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

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

3
Brief history

• 2002
• 2003
• 2004
• 2005

• Start thinking on co-operation between CEN
  Construction and Environmental Sectors
• SCC decides to set up a database with MS
  regulations on dangerous substances
• First draft of mandate on dangerous substances by
  European Commission Expert Group
• CSN Conference on progress (Coïmbra)
• Mandate accepted by SCC (draft 11)
• Mandate submitted to CEN (final version)
• BT/WG 176 meeting on Work Programme
• Establishment of new horizontal CEN/TC 351

4
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

5
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

6
Commissions 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

7
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)

8
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

9
Structure of CEN/TC 351
CEN/TC 351 plenary
(2008)
WG 2 Emissions from construction products into
Indoor Air
WG 1 Release from construction products into
soil, ground water and surface water
Continuation of TG 3 WT/WFT, TG 6 Radiation
5 TGs Barriers to trade, Horizontal testing,
WT/WFT, Complement to sampling, Content
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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)

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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

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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

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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
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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
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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
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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
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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

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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

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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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Network
Delegates of National Standardisation Bodies
Environment
Construction
Environment
Construction
TC
TC
TC
TC
TC
TC
(SABE)
(CSNPE)
(SABE)
(CSNPE)
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
TC
TC
TC
TC
TC
TC
CEN/TC 351
DG
Enterprise
DG
Enterprise
DG
Enterprise
DG
Enterprise
DG
Enterprise
DG
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
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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

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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

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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 lt 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
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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

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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

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Thank you for your attention

• Annemieke Venemans
• NEN Construction
• Phone [phone]
• Telefax 31 15 269 06 30
• E-mail annemieke.venemans_at_nen.nl
• www.centc351.org

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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.

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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.