Legal requirements for documentation

Legal requirements for documentation

Few other industries accept a level of defectiveness and inaccuracy in their documentation procedures like the fire retardant treated wood business. This forces downstream users to indirectly violate the law, and consumers and residents may be given a false sense of security when a contractor uses wood products without first ensuring their reaction to fire properties. It is your duty as an architect and consultant to have the knowledge needed in order for you to prescribe fire retardant treated wood in an informed manner. It is your ultimate responsibility as a contractor and builder to ensure that the standards for technical characteristics are being met and documented correctly.

Solid wood and wood-based boards, e.g. plywood, are under strict guidelines in the harmonized product standards with rigorous instructions and requirements for initial type testing, classification, certification and continuous monitoring. Despite this fact, it has become increasingly common that fire retardant treated products that are being put on the market are also subject to faulty performance and misleading documentation (or a lack thereof). The fact that some operators within the industry then disregard the requirements in place does not make the situation better.

The fire retardant treatment of wood is ultimately about safety. Products placed on the market must be documented by independent third parties. Manufacturers are allowed to decide the type of documentation that they themselves wish to use in the marketing of their products and services. However, you as an expert must always follow the guidelines stated in, inter alia, the ZA Annexes which state that the documentation must be in the form of certified documents in accordance with harmonized product standards.

Unfortunately, the word "Certificate", is used all too often in the context of document approval. There are examples of accredited institutes creating a certificate on behalf of the producer that contains little actual information but a compilation of facts from the fire testing and the classification report. A certificate cannot be considered a certification document when it does not refer to harmonized product standards, but is instead a directly misleading document for the downstream user who is in need of approved CPR documents and not a statement titled ”certificate”.

You must request third party documentation that is certifying, e.g. CE certification and type-approval certificates, which specifies wood type and performance and which refers to the relevant harmonized product standards e.g. EN14915: 2013 (solid wood) or EN13986: 2004 (wood-based panels such as plywood).

The FBT understands the difficulty of knowing which part of the documentation corresponds to a specific requirement, considering the vast range of incorrect documentation practices and arbitrary praise in the assessments and reviews of product performance. Therefore, the FBT recommends using Appendix-E and Appendix-C for documentation control of product properties, the manufacturer certification and the manufacturer quality manual.

FACTS

PRODUCT DOCUMENTATION REQUIREMENTS ARE AS FOLLOWS

  • A Declaration of Performance (DoP) according to Annex ZA.
  • A CE certificate supporting the DoP when declaring Euroclass B and C.
  • A CE certificate that refers to the current harmonized product standard.
  • Related documents for e.g. assembly, maintenance, attachment, and waste disposal.
  • A Certificate of Delivery from the manufacturer at final delivery (CoD).
  • The PBL (Planning and Building Act (SFS 2010: 900) is fulfilled through a type-approval certificate, e.g. SP-Fire 105, K210 / B-s1, d0, durability and emissions.
  • The European harmonized product standard is for solid wood EN14915:2013+A1:2017 and for wood-based panels EN13986:2004+A1:2015.