This feature explores the complex issue of EN 54 product certification and highlights the potentially far-reaching consequences of taking an inconsistent approach to certification when specifying fire detection and alarm products.
Global Fire Equipment (GFE) has been operating since 1994 and, over many years, we and the wider industry have become increasingly aware of the inconsistent approach taken when specifying fire detection and alarm products in some regions of the world. This tends to be the case in countries that do not have their own national standards and are instead implementing other national or international standards.
In Europe, fire detection and alarm products must comply with the essential safety and performance requirements of the EN 54 Construction Products Regulation (CPR) and must be CE marked to be legally sold or placed on the market in European Union countries. CE stands for Conformité Européenne, which literally means European Conformity.
Performance specifications in Europe must state that the products have to meet the relevant EN 54 product standards. Product testing, inspection and certification must be carried out by a Notified Body – more about which later.
In comparison, in some countries it has become common practice to name a chosen ‘approval’ or ‘approval body’ on performance specifications as the sole mark of product certification or compliance. This misunderstanding of the EN 54 certification process can have far-reaching consequences.
Understanding the difference between a Notified Body and an approval
Let me start by explaining the difference between a Notified Body and an approval. A Notified Body is authorised by the EU to assess products under the relevant EN 54 CPR regulations. Under the Nando (New Approach Notified and Designated Organisations) Information System, notification is an act whereby a member state informs the European Commission and the other member states that a body, which fulfils the relevant requirements, has been designated to carry out conformity assessment according to a specific standard.
Notified Bodies perform critical tasks including product testing, verifying the supporting evidence that a product meets the test requirements, and issuing a product certificate. They also undertake any required ongoing testing or surveillance activities. As long as the EU Notified Body is certified to test against the relevant EN 54 standards, manufacturers can choose which Notified Body to appoint in order to achieve consistent regulatory compliance for their products.
An ‘approval’ is not the same thing as EN 54 product certification via an EU Notified Body. Whereas Notified Body work is regulated and verifies that products comply with a standard, approvals are normally voluntary schemes which certain Notified Bodies sometimes offer as an additional service. For example, some Notified Bodies run their own product directories, listings or certification schemes. These schemes may go beyond the legal EN 54 product standard requirements under their Notified Body activities and these schemes are not mandated by a regulation.
In the case of fire detection products, some of these schemes are promoted within the system performance specification and therefore may be perceived as the only route to compliance – as witnessed in some countries. However, as I explained earlier, the only performance route to EN 54 standard compliance is via an EU Notified Body certifying that products meet the requirements of the relevant EN 54 standards. It is important to specify the correct product and system standards within the fire detection and alarm performance specification, rather than just a specific Notified Body.
Accreditation is key
I will now explain the process of a system of accreditation which underpins global trade, and which plays a pivotal role in the certification of fire detection and alarm products. The ISO (International Organisation for Standardisation)/IEC (International Electrotechnical Commission) 17000 set of documents is an international system designed to support commerce and industry. The well-established system, which Notified Bodies are part of, is a route to European compliance and is highly respected internationally.
Under this system, each member country generally has just one national accreditation body which is appointed by the country’s government. This system provides reassurance to purchasers that products have been tested by an accredited laboratory which is set up to do the testing and has been visited by an accreditation inspection body.
Some countries that do not recognise the CE mark may instead choose system/product performance specifications, stating that the product has to be approved by a particular ‘approval body’ who may or may not be an EU Notified Body. In some cases, the end client may specify a particular approval as they believe it to be EN 54 compliant within that region. However, specifying any type of mark or logo other than the CPR CE mark is misguided and means you are drifting away from the pure premise of what the ISO/IEC 17000 standards are about, i.e. ensuring that the product has been certified and tested appropriately to the relevant EN 54 standard.
If specifications state that products only have to have an approval (rather than a CPR CE mark from a Notified Body), there is a real risk that the manufacturer might have outdated products and may not have updated their standards in line with EN 54 requirements. Specifiers may not have sufficient documentation to demonstrate to the end customer how the manufacturer obtained their product certification and whether they have been tested by an accredited body. Having the stamp or logo of an approval body in no way proves that the body is accredited to ISO/IEC 17065, the standard for certification bodies.
Specifiers should instead be looking to adhere to the same regulations covered under the CPR by writing performance specifications that quote the European EN 54 standards. This will ensure the manufacturer and its products are certified by an EU Notified Body through the CPR to EN 54 product standards and can therefore carry the CE Mark as required.
Another compelling reason to work with a Notified Body is that they will have a surveillance system which ensures that the certification remains valid against the test performance. A test report is only really valid at the time it is undertaken, and that is why certification is so important. Notified Bodies undertake ongoing Factory Production Control (FPC) surveillance, returning to the manufacturers to check the products still meet the relevant requirement of the standard. Similarly, should the manufacturer wish to make a change to their product, they would have to apply back to the Notified Body. The manufacturer would be required to send samples of the new product to the Notified Body which would then do the required testing and update the specification document or technical file.
As we have seen, EN 54 product certification is a complex area and it is easy to see why some confusion can exist around the roles of Notified Bodies and approvals, but I hope this article has helped to clarify the importance of accreditation and following the right route to EN 54 certification of fire detection and alarm products.
For more information, go to www.globalfire-equipment.com
Top tips for EN 54 system specifiers:
1. Ensure you understand the difference between an EU Notified Body and an approval.
2. When specifying EN 54 equipment from manufacturers, ask them how they obtained the product certification. Make sure you are satisfied that the products have been tested by the relevant country’s Accredited Body.
3. When writing a performance specification, quote the European EN 54 standards and state that products must be certified by an EU Notified Body through the Construction Products Regulation (CPR).
4. Look out for manufacturers or approval bodies using terminology such as ‘Complies with…’ as this has no regulatory meaning and can be misleading as it does not mean formal certification.
5. Ensure that the local and national standards of the territory are adhered to, along with any additional government/defence certificates of conformity that may be in force.
Dr Francisco Barroca, CEO of Portuguese-based certification association, Certif:
‘Our certification work spans a number of countries in Europe and further afield. Like Global Fire Equipment, we have come across a number of situations where we have had to explain the certification process in detail as the difference between the ‘approval’ of a product and the ‘certification’ of a product has not been fully understood. It is clear there is the need to raise awareness of the difference between the two in order to avoid specifying outdated fire detection and alarm products that do not conform to the EN 54 standards.’
Madeira Cruz, Eng, Technical Manager at the Portuguese accredited testing laboratory, ISQ:
‘Our laboratories carry out testing, calibration and technical inspections in a diverse range of technical areas. Most result from the need for our customers to demonstrate compliance with international regulations and standards. We work closely with many specialist organisations, such as Certif, conducting EN 54 fire detection and alarm product testing to the Construction Products Regulation (CPR). It cannot be emphasised enough that accreditation and expertise are fundamental requirements to be met by testing laboratories to ensure that life safety products which fall under the EN 54 standards meet the demanding CPR requirements.’
A list of the EU notified bodies who can certify against the Construction Products Regulations standard (EN 54) can be found here https://ec.europa.eu/growth/tools-databases/nando/. The list includes the identification number of each Notified Body, as well as the tasks for which it has been notified.