Hot topic: Construction Products Regulation
Following the introduction of the Construction Products Regulation in July, Iain Mason spoke to two leading industry figures about its impact
Dr Jeremy Hodge is Chief Executive of British Approvals Service for Cables (BASEC), a notified body involved with cable testing for CPR
Hello Jeremy, what’s the advantage of CPR?
The key thing is it’s a new harmonised standard for reaction to fire testing that applies over and above all the other cable product standards. So products like twin and earth to BS 6004 will all still exist, but the CPR requirement is above all that. This means it can also be applied to non-standard cables to private specifications, cable that’s slightly out of spec, things like that. It focuses upon reaction to fire, which is effectively: ‘Will it burn? How badly does it burn? And does it contribute to a fire in the building?’ The main thing is that it creates consistency across Europe. It also provides quite a lot more technical information, particularly at the top end, for fire engineers and people who want to create good building design. It addresses things like smoke and acid gas emission, which are key issues for safety, as well as fire spread. It also gives the specifier a choice of grades.
How has it affected your workload?
For us, it’s meant we’ve had to invest in a lot of equipment, which we’ve had to get working in advance of CPR going live. We also had to get ourselves assessed and ready to provide the service. The first six months were quite slow, but the past six months have been a mad rush. The volume of testing has been three or four times what we expected, so we’ve had to take on a lot more staff to deal with it. We’re still getting applications now, even though the deadline has gone. So we’ve had a busy time. I don’t think the industry appreciated the scale of the problem. We’ve been working with manufacturers from all over the world, particularly the Far East, North America and Europe. So there’s a capacity issue in the test labs, because there’s only 15-20 labs with the relevant test equipment to push all this cable though. That’s why we encouraged people to start early – but of course that didn’t happen. We’re still trying to push things through as rapidly as we can.
How has cable been performing?
In general, we’ve found that cable has performed slightly less well than people were expecting, because the new test is quite demanding. The other things is, you can’t read directly across from a cable standard to the performance in the new test. It very much depends on which quality of material the manufacturer has been using. So if they’ve been buying a cheap and nasty compound, that may perform less well than a good, higher cost compound. The cable may still comply to the same cable standard, but you’ll get a different performance in the CPR. So you’ll end up with products on the market that have different CPR grades, but which are nominally the same design of cable. Substitution from one manufacturer to another won’t be as straightforward if the CPR classes are specified.
Do you anticipate any issues?
One complicating factor is that cable distributors who have products branded in their own name have to go through the process of getting the document in their own name as well. So they can either get the cable tested themselves or ask their manufacturer to do it, then there’s a sort of reissue of documents in their own name. So there will possibly be quite a lot of different documents floating around from different parties. Plus they don’t have to be in the same format, as long as they have the right information. So some people are producing nice glossy DoPs, and some are producing very simple ones. Also, some people are integrating the CPR information into their existing product labels, and some are putting a separate label on. So there’s standard content, but not standard format. But people will soon get used to seeing these things.
What do you think the effect will be on the market? And how can it be policed?
It will provide the user with a lot more detail and information about any cables they are fitting. We as a notified body don’t have any official role in policing what’s happening in the market, ie the quality of DoPs and whether the labels are right. We’ve seen a number of occasions where the declarations aren’t right and have wrong information. I know bodies like the ACI are going to keep an eye on fake, incorrect and misleading documentation. Trading Standards have the formal role of enforcing it, but the Government would like the industry to police itself as much as it can. If they’re suspicious about any documentation they’ve been given, contractors could go to Trading Standards, but it might be just as easy to go to an organisation like the ACI. Plus, the British Cables Association has issued a couple of sets of specific guidance on CPR for distributors and specifiers.
Martin Boorman is UK Sales Manager of Prysmian Group, and is closely involved with the British Cable Association and Approved Cables Initiative
Hello Martin, why is CPR so vital for the electrotechnical industry?
It’s a crucial thing for us. We’ve been trying to tackle the problem of people supplying cables that are non-compliant in the market, or are under-spec, or don’t meet British Standards for a while. The biggest problem is that there’s no legal framework. So if someone makes a copper conductor slightly undersize, they can reduce the price to be more competitive, even though they’re effectively cheating. But unless it’s dangerous, they’re not breaking any law. So if you go to Government agencies and say, ‘Look, these people are cheating’ there’s nowhere to take it because they’re not breaking any regulation or law. With CPR, when people declare a performance in terms of reaction to fire – ie is it low smoke or zero halogen – if they’re not complying with what they declare, they’re breaking the law. That’s quite powerful, because it means you can take action to stop people cheating or putting in sub-standard cables. Its aim is to ensure that products are safe, and also helps those with less technical knowledge. It means we can say: ‘This cable meets this performance, and here’s the legal document – the DoP – to prove it.’ So at least they know they’re complying with the law without having to be a technical expert on fire performance and cables.
What were the problems before CPR?
There was a lot of under-sizing, with people putting less copper in. So we saw one significant example where someone was claiming a cable was 2.5mm conductor when it was much closer to 1.5mm. Yet they were still marking it and selling it as 2.5mm. There were also lots of issues with people claiming a cable was flexible and low-smoke. Yet when you looked at them, they were just enhanced PVC, so if you burned them they would give off dangerous toxins, chemicals and halogens. A lot weren’t flexible either, so if you put them into the flexing test, they would break or shatter after only a few bends. And when we found these cables, they just weren’t marked. They were on plain reels, with very vague printing; you couldn’t tell who’d made them or who was supplying them. There was no way of taking anything back to take any action against anyone.
Again, this is where CPR helps – now, everyone in the supply chain has a legal obligation to make sure cables are compliant, with the name and address of the manufacturer. Everything becomes traceable.
Are there any other advantages?
If you pick up a reel, there should be a number on it that allows you to get the DoP. So you could go to our website, put in the number and it would bring up all the technical claims we’re making about it, such as the reaction to fire. And if you wanted, you could get that tested. So you could go to Jeremy at BASEC and say, ‘Somebody’s saying this cable performs to this level. Could you do a test for us to check it?’ And if it meets it, great, but if it doesn’t – and we’ve certainly found cables that don’t – they could come back and say, ‘No, it fails.’ And then we know who to take action against. Again, when people are importing cables, whoever the importer is also has to put their name and address on it. So if you had a cable made in Saudi Arabia for example, as an importer I would have to add my name and address so that people could also identify who the importer was.
What kind of impact have you seen?
The manufacturers have obviously all been trying to comply with it, but I’ve found that a large percentage of the DoPs are not correct. People aren’t putting the right information in and are filling them out incorrectly. Also, they’re not traceable, so people are just saying, ‘We’ve got a DoP for this product range’, but it doesn’t say what the range is. In the majority of cases, they’re not putting the individual numbers in that can then be traced. So there’s no way of tracing back from the product to the DoP. So where we’re finding examples of this we’re contacting the ACI and they’re taking action. We just want to make sure that if people are making a genuine mistake, that they go back and correct it. Obviously if all the documentation is incorrect, then effectively it’s not a legal document. So if you’re a wholesaler and you have a document that isn’t correct, then technically you’re not complying with the CPR. And I’m not convinced that all the wholesalers are actually checking. I think they’ve taken a head office approach and just written to the manufacturer asking them to make sure they’re CPR compliant, but not actually made detailed checks about the DoP and made sure everything is correct. They have legal responsibilities and they need to be sure that they’re executing their side of the bargain.
What impact will it have on day-to-day working in the electrical sector?
It gives people additional confidence in the products they’re buying. Particularly after the Grenfell fire, there’s a lot of uncertainty. People are thinking, ‘Am I doing the right thing?’ At least now they can say, ‘I bought a product and it’s CPR compliant.’ This is all about fire safety, so it gives them an extra bit of security. As long as they are asking for CPR-compliant cable, then they’re showing that they’re trying to do the right thing. Everybody needs that bit of security.
And what are the next steps?
Going forward, there are two things. The first is, how do we police it to make sure people aren’t trying to cheat or put in cables that don’t perform? The other thing is, how do we take it to the next stage? So we have things like the IET Wiring Regulations and British Standards, that refer to technical tests like heat release, flame propagation and low smoke, which are all very different to the tests that have been put into the CPR. So the next stage is, how do we incorporate CPR into all the existing standards and wiring regs? We just need clarity in the market, so people can say, ‘If I’ve got a low-rise building, I do this. And if I’m going into a high-rise building, with complex evacuation, what level of performance do I need?’ If you’ve got a single-storey building, then a 20-storey building, fire performance suddenly becomes a very different issue.