Monday 11 January 2021

Why do fire shutters need to be CE marked?

All manufacturers of roller shutter products and components must supply the correct documentation and assessment data for CE marking to be applicable. It has been a compulsory requirement for CE marking of roller shutters since the introduction of the Machinery Directive 1995. 

As of July 2013, the Construction Product Regulations 2013 compliance and associated marking became mandatory for doors within the scope of BS EN 13241:2003+A1:2011. Doors with fire and smoke resisting characteristics were excluded from the scope at that time, from 2016 the scope was amended to incorporate these characteristics. 

Under the Construction Product Regulations (EU) 305/2011, the legislation requires “assessment and verification of constancy of performance for essential characteristic” of the product is a requirement. A standard roller shutter comes under the scope of AVCP system 3 & 4 and requires test evidence from a notified test laboratory for characteristics such as ‘Resistance to Wind load’ for external doorsets, ‘Safe opening’ with anti-fall back technology and ‘Operating forces’ are a minimum requirement. 

Under Article 36 of the Construction Product Regulations 2013, allows manufactures of components to have approved testing evidence to be cascaded but must be referenced correctly in the Declaration of Performance and technical documentation. Any manufacturer who desires to make use of the cascaded evidence for the compliance of their product, must gain written permission and details of the limitation from the component manufacturer. Once this technical documentation is obtained, the manufacturer must include this within their Factory Product Control file (F.P.C). SSS Industrial Doors Ltd use cascaded evidence for such components as the roller shutter lath or motors, this is referencing to such testing data is stated in the Declaration of Performance.

A fire shutter on the other hand comes under the scope of AVCP (Assessment and Verification of Constancy of Performance) system 1. Therefore, it is a necessary requirement that a notified body audit test the manufacturer prior to the furnace test being considered (BS EN 1634-1). 

Once the notified body observes a successful completion of the furnace test, a certificate of Constancy of Performance is provided. This certificate allows the manufacturer to produce, supply and install their fire shutters within the UK marketplace. 

Since the 1st November 2019, new legislation was introduced regarding the manufacturing, testing and installation of fire shutters. It is now a mandatory requirement that all fire shutters must be CE marked to BS EN 16034:2014 under the Construction Product Regulations (EU) 305/2011. The previous standard BS 476 part 22 (1987) is now a non-compliant and cannot be sold on the UK marketplace. 

The testing methodology for fire shutters has altered slightly, the furnace test (BS EN 1634-1) is a compulsory requirement which is observed and recorded by a notified body. A manufacturer of a fire shutter must supply the correct documentation and assessment data so that the product can be CE marking correctly. 

What is CE marking?

The CE mark is a conformity mark that is recognized worldwide. Primarily, the CE mark is only applicable within the European Economic Area (EEA). However, some countries also accept CE mark products due to the manufacturer’s declaration which states the product meets the EU standards for health, safety and environmental protection requirements. The CE mark is not a quality indictor for the product(s) or a certification mark. 

As a result of the United Kingdom’s referendum in 2016, which took place on the 23rd June 2016. The United Kingdom and Gibraltar asked the electorate whether the country should remain within the European Union as a member state or leave. The people of the United Kingdom voted to leave the European Union. Therefore, on the 31st January 2020 the United Kingdom left the EU27. 

Will CE marking still be applicable after the UK has left the EU27?

As of January 2021, the United Kingdom has left the European Union with a new agreement. As a result, CE marking will no longer be recognized within the GB marketplace after 31st December 2021. It will be replaced by the United Kingdom Conformity Assessment mark, commonly referred to as UKCA mark. 

UKCA marking will still be applicable for goods currently subject to the CE marking. The technical requirements (‘essential requirements’) for the conformity assessment processes and standards will still be required. The previous EU standards will become ‘designated standards’ within the GB marketplace and therefore will still have relevance and be required. 

All CE marked fire shutters manufactured within the United Kingdom will be recognized and legally compliant up until the end of the transition period. Once this date has passed, it will be necessary for fire shutters to be UKCA marked. 

All notified bodies, such as WarringtonFire, within the UK which were previously EU notified bodies will no longer be recognized. They will however be recognized as UK approved bodies and will be able to provide UKCA marked certification.

SSS Industrial Doors Ltd has pro-actively transferred their certification (BS EN 16034) from WarringtonFire Ltd (UK) to Elements Materials Technology (Rotterdam), which is the subsidiary company based within the Netherlands. As a result of transferring the fire certification, SSS Industrial Doors Ltd will be able to continue to CE mark fire shutters regardless of any potential agreement between the UK and EU27. WarringtonFire will also be able to supply UKCA marked certification once the transition period has begun. 

Is it possible to identify if a manufacturer can supply CE marked fire shutters?

BS 476 part 22 (1987) is no longer recognized for CE marking or UKCA marking purposes. However, it is still valid for existing products installed within the GB marketplace. It is not a requirement to replace existing fire shutters which were manufactured under this standard unless they operate without anti-fall back protection. If a fire shutter does not have a valid conformity mark (CE mark or UKCA mark) it is illegal to be manufactured, distributed and installed within the United Kingdom. 

Any manufacturer of compliant fire shutters will be aware of the testing procedure(s), documentation and regulations which are necessary for CE and UKCA marking a fire shutter. Prior to purchasing a fire shutter, it is recommended that the customer request a copy of the certification from the notified body which states BS EN 16034, ‘Declaration of Performance’ and ‘Certificate of Constancy of Performance’. Failure to provide the following documentation is evidence of non-compliant fire shutter. 

The notified body or UK approved body, who provided the manufacturer with the certification, will be able to confirm the validity of the certificate if required. Also, the ‘Declaration of Conformity’ will clearly state the classification of the fire shutter and include the certificates reference number. 

What documentation is provided to the manufacturer upon achieving certification?

A fire shutter is tested to BS EN 1634-1 at a notified body testing facility. However, due to the limitations of the testing facility it is not possible to test fire shutters that are installed on larger applications. Therefore, the notified body use data collated from the furnace test and calculate the necessary components required to increase the size of the fire shutter or integrity rating of that which was tested. The Extended Application Report (BS EN 15269-10), commonly referenced to as the EXAP report, is calculated by the UK Approved body and provides the manufactured with critical information on the components required for manufacturing fire shutters to the size required

Can a fire shutter be installed on a supporting structure for which a manufacturer has no evidence of performance?

It is not possible for a manufacturer to supply a fire shutter to an alternative structural type than that which was tested. Due to the structural type reacting differently whilst under fire conditions, the Extended Application Report (BS EN 15269-10) clearly states on Section J.1.2 that changing the structural type from a rigid to a flexible structure is “not possible without additional testing”.
If a manufacturer’s original fire shutter was tested to a masonry (rigid) structure, then the manufacture can only supply fire shutters which are only intended to be installed on a masonry structural type. The same applies to fire shutters which were originally tested to a timber (flexible) structure. Failure to provide additional test data for both structural types is evidence of non-compliance. 

If manufacturer has the additional test data for both structural types, which is necessary for a fully compliant fire shutter. The manufacturer must be able to provide this evidence prior to placing the product on the GB marketplace. Below are two extracts taken from the Extended Application Report which was provided to SSS Industrial Doors Limited by WarringtonFire upon ascertaining test data from both structural types.  
(WF Test No. 404452) The above extract is taken from the Extended Application Report for a Masonry / Concrete structure. This is commonly referred to as a rigid structure. 

(WF Test No. 429933) – The above extract is taken from page 22 of the Extended Application Report which clearly states that a Timber Stud Partition was tested. This is commonly referred to as a flexible structure. 

In-conjunction with the Extended Application Report (BS EN 15269-10) the building regulations compliance for CE marking is also applicable. The following information has been taken from approved Document B:

Any test evidence used to verify the fire resistance rating of a doorset or shutter should be checked to ensure both of the following:

a. It adequately demonstrates compliance. 
b. It is applicable to the complete installed assembly. Small differences in detail may significantly affect the rating.

Therefore, if a fire shutter is installed on a structural type which the manufacturer cannot provided evidence of additional testing or, fails to provide data which supports that the structure has been tested by a UK approved body. It would be in violation of section b and is therefore a non-complaint product and the persons responsible would be liable. 

SSS Industrial Doors Ltd recommends that any contractor/installer should ask to see the additional test data (an example is provided above) as evidence that their fire shutters are tested to both timber and masonry structural types. 

About SSS Industrial Doors

As one of the UK’s most reliable manufacturers of roller shutters and industrial doors, SSS is ready to meet the most demanding market needs. Based in the North West and operating from Red Earth Farm, Edgworth. SSS Industrial Doors can provide a quality service nationwide with short lead times and reliable after sales support.

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