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Horizontal organisations representing SMEs in EU policies: |
The Voice of Crafts and SMEs in Europe: |
The European association of young entrepreneurs: |
NORMAPME actions are both at strategic and technical levels. At strategic level, we are mainly active towards the European Commission, especially in the European Commission Construction Standing Committee. We have taken part in this committee since 2004. It is in charge of defining the European policy of the construction sector and approving harmonised standards. It meets twice a year and preparatory meetings are held prior to these events. On a more regular basis, we follow new releases of mandates and we provide input for the draft ones. At technical level, we are especially active in the following Technical Committees represented by our experts:
European Commission Construction Standing Committee (SCC) In the framework of this Committee, we tackled some specific generic issues. This Committee provided the discussion platform for the Guidance Paper M on conformity in the framework of the Construction Product Directive. In addition, in the SCC we managed to avoid the adoption of an ETAG on building anchors. Possible negative effects of this ETAG could be banned like this for the moment. Moreover, our participation can guide to subjects that seem important and appropriate to work on. Generally speaking, CEN provides a more favourable framework than EOTA for SMEs for the European Construction sector. CEN proves to be more open minded and standardisation committee members do not only represent testing laboratories. CEN TC 10 The lift sector is an oligopolistic market dominated by four companies, each accounting for 10% of the market share. 10-15 mid-size companies account for over 1% each of the market. There are over 3000 small companies. The sector employs 120.000 people. SMEs are mostly specialised in installation, maintenance, reparation and providing spare parts as well as in lifts for special users.
CEN TC 33 The market of doors and windows consists mainly of a few large companies and many thousand SMEs and craft enterprises. It reflects largely the general situation of the construction sector. Micro enterprises account for 93% of construction companies, whilst SMEs are responsible for 78% of the annual turnover and 80% of the workforce. Worldwide demand for doors and windows was up to $125 billion in 2004 (22% in Western Europe, 26% North America, 37% in Asia/Pacific and 15% in other regions). Market growth in developing countries will outpace demand in industrialised regions, although the intensity of product use will remain comparatively low in most developing countries. Construction standards, such as doors and windows standards are the basis for CE marking. On the one hand, large companies and test laboratories promote heavy conformity assessment requirements. On the other hand, SMEs need affordable and simple processes to have their non-series products CE marked. If custom made windows had to be fully tested in the same way as series production, a small window would cost more than 5 000€. External doors and windows prEN 14351-1 standard (external doors and windows) was a key issue for small and medium sized manufacturers of doors and windows, as far as the CE marking for custom made products was concerned. This issue combined, with the obscurity of the Construction Product Directive (CPD) article 13.5, led NORMAPME to ask for clarification from the European Commission. Consequently, the European Commission released the Guidance Paper M (GPM) on conformity within the framework of the CPD. The Guidance Paper enables non-series production to be CE marked without excessive testing and administrative burdens. Nonetheless, this draft standard was adopted unanimously at the end of 2005, but under condition of being immediately revised. NORMAPME members are extremely concerned about the consequences of this standard when its application will become compulsory, as from the 1st of February 2010. These concerns have unfortunately been confirmed and even amplified at the presentation of the results of the above mentioned study commissioned by the European Commission on the impact of the Construction Products Directive. Although the study does not give specific numbers it is stated that SMEs producing doors and windows will have to leave the market. Industrial, commercial and garage doors and gates According to the requirements of the contract with the European Commission, NORMAPME has to provide eLearning tools to help standard developers to understand SME concerns. Hence, it was decided to make a film on practical experiences. NORMAPME asked its members to provide details on SMEs, which face difficulties in implementing a standard. It appeared that EN13241-1:2003 (Industrial, commercial and garage doors and gates – Product standard - Part 1: Products without fire resistance or smoke control characteristics) is especially problematic. The film demonstrated huge difficulties small businesses face in coping with EN13241-1, namely:
The wood and wood products industry is faced with cyclical demands from other industrial activities, such as construction and furniture industries. These two downstream industries are highly influenced by the evolution of economical activity, income levels and interest rates. On a more long term basis the increased focus in the general public opinion on lower energy consumption, sustainable building materials and low emission production methods is anticipated to be of major interest to CEN/TC 124 and its stakeholders. The CEN/TC 124, whose work is followed by our expert Mr. Hugues Frere, will elaborate a set of European Standards in the timber construction sector including aspect of load bearing capacity being the primary topic of standards, and including durability and fire safety aspects by referencing to standards made by other TC´s. The CEN/TC proposes the following objectives and strategic directions for its future work: to draft and provide the harmonized standards needed for the implementation of the Internal Market and in support of the CE-marking in relation to timber products as defined in the scope to draft and provide the necessary standards supporting the European design codes. Because of the need for European Standards as a vehicle for the implementation of the Building Products Directive, priority is given to the preparation of mandated harmonized standards. Furthermore, in order to avoid duplication of work and avoid the creation of new technical barriers to trade, liaisons with ISO/TC 165 has been established. A NORMAPME position paper on the request for the extension of the coexistence period of Standard EN 14081-4 (CE Marking for Timber Structure) - available on our web site – propose the following issues to avoid extra costs for SMEs:
As marking of timber structure is a big issue for SMEs, we met the European Commission on the 2nd of September to find a solution to maintain economic sustainability of SMEs of the wood sector (http://www.normapme.com/english/newsletter.htm). The agreement that was reached at this meeting still needed to be worded in the draft standard. On the 8th of December, the CEN TC 124 WG 2 met in Paris and despite the strong opposition of certifiers against this agreement, an amendment to be sent for public enquiry was produced in line with the output of the meeting with the European Commission. For more information please contact Mr Lorenzo Accardo at l.accardo@normapme.com CEN TC 127
CEN TC 127 is of interest for all as it is one of the horizontal TCs across all construction areas. The TC with NORMAPME contribution has done a very successful work over the past years in the field of standards on the test methods for building constructions exposed to fire. Dr Mandy Peter, NORMAPME expert in CEN TC 127, has been following mainly WG 4 (Reaction to fire (focus on the fire resistance of constructions) and 7 (Classification (focused on the fire behaviour of building materials)) as they are the most significant groups for SMEs. In the fire standardisation the main focus is based on the reproducibility of test results. We try to promote the use of existing tests rather than inventing new ones. This solution is not only cheaper, but also essential for faster introduction of comparable fire classification in all European countries. For more information please contact Mr Rémi Orth at r.orth@normapme.com CEN TC 128 Our expert in CEN TC 254, Mr Detlef Stauch works also in CEN TC 128. According to him, this participation completes his activities in CEN TC 254. A huge number of harmonized standards have been drafted or are in preparation. SMEs need these harmonized standards. CEN TC 128 is working in 11 subcommittees. During one of the CEN TC 128 plenary meeting it was requested to add to the work programme two new items dealing with light transmitting single solid flat polycarbonate sheets and light transmitting flat multiwall polycarbonate sheets. These two new standards for products are helpful to obtain products fit for use. This also gives more security in production and use. Referring to the absence of guidance on mounting and fixing in accordance with EN 13823 and taking into account that this situation causes important difficulties for manufacturers concerned, the product (EN 490:2004) standard had to have the coexistence period extended. NORMAPME supported the request for the extension of coexistence period of EN 490:2004 and EN 14509 by 9 months. In addition, TC 351 wants to facilitate and organize the answering to the questionnaire on dangerous substances. Subcommittees were requested to consider the information need and to formulate a response, permitting the working group to develop a consolidated response. CEN TC 156 - VENTILATION FOR BUIDINGS According to the Commission's calculations the buildings sector accounts for 40% of the EU’s energy requirements. Therfore, there is a huge potential for energy savings, by elaborating ambitious standards to new and refurbished buildings. The Directive on the energy performance of buildings (EPBD) has been in force since January 2003 and has an important impact on the national legislation in the Member States regarding the inspection of installations and energy performance of public, commercial and private buildings. Within the transition period of 3-6 years depending on the article all the Member States should have proper building legislation in place requiring energy performance improvements and inspection of boilers, heating systems and AC systems. In most of the Member States these services are mainly delivered by SMEs. The overall turnover of such companies (with an average of 5 employees) represents within the EU about 200 billion Euros. CEN has drafted several standards to help the member countries implementing the directive. The main objective of our expert, Mr Jaap Hogeling is to assure the coordination between various standards drafted in TC156 and TC228. One of the most important standards for SMEs is the “Criteria for the indoor environment including thermal, indoor air quality (ventilation) light and noise”. This European Standard specifies the parameters of impact and/or criteria for indoor environment and how they are used to meet the intent in the EPBD. The standard specifies how to establish indoor environmental input parameters for the building system design and energy performance calculations. The standard also specifies methods for long-term evaluation of the obtained indoor environment as a result of calculations or measurements. More precisely, the European SMEs’ interests are seen in the following areas: Our expert has already produced training material used to prepare SMEs in the sector for the upcoming new calculation systems. Currently, there is a discussion on the interest of ISO TC163 and 205 to take over the CEN work items on the EPBD standards. This shift of standardization body could benefit SMEs producing HVAC systems and components and specialised building products. In addition, a draft standard prEN15603 is under development. It is an umbrella document, harmonising a set of standards and definitions used in these. Harmonising symbols and definitions is an issue of great importance for SME’s as they produce the Energy Performance Certificate or are involved in improving energy saving measures. CEN TC 175
NORMAPME expert, Mr Ralf Spiekers, represents the German Association for Timber and Synthetic Material and follows the development of standards in both CEN and DIN. His work focuses on CEN/TC 175/WG3/TG7 that deals with normalization of wooden stairs and his main objective is to ensure easy CE-marking for SME producers of traditional timber stairs. TC 175 has fostered its work on a non-harmonised voluntary standard for traditional wooden stairs. For the moment the standard is not foreseen to contain the Annex ZA and therefore it will not be possible to CE-mark the staircase on the base of this standard. Since this approach was very controversial, NORMAPME tries to inform constantly the stakeholders from different countries about the developments in the work. The main controversy arises from the pressure of some parties to obtain a possibility of the CE-marking for traditional designed stairs from solid wood. These parties argue that craftsman production is at disadvantage because the industrial and design stairs have the CE marking on the basis of the EOTA guidelines. It has been argued that the market demand for CE-marking may arise i.e. consumers will ask for a proof of conformity with safety requirements. On the other hand most of the interested parties showed resistance to create a standard for single made wooden stairs as it would in their view only bring additional constraints and increase costs that would have to be passed then to customers. Traditional carpenters would be most likely excluded from a market without any good technical reason. Nowadays, the Guidance Paper M of the European Commission stipulates that single orders are outside the CE-Marking which supports the arguments of CE- opponents. Besides, CEN works on a set of other standards that are going to cover solid wood timber stairs. We have been closely following their development, but so far we have not seen any major problems that could arise for SMEs from this standardisation activity. CEN TC 217
The priority of TC 217 is to standardise a series of test methods to determine the desired properties that are important to the performance of sport surfaces and to the protection of those performing on them. Current discussions focus mainly on tests concerning leaching, VOC’s and dust. In addition WG6 - Synthetic turf areas aims at incorporating elements of environmental compatibility into the CEN Standards currently being produced and future standards to be produced. Our expert Mr Frank Kempeneers actively participates in the work of WG6 TG1 ‘Environmental Aspects’ which debates on a standard on leaching test for artificial turf systems. There are various national standards in this area and the incorporation of particular tests in the final document and the definition of monitoring frequency for each compartment involved in testing can strongly affect SME companies from this sector. The aim is to get a standard which adheres to national environmental legislation, if possible, and to minimise the frequency of sampling and testing to the limits of scientifically acceptable schemes in order to keep the EN norm affordable. Due to the wide range of costly tests on environmental and health issues involved, there is a potential risk of significant costs for SMEs. During the meetings of the TG1 various tests were endorsed by the national delegations. Our expert backed by NORMAPME presented a position paper regarding a Dutch research on health and environmental aspects of rubber infill from recycled tires. The document concluded that the leaching of all components listed in the Building Materials Decree would not exceed environmental limit values, with an exception for zinc. However, currently there are no tests or research available that would include the impact of aging and weathering and as a result the existing tests may not actually reflect reality. Therefore, Switzerland, France and the Netherlands decided to conduct lysimeter tests to check again the leaching of zinc in a more comprehensive way. The final results of the tests indicate that there is no danger for environment because of the leaching of zinc. Nonetheless, the applied testing method needs to be validated so that it could be put in the standard. Validation of testing requires a lot of preparatory work and is quite expensive. Therefore NORMAPME expert tries to create an inventory of costs for relevant round-robin testing before starting to look for the funds. In addition to this activity we also follow the documents distributed in CEN PC 366 – Tyre recycling working on the standardization of the materials produced in the tyre recycling cycle and – at the same time – of their utilization in specific end uses market sectors (applications). Luckily, for the time being there are no major concerns for us related to the developments in this Project Committee. The scope of this TC covers a wide range of aspects including gas installations, supply systems, pressure testing, gas regulation, gas compression and industrial piping. Large companies often operating at a national level dominate the market of gas supplies in Europe. However, SMEs are traditionally very active in the market of domestic gas installations. In Europe there are a limited number of large and medium size companies operating in gas installations for domestic use, whilst small and micro businesses represent over 70% of the market share. Thus, due to this particular market structure, SMEs operating in domestic gas installations fear that large gas supply companies take advantage of technical and administrative constraints imposed by European standards, in order to gain important shares in this market. In the light of these considerations during the spring 2006 NORMAPME appointed Mr Pem Kubbe as expert in CEN TC 234. Mr Kubbe, nominated by UNETO VNI, the Dutch association of gas installers, has a long experience in gas supplies and runs his own small business in the sector. NORMAPME expert monitors WG 1, dealing with gas installations, as it is the field of application most relevant for SMEs. Mr Kubbe pointed out that according to prEN 1775 the maximum operating pressure in buildings is fixed to 5 bar, while the normal pressure in buildings is usually lower than 100 mbar. Such condition could harm small companies that do not have the right equipment to install those gas installations. However TC members reassured Mr Kubbe that this condition is only due to the particular situation of certain countries, namely France and UK, where the distribution systems are build partly inside the buildings (under the responsibility of the gas delivering company). In addition, WG 2 - gas distribution is also to our interest. This working group will address the issue of “rapid crack propagation” of PE systems. The issue of responsibility arising from this topic could have consequences on many small companies. Furthermore, WG 8 that is in charge of industrial piping is followed by our expert as it deals with the harmonisation of the use of materials and their definitions. These items are in common with WG1 and WG2. Our expert also participates in WG IGI on guidelines for Industrial Gas Installations. Moreover, Mr Kubbe is also member of a Marcogaz / GCI-UICP joint group that conveys the opinions of industry of the gas sector. Recently the group approved a document, named “Recommendation on Safety of Domestic Gas Installations” that gives guidelines to installers on how to handle their cross border activities. These recommendations were also presented to TC 234. The question is debated within the TC on whether it would be useful to create a WG on Domestic Gas Installations. As it was confirmed by TC 243 members NORMAPME is the first SME representative organization that participates in this standardization work. In light of this situation one can judge as positive the fact that since 2006 NORMAPME expert is involved in the activities of several WGs and tries to be more influential through its participation in the Marcogaz / GCI-UICP industry group. However, at member state national level there is still need for raising awareness about standardization among SMEs and their organizations, and consequently NORMAPME’s position in the TC remains isolated. The revision of the drinking water directive will have important consequences on the industry and needs close monitoring. CEN TC 254 Flexible sheets of waterproofing standards affect roofers and manufacturers. SMEs represent users and manufacturers of these products. Worldwide demand for roofing materials is forecast to rise by 2.7 percent per year through 2008 to nearly seven billion square meters, with a value of almost US$48 billion. For each application a separate standard has been drafted. This has been done because of the relevant mandates of the commissions. A lot of products can be used for different applications. As result the producers have to mark and label one product for different applications. This means more than one related standard and sometimes different tests and different AOC. The aim objective is to have not anymore application standards but product standards regardless of their application. CEN TC 350 Environmental measures are high on the political agenda and up to now SMEs have been less involved as many exemptions existed. Considering the exhaustion of consumable energy resources and the waste issues, it seems obvious that industrialised societies will need to find solutions to save energy and to recycle products. Construction appears as a sector where many environmental improvements can be made. In addition, it will concern essentially SMEs due to the structure of the sector. This committee, which has been recently created, will draft a series of standards and technical documents supporting the mandate M 350 on the integrated environmental performance of buildings. NORMAPME identified the interests of many of its members that could be affected while drafting this set of standards. In order to follow the CEN TC 350, Mr Frank Koos has been appointed as NORMAPME expert. This TC is composed of 5 Working Groups CEN TC 350 WG 1 Environmental performances of buildings, CEN TC 350 WG 2 Building Life Cycle Descriptions and CEN TC 350 WG 3 Products Level, CEN/TC 350 WG 4 Economic performance assessment of buildings and Working Group 5 Social performance assessment of building. Mr. Koos is following four of these five groups and one task group which are developing Standards in different fields, particularly: TG Framework: General Framework and Environmental Performance assessment of buildings. WG 1: Assessment of environmental performance of buildings - Calculation methods and Use of environmental information from environmental product declaration (EPD). WG 3: Product level - Environmental product declarations (EPD). WG 4: Economic performance assessment of buildings. WG 5: Social performance assessment of buildings. The most relevant activities for SMEs took place in the framework of CEN TC 350 WG3. It was related to the Environmental Product Declaration (EPD). In February 2010, Mr. Koos issued a position regarding the validity of EPD and the +-I0 percent rule for review vs. cut-off rules at building level assessment. This position was circulated for comment to the TC 350 Working Group members ahead of the CEN/TC350/WG3 meeting on february22/23, 2010. - Data is provided in form of EPDs to be used at building level assessment. Construction Products are used in their intended use, as part of that building. TC350 agreed that EPDs should not be used for product level comparisons, only for building level comparisons. - Considering this, how can +-10 percent for EPD review be justified? There should be evidence that a certain product has a significant effect on the impact at building level. Otherwise we make wrong decisions at product level especially when the product's technical characteristic is playing the main role at building level during the life time, as is the performance of e.g. insulation material. The environmental impact of that product's product stage has no meaning. - How can a manufacturer monitor this +-10 percent rule? Who is responsible for the reaction to the rule? This is an extra burden for SMEs, who do not have the capacity, be it through resources or know how to comply with the rule. - Only a comparison at building level could reveal this need for this review, again remembering the aim to use EPD data only at building level. - In practise many, very many construction products can claim in the future that their impact (product stage), considering the life cycle approach, is meaningless. We find this issue tricky but it must be discussed. - The last concern is that of the real uncertainties and variations in LCA calculations. Consultants are not willing to discuss it but that will take place sooner or later. Manufacturers are tight with strict rules but there is no responsibility of consultants. CEN/TC350/WG3 empathized on the issue and concluded that it is therefore informative, not mandatory and shall give only some guidance to the user of the standard. It was decided not to remove the note. But the text of chapter 9 was changed in accordance with ISO standards into: “An EPD is valid for a 5 year period from the date of issue, after which it shall be reviewed and verified. The process for verification and establishing the validity of an EPD shall follow ISO 14025 and ISO 21930.” CEN TC 351 Committee 351 aims at the development of test methods for release scenario of dangerous substances from construction products. Mr. Norbert Buddendick from the German Timber Council was nominated NORMAPME expert on this Technical Committee. The members of NORMAPME have shown the interest in this subject, because the standardisation work will regard the intended use of a product. The deliverables will not concern the contents of substances in the item itself, but the release scenario of the products e.g. when working with them on work sites. At the moment, a number of Member States (MS) have their own regulations on dangerous substances. This situation results in different testing methods and in consequence in mounting costs for industry since mutual acceptance of test results is not possible due to the differences in test methods. In addition, SMEs are affected by health and environmental regulation as they have hardly any capacity neither to change the products, production method, raw materials nor to prove whether their products are fit to be used. In this matter SMEs hope that a concept of WT (without testing) or WFT (without further testing) will be a helpful tool. As a result of TC 351 work a list of substances to be approached has been developed. NORMAPME has sent it to its members. This way, NORMAPME members could verify, whether their products, releasing some chemical substances, would be subject to the new tests methods, and if needed, join the work. Furthermore, a study is conducted to provide information about barriers to trade. Any difficulty of a producer exporting his construction products to another Members State because of differences in regulation regarding the environmental aspects of the product should be regarded as a barrier to trade. On the other hand, some committee members raised opinions that it is not only the regulation of MS but the one of European Level also. NORMAPME Expert supported this opinion. At the moment examples of such barriers are being collected. On the basis of expert’s reports, NORMAPME prepared a circular with a list of examples, asking members to come up with the barriers they have encountered. The TC 351 working groups have made also progress in the subject of WT and WFT. Both: CEN committee and EDGS drafted already their opinions on this subject. The opinion of the CEN committee discussing both drafts is that the FT procedure (Further Testing) has been described too negatively. It should be possible to reduce particular measurements or evaluation in the FT procedure, too. NORMAPME is happy to hear such an opinion, and hopes that procedures of testing will be simplified. The other on going issue is related to the evaluation of a horizontal approach to assess the possible release of dangerous substances from construction products in support of requirements from the CPD. Following the assessment of the 1st related draft on the subject, we noticed the reality of the European market is not well mirrored. We estimate that many SMEs manufacturers will not be able to fulfil unnecessary testing that might be required by the standards developed in the Technical Committee. The development of new products will be hampered significantly and cause a decrease of the markets. EOTA
CEN TC 213 CARTRIDGE OPERATED HAND-HELD TOOLS - SAFETY
Although this TC deals with machinery our concern considered not the main product, but its components i.e. cartridges and nails. The manufacturers of Powder Actuated Tools tried to put in one standard “Cartridge-operated hand-held tools - Safety requirements - Part 1: Fixing and marking tools” safety requirements for their tools together with cartridges and nails. This situation could lead to a system “PAT+nail” with a risk of a barrier to trade on the nails market (there are independent manufacturers of nails for PATs that do not produce the tools), because large producers of PATs could simply impose their own requirements for the components and claim that only their products are safe to use with their tools. After several meetings and discussions it seems that the WG could reach a compromise and some technical rules for the nails would be included in this standard. This would provide a reference point for producers of the nails that would like to prove that their products are also safe to use. For more information please contact Mr Rémi Orth at r.orth@normapme.com |
with the financial support of the
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