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CEN/TC 351 Construction Products: Assessment of Release of Dangerous Substances

CEN/TC 351 Construction Products: Assessment of Release of Dangerous Substances. Annemieke Venemans CEN/TC 351 Secretary NEN Construction. Overview. History CPD Mandate M/366 CEN/TC 351 Work Programme and structure Communication Recycling sector & CEN/TC 351. CPD & ER 3 (1).

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CEN/TC 351 Construction Products: Assessment of Release of Dangerous Substances

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  1. CEN/TC 351Construction Products: Assessment of Release of Dangerous Substances Annemieke Venemans CEN/TC 351 Secretary NEN Construction

  2. Overview • History • CPD • Mandate M/366 • CEN/TC 351 Work Programme and structure • Communication • Recycling sector & CEN/TC 351 FIR Interforum 2007

  3. 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 FIR Interforum 2007

  4. 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 FIR Interforum 2007

  5. 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 FIR Interforum 2007

  6. 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) FIR Interforum 2007

  7. 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 FIR Interforum 2007

  8. Structure of CEN/TC 351 CEN/TC 351 plenary (2008) WG 1 Release from construction products into soil, ground water and surface water WG 2 Emissions from construction products into Indoor Air Continuation of TG 3 WT/WFT, TG 6 Radiation 5 TG’s: Barriers to trade, Horizontal testing, WT/WFT, Complement to sampling, Content FIR Interforum 2007

  9. 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) FIR Interforum 2007

  10. 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 FIR Interforum 2007

  11. 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 FIR Interforum 2007

  12. 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 FIR Interforum 2007

  13. 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 FIR Interforum 2007

  14. 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 FIR Interforum 2007

  15. 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 FIR Interforum 2007

  16. 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 FIR Interforum 2007

  17. 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 FIR Interforum 2007

  18. 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 FIR Interforum 2007

  19. TC TC TC TC Construction Environment (CSNPE) (SABE) TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC DG DG DG DG Enterprise Enterprise Enterprise Enterprise TC TC TC TC Member States TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC DG Environment DG Environment DG Environment DG Environment Network Delegates of National Standardisation Bodies Construction Construction Environment Environment TC TC TC TC TC TC (CSNPE) (CSNPE) (SABE) (SABE) TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC Mandate M/366 Construction TC TC TC TC TC TC CEN/TC 351 TC TC TC TC TC TC DG DG DG DG DG DG Enterprise Enterprise Enterprise Enterprise Enterprise Enterprise Member States Member States TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC TC Environment Environment TC TC TC TC TC TC TC TC TC TC TC TC DG Environment DG Environment DG Environment DG Environment DG Environment DG Environment Individual European trade organizations FIR Interforum 2007

  20. 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 FIR Interforum 2007

  21. 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 FIR Interforum 2007

  22. Activities for 2007/2008 FIR Interforum 2007

  23. 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’ FIR Interforum 2007

  24. 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 FIR Interforum 2007

  25. Thank you for your attention Annemieke Venemans NEN Construction Phone +31 15 269 02 80 Telefax +31 15 269 06 30 E-mail annemieke.venemans@nen.nl www.centc351.org FIR Interforum 2007

  26. 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. FIR Interforum 2007

  27. 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. FIR Interforum 2007

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