Construction Fixings

Whereas the issuance of the ETA is the responsibility of a TAB, designated by a European Member State, we use the scientific and technological expertise of our members – the Technical Assessment Bodies (TABs) – to document the assessment methods and criteria used and mutually recognised amongst our members and ensure publication in the Official Journal of the European Union (OJEU), as well as make the EAD publicly available.

ETAs are needed, alongside the Document of Performance (DoP), for the CE Marking of a construction product not or not fully covered by a harmonised European standard (hEN). As such, we work in close cooperation with the European Commission, the various Member States, EFTA, European standardisation organisations, stakeholders and research bodies.

EOTA is now structured to face the challenges defined by the Regulation (EU) No 305/2011, CPR, which fully entered into force on 1st July 2013. EOTA had to turn a new page and re-establish itself accordingly, but goes on supporting innovation in Construction. In this new context, EOTA prepared several guideline documents to facilitate and ensure consistency in the activities of its members. The biggest challenge was the mind switch from a directive to a regulation and no longer issuing Approvals but developing European Assessment Documents as a basis for ETAs. The manufacturer is now responsible for which characteristics it wants to declare for the free circulation if its product is available in Europe.

The ETA concentrates on the performances of the product, of those essential characteristics agreed by the manufacturer and the TAB, for the declared intended use. It also includes the technical details necessary for the implementation of the system of assessment and verification of constancy of performance. It is like a technical file synthesis supporting the declaration of performance (DoP) of the product. Where the EAD explains the ‘how to’, the ETA is about the results: What is the performance of the product? What has the manufacturer done to ensure consistent performance and conformity in performance and in the manufacturing process? Also, an EAD may concern several products from different manufacturers, while the ETA is awarded to a single product from one single manufacturer.

Also set out in the CPR is the issue of timings. Manufacturers had been looking for a fast track assessment of their products. Through the EOTA/ETA route it can be completed in a matter of a couple of months, with a maximum delay of nine months. The streamlining and designing of an efficient procedure caused some implementation delays during the start up phase of the CPR. These are now out of the way thanks to a better understanding between the Commission and EOTA on how to address and interpret some specifics within the new regulation. This debate will remain alive as long as all articles within the CPR are not mutually understood amongst ALL stakeholders. Fortunately the issuing time is now under control and manufacturers can expect effective, in time, results for the issuing of their ETA based on the EOTA adopted EADs. The citation of the EADs in the OJEU is within the remit of the Commission. The EAD is a legal document, owned by EOTA, developed by the TABs, free of charge, for the benefit of the construction industry (especially SMEs) and the free internal market.

As a consequence the added value to the industry is that the ETA is a document providing information on the assessment of the performance of a construction product, in relation to its essential characteristics, and is a way for manufacturers to affix CE Marking to a product. An ETA can be issued if the product is not fully covered by a technical specification such as EADs or harmonised European Standards (hENs) and is valid indefinitely. It is being observed that the ETAs create confidence in the performance of the essential characteristics of a construction product for its intended use, which contributes to the free movement of construction products and thus the Single European market. Beyond Europe, we know that CE Marking is well recognised in countries and regions where they have no national system, such as countries in the north of Africa and South America. For example, the ETAG for anchors is widely referred to around the world from Japan, China, Australia, and the USA and beyond.

Under the CPD the Approval Bodies issued more than 4,000 European Technical Approvals (ETAs) from 1998 til 2013. The ETApprovals will disappear from the market throughout 2018 as their validity expires. The interest of manufacturers in obtaining ETAs increased significantly since the last seven years and even more so since the CPR came into force. As from that date, 1^st July 2013, already over 2,200 ETAs have been issued of which half are related to fasteners. Experience demonstrates that ETAs support building up confidence in the fitness for use of construction products on the European market. By serving the interests of manufacturers, mostly SMEs, of construction products not covered or not fully covered by harmonised European standards, EOTA will continue adding value by enhancing best practices and developing Technical Reports. For instance, the CPR doesn’t provide for the ETA to ensure the installation of the product concerned. It’s up to the manufacturer to make sure the adequate procedure is being recommended. This is where both the CPR, and as a consequence EOTA, invites for a performance based paradigm where all involved take up their responsibility.

However, there are many instances where design rules occur in product standards and CE Marking relates to the relevant product standard or ETA. Pragmatically some design issues are very specialist and would sit uncomfortably in the main standard. The compromise being debated is that the design clauses in a product standard should be listed in an Annex of the product standard and where there are inconsistencies, the DoP should perhaps state whether the design standard/specification or the product standard has priority. There are bound to be teething problems! But clearly the designer must be able to determine how the product has been designed and how it’s being used, resulting in a performance way of thinking to the benefit of society as a whole.

Many designers and suppliers are happy for products to be supplied and used as long as they conform to the technical information the manufacturer provided and upon which the specification or design had been based – it would be the manufacturer’s responsibility if the product did not perform. Product liability rules will always apply. No one would want that situation to change. The CPR affects the whole supply chain – manufacturers, importers, distributors, suppliers and users. National manufacturers and suppliers will pay heed and will go through the pain and expense of acceding to the CPR and CE Marking. It appears that no one can be really certain of their position until the situation is tested in the courts. In the meantime manufacturers, as well as EOTA and its members, are aiming towards industry best practice.

For any area that needs improvement, the first step is to replace commodity based standards with performance based standards. ‘Performance’ in the construction sector always relates to ‘total building performance,’ so that, even though you can talk about the performance of a component part or sub-system, it must be measured in relation to the performance of the total building system or the whole construction works. The purpose of CE Marking for construction products is the same as for any other product with CE Marking. It is to demonstrate that the product is safe for its intended purpose, and that the manufacturing methods can be trusted. The CPR seeks to clarify the affixing of CE Marking and introduce simplified procedures enabling costs borne by business, especially SMEs, to be reduced and to impose stricter designation for organisations responsible for assessing the performance of construction products and the verification of the products’ constancy.

Every industry has standards and measures, and every industry organises itself around its basic units of measure. In the industrial paradigm, the unit is cost of parts and services (which, in the end, is only one aspect of true value, which includes qualities like sustainability, functionality, efficiency, etc). As long as buildings are planned and built according to cost units, they will function at the lowest value within a specification. Within the CPR, the EOTA organisation is aiming to develop tools and methodologies allowing for performance to become the fundamental unit of building and enhance the safety, health and sustainability aspects of construction works at the same time. By doing this all planning and construction will reorganise itself to produce the highest building performance for the lowest cost.

The introduction of the CPR invites the industry to produce innovative, cost-effective, and high performance buildings using innovative products with CE Marking within the period of nine months following the ETA route. Once performance measures and standards are operating, the industry will reorganise itself to meet performance objectives. Like other high performing industries, construction will integrate and consolidate, and will be able to pursue the capacity development and application necessary to support premium research and development. The meaning of CE Marking could become a driver.

When production and procurement revolve around total building performance (instead of component commodities), all purchases, designs, contracts, etc, are chosen for how well they contribute to the overall performance of the building system.

The benefits of this practice are twofold:

1. Over time, exclusive focus on performance leads to increased quality, which leads to increased productivity, value and reduced costs.

2. Working within a performance based specification means innovative alternatives are encouraged because whatever system or combinations of systems best perform that function wins.

In this way, performance based value, embraced by the EAD and its extensions, opens up procurement and production to all sorts of innovations that commodity based procurement discourages.

Innovation in construction will continue to be severely hampered until the industry makes the performance paradigm shift. With the focus on outcomes rather than specifications, performance based regulations are better equipped to take advantage of market capabilities to quickly and appropriately respond to changes, pressures and threats impacting the built environment – without compromising core objectives of health, safety and welfare. This includes adapting to such factors as changing demographics (aging population, percentage of persons with disabilities – permanent or temporary), sustainability (energy performance, materials usage, carbon footprint), resilience to extreme events (driven by climate change, acts of malice or other), and rapid changes in technology and practice, which could result in defective design or construction (inadequate ventilation, plumbing cross-connections, leakages, lose anchors, etc).