Demonstrating Installation Competence in Europe
Adopted in 1989, the OSH “Framework Directive” was hailed as a substantial milestone in improving safety and health at work. The Framework Directive, along with associated Directive 89/654/EEC – Workplace Requirements, introduced a range of measures to encourage improvements in the safety and health of workers at work and laid out minimum safety and health requirements for the workplace.
But, while many managers realise they are responsible for conducting fire risk assessments and ensuring adequate fire safety precautions are in place, many are unaware of the full implications with regards to employing competent contractors to install and maintain fire safety measures, particularly related to passive fire protection.
Although passive fire protection products play a vital role in protecting lives and property in the event of a fire, the importance of appropriate installation and maintenance is seldom reflected in legislation across Europe. There are very few requirements for those who specify, install or maintain PFP products to demonstrate their competence and few formal qualifications available. And, while many European states recommend the use of third party certificated products and installers, such requirements are generally not mandatory.
Framework Directive requirements
The Framework Directive introduced the concept of a ‘Responsible Person’ (the definition of which will vary within member states), who can be the employer, any other person who may have control of any part of the premises (occupier/owner), or the person in control of the premises. To fully comply with the Directive, it is essential that he/she ensures that an appropriate risk assessment is carried out and maintained on all premises that he/she is legally responsible for.
This includes creating a safety manual that contains a fire safety policy statement (or fire strategy), a fire safety specification for the building, information relating to regulatory requirements and planned inspection, maintenance and testing schedules and records.
Passive fire protection is the primary safety measure built into the fabric of a building. It helps to ensure the stability and integrity of the building and protect the means of escape in fire conditions. It is therefore one of the key aspects of a fire risk assessment and management.
As a result, where work involving alterations or additions to the fabric of the building is undertaken, the Responsible Person must ensure that the passive fire protection measures are not compromised in any way. Where such work involves the addition, or reinstatement of passive fire protection measures, it is essential that the work is undertaken by experienced and qualified installers, utilising appropriate materials and practices.
Anyone responsible for specifying the materials and/or appointing an installation contractor, is also responsible for ensuring that they can prove competency for the fire protection materials used, or the works to be carried out. A Responsible Person who knowingly ignores advice that leads to a failure in the fire performance of any element of installed fire protection within a building, is likely to be found to be just as culpable as the deficient installer. But how can competency be demonstrated?
Third party certification
The European Association for Passive Fire Protection (EAPFP) strongly advocates the use of third party certification of contractors for the installation of passive fire protection products. By specifying a third party certificated company, managers can be assured of the competency of the contractor, since a third party has verified that installations are satisfactory. The process is undertaken by a mixture of
audits of records and randomly selected site visits, by the third party, at which workmanship is checked for compliance.
A competent person is one who can demonstrate to a third party that they have the expertise, skills and commitment for the professional installation of passive fire protection products. Proof of competency can be demonstrated by working for a third party certificated installer under the conditions of that scheme; demonstrating their skills to a certification body running an accredited competent persons scheme in the installation of passive fire protection; or working for a company operating a ‘company based’ competent person scheme certificated by an accredited certification body.
Accredited certification bodies are those which are signatories to the European Co-operation for Accreditation (EA), the International Accreditation Forum (IAF) and the International Laboratory Accreditation Co-operation (ILAC).
A recent survey conducted by the EAPFP highlights that while there are a range of voluntary third party certification schemes for passive fire protection products and installers, they are generally not mandatory. Furthermore, there are few formal qualifications or registration schemes for passive fire protection installers.
In Austria there is no registration scheme for installers but there is a mandatory qualification process. Installation is regulated under commercial law for heating, cooling, acoustics and fire protection. There is a regulation OENORM H6013 for the installation and inspection of fire dampers and smoke control dampers and there are initiatives to develop further schemes.
In Belgium there is a voluntary registration and qualifications scheme for fire door installers, which is applicable on a regional basis. The national bodies are working together on a voluntary qualification system for installers of passive fire protection. The first scheme will be for fire resistant penetrations.
In Denmark there is no registration scheme or qualification process for installers of passive fire protection.
The Danish Buildings Regulation and its Guide (Eksempelsamlingen) describes where and which form passive fire systems should be, but does not place any detailed requirements on how it should be maintained, despite stating that it should function for the whole life of the building.
There is no requirement for mandatory third party certification, although all products shall be CE-marked due to CPR (where appropriate). The Fire Safety committee of the Danish Trade Organisation for Safety and Security has established a subcommittee for Passive Fire Protection which is investigating the development of a voluntary certification scheme for installations.
In France, there is a voluntary qualification process and regulations that apply throughout the country.
In Germany, there is regulation for the installation and maintenance of passive fire protection products and guidance which is applicable throughout the country. But there is no registration scheme for installers of passive fire protection products. There is a voluntary qualification process for installers of passive fire protection, which is applied on a company (private level).
In Ireland, the importance of ensuring that fire safety installations are fit for purpose was highlighted by a High Court ruling related to the Priory Hall Apartment Complex. The ruling resulted in the eviction of 249 residents from the complex, due to fire safety concerns related to the building’s construction. It prompted an overhaul of the Irish Building Regulations.
The implementation of the Building Control (Amendment) Regulations 2013 on the 1st March 2014, backed up by a revised Technical Guidance Document B, creates a significantly more onerous environment for all involved in the specification, design, installation, certification, inspection, management and maintenance of passive fire protection in buildings.
The new regulations introduce Assigned Certifiers, who will inspect building works at key stages during construction, with both the Assigned Certifier and the builders both required to certify that a finished building complies with the requirements of the building regulations.
There are no existing registration, qualifications or regulations but there are schemes being developed by Avisa Federchimic.
In the Netherlands there is no registration scheme for installers of passive fire protection products but there is a voluntary qualification process for installers of passive fire protection available from product manufacturers. This is applied throughout the country on a company (private) level. There is no regulation for the installation and maintenance of passive fire protection products but there is guidance which is applicable throughout the country. There is a voluntary scheme being developed.
In Norway there is a mandatory scheme for installers of passive fire protection products. This forms part of the legislation and places professional responsibility for the passive fire protection in new buildings on the installing company. There is also a voluntary qualification process with a new standard developed by the BFO, based on NS ISO 9001-2008.
There are no existing registration, qualifications or regulations. There is regional guidance from the Canary Islands Government Ministry of Commerce Industry and New Technologies General Directorate of Industry and Energy. Tecnifuego-Aespi offers guidance on installation, and maintenance of passive fire protection systems.
However, in 2014, the Department for Housing, part of the Ministry for Construction, mandated the team responsible for regulations on fire safety in buildings to develop an installation code. The Spanish association of paint and ink manufacturers (ASEFAPI), CS Pasiva en Tecnifuego (the Technical Committee for Passive Fire Protection within the Spanish association Tecnifuego-Aespi) and CTN 48 (the Technical Committee for standardization in AENOR in Spain) are working to develop a draft, which includes installation guides for different products, and is complemented by the recent publication of a new standard on appropriate maintenance and inspection regimes (UNE 192005). The Code will also include necessary conditions for qualification as an installer of passive
There is no formal registration scheme but there are several voluntary schemes for installers with a good take-up in several areas. The only formal registration scheme is the CSCS card that all construction site operatives are required to have to gain access to a commercial site. For passive fire protection, the CSCS card is for a skilled operative. However, it is not mandatory that the skilled operative card is obtained.
There is a voluntary qualifications scheme leading to an NVQ Level 2/3 qualification in passive fire protection. In addition there is a voluntary qualification scheme for fire doors, the Competent Approved Fire Door Inspectors (FDIS) scheme. The UK Industry body, the Association for Specialist Fire Protection (ASFP) representing the passive fire protection sector now offers a new ASFP training scheme which aims to improve the knowledge of those in the supply chain involved in the installation of passive fire protection as well as raising the awareness of those involved in the design, supply and maintenance of passive fire protection.
Campaigning for improvements
Provided that those responsible for design, construction and maintenance ensure that the fire provision within their remit of responsibility is undertaken in an appropriate manner, using competent installers, then it is reasonable to assume that the development and spread of a fire will be held to a minimum.
The EAPFP survey has identified that there appears to be little appetite across Europe to insist on minimum standards for the installation of passive fire protection. The Association aims to improve installation standards and is calling for European states to recognise the need for specialist skills for the installation and maintenance of passive fire protection by requiring installers to join third party certification schemes to provide proof of competence. EAPFP would like to help member states by seeking to take action at a European level.
For more information, go to www.eapfp.com