cen/tc 351 construction products: assessment of release of dangerous substances

CEN/TC 351Construction Products: Assessment

of Release of Dangerous Substances

Annemieke Venemans

CEN/TC 351 Secretary

NEN Construction

September 26, 2007 FIR Interforum 2007

Overview

• History

• CPD

• Mandate M/366

• CEN/TC 351 Work Programme and structure

• Communication

• Recycling sector & CEN/TC 351


CPD & ER 3 (1)

• New Approach Directive: EC mandates CEN to develop harmonised standards

• Construction products in their normal intended use

• Essential Requirement 3: Hygiene, health and the environment

• Other regulations also deal with dangerous substances: Keep open eye for what is happening and what may be usable


CPD & ER 3 (2)

• Note in existing Annexes ZA: existing national requirements regarding DS have to be met

• Note is to be replaced by DS as essential characteristic (CE mark has to provide information: value/class or NPD)

• Need for horizontal harmonized standardised test methods that meet needs of regulators and wishes of industry


Commission’s approach regarding Dangerous Substances (as in M/366)

• Risk management approach: which substances pose a risk

• Regulated Substances: look at substances that are regulated by existing national (notified) or international (European) regulations

• Construction products for an intended use (indoor, outdoor)

• A limited number of exposure paths can be defined as exposure scenarios


Mandate M/366

Full title: Horizontal complement to the mandates to CEN/CENELEC concerning the execution of standardisation work for the development of horizontal standardised assessment methods for harmonised approaches relating to dangerous substances under the Construction Products Directive (CPD)


Scope of CEN/TC 351

Development of horizontal standardised assessment methods for harmonised approaches relating to the release (and/or the content when this is the only practicable or legally required solution) of regulated dangerous substances under the Construction Products Directive (CPD) taking into account the intended conditions of use of the product. It addresses emission to indoor air, and release to soil, surface water and ground water


Structure of CEN/TC 351

CEN/TC 351 plenary

WG 2 Emissions from construction products

into Indoor Air

WG 1 Release from construction products into soil, ground water

and surface water

5 TG’s: Barriers to trade, Horizontal testing, WT/WFT, Complement to sampling, Content

Continuation of TG 3 WT/WFT, TG 6 Radiation

(2008)


Work plan of CEN/TC 351• For most or all parameters, standards exist both on leaching and

on emission to indoor air; they are the basis• Work plan:

– Listing of existing standards– Selecting and adapting test method standards– Publication as TS– Validation programme, 24 months (no EN without validation)– Publication EN after voting procedure

• Revision of harmonised product standards (mandated under CPD)


WG 1 Release from construction products into soil, ground water and surface water

• Methods for leaching and for analysis of eluate• Based on existing methods (product TCs, CEN/TC 292)• Scenarios for release of DS in intended use• All relevant aspects from sampling, sample preparation,

measurement equipment and procedures to the evaluation of the measurement results

• Chairman Gerd Thielen• Secretary Udo Wiens DIN


WG 2 Emission from construction products into indoor air

• Methods for emission and for analysis of indoor air samples, obtained in standardized testing facilities

• Based on existing methods (product TCs, CEN/TC 264)• Scenarios for release of DS in intended use• All relevant aspects from sampling, sample preparation,

measurement equipment and procedures to the evaluation of the measurement results

• Chairman Jean-François Vicard• Secretary Monique Pottevin AFNOR


TG 1 Barriers to trade (TR 1)

• Inventory of barriers-to-trade for construction products, caused by regulations on content or emission of dangerous substances

• Suggestions on how horizontal standards can help to resolve these barriers-to-trade

• Proposal: extension with informative report on barriers-to-use

The TR will be used by the Commission to discuss barriers-to-trade with Member States regulators


TG 2 Horizontal testing (1 - TR 2)• How to deal with horizontal standards• Incorporating the experience of the Product TCs• Sets the guidelines for deciding whether a horizontal test

method is applicable or a vertical test method is required• Suggestions on how to set up a test programme based on

horizontal test methods

TR 2 is intended to support Product TCs in amending ‘second generation’ product standards


TG 2 Horizontal testing (2 - TR 4)• Step-by-step guidance for Product TCs to incorporate test

methods on DS in product standards• Addresses the Attestation of Conformity for CE-marking• Suggests levels for Attestation of Conformity• States possibilities and limitations testing schemes (TR2)• Addresses the ability of measurement methods and testing

schemes for use in regulations

TR 4 supports the Commissions Expert Group in advising the SCC on the use of the test methods in regulations


TG 3 WT/WFT (TR 3)• Develops criteria for classifying products as

– Without Testing (WT)– Without Further Testing (WFT)– Further Testing (FT)

• Does not set limit values for regulations• Could result in a list of WT products based on ITT, general knowledge

and historical data

TR 3 might support the Commissions EGDS in advising the SCC in acknowledging a WT list and procedure


TG 4 Complement to Sampling (WI 5)

• The issue of sampling, in particular the quality characteristics of sampling and the overall sampling strategy, for the determination of content or release or emission of regulated dangerous substances

• Related to the scenarios of intended use• Complementing the existing product standards,

ETAGs and CUAPs, as far as sampling is concerned

Convenor Jean-François Vicard


TG 5 Content (WI 6)• Selection of appropriate test method standards from those

already available

• Non-destructive and destructive methods for potential release of dangerous substances

• Horizontal method for the determination of the content of regulated dangerous substances in construction products

• Proposal on when ‘content’ is the ‘only practicable or legally required solution’

• Intended for ITT to support claim on WT/WFT

Convenor Hans van der Sloot


TG 6 Radiation (WI 11)

• First deliverable: state of the art document• Horizontal standard on the measurement of radiation

from construction products• Based on EN 112, Erricca report, Beir VI• Proposal for further steps (if any)• Start in 2008 (2nd phase of contract with EC)

Convenor Pekka Vuorinen


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Mandate M/366

Delegates of National Standardisation Bodies

Individual European trade organizations


Communication is the key

• Over 60 product TCs, environmental TCs• European Commission: SCC, DG Enterprise, DG

Environment• 29 Member States• 30 National Standardization Bodies (CEN Members)• Industry, industrial sectors• CEN bodies: CMC, CSN, CSNPE, SABE• Regulators, experts from various fields• Liaisons with interest groups


Ways to communicate

• Various enquiries and questionnaires to product TCs, EOTA and organizations in liaison– on the ´indicative list of substances to be considered´– on existing sampling methods– on barriers to trade– on tests, substances, scenarios, etc. to be completed(also to increase the awareness)

• Encourage establishment of liaisons to CEN/TC 351• www.centc351.org


Activities for 2007/2008

Conference with construction product TCs and industries, on TR 1 and TR 3

November 29, 2007Berlin

TR 1 1st Working Document in CEN/TC 351

& Draft TR for TC Approval

TR 3 Text available

Sept 2007

April 2008

August 2008

Complete evaluation sheets with help of product TCs

Draft TR 2 for comments to CEN/TC 351

< October 31, 2007

February 2008

WG 1 Evaluation of existing standards and decide

& which will be the basis for the horizontal method(s)

WG 2 Plan and prepare for the validation process


Recycling sector & CEN/TC 351 (1)

Being recycled or not is no issue for CEN/TC 351, as– The CPD is limited to the release of the

product in its indented use– Waste and demolition effects are up to

CEN/TC 350 (Life cycle analysis)And: CE mark for secondary materials is ‘license to use’


Recycling sector & CEN/TC 351 (2) Liaison to CEN/TC 351:

• CEN/TCs 51, 104, 154, 227

• FIR, UePG

Involvement in groups:• TC plenary FIR – Cuperus

UePG & CEN/TC 154 – Loveday, Lay

• WG 1, TGs various representatives


Thank you for your attention

Annemieke Venemans

NEN Construction

Phone +31 15 269 02 80

Telefax +31 15 269 06 30

E-mail [email protected]

www.centc351.org


Questions asked (1)

• Which product TCs are affected by the work under Mandate M/366 (i.e. CEN/TC 351?)

All CEN/TCs that have a mandate under the CPD. The harmonised product standards under these mandates will have to be amended with the essential characteristic on dangerous substances and the appropriate test method.

• How do I know that my test results are accepted in another country?

Analogue to other essential characteristics, a system of notified approved bodies will be established.


Questions asked (2)

• What is the relation of CEN/TC 351 to REACH?DG Enterprise has stated that for construction products, the work of CEN/TC 351 will be leading. Of course, both systems should be in line with each other as much as possible. CEN/TC 351 will have more specific feedback from the ECB (European Chemicals Bureau) in a later stage, when the “cookbook” for manufacturers in the construction sector has been finalised and would allow a more detailed discussion with the right experts.

cen/tc 351 construction products: assessment of release of dangerous substances

Documents

radiation2008fir interforum

industryfir interforum

usablefir interforum

cen construction

riskregulated substances

work plan of centc

ground waterfir interforum

scope of centc