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consultations Political interventions Defending SMEs' interests Projects Seminars Events Collaboration with the Commission
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With 11.8 million operatives directly employed in the sector, it is Europe 's largest industrial employer accounting for 7% of total employment and 28% of industrial employment in the 15 EU-Member States. It is estimated that 26 million workers in the EU-15 depend in one way or another on the construction sector. Construction is also an important sector of the economy in new Member States. In Poland, Czech Republic and Hungary alone, the turnover was about 38 billion Euro in 2003 and the market is estimated to be growing significantly at an average rate of +4.2% per year.
Micro enterprises (1-9 persons employed) generate on average 33 % of turnover (based on data available for 22 EU countries, Bulgaria and Romania) with great varieties in the construction industry in the different Member States accounting for the higher share in Italy (58 %) and the lowest one in Lithuania (6 %). 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. Giuseppe Iotti, appointed expert of NORMAPME in CEN TC 10, owns a lift company, and is supported by EFESME, the recently created European umbrella association representing SMEs in the lift sector. The main standardisation activities are now taking place in WG6, which is working on the draft prEN 81-76 “lifts for evacuation of disabled people”. Although the discussion on this document is still in the early phase, Mr Iotti predicts it will raise a lot of interest in the near future. In addition, WG10 is working on the draft technical report prTR 81-82 “Accessibility for all to Existing lifts”. This document indicates several requirements in order to meet the needs of accessibility for disabled people. However, it does not yet provide clear technical solutions that would allow companies to adapt the existing product without replacing the lift. Another important and recent standardization item dealt with by TC10 is PESSRAL (Programmable Electronic Systems in Safety Related Applications for Lifts) as part of the annex A1 of EN 81-1/2. The document allows multinational lift manufacturers to introduce electronic devices in their product in order to control the operation of the lifts. According to NORMAPME expert, only lift manufacturers would have access to these devices and SMEs would not be to perform maintenance or reparation. EFESME and ELCA, together with NORMAPME, will raise this issue at the European Commission level in order to stop the introduction of the PESSRAL or to modify its rules and allow SMEs operating in this sector. 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 2009. 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. Hopefully, the revised version of the standard where Guidance Paper M provisions will be incorporated will come into force before February 2009. Hence, the cost of CE marking for SMEs will be lower. 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:
Hence, NORMAPME decided that its expert in TC 33 would also take part in the Working Group 5 dealing with issues on gates. Our expert Ms Agnes Thibault asked for an urgent simplification and revision of EN 13241-so that takes into account guidance paper M. This position was accepted and an according decision was adopted at the plenary meeting of the CEN TC 33 that took place in Bucharest on 26th and 27th April 2007. CEN TC 127 At present, the fire regulations move from national to European level. Up to the year 2010 all European level standards for timber construction should be completed. All national design codes are to be withdrawn by 2010. They will be replaced by uniform European design standards (Eurocodes). This standardisation work must take place in close coordination with the SME enterprises, in order to consider the needs of the industry, especially the needs of the SME sector. This working process is to the advantage both of enterprises and structural engineers. The TC 127 is of interest for all as it is one of the horizontal TCs across all construction areas, wood or else. It is covered by Mandate M/88 and its recent update - Mandate M/385 that covers the continuous glowing testing. This was recently adopted but causes a problem as it extends the testing beyond insulation products and that was never to be done. NORMAPME is together with DIBt preparing a position against this extension into unnecessary and costly extra testing for SMEs. In the fire standardisation the main focus is based on the reproducibility of test results. For example the guidelines for ventilation and fume outlets are to be concretized. We strive for using a maximum of existing tests not invents new ones. This is essential to make the fire classification faster available and make them comparable in all European countries. NORMPAME expert Mandy Peter follows the most important Working Groups for the SMEs i.e.
CEN TC 128 Our expert in CEN TC 254, Mr Detlef Stauch works since recently 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. CEN TC 128 in relation to EN 14509 Sandwich Panel adopted the arguments of TC 128 SC 11 (SC11: Double skin metal faced insulating sandwich panels for roofing and cladding)and send out a draft resolution to agree that an extension of the co-existence period is necessary for the following reasons:
Taking into account that this situation may cause important difficulties for manufacturers concerned, TC 128 SC 11 decided to instruct the CEN TC 128 secretariat to ask the European Commission for an extension by 9 months to obtain a co-existence period of 21 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 Timber construction SMEs alone make up for 15% of the whole construction industry in Europe. Having as our member EVH (Europäische Verband Holzbau) and EBC (European Builders Confederation) NORMAPME represents over 80,000 companies in this field. CEN TC 175 is relevant to joinery, accounting for 280,000 SMEs in Europe. Standardisation work in this sector is of high importance as standards help to comply with the commonly required CE-marking. One of the main issues in question was related to stairs. It has become clear that the production of traditional solid wood staircase as produced by the carpenter shop for single orders is outside the present regulation for CE-Marking and the CEN and EOTA standards or guidelines. However, these staircases have been made in a traditional manner for centuries. After the meetings with CEN, DG-Enterprise/Construction and circulars in this respect a conference was organised where we invited the main experts form our members (Germany, Austria, Italy, France, Belgium) as well as members from CEN management, TC 175 secretariat and the European Commission, etc. in order to find a solution for the standard strategy. There was considerable debate and opposing views.The majority of our members spoke against the creation of another standard for such single order wooden stairs as it would in their view only lead to constraints and the need for CE-Marking without justifying higher costs not even able to pass them on to the customer. Traditional carpenters would be excluded from a market which is now satisfactory for customer and workplace and this for no good technical reason. The standards are still under development. Besides, many standards concerning timber products are currently under the process of 5 year revision. The review shows that most of the standards are generally accepted on the market and used for a long time. Consequently, not many significant changes are expected. CEN TC 217 The old tyres are ground up and a large part of it is recycled by incorporating the ground rubber waste in the sport surfaces. There is growing pressure from the large plastic and rubber suppliers to replace this recycling material by virgin rubber, a move that is the reverse of what should be done if we want to increase the percentage of recycled rubber. The priority of TC 217 is to standardise a series of test methods to determine the desired properties of sports surfaces, of a variety of constructions that are important to the performance of the surface and to the protection of those performing on the surface. There are many national standards in this area that are often hard to compare with. There also many doubts which test methods represent the real field situations. Current discussions focus mainly on tests concerning leaching, VOC’s and dust. In addition WG6 aims at incorporating elements of environmental compatibility into the CEN Standards currently being produced and future standards to be produced. Thus, the work of this TC requires a close follow-up to see if the proper norms and testing methods are accepted. The role of NORMAPME and our expert is to minimise the frequency of sampling and testing to limits of scientifically acceptable sampling 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 SME’s. So far the meetings of the TC focus more on the information exchange and no significant positions have been taken. 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. 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. 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. 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. Enjoying more than 70% share of the European flat roofing market, bitumen membranes are estimated to cover annually over 200 million square meters of roof area. They are installed by a workforce of over 40 000 trained applicators. Considering the importance of these standards and the number of SMEs in this sector, IFD, one of the most representative international sectoral SME associations active in 15 European countries, has become a member of NORMAPME to work more effectively on European and international standardisation. Originally, both the requirements and tests were different regarding products and applications in all European countries. The bitumen and plastic sheets are used for waterproofing, but waterproofing is done differently in various countries. Not only the products are different but also the methods of ‘laying’ vary. It is however necessary to ensure responsibility for the final performance. All changes will have an impact on the results and with these results one can also influence the market. The CEN TC 254, whose work is followed by our expert Mr Detlef Stauch, decided to develop test methods relevant for all waterproofing sheets and other application related requirements. The committee has aimed at not excluding the established products from the EU-market. However, there are still some problems arising from the decisions of the Commission mainly regarding fire issues as well as health and safety regulations. All these problems should be solved during the next revision of the standards and, as a result, the drafted product standards should no longer be delayed. In April 2006 the Member States were informed that a mandate had been given to EOTA to work on inverted roof kits despite the risk of useless costs for thermal insulation producers and the users’ objections to the idea of having an EOTA guideline (ETAG) on inverted roof kits (as both products of the so-called kit are already subject to CE marking and there is presently no manufacturer of these “kits”). The ETAG should have been made available in December 2006, but nothing happened. NORMAPME will oppose the approval of this ETAG at European Commission level and at the SCC as an ETAG on inverted roof kits is against SME interests by duplicating tests (components of the kit are already tested). On the latest meetings TC 254 SC1 was discussing the amendments of EN 13707 i.e. the product standard “Flexible sheets for waterproofing - Reinforced bitumen sheets for roof waterproofing – Definitions and characteristics”. Some of the identified issues need to be taken into account in the upcoming shortly revisions of standards that were in many cases published more than five years ago. Most of the product standards are available and have been published in the European Journal. The relevant test method standards have to be checked also. The requirement for “external fire performance” is still very difficult, especially due to the different understanding in every member states. In some countries, all tests available for special products have to be redone and this is neither acceptable, nor necessary and very costly. 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 3 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. 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). The draft for WI 00350004 “Environmental product declarations - Product category rules” is based on ISO FDIS 21930 and requires “liability and responsibility for the EPD” entirely from the manufacturer up to “any part of the life cycle”. The EPD may include “all life cycle stages, such as production, installation into a building, use and maintenance, replacements, demolition, recycling and disposal” (“cradle to grave”). For the stages where a manufacturer has no real influence his declaration should be based on possible fields of application. NORMAPME expert estimates from evaluation of the draft document that requirements for a manufacturer may lead to an endless and expensive paper work. He doubts that SMEs will be able to fulfil the requirements without additional consulting services. One has to expect some additional costs for manufacturers. The “liability and responsibility for the EPD” will surly overburden SMEs and the real consequences are not assessable at the moment. NORMAPME together with some other SME associations sent to the CEN TC 350 members & officials and to the European Commission a position paper presenting a tool that could help SMEs complying with theEPD requirements. The European Commission has answered in a way that makes us think that it understands the situation and is willing to take appropriate measures. CEN TC 350 agreed to liaise with CEN TC 351 "Construction Products: Assessment of release of dangerous substances". Therefore the same liaison will be organised within NORMAPME, as NORMAPME experts in both committees represent European SMEs. In addition there are numerous highly skilled experts in both NORMAPME mirror committees. 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. EOTA The ETAG standard approach by EOTA in this product range has been a long-standing problem for SME producers of building anchors, because of the CE marking scheme that required too long and costly laboratory tests. ETAG 001 and its following guidelines were created without the participation of SMEs and despite their objections. NORMAPME organised a campaign to change the ETAG 001. Although the guideline was improved as a result of our interventions, we requested EOTA to further change the guideline by simplifying it and better recognition of the interests of SMEs. Participation of our expert (Ms Barbara Sorgatto) in the Working Groups, in the BT and in the Construction Standing Committee will help to improve the conditions for SMEs. A simplified version of ETAG 020 on plastic anchors was elaborated by ECAP and then presented with our support to the EOTA WG, where it received positive opinions. At present we try to ensure the simplified guideline is accepted by EOTA TB and promote it as a general template of ETAG for products other than building anchors. |
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Email: info@normapme.com Website: http://www.normapme.com
