Many readers will recall a DIY product advert that said ‘it does what it says on the tin’. Everyone wants products that do what the marketing claims, whatever the application. But for safety critical products where real-life performance could be the difference between life and death for a building occupant or an emergency responder, accurate and reliable product information takes on a whole extra dimension.
For some products that is already recognised. Key structural products have had third-party quality assurance schemes for many years, with regular audits of production and random checking of products delivered to projects undertaken to minimise the risks of defective products being used in real projects.
But recent evidence shows that products can be placed on the market that do not meet such stringent requirements. Recently, one such product was found to have been on the market for 15 years, from 2006 onwards, based on fire test results that the manufacturer has now acknowledged were not representative of the product sold. Put another way, the product originally tested in 2005 was, essentially, a different product from that being sold after 2006. Yet, for 15 years, the ‘label on the tin’ said it was the same product. And designers and installers used it in the mistaken belief that key product data on fire performance was accurate.
Another topical concern is with various products that are now being brought to the market in response to the pandemic. Devices are being presented on the basis of their claimed ability to deactivate the SARS-CoV-2 virus using various technologies. In some cases, laboratory test reports are available that support aspects of the performance of the product. But it is less common to receive evidence that demonstrates the effectiveness of the products in realistic and typical applications.
And, in many cases, it may not be possible to find reliable scientific or engineering evidence to support claims being made, and show that the product does what it says on the website, advert or brochure.
If it was merely a decorative product for home use it might not matter so much. But for devices claiming to treat and purify air to deactivate SARS-CoV-2, it is vital that the effectiveness of the product is clearly and independently verified. Because if they are installed as part of a system to provide a safe indoor environment and they do not work as claimed, then that environment will not be safe. Nor those who occupy it.
Devices that use UVC radiation must not emit radiation into occupied areas, as UVC is harmful to humans. Concentrations of reactive chemical species such as ozone must be controlled below safe exposure levels, especially if other constituents of the local atmosphere may react with the active chemical to form harmful by-products. And it’s essential to know the background levels of, for example, ozone, which is generated by copiers and other office machines, and to know that the ventilation provision in the space is sufficient to keep the concentration at safe levels.
A major concern is that both these approaches fail dangerously, whether by just not cleaning the air and not protecting occupants, or by emitting harmful radiation or chemicals because of the product failure. If they are to be installed, then there needs to be a robust means of alerting the building manager to the failure immediately, so that mitigating measures can be put in place at once to maintain the safety of occupants of the affected space or spaces. And if that failure means harmful materials or radiation are escaping, then that equipment needs to be shut down equally quickly and competent technicians called to repair the problem, and then to test that the device is working safely again.
All of this means that the building managers need to understand how the device works, what safety mechanisms are in place to detect failures, alert the facility managers, and deactivate the device. This is anything but ‘fit and forget’ or ‘plug and play’ technology.
Everyone is aware of the requirements for testing medical devices or even vaccines, and the rigour that is applied. Yet there is currently no such safeguard in place for the many new products being brought to market to ‘deal with’ SARS-CoV-2. And, as shown by recent revelations, there is also real concern over the accuracy and relevance of product test data for various fire-safety products. Not only that, but concern that manufacturers have been partial in their disclosure of test results to product-approvals bodies, with the suggestion that poor results have been withheld.
Two initiatives are now under way to address these concerns. The first is the creation of a new safety regulator for construction products with the Office for Product Safety and Standards. This regulator will work alongside the new Building Safety Regulator and have the power to remove unsafe products from the market, and to set minimum levels of testing and evidence of safety and effectiveness to be met.
The second is the Code for Construction Product Information, a new code of practice and conduct for testing, marketing and delivery of product data for all construction products. The Independent Review of Building Regulations and Fire Safety called for radical change in the regulation and marketing of construction products, and challenged industry to improve the communication of construction product information.
The draft code has been developed by the Construction Products Association (CPA), but is designed for all who make products to be installed in buildings or civil engineering works. The code will require manufacturers to deliver specific information to support claims of compliance with, or achievement of, the requirements of any industry standard or certification scheme, and to provide verifiable information to support any claims about the product. It will also require that the information provided is consistent with the product that is actually supplied to the market.
Under the code, producers of novel products will have to obtain robust evidence of the effectiveness of their product before making claims about it in marketing literature or in advertisements. The code also seeks to drive a change of culture within the construction products sector to focus on reliable and accurate product information. Given recent revelations, this will need to include a culture of openness and transparency with product testing, certification and regulatory bodies.
The draft code, which is being managed by MRA Research for the CPA, is out for consultation
until 31 March 2021. You can respond directly at www.buildingsafely.co.uk and CIBSE would also like to hear from readers with comments at email@example.com. We would particularly like to hear from those responsible for product information relating to building services products.