To address this situation, DG GROW launched this summer a call for tender to develop a standard, following a consultation process with the Member States technical experts in late 2015. It is encouraging to see that the European Commission is taking such an important step towards better regulation of façade products across the EU. However, the proposal at the basis of the call for tender entails some flaws that risk undermining the harmonisation effort.
One proposal, two tests, too many flaws
The route indicated in the call for tender combines two different tests, the British test BS8414 and an old draft DIN test 4102-20 from Germany. A quick comparison of the two tests shows that the fire exposure in the draft German test is approximately 10 times lower than in the British test as well as most other national large-scale tests. It is acknowledged that there is no correlation between the two tests so member states would have to choose which one they would refer to in their regulations.
Additionally, German authorities have recognized that their old draft test does not provide an acceptable fire safety level. To compensate for this they have implemented additional prescriptive rules for a specific type of facade systems – ETICS with Polystyrene Insulation.
Fire Safe Europe believes this solution entails serious shortcomings in terms of:
- Barriers to trade: having two tests that do not correlate, and which member states can choose between, will oblige manufacturers selling in a country using the small German test to retest to the British test if they start to sell in a country referring to that one.
- Competition: the proposal concerns only one type of façade system (ETICS). The same is true for the additional German safety requirements. Consequently, other façade systems will be left without a harmonized testing method, which puts them at a disadvantage.
- Unfair advantage for a few Member States: when the EU system enters into force, British, German and Austrian ETICS manufacturers (Austria currently uses the same test as Germany) who already hold a national approval will be at an advantage, as their national approvals will count directly for a European approval. On the other hand, manufacturers from other countries will have to test to the European testing method, without being able to use their national approvals.
- Safety in case of fire: it is well known that the draft German test does not reflect the actual behaviour of façade systems in case of fire. Only by adding additional safety features at the regulatory level can an acceptable safety level be obtained. Since the EU cannot force fire safety regulations at the member state level, member states who choose the German test will have to adopt these additional safety measures at their own will. If they do not willingly adopt these additional measures, the fire safety of buildings will be seriously compromised.
An alternative solution
An alternative solution is possible, and could be articulated as follows:
- To start the work by scoping national regulations on façade fire safety and mapping the needs of Member States. This would hopefully clarify why Member States have adopted different test procedures.
- To investigate how to address Member States’ needs.
- To potentially define more than one class of performance in the large-scale test, making it possible for Member States to set different safety levels depending on building types.
- To define the rules for extended application of test results in the harmonised large-scale test.
This could be done via a mandate to CEN TC127, the European Committee for Standardisation, whose role it is to develop standards for assessing fire hazard and for providing fire safety in buildings.
Implementing a harmonised large-scale test and classification system for facades is a big step towards European harmonisation, and it is paramount that it is done right.