GB

BREXIT & EU Construction Products Regulation 305/2011 ~ Woeful Implications for Britain’s Fire Industry

Posted by CJ Walsh

2020-09-08:  Ignoring Britain’s silly sabre-rattling, toothless threats and boorish blackmail attempts reported in the Media during this past weekend, yesterday and today … the actual state of play in the tortuous Brexit Negotiations can best be judged from the following sources …

Michel Barnier’s Presentation to the Institute for International and European Affairs (IIEA), on 2 September 2020 … View it Here on YouTube

Britain’s National Audit Office Report: ‘Learning for Government from EU Exit Preparations’, dated 4 September 2020   (Download PDF File, 197 Kb)

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Map of Europe, in colour, showing the current extent of the European Union.  Points to Note:  a) Europe, as a continent, extends as far as the Ural Mountains in Russia;  b) From 1 January 2021, after an implementation period of one year, Great Britain will be entirely outside the EU and the Single Market;  c) The EU is not a Christian organization and as soon the political classes in certain countries (e.g. France and The Netherlands) get over their hysterical hatreds, Turkey will enter the EU as a full Member State;  d) furthermore and eventually, an Independent Scotland will re-join the EU.  Click map to enlarge.

This is the European Union (EU), a Single Market of approximately 450 Million consumers.  The EU operates under the freedoms and protections of Codified / Written Law, i.e. EU Treaties ratified by all of the EU Member States, EU Secondary Legislation (Regulations and Directives), and EU Administrative Provisions.

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A suite of EU Regulations and Directives covers Industrial Products.  While there is some flexibility with regard to how Directives are implemented at national level in the Member States, no such flexibility exists with Regulations.  Construction Products can only be placed on the EU Single Market if they can be shown to comply with the requirements of the EU’s Construction Products Regulation (CPR) Framework, or in other words, be shown to be ‘fit for their intended use’ in the European Union …

REGULATION (EU) No 305/2011 of the European Parliament and of the Council, dated 9 March 2011, laying down harmonised conditions for the marketing of construction products and repealing Council Directive 89/106/EEC   (Download PDF File, 998 Kb)

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EU Regulation 305/2011.  Article 13(2) Before placing a Construction Product on the market, Importers shall ensure that the assessment and the verification of constancy of performance has been carried out by the Manufacturer.  They shall ensure that the Manufacturer has drawn up the Technical Documentation referred to in the second sub-paragraph of Article 11(1) and the Declaration of Performance in accordance with Articles 4 and 6.  They shall also ensure that the Product, where required, bears the CE Marking, that the Product is accompanied by the required documents and that the Manufacturer has complied with the requirements set out in Article 11(4) and (5).

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BREXIT ~ IMPLICATIONS FOR THE BRITISH FIRE INDUSTRY

Trade ‘No Deal’ or ‘Minimal Deal’ … from 1 January 2021, Great Britain will be completely outside the European Single Market, and the EU’s Construction Products Regulation Framework.  The designation ‘Notified Body’ under that Framework will fall away from British Organizations.  Construction Products/Systems manufactured in, or supplied from, Britain will then have to undergo an entirely new EU Testing and Approvals Programme in order to access the European Single Market.  Fire Safety related Construction Products will have to be tested, and assessed or appraised, against all 7 Basic Requirements for Buildings together, during the same period of time (see Annex I, EU Regulation 305/2011) …

      1.  Mechanical Resistance and Stability
      2.  Safety in Case of Fire
      3.  Hygiene, Health and the Environment
      4.  Safety and Accessibility in Use
      5.  Protection against Noise
      6.  Energy Economy and Heat Retention
      7.  Sustainable Use of Natural Resources

… a process which will be very interesting to observe, since the Fire Industry (particularly England’s Fire Establishment, AHJ’s, etc) dislikes, with intensity, the whole idea of ‘environmental impact’ … the concept of ‘sustainable development’ is hardly understood … and no consideration is given to the reasonable fire safety and accessibility needs of ‘vulnerable building users’ (including people with activity limitations, refugees, migrants, etc).

The tragic 2017 Grenfell Tower Fire, and its sad aftermath, have demonstrated how dysfunctional, and rotten to the core, is the whole national system of Building Fire Safety in England.  More than 3 years later … on the evidence to date of an ongoing, incompetent Inquiry and a series of shoddy responses from Government … will survivors and the victims’ families ever receive Justice, and find Peace ?   cf. The 1981 Stardust Discotheque Fire in Dublin.  Survivors and victims’ families are still waiting for the truth to be revealed.

In parallel, mutual recognition of British Professional Building Designers, e.g. Architects, Structural Engineers, Fire Engineers, etc., within the European Union will cease.

In parallel, British Fire Research involvement in EU Research Networks will also cease … unless a heavy price is paid to be involved as a 3rd Country.  British Institutions should forget any notions they might have about Network Leadership.

In parallel, Information and Data Flows between Britain and the EU will be disrupted or cease altogether … unless Britain complies fully with the requirements of EU General Data Protection Regulation (GDPR) 2016/679.  As a vassal state of the USA, this compliance may prove difficult for Britain !

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EU Fire Safety Related Product/System Manufacturers ~ A Word of Caution !

Many EU Construction Product/System Manufacturers continue to use the services provided by British Fire Test Laboratories and/or Fire Consultancy Organizations located in Great Britain … some of which have already established EU-based dummy companies and letterheads.  These British organizations must be avoided altogether.  For example, the practice of fire testing in England and later adding a title page of a Full Test Report with an EU location address is entirely unacceptable !

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#Sustainability #Brexit #EU #England #MichelBarnier #GB #PerfidiousAlbion #ConstructionProducts #FireSafety4ALL #VulnerableBuildingUsers #EnvironmentalImpact #SustainableDevelopment #BrexitTrainCrash #BorisCummings #BuildingDesigners #FireEngineers #Architects #Turkey #Scotland #EuropeanUnion #NationalAuditOffice #NobodyLeftBehind #TechnicalControl #FireCodes #SFE #SIA #SustainableFireEngineering #Resilience #Reliability #GrenfellTowerFire #StardustDiscoFire #Dublin #CEmark #FireResearch #GDPR #IIEA #CPRframework #MutualRecognition #Russia #USA #CodifiedLaw #EUtreaties #PwAL

GB Climate Change’s Green Deal – National Audit Office Report !

Posted by CJ Walsh

2016-04-23:  Yesterday … Earth Day … and also the Official Signing Ceremony for the 2015 Paris Climate Change Agreement at United Nations Headquarters, in New York City …

UN Official Signing Ceremony for the 2015 Paris Climate Change Agreement
Click image to enlarge.

On the day before that, 21 April, in a Press Release issued by the World Meteorological Organization (WMO) …

A prolonged run of record global temperatures and extreme weather, the rapid melting of Arctic ice, and widespread bleaching of ocean coral reefs underline the urgent need to sign and implement the Paris Agreement on Climate Change, according to the World Meteorological Organization (WMO).

WMO Secretary-General Petteri Taalas said that 2016 has so far overshadowed even the record-breaking year of 2015.

“The magnitude of the changes has been a surprise even for veteran climate scientists. The state of the planet is changing before our eyes,” said Mr Taalas.

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A little earlier in April 2016 … and within the above international context came this problematic, but not-entirely-unexpected tale from Great Britain … the tip of a foul-smelling iceberg in quite a few countries …

Green Deal & Energy Company Obligation

“Improving household energy efficiency is central to government achieving its aims of providing taxpayers with secure, affordable and sustainable energy.  The Department of Energy and Climate Change’s ambitious aim to encourage households to pay for measures looked good on paper, as it would have reduced the financial burden of improvements on all energy consumers.  But in practice, its Green Deal design not only failed to deliver any meaningful benefit, it increased suppliers’ costs – and therefore energy bills – in meeting their obligations through the Energy Company Obligation (ECO) Scheme.  The Department now needs to be more realistic about consumers’ and suppliers’ motivations when designing schemes in future to ensure it achieves its aims.”

Amyas Morse, Head of the British National Audit Office (NAO), 14 April 2016.

[ And as you read further down … consider how important it must be for future effective climate change policy implementation in all of our countries, particularly those countries with an ‘historical responsibility’ …

  • that accurate, precise and reliable climate change data and statistics be gathered together and properly managed … and this means, for example, that at European Union Member State level, the national statistics organization must be in control of the process … and at EU level, Eurostat must be in control ;
  • that implementation be stringently and independently monitored for long-term effectiveness ;
  • that economists be removed from core decision-making in this area … and the veto they currently exercise over necessary mitigation and adaptation actions be removed. ]

The National Audit Office has today concluded that the Department of Energy and Climate Change’s (DECC) Green Deal has not achieved value for money.  The scheme, which cost taxpayers £240 Million including grants to stimulate demand, has not generated additional energy savings.  This is because DECC’s design and implementation did not persuade householders that energy efficiency measures are worth paying for.

The NAO Report: Green Deal and Energy Company Obligation also found that DECC’s design of its Energy Company Obligation (ECO) scheme to support the Green Deal added to energy suppliers’ costs of meeting their obligations.  This reduced the value for money of ECO, but the Department’s information is not detailed enough to conclude by how much suppliers have met their obligations for saving carbon dioxide (CO2) and reducing bills.

The report finds that while the Department achieved its target to improve 1 Million Homes with the schemes, this is not a direct indicator of progress against the objective of reducing carbon dioxide (CO2) emissions.  This is because different types of energy-efficiency measures save different amounts of CO2.

The schemes have saved substantially less CO2 than previous supplier obligations, mainly because of the Department’s initial focus on ‘harder-to-treat’ homes, as its analysis showed that previous schemes had absorbed demand for cheaper measures.  The Department expects the measures installed through ECO up to 31 December 2015 to generate 24 Mega Tonnes of carbon dioxide (Mt CO2) savings over their lifetime, only around 30% of what the predecessor schemes achieved over similar timescales.

Demand for Green Deal finance has fallen well below the government’s expectations, with households only funding 1% of the measures installed through the schemes with a Green Deal loan.  The schemes have not improved as many solid-walled homes, a key type of ‘harder-to-treat’ homes, as the Department initially planned.  As part of changes to ECO in 2014, the Department enabled suppliers to achieve their obligations with cheaper measures, moving away from its focus on harder-to-treat properties.  ECO has generated £6.2 Billion of notional lifetime bill savings to 31 December 2015 in homes most likely to be occupied by fuel poor people.  Beyond this, the Department cannot measure the impact of the schemes on fuel poverty.

There are significant gaps in the Department’s information on costs, which means it is unable to measure progress towards two of its objectives: to increase the efficiency with which suppliers improve the energy efficiency of ‘harder-to-treat’ houses, and to stimulate private investment.  The lack of consistency in the government’s approach during the schemes could increase the long-term costs of improving household energy efficiency.

In the NAO’s accompanying investigation into DECC’s loans to the Green Deal Finance Company, also published today, it found that the Department expects that it will not recover its £25 Million stakeholder loan to the finance company, plus £6 Million of interest that has accrued on it.  The Department based its stakeholder loan on forecasts of significant consumer demand for Green Deal loans.  But demand for Green Deal finance was lower than the Department forecast from the outset, meaning the finance company could not cover its operating costs.  The Department agreed a second loan worth up to £34 Million in October 2014, of which the finance company has drawn down £23.5 Million.  The Department still expects to recover this loan in full as it will be repaid before other investors in the finance company.

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Is it any wonder that the ‘real’ Greenhouse Gas (GHG) Numbers continue to climb relentlessly ?!?

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