How to verify that construction products are safe for health and the environment without excessive testing?
All construction products traded freely on the single European market have to be verified as safe, demands the German Federal Environment Agency (Umweltbundesamt – UBA
). This is a must for the implementation of the Construction Products Directive / Regulation in conformity with the Treaty on the Functioning of the European Union, the UBA says. Which verifications are necessary, and how frequently? When can manufacturers omit routine tests for emissions and contaminants? The think tank Öko-Institut explores these questions in a study commissioned by UBA. The study focuses on plasters and mortars for indoor use and on road construction products. All construction product producers can profit from the suggestions for minimising the testing burden.
The report ”Safe Construction Products for Health and the Environment: How much testing is necessary to implement the EC Construction Products Directive?” contributes to the current efforts of the European Commission and the European Committee for Standardization (CEN) to restrict the burden of testing. All stakeholders in the construction sector wish to avoid repeated tests for construction products already demonstrated as safe for health and the environment. Safe products with a stable quality should be able to obtain the CE mark without routine tests, the report argues.
The European Commission and CEN envisage three test categories for construction products:
- products whose performance is verified without testing (WT),
- products whose performance is verified after a type test without further testing (WFT), and
- products for which further testing is required (FT) in the respective product standard.
Similar categories are already in use for fire resistance performance in European standards. The Öko-Institut report is based on the assumption that for a WT status a satisfactory existing knowledge is sufficient, while a WFT classification would involve experience from harmonised European tests. The European Commission intends to specify which verifications need to be handed in to apply for WT/WFT after first trial runs with candidate products. The Commission Services have currently assigned their Expert Group on Dangerous Substances to assess the first test run dossiers.
Harmonised European standards are and should be performance oriented. For the definition of mechanical characteristics, this can usually be achieved without defining the product’s material composition. The emission performance depends on the chemical composition, (i.e., the substances contained and their chemical bond). For products continuously tested for their emission performance, a substance-based product definition is not essential. However, for a WT classification it is obligatory to define product groups so clearly that all product variants on the market are covered. This may be unproblematic, for example, for glass panes. For formulation-based products, the Öko-Institut recommends including substance-related product definitions or appropriate descriptive attributes in the standards.
Product standards too vague on health and environmental requirements can hamper quality-oriented innovation. The WT/WFT concept does not only contribute to keeping the testing effort at a proportionate level. It also ensures that existing and new products effectively correspond to the same protection levels. In this way the concept prevents obstacles to innovation from occurring as a result of the definition of stricter requirements for new products, the Öko-Institut says.