The Fire Australia Conference and Tradeshow was held recently in Sydney. It was great to see the building safety community coming together and continuing to seek improvement and growth, especially coming out of a very challenging year in 2020.
Speaking to a range of product manufacturers, regulatory officials and other stakeholders, it became clear to me that the industry remains concerned, perhaps more than ever before, about strengthening confidence in the safety of buildings and placing greater importance in product conformity to regulations and standards. This concerned mindset is supported by a string of independent reports and leaders who spoke at the conference, suggesting there is still more to do to realise building safety objectives. It was encouraging that regulators like the New South Wales (NSW) Building Commissioners office are fulfilling commitments to increase accountability and actively influence positive changes. For collective confidence to be reached, regulators also need manufacturers and practitioners to make change. Industry leaders must set examples that will influence industry culture and redefine the status quo of what is acceptable. One significant opportunity to do this is through product conformity.
Improvements in design, application and practitioner competencies will yield positive results. This can be greatly enhanced by conforming products. Multiple people at the conference spoke of the need for a more transparent playing field where products that meet conformity benchmarks are more readily identifiable and stand out from products that do not conform.
It’s fair to say that for the most part, the fire protection industry in Australia has had an enduring relationship with product testing. While not all manufacturers readily embrace this concept, there is a widespread understanding of the need to invest in a test to evaluate product performance and conformity in this region. The problem is that when scrutinised, this conformity path still has many gaps.
Australia’s import activity outweighs that of our exports for many building products. While our market size is diminutive in comparison to other regions, we enjoy a mature market in terms of local regulations and standards with unique conformity expectations. Such expectations can support acceptance of products that meet standards from other regions or, conversely, and more likely, prevent this in favour of setting local parameters. The factors that have historically influenced ‘home grown’ standards can be traced back to our geographical proximity to other markets and the capacity of local manufacturing. The increase in global trade and supply chains coupled with changing manufacturing capability is challenging this, and Australia is a signatory to the World Trade Organisation Agreement – ‘Reduction of Technical Barriers to Trade’. Despite this, local benchmarks are deeply established. Accordingly, parameters for the evaluation of a product in this market are likely prescribed in an Australian Standard.
Market behaviour would suggest that previously, in the absence of other options, evaluation of a product has ended with testing to a regional standard. Now this contentment with a simple product test report undertaken in accordance with these Australian Standards is being challenged. Australian test Standards intend to establish acceptable minimum levels of product fire safety. To better understand the growing challenges, let’s examine what a test report actually tells you and what it does not.
1. Who conducted the test?
Hopefully, the test was conducted by a laboratory that has independent accreditation regarding its capability and competency to undertake such work. This is inherent to the test report and might be regarded as threshold number one regarding trust and acceptability of the results.
2. What Standard was used?
Within the test reports, you should see referenced the relevant test Standard that the product was tested against and the information regarding the product’s performance under test. This information should be described in a manner reflecting what is required by the Standard.
3. What product was tested?
There should be confirmation of the actual product tested, including the particular model and, sometimes, the intended manner of installation or configuration with other components.
4. Is the report still valid?
While the test report will describe a particular product tested and some aspects of the intended installation, it is valid for the product at the time of test. It is a ‘snapshot’ in time. One must examine whether a test report continues to apply if either 1) the product changes from what was originally tested, or 2) the standard changes in a manner where the results would be impacted. Guidelines in this regard are described in ASTM E2989, Standard Guide for Assessment of Continued Applicability of Reaction to Fire Test Reports Used in Building Regulation.
Note that a test certificate should not be confused with an actual test report and results, which some manufacturers consider private intellectual property. Nor should a test certificate be confused with product certification.
5. Product sample selection
For test reports, products are often sent in by manufacturers without those samples being witnessed or selected by the testing organisation. However, certification programmes typically include the certification organisation’s involvement in sample witnessing and selection. This provides greater confidence that the product intended to bear a certification marking is the same as the product actually tested.
For test reports, the only way to match products installed in the field to the product described by the test report is by way of the model name or designation. There’s no way to know whether that particular model has changed in its characteristics or design. Third-party certification offers a method to confidently determine product conformity via a unique product mark. Products bearing a certification mark can be identified as having been evaluated and subjected to ongoing production surveillance. This gives greater confidence that the product installed in the field is of the same exact construction that complied with the test requirements and, therefore, the regulatory demands.
Providing part of the solution
Test results provide valuable and useful information, but testing is only part of the solution if you really want to have confidence in a product and its ongoing conformity.
To have confidence in product conformity, you also need to know that the product currently being produced and that will be shipped to your site will continue to achieve the same level of conformity. Without this, a test report simply confirms that a manufacturer-selected limited sample was tested once and was found to conform at that time.
Changes to test Standards referenced in regulation or the National Construction Code typically results in a flurry of new testing activity by industry. A recent example is the NCC 2019 that amended the note associated with AS 1530.4, the standard fire test for passive products. This resulted in expectations for conformity changing to more recent editions of the Standard. You are right to question how best to demonstrate ongoing conformity to the Standard.
Recognition for best practice
Leading manufacturers invest significantly in quality-management processes for the production of their product. This serves two main objectives:
- Ensures efficiency in production processes and sustains quality thresholds that help the brand win and maintain market share; and
- Prevents non-conforming products from entering the market, helping to avoid liability and costly brand-damaging recalls or rectifications.
Product manufacturing can involve multiple components, complex supply chains and management of multiple variables and tolerances. Any of these aspects can directly impact product conformity. The results of a single point in time test, however accurate, cannot account for these ongoing aspects of production.
Manufacturers investing in management processes that deliver products that consistently satisfy conformity expectations and obtain independent third-party certification for this are currently competing in a market against those who don’t, only producing information about test results. This can mislead other stakeholders and perpetuate an illusion that testing and product certification are somehow equivalent, which they are not.
Testing is part of product certification, but product certification is not part of testing. Product certification is an adopted concept that takes product evaluation information from testing and adds additional and ongoing components applied independently to support confidence in product conformity. The prevalence and value of product certification globally is supported by an ISO/IEC Standards suite. These Standards outline a framework to improve application and product conformity.
To improve confidence in product conformity, these are some of the key factors that the evaluation process applied to achieve product certification can add beyond a single-point-in-time test:
- Initial factory inspection prior to certification of the product to confirm production is consistent with test samples
- Where products include formulated materials, such as intumescents, ‘fingerprinting’ this formulation for future traceability that supports ongoing conformity
- Evaluation of literature and product marking
- Independent certification decision making by individuals at the organization who did not partake in any evaluation or testing activities
- Certificates that include information regarding the installation configurations where conformity has been determined including conditions of acceptability, ratings or any required caution/hazard markings
- License or approval from the certification body for the manufacturer to apply approval marks on the conforming product
- Listing on publicly searchable directories so that multiple stakeholders can confirm the conformity of a product
- Production surveillance with a range of different approaches, including batch testing, factory inspections and/or quality-management system reviews to ensure conforming product continues to be produced in accordance with the certification
Not all product certification schemes are the same, though. The ISO/IEC Standards recognise this and provide for different types that reflect different assessment rigour.
Time to lead – take positive steps
Acknowledging that the construction industry is one barometer of a healthy economy, the Federal government has sought to reduce technical barriers to trade. These reductions are also expected to be balanced to help maintain the health and safety expectations of the Australian community.
Certification bodies are providing solutions. For example, global organisations like UL are investing in the Australian market — tailoring certification schemes to recognise local regulations and Standards. UL1 is independently accredited by the Joint Accreditation System of Australia and New Zealand to deliver the UL-AU Mark Scheme which continues to expand. So, product certification is available.
Leading manufacturers deserve independent recognition for the effort they apply to producing conforming products. Product certification provides this with undeniably more trust and confidence than a single point in time test. If you are a manufacturer, you can lead by seeking product certification solutions and demonstrating the value of your product. This will also help maintain your brand integrity, manage liability and provide you with a point of difference to win market share from competitors who cannot demonstrate similar quality.
Designers, specifiers, approval agencies, building surveyors and builders all have a role to play. As regulators tighten expectations for documentation and compliance, you can have greater confidence that your responsibilities have been met by simply asking more questions about products, such as:
- What product certification is available? Does it include testing and ongoing production surveillance? What other evaluation activities are included as part of the certification? How can I be confident product conformity will be achieved?
- Who provided product certification? Are they independently accredited by a recognised accrediting body?
- Can the physical product received on site be linked back to product certification information?
- Is there a publicly searchable directory to confirm the product’s certification and application status?
- What actions are taken to avoid delivery of non-conforming products?
Testing alone may not be fully adequate to satisfy product conformity expectations. It only provides some of the information. Taking positive steps towards product certification is one of the most important ways industry can improve confidence in product conformity and lay the foundation for the successful implementation of other reforms.
Download a free copy of UL’s product conformity e-book2 or contact UL to learn more about the UL-AU Mark product certification scheme.
For more information, go to www.ul.com
- UL International New Zealand is the formal name of the JAS-ANZ accredited body.