Door Industry Journal - Winter 2020
Also online at: www.d ijonline.co.uk 10 THE door industry journal winter 2020 Industry News CE Marking Legal Requirements Change for Fire (and smoke) Resisting Industrial Doors Since November 2019, there has been a change in the legal requirements for placing fire (and smoke) resisting industrial doors on the market in the UK (and the wider European Economic Area). dhf ’s Training and Compliance Officer, Nick Perkins, discusses the changes to legal compliance that affects all fire and smoke-resisting industrial doors. “This change is as a result of how Construction Products Regulation 305/2011 (CPR) is applied,” explains Nick. “The CPR, which is enforced in the UK via the Construction Products Regulation 2013, applies to any construction product covered by a CPR harmonised standard.” Until November 2016, the applicable CPR standard (BS EN 13241) did not cover doors with fire or smoke resisting properties. Following November 2016, the scope was altered to include doors with fire or smoke resisting properties. Although the standard was changed in 2016, the new requirements did not become mandatory until November 2019, following the usual co-existence period during which compliance is voluntary. Today, all industrial and garage doors within the scope of BS EN 13241:2003 + A2:2016 must comply with the CPR, and if they are fire or smoke resting, must also comply with BS EN 16034:2014. “Compliance involves using the services of a ‘notified product certification body’ for the fire and smoke resisting properties,” says Nick. “In the UK, CPR notified product certification bodies are appointed by UK government under the advice of UKAS. The CPR compliance function should not be confused with existing voluntary third-party certification schemes, although many organisations do provide both services. Certification bodies continue to offer voluntary third-party certification schemes alongside the legally required notified product certification services required by CPR legislation.” The notified product certification body role in the CPR compliance process is to: • Assess the manufacturer’s factory production control system. • Select a sample for testing. • Oversee testing to BS EN 1634-1:2014 + A1:2018 and assess the report. • Apply the extended application standard (BS EN 15269-10:2011) to enable manufacture of door sizes not tested and provide a report. • Apply the classification standard (BS EN 13501-2:2016) to determine performance and provide a report. Upon completion of the process, the notified product certification body will issue the manufacturer with a ‘certificate of constancy of performance’. This certificate is the final stage in the legal compliance process and will enable the manufacturer to draw up and issue a declaration of performance and CE mark the door. This is the evidence of compliance required by CPR legislation and must be supplied with the product. To achieve overall CPR compliance, the manufacturer must address the general characteristics covered by BS EN 13241 (that affect all doors) via notified test laboratory testing, and the fire/smoke resistance characteristics covered by BS EN 16034 via the services of a notified product certification body. “The bulk of the responsibility for compliance lies with the door manufacturer, but there is still a degree of legal responsibility under the CPR for companies that distribute doors that are supplied by third-party manufacturers,” says Nick. “This element of responsibility will apply to traditional
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