Kevin,
You have my sympathy. I wasn't involved in the writing the CPD, but
I've kept an eye on it for a number of years now and the signs do not
look good. The CPD is a right mess and seems to be the result of
input from a large number of vested interests which the Commission
did not have the strength to resist in the early development of the
CE marking concept. (Mind you, looking at the recent Noise Emissions
from Outdoor Equipment Directive, I'm not sure they could resist it
now either, but I digress...)
Quality system certification is a feature of quite a few of the CE
marking directives, although most of them cover products which are
rarely mentioned in this forum. Examples are pressure equipment, gas
appliances and medical devices. There is also a more general
requirement in all of the Directives to ensure continued compliance
for production, which means a manufacturer having some sort of
documented quality control system in their technical file.
Directives which require an accredited quality control system
specifically do not require that the same notified body be used for
product testing as for quality system accreditation and there are
some clear advantages for manufacturers in keeping the product
testing and quality system assessment functions separate. In the case
of the CPD, annex II covers the issues of attestation including the
role of independent certification and approval bodies, and it
specifically says that different bodies can be appointed to perform
the testing, approval and certification functions on a given product.
You should consider making it clear to whoever you engage to do any
of this work that you will be placing the business for other aspects
elsewhere, so that you keep full control of the process (although in
the early days your choice of alternatives may be limited).
This aspect of the CPD is dealt with in article 12. Regrettably, it
is a lot less clear in what it is trying to achieve than the other CE
marking directives and in particular it appears to allow the product
standards to dictate whether independent certification is required as
part of the conformity assessment procedure. However, it also says
"The choice of the procedure ... for a given product or family of
products shall be specified by the Commission... In each case, the
least onerous possible procedure consistent with safety shall be
chosen." My guess is that some of the certification bodies will
conveniently overlook this in the period during which the directive
is being introduced and leave many clients with the impression that
they have to have their quality system formally audited when in fact
this is not the case. Many clients will not know enough to question
this approach.
If you've not already found them, you may like to investigate the
guidance documents on the CPD at:
http://europa.eu.int/comm/enterprise/construction/index.htm
and in particular paper B which includes the following statement:
"The writers of technical specifications and guidelines for European
technical approvals should also take into account that the
manufacturer's compliance with the EN ISO 9000 series of standards is
not a mandatory requirement in the framework of the Construction
Products Directive and should not be included as such in harmonised
technical specifications or guidelines for ETAs."
In general, you are strongly advised to make sure you have read the
directive and understood how it applies to your products, and make it
clear to prospective suppliers of certification and testing services
that this is the case. When they suggest something which you don't
think is right, ask them to clarify it. My experience of CPD related
testing so far leads me to think that most of the certification and
testing bodies who operate in this sector have yet to feel the wind
of change which has provided (if you know where to look, and shop
around) cheap and quick test and certification services for the
electrical sector as a result of the influence of the LVD.
Regards
Nick.
At 14:57 -0500 1/11/02, Kevin Harris wrote:
Hello,
The construction product directive is one of the most recent directives
affecting fire detection devices. Currently if you have a smoke detector
you would like to sell in the EU then you have to go through all the local
national agencies (ANPI, VdS LPCB etc) in Europe to obtain approvals. As of
next March (when the first standard get published in the OJ for the CPD )
the manufacturer can now go to any one of those agencies ( provided they
have been listed as a certification body under the new scheme) and be
approved across the EU. Hooray say I! Chop tens of thousands of Euros off
my testing bill! Unfortunately it is not all as it seems! The CPD writers in
their wisdom have a provision in the directive that not only does the
notified body have to do type testing and regular auditing but they must
also certify the quality plan!. The certified bodies take this to mean that
they must do something like an ISO9000 certification and audit plan. I'm
wondering why the directive was written this way. If one already has a
quality plan in place that is registered, why do we have to do it again? It
seems to be counterproductive to say on one hand that a particular agency is
qualified to assess quality plans and then have a directive that says
otherwise.
This also has the effect that if I choose one certification body to test
something then I must choose them again and again or else face re evaluation
of my quality plan by yet another certification body. What a convenient
clause for non competition amongst the certification bodies!
Is there anyone out there that may have contributed to the Construction
Product Directive that might shed some light on this subject? Am I missing
something? Was that the intent of the directive or perhaps this wasn't
foreseen?
Grumbling complete
Best Regards,
Kevin Harris
Manager, Approvals and CAD Services
Digital Security Controls
3301 Langstaff Road
Concord, Ontario
CANADA
L4K 4L2
Tel: +1 905 760 3000 Ext. 2378
Fax +1 905 760 3020
Email: [email protected]
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