EU requirements for safety flooring and matting
Current and forthcoming European legislation and standards for safety flooring and matting.
Flooring materials are considered as permanent fixtures within a building and, as such, are 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. As 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.
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 and specifications in order to be CE marked.
One significant difference between the CPD and other directives is that it is not possible to CE mark a product against the directive unless there is a recognised standard or specification in place. Generally, there will be European harmonised standards (the hENs) that have been developed and published in the OJ. These have a presumption of conformity and an informative Annex (Annex ZA) at the back of the standard, which 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, the European standards body (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 cannot 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. In the case of the CPD, implantation has been 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 CEN. Despite this, some countries still have not fully implemented the directive and 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 also to change it to an EU regulation.
This effectively means that once published in the OJ, it will automatically have status as European law, and there will be no requirement for member states to copy it into their own national laws in order for it to be implemented. It is hoped that this, along with changes to the contents, will rationalise the requirements made upon those products that are considered as construction products, and to 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 in May 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 towards the end 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 of 2010 or early in 2011. If the regulation is adopted and published in early 2011, a transition period of up to two years is anticipated, giving 2013 as a final deadline by which time product must comply.
Routes to a CE mark
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 (1+ having the most mandatory requirements), depending on the type of product, its intended end use and also the degree of risk associated it. Table 1 shows the responsibilities for the different parts of the process for each route, which are known as ‘Attestation of Conformity’ or ‘AoC systems’. They detail not only the requirements and procedures, but also which parts are the responsibility of the manufacturer and which parts 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 14041:2004 incorporating corrigenda numbers 1 and 2 – ‘Resilient, textile and laminate floor coverings – Essential characteristics’.
|Table 1: Attestation tasks for each system|
|Tasks for the manufacturer||AoC system|
|Factory production control (FPC)||Yes||Yes||Yes||Yes||Yes||Yes|
|Further testing of samples taken at factory
according to prescribed test plan
|Initial type testing of product||Yes||Yes||Yes|
|Tasks for the Notified Body|
|Initial type testing of the product||Yes||Yes||Yes|
|Initial inspection of factory and of factory
|Certification of product conformity||Yes||Yes|
|Certification of factory production control||Yes||Yes|
|Declaration of conformity by the manufacturer||Yes||Yes||Yes||Yes||Yes||Yes|
The Annex ZA in the standard which relates to the product, states the route that must be followed for the different products. The standard itself will provide information on the specific requirements for all aspects of the CE marking process.
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, the manufacturer needs to show not only that a factory production control system is in place, but also 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 point, and that it is audited and maintained on a regular basis. Where AoC system levels 1+, 1, 2+ and 2 are applicable, 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.
A number of what can be considered ‘primary standards’ exist for the different flooring types. Essentially, these provide a checklist 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 and addresses the requirements for the materials used. The scope of the standard states that loose mats and rugs are not covered by the contents of the standard, the reason being 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. As such, they 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).
|Table 2: Reaction to fire testing – applicable to flooring (see figure 1)|
|Product||Intended use(s)||Level(s) or class(es)||AoC system|
|Resilient, textile and laminate floor coverings||Internal and external use as floor coverings||A1fl A2fl Bfl and Cfl||1|
|A1fl A2fl Bfl Cfl Dfl and Efl||3|
|A1fl to Efl and Ffl||4|
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 (for example, 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. It also applies to those materials which achieve A1fl, A2f, Bfl and Cfl classification, and where the production process does not include any stages that are intended to improve the reaction to fire performance properties of the product. For instance, 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. It also applies to those products that are covered by a CWFT (Classified Without Further Testing) decision.
In addition, Annex ZA provides detailed information on the responsibilities of the manufacturer and the Notified Body for each system, as well as the clauses of the standard to which it relates.
EN 14041 Clause 4
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 the following:
- 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, 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 (figure 2)
- electrical behaviour (static electricity) – as with water tightness and slip resistance, the requirements given for antistatic floor coverings and also electrical resistance depend upon the claims made by the manufacturer. Where such claims are made, 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, either design calculations or test results must be provided.
Clause 5 of EN 14041 covers conformity to 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 details what must be covered. This is further detailed within Annex D of the standard.
Clause 6 of the standard, along with Annex ZA.3, provides requirements for the labelling of the finished product. These requirements depend on the AoC system within which the product falls, in addition to the results and claims made.
Although EN 14041 gives the requirements for those properties listed above, all of the different flooring materials also have specific specifications that relate to the properties of the individual material. These are listed in table 3.
|Table 3: Specification standard for use in conjunction with EN 14041|
|EN 548||Resilient floor coverings – specification for plain and decorative linoleum|
|EN 649||Resilient floor coverings – homogeneous and heterogeneous polyvinyl chloride floor coverings –specification|
|EN 651||Resilient floor coverings – polyvinyl chloride floor coverings with foam layer – specification|
|EN 652||Resilient floor coverings – polyvinyl chloride floor coverings with cork-based backing – specification|
|EN 653||Resilient floor coverings – expanded (cushioned) polyvinyl chloride floor coverings – specification|
|EN 654||Resilient floor coverings – semi-flexible polyvinyl chloride tiles – specification|
|EN 687||Resilient floor coverings – specification for plain and decorative linoleum on a corkment backing|
|EN 1307||Textile floorcoverings – classification of pile carpet|
|EN 1816||Resilient floor coverings – specification for homogeneous and heterogeneous smooth rubber floor coverings with foam backing|
|EN 1817||Resilient floor coverings – specification for homogeneous and heterogeneous smooth rubber floor coverings|
|EN 12199||Resilient floor coverings – specifications for homogeneous and heterogeneous relief floor coverings|
|EN 13329||Laminate floor coverings – specifications, requirements and test methods|
|EN 13553||Resilient floor coverings – polyvinyl chloride floor coverings for use in special wet areas – specification|
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 particular specifications for the building.
Although EN 14041 and the relating classification standards provide classifications and labelling requirements that are accepted across Europe, it should be remembered that the final choice of what is acceptable for different buildings may differ from country to country and that these requirements are outside the CPD and its corresponding standards and documents.
Earlier in this article, changes to the CPD were mentioned, which will result in it 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 (figure 3). 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 is 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’, where the sample is placed in a chamber (usually made from stainless steel – figure 4) 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.
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