Ignorance is no defence

The Construction Products Directive (CPD) has been applicable for wood-based panels since 2004 and EN 13986 has implemented its requirements for supplying such products into construction projects. Or has it?

It is well-known among panel distributors that structural plywood requires “System of Attestation 2+”, which ensures the mechanical performance of the product and, for the manufacturer, requires: third party-audited Factory Production Control (FPC), initial type testing, mechanical performance data and a CE mark. This is due to the safety-critical nature of structural components in buildings.

The sale of flame retardant (FR) panels (to the European classes B&C) into construction is governed by a still higher level of attestation. Distributors who send panels (mostly plywood) for FR processing become the manufacturers and should have their own FPC certificate, because they are “placing the product on the market”. This is Attestation System 1, to EN 13986. There is no lack of understanding that FR panels become safety-critical building components, so why is this requirement almost universally ignored in the UK?

The audited FPC process is combined with the data from the technical file (ie. Classification Reports) of the entity that processed the panel and changed the reaction-to-fire classification. If the processor has no technical file for Euroclasses, then the output from the plant cannot comply with the CPD nor receive a CE mark.

Only with this entire process in place can the distributor provide the performance data for the panel which includes: a unique CPD product number, reaction-to-fire classification and, most important of all, limitations of use such as the exclusion of an air gap. Companies placing FR processed panels on the market according to Attestation System 1 are entitled to raise their own Declarations of Conformity, which state all these performance measurements and, if they wish, place their CE mark on the product, although it is much easier to place it on the document.

Placing FR products on the market for construction outside of Attestation System 1 contravenes the CPD. This is not yet illegal, though it soon will be, but this is not the point. Avoiding the requirements of EN 13986 for FR panels represents an appalling neglect of customer service to which specifiers and installers are justly entitled, denying them the opportunity to correctly fulfil their obligations, both to their clients and to public safety.

FR processed plywood is routinely bought and sold without any regard to attestation of performance, based on a blind assumption that responsibility rests with the treatment company. It does in part but not exclusively. Some treatment companies commission indicative tests only, then to pass them off as classification reports. This is totally dishonest but does not absolve their distributor customers from establishing their legal standing.

Specifiers and installers alike should at least demand a Declaration of Conformity that tells them everything they need to know about the “Euroclassed” FR panel. To assist them, the Wood Protection Association has published an excellent checklist enabling specifiers and installers to meet their obligations successfully. It is available from the WPA website www.wood-protection.org.

In the meantime, companies that place FR panels on the market outside of Attestation System 1 had better watch out. The Construction Products Regulation is coming and ignorance will be no defence.