Lack of a Harmonized Standard

20 February 2014

What do I do if my product is not CE marked because there is no standard against which to test it?

Where there is no harmonized standard covering a product, it is possible to use that product on 'life safety doors' provided you can still show fitness for purpose and any necessary fire test evidence.  According to 'Approved Document 7' of the 'Building Regulations 2010', preferred ways of showing fitness for purpose are:

  • Compliance with a standard – harmonized or not

  • Product 3rd party certification

  • Tests and calculations by a UKAS accredited test lab

  • Previous good experience.

Examples:

Pivots -

If you are using pivots which would be normally used with floor springs (e.g. a top centre and bottom strap on a pivot bearing), evidence of inclusion in tests to EN 1154 would be pretty robust proof of fitness for purpose, assuming also that all necessary fire test evidence is in place. 

Geared Continuous Hinges -

Although not included in the scope of EN 1935, some manufacturers have tested to the regime of that or similar standards (e.g. ANSI in the case of Pemko Manufacturing) and can supply performance data based on those tests.  In terms of the requirement to show evidence of fitness for purpose, that displays incontrovertible proof of performance rather than a reliance upon “previous good experience” only.

In the specific case of Pemko Continuous Geared Hinges, the additional UK fire test certification means that Pemko hinges may be specified for use on 'life safety' doors (timber fire compartmentation doors and doors on escape routes) with impunity.

Ultimately, those involved in the supply chain must to be able to justify their decisions and reasoning in court.  Hopefully, it never comes to that, but if it does, you need to be able to say and prove that you have exercised your duty of care in supplying products that are fit for purpose. 

That is why test evidence is such a reliable basis upon which to make a judgement. 

Related Tags:  Certification |  Door Hardware | 
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Relcross Ltd
Hambleton Avenue
Devizes
Wiltshire
SN10 2RT

t: 01380 729 600

w: www.relcross.co.uk
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