Annex B - Costs for Fire Testing and Re-Engineering Construction Products

(i) Cost of Fire Testing

With respect to the costs of fire testing (and re-testing) construction products it is not possible to calculate a cost implication to a 'typical' company because of the wide diversity of the construction products industry. However, a cost model has been developed that attempts to illustrate the likely cost implications for product manufacturers in England & Wales. The key features of the model are:

• Data on the cost and number of both reaction to fire and fire resistance tests under both the current BS and the proposed new European standards was obtained from a testing laboratory.
• For the reaction to fire tests it is possible to say what the additional cost for testing each construction product for each of the required tests under the two regimes. It is therefore possible to calculate a range for the cost increases and a weighted average cost increase. The cost increase for testing non-combustible products to the new European standards amounts to about £1,500 (range £1,200 to £2,100), and for other products the increase is about £1,300 (range £1,100 to £2,000). These costs represent a 100% to 300% increase depending on the nature of the product and the ease with which it can be mounted and fixed.
• The situation for fire resistance tests is more complex because of the wide variety of test methods and products. The products tested include structural steelwork (which makes up the majority of tests/income), doors, partitions, floors and penetration seals. Compared with the fees for the equivalent British Standard tests, a manufacturer would have to pay typically 25-30% more for the European tests.
• A five-year time period was assumed during which the balance of testing moves from a majority of British Standard tests to a situation where all tests conform to the new European regime.
• The rate of testing was assumed to rise after two years to accommodate the need to re-test products that currently comply with the British Standard regime to ensure that they comply with the new harmonised regime once the transition period is over.
• The figures for the single test laboratory were then grossed up to obtain the national cost implication for England & Wales.

On the basis of this model it is estimated that the additional cost for the resistance to fire tests in England & Wales attributable to the new regime amounts to £2.5 million over 5 years discounted at the Treasury's 6% discount rate. (In other words, this is the cost that product manufacturers will have to pay above and beyond what they would have had to pay anyway.) Similarly, the additional cost of the reaction to fire tests amounts to £1.0 million over 5 years discounted at 6%.

Therefore, the total additional cost in England & Wales for construction product manufacturers using the new harmonised European fire tests amounts to £4.0 million over 5 years discounted at 6%.

The burden of extensive product testing can be reduced though, through the "Classified without further testing" (CWFT) regime. CWFT corresponds to the definition:

"Products which have been proven to be stable in a given European class (on the basis of testing to the appropriate EN test method(s)) within the scope of their variability in manufacture allowed by the product specification (standard or ETA), and when evaluated for the influence of other possible variations, that may occur outside the scope of the specification, which may have an impact on their fire performance."

CWFT is a list of generic products, not a list of proprietary products.

CWFT lists will be established by Commission Decision(s) in consultation with the Standing Committee on Construction (SCC). The Fire Regulators Group (FRG), advised by its CWFT Working Group - made up of representatives of regulators, CEPMC, a Notified Bodies Group representative, a representative of CEN TC127 WG4, and CEN/EOTA TC representatives (invited for specific cases, as applicants) - will consider all requests made and forward recommendations onto the SCC for final opinion.

CWFT lists will refer to products of known and stable performance for defined end use applications with respect to their reaction to fire performance, their external fire performance and/or their resistance to fire (the latter to be developed in due course). "Products" are product families, product sub-families and generic products as defined in Guidance Paper G and specified by European standards or European Technical Approvals. It may also be possible to extend the concept to kits and systems, if it is possible to define them with sufficient precision.

Products will only be considered for inclusion onto the lists where:

• their fire performance can be considered to be 'stable' (typically, this means that it must be proven by test that the fire performance of a product is not subject to major change by virtue of the variability of the manufacturing process) ;
• they (the product) have been defined with sufficient precision.

Regardless of the fact that the product must correspond to the product description given in the CWFT list, the fire performance of the product should correspond with the given class. The normal safeguard procedures of the CPD apply if a manufacturer is considered to have incorrectly applied the CE marking (e.g. by claiming his product meets the criteria of a 'CWFT' list when it does not). The manufacturer is always responsible for ensuring that his product corresponds to the description, and is within the limits defined.

Positive lists (i.e. lists of products included) will be prepared, although it may be necessary to highlight exceptions within a product family, e.g. all products in product family x, with the exception of y.

(ii) Re-engineering costs

Because of the very diverse nature of building products market it is not possible to say what a 'typical' re-engineering cost is likely to be. Some products only require minimal re-engineering to ensure that they continue to achieve their current classification and manufacturers feel this is broadly acceptable. On the other hand, some products will need more fundamental re-engineering which could entail substantial additional costs. Nationally these costs could amount to millions of pounds and are likely to be passed onto consumers. However, manufacturers may feel that such costs do not justify the wider benefits of trading in the EEA and so may decide not to pursue this option.

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