Apart from the regular representation of small business in the standardisation process, NORMAPME sometimes has to intervene beyond the forum of the Working Groups and postulate some changes in the functioning of the standardisation bodies or Technical Committees. These situations usually emerge as a result of some procedural flaws or inadequate adaptation of standardisation system to the needs of SMEs.

Below you can find described some of our concerns that stimulated our interventions.

• Thin multifoil insulation products

NORMAPME has been alerted to some problems for SME manufacturers resulting from the recent developments both in EOTA and CEN WG concerning the tests for thin multifoil insulation products. These insulators, which are exclusively produced by SMEs, are an innovative type of insulation made of layers of reflective foils spaced with synthetic wadding and foams. They insulate primarily through radiation, as opposed to traditional bulk insulation products (such as mineral wool or polyurethane foams) which operate through low conductivity.

In March 2007 a CEN TC 89 "Thermal performance of buildings and building components" plenary meeting took place. It was dominated by the representatives of large industries and big national laboratories and no SME representatives were present, but NORMAPME that had the observer's status. We were presenting new findings that were proving the inadequacy of traditional tests. Concequently we also lobbied for new, more relevant testing methods. However, the compromise to exclude multifoil material from the existing tests was rejected with a vote of 12 to 0.

On 16th April 2007, in parallel with the SME conference that took place in Stuttgart, NORMAPME organised a scientific colloquium to publicise research results for thin multi-foil reflective insulation products and to launch a research programme on these products. Several notified body's laboratories coming from the EOTA circle presented during this event their results on multifoil insulation material testing which were compared to standardised tests. According to BM Trada (UK), SFIRMM (Syndicat Français des Isolants Reflecteurs Minces Multicouches - Associate member of NORMAPME - FR), Sheffield University (UK) and the laboratory IBP Frauenhofer Institut ( Germany), thin multifoil insulation products insulate better. Their results confirm that traditional tests are applicable to conventional products but not to innovative products based on reflection and not conduction.

Despite these findings, EOTA and CEN TC 89 seem to refuse to accept this new scientific evidence, most probably in order to favour large manufacturers producing traditional insulation products. Certainly, tests under real conditions are more representative but might not be the most appropriate tests as they need a specific set-up. Laboratory findings on the other hand, have positive results as they do not take into account e.g. climate change. In order to confirm the positive test results for thin multifoil reflective insulation products a new round robin test has started.

NORMAPME has undertaken a campaign to protect SME interests and has initiated this major research programme. Our main requests include:

• Simplification of ETAG

European Technical Approval Guideline (ETAG) 001 is the first EOTA guideline on building anchors. It consists of 6 parts, 3 annexes and 2 technical reports, and foresees 12 CE options. After a 50% reduction of the tests it still has over 300 pages, full of cross references and overlaps, which are incomprehensible for SMEs without assistance of a specialist. Moreover, in order to know which requirements their products have to comply with, SMEs are obliged first to apply for an ETA at one of the few Approval Bodies. Since 2004 ECAP and NORMAPME has been working on a revision and simplification of ETAG 001 which has lead to a reduction of costs and the number of tests.

Based on a request of EOTA WG Building Anchors in September 2005 to re-write the EOTA guideline ETAG 020 on plastic anchors, ECAP, Politecnico di Milano and NORMAPME elaborated a complete revision of ETAG in 6 months. This revision proposed a new, dramatically simplified, clarified ETA and ETAG format. It was presented in April 2006 to EOTA General Secretary and to DG Enterprise at the European Commission. Both were in favour of a simplification of the guideline, and encouraged ECAP to inform Member States and EOTA members about this new format in order to create support for the process of simplification.

NORMAPME met twice with the management of EOTA and stated that it would give EOTA its full support in the simplification of ETAG's guidelines, starting from ETAG 020, if and when required. NORMAPME expert was promoting the simplified ETAG and managed to put it on the agenda of EOTA WG. During the November 2006 meeting EOTA WG expressed its negative position regarding ECAP technical proposals on ETAG 020. The given reason was that the same safety level of the current ETAG 020 would not be retained. Nonetheless, the WG endorsed the new simplified format of ETAG.

However, EOTA TB, during its last meeting on 6th February 2007, decided neither to consider the test reduction nor the new ETAG format exemplified by the ETAG 020. This decision cancelled the 10 month work done by NORMAPME and ECAP. Furthermore, the position of the TB is not quite understandable, as EOTA WG gave a favourable opinion on the new format.

NORMAPME secretariat has contacted the European Commission and EOTA to obtain from the EOTA TB a withdrawal of the above mentioned decision. So far we have received no response from EOTA TB and we keep trying to put the simplification back on the agenda.