In addition to the product testing the “notified body” carry out a Factory Production Control (FPC) on the company to ensure that products placed on the market conform to the stated performance characteristic. The FPC shall consist of procedures, regular inspections and test/ or assessments and the use of results to control raw and other incoming materials or components, equipment, the production process and the product and shall be sufficiently detailed to ensure that the conformity of the product is apparent. The manufacturer is required to retain a declaration of conformity and also affix a CE mark on the product that will include specific data relating to performance.
“ We must remember that the whole point of this regulation is to ensure safe, fit for purpose, products are supplied to the market.”
A worthwhile cost
As you would expect, the cost of producing compliant products and the process of testing to the required level is not insignificant and those manufacturers who have embraced this change have invested to ensure that their products are fit for purpose and meet the new regulations. The risk that some manufacturers will ignore the new regulations (or just as worryingly be unaware of them!) and supply lower cost but non compliant products exists. Specifiers and purchasers of construction products need to be aware that this legislation is in place and should insist on having CE marked products supplied. For those buyers who choose to disregard the regulation and procure a non compliant product, there is a high level of commercial risk. In the event that non CE marked product is found to have been used on a project, they may be required to replace this with a suitable CE marked item – the cost both financial and in terms of damage to reputation being potentially very significant.
Although the method of policing the new regulations is still a little unclear, anyone involved in the construction industry, whether it be manufacturing,
Building & Facilities Management – September 2013
architect, contractor /sub-contractor or even the construction operative who installs the item, is obliged to report the use of any non compliant product.
Ignorance of a law is no excuse Under UK law, ignorance of legislation does not constitute a legitimate defence. Whilst less reputable companies may attempt to obtain a commercial advantage by offering non CE marked product whilst claiming it conforms, the risks of procuring such items is not worth the obvious dangers. We must remember that the whole point of this regulation is to ensure safe, fit for purpose, products are supplied to the market. Especially with products such as smoke vents, the potential consequences of installing non compliant products could be life threatening. As with all of its products, whether it be roof access hatches, ladders, or floor doors, Bilco smoke vents now deliver a guaranteed product which meets all current legislation.
Contact them for more information on Tel: 01284 701696, or visit their website:
www.bilcouk.com
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