a clearly identifiable stage in the production process that results in an improvement of the reaction to fire classification (e.g. the addition of fire retardants or a limit to the amount of organic material present).
System 3 applies to those materials that achieve a Dfl and Efl classification and also to those materials where A1fl A2fl Bfl and Cfl classifications have been achieved, where the production process does not include any stages that are intended to improve the reaction to fire performance properties of the product - for example, flame retardants have not been used and organic material content is not limited or controlled.
System 4 applies to those products that do not need to be tested for reaction to fire and are rated A1fl to Efl according to commission decision 96/603/EC as amended, and also those products that are covered by a CWFT (classified without further testing) decision.
Annex ZA also provides detailed information on the responsibilities of the manufacturer and the notified body for each system, and the clauses of the standard to which it relates. EN 14041 is best considered as a primary standard and should be read in conjunction with those other standards applicable to the material, and intended end use of the product. These are listed and incorporated within EN 14041 and the associated requirements. Clause 4 covers the requirements relating to:
- Reaction to fire - including the preparation and conditioning of samples, the use of adhesives in the samples tested, and why and how samples can be classified in terms of reaction to fire without further testing
- Pentachlorophenol content - used as a pesticide/fungicide the use of pentachlorophenol is restricted under annex XVII of the European REACH regulations and EN 14041 provides a requirement and appropriate test methods for those materials that require verification testing
- Formaldehyde emission - here the classification of E1 or E2 is given to materials depending on whether formaldehyde has been added as part of the production process and to the level of formaldehyde released by the finished product
- Water-tightness - where a claim is made about the finished product being able to provide a watertight barrier, then it is tested and must meet the requirements listed within clause 4.4 of EN 14041
- Slip resistance - a requirement of dynamic coefficient of friction of equal to or greater than 0.3 and a test method (EN 13893) is stated within clause 4.5 of EN 14041. This relates to dry slip only
- Electrical behaviour (static electricity) - as with water-tightness and slip resistance, whether the requirements given for antistatic floor coverings and also electrical resistance depends upon the claims made by the manufacturer. Where such claims are made then these have to meet with the requirements and methods of test given in clause 4.6 of EN 14041
- Thermal conductivity - when floorings are intended to be laid over under-floor heating systems then either design calculations or test results must be provided
Clause 5 of EN 14041 covers the conformity part of the CPD: it gives requirements for both the type testing, how the samples are selected and how previous testing of similar products can be used. It also provides criteria for the factory production control system and what it needs to cover. This is further detailed within annex D of the standard.
Clause 6 of the standard along with ZA.3 finally provides requirements for the labelling of the finished product. These requirements depend on the AOC system that the product falls within and results and claims made.
Although EN 14041 gives the requirements for those properties listed above, all of the different flooring materials also have detailed specifications that relate to the properties of the individual material. These are listed in Table 3.
These standards give a variety of requirements and test methods for each material type, the results often providing classifications that are used in the labelling of the product, which in turn allows the end user to make an informed choice depending on their own specifications for the building.
It should be remembered that although EN 14041 and the relating classification standards provide classifications and labelling requirements that are accepted across Europe, the final choice of what is acceptable for different buildings will differ from country to country and these laws and regulations are not covered by the CPD or corresponding standards and documents.
Revision of EN 14041
Changes to the CPD were discussed earlier in this article which will result in this becoming a European regulation. Along with these changes is a revision of EN 14041, which is required due to changes to the contents of the directive. Once published this will include a requirement to consider the presence of dangerous substances and also VOC emissions - volatile organic compounds that are emitted from the material into the atmosphere.
The presence of formaldehyde and pentachlorophenol is addressed in the current revision of 14041 but the proposed draft will extend this to include additional substances that are listed within annex XIV and annex XVII of the European REACH regulations.
The final list of substances that will be included within the new version of 14041 is being discussed at the time of writing and it is anticipated that the published revision will contain not only maximum limits for a number of substances, but also reference to, or documented test methods for analysis of these within the finished product.
The proposed requirements and test methods for determining VOC emissions are also being discussed and it is thought that the test methods for both sampling of materials and analytical techniques will be based on, or directly reference the various parts of ISO 16000 - this being a series of standards that give test methods for the selection of samples, their preparation and also the actual analysis.
These are based on what are termed ‘chamber methods’. Here the sample is placed in a chamber, usually constructed of stainless steel, within which the temperature, humidity and airflow is tightly controlled. At defined periods of time, samples of the air within the chamber are collected and analysed to determine the substances and their amounts that have been emitted form the material being tested. The requirements are likely to be based on the German AgBB list of substances and limits.
SATRA would recommend that manufacturers of flooring products start to investigate how these changes will affect their products and begin to plan testing programmes to ensure that they are ready for full implementation of the regulation in 2013.
SATRA will be holding a seminar on November 2, 2010 to discuss the changes to the CPD.
To book a place on the seminar or for specific assistance on how individual products are affected, call +44 (0) 1536 410000.
For more general information on the Construction Products Directive and floorcoverings, visit www.satra.co.uk/cpdhis
Published: 01st Sep 2010 in Health and Safety International