USE OF ETAGs AS EADsFOR

EUROPEAN TECHNICAL ASSESSMENTs

[Version including agreed criteria]

Santiago del Pozo

ITeC

www.itec.cat

Workshop ETA process under CPR

EOTA , 30 January 2014

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PRINCIPLES

The concept “fitness for use” disappeared from the CPR

In general, the ETAG technical information is applicable but information linked to the CPD clauses and terms is not

Conditions, a part from those influencing the performance(s) of the product(s), or recommendations can not be included in the ETA (EC)

Threshold values as such can only be used if agreed to with EC

The ETA is the base to be used by the manufacturer for preparing the DoP

Responsibilities, role, tasks or information already stated in the legal bases must not be repeated (EC)

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APPLICABLE ETAG CHAPTERS FOR ETA ISSUING

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STRUCTURE

Four items for each applicable part of the ETAG:

A. What you can findB. ApplicabilityC. Handling in the ETA elaborationD. Some criteria to be taken into account [criteria agreed at

the Workshop in brown color]

Observations:

Information in A in general comes from the old “Guidance to ETAG/CUAP Writers” used under CPD

Texts of C. inserted in a rectangle are extracted from EOTA GD 07 “Guidance on How to write an ETA”, edition November 2013

An additional point, not included in the applicable ETAG parts table, has been included dealing with the definition of the product type

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SCOPE OF ETAG (1)

A. What you can find

1. Definition of the construction product

2. Intended use of the construction product

3. Assumed working life of the construction product

4. Terminology

5. Procedure in the case of the significant deviation from

ETAG/CUAP

B. Applicability

1,2,3 and 4 are applicable. See specific point for 4

When the definition and/or the intended use does not adjust

to the product to be assessed, then an EAD will be

necessary

When another working life is requested by the manuf., then

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SCOPE OF ETAG (2)

C. Handling in the ETA elaboration

1 Technical description of the product

2 &3 Specification of the intended use(s) in accordance with the applicable European Assessment Document (…)

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(Description of:- types and form of product(s)-type (may include constituent materials, components (in particular for a kit) …),- listing of any specific features with its data or a description for identification of product(s)-type, in so far as necessary)

Note: the description shall be very specific, with the objective that this ETA is limited to the product(s)-type as introduced by the manufacturer and the intended use(s) as specified by the manufacturer to the Technical Assessment Body, only.………….Where relevant, refer to Annex(es):Detailed information and data are given in Annex(es) …

(Description of:the intended use(s) of the product(s)-type as well as relevant general condition(s) for the use of the product(s)-type précising each intended use:

- Specification of the provisions (acc. to manufacturer’s recommendations) on design of works and installation of product(s) on site (incl. assembly of kit) in so far as is relevant for the performance(s) of the product(s)-type for the intended use(s).- If necessary, specification of the provisions on other phases of the product(s) life cycle (e.g. maintenance, end of life treatment) in so far is relevant for the performance of the product(s)-type for the intended use(s).)

Note: the description shall be very specific, with the objective that this ETA is limited to the product(s)-type as introduced by the manufacturer and the intended use(s) as specified by the manufacturer to the Technical Assessment Body, only.

Note: dealing with a specific product (in particular, situation for an innovative product), the provisions on its use(s) shall be provided to allow the use of the product getting the performance(s) as it(they) is(are) declared.

Where relevant, refer to Annex(es):Detailed information and data are given in Annex(es) …

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SCOPE OF ETAG (3)

D. Some criteria to be taken into account

a. Identification data in the technical product description: data

necessary for the user, e.g. dimensions, density,.. Information

on product marking is also relevant.

b. Annexes can be used to complete both points

c. Handling of the working life:

Minimum information to be given

Statement on the assumed working life acc. to ETAG

Standard paragraph to clarify that working life is not a

guarantee

See text model

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(Statement on the assumed working life of the product(s)-type for the intended use(s) within the meaning of the CPR)

Note: the assumed working life can be defined as the foreseen period of time throughout which the construction product, as installed into the construction work, will keep its performances allowing the construction work, behaving under predictable actions and with normal maintenance, to meet the basic requirements for construction works

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Text model for working life for ETAs

The provisions made in this European Technical Assessment are based on an assumed intended working life of the (product) of xx years.

The indications given on the working life cannot be interpreted as a guarantee given by the producer or Assessment Body, but are to be regarded only as a means for choosing the appropriate product(s) in relation to the expected economically reasonable working life of the works. 

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ASSESSMENT OF THE FITNESS FOR USE (1)

A. What you can find

1. “Product characteristicsand methods of verificationand assessment” Table

2. Detailed information on theverification methods andassessment

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ASSESSMENT OF THE FITNESS FOR USE (2)

B. Applicability

Product characteristics

Applicable. Coming from the ETAG Mandate, they can be considered as

possible essential characteristics to be agreed with the manufacturer

NOTE: ER BWR and related text

NPD option

It is not possible to limit the NPD option for any characteristic according

to the CPR. The characteristics to be assessed should be agreed with the

manufacturer

Methods of verification

Applicable, provided they don’t need to be updated or replaced by a new

EN method or other appropriate test method

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ASSESSMENT OF THE FITNESS FOR USE (3)

Assessment and expression of product performance

Applicable, when the result can be expressed by means of

levels or classes, or a description (CPR Art.6 (3) (d)). Use

categories can also be used.

However:

the application of threshold values, if any, should be

authorized by the Commission (Art. 27 (4) 2nd paragr.)

the application of pass/fail criteria is not foreseen in the

expression of the product performances

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ASSESSMENT OF THE FITNESS FOR USE (4)

C. Handling in the ETA elaboration

1 and 2 Performance of the product and references to the

methods used for its assessment

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ASSESSMENT OF THE FITNESS FOR USE (4)

Comments on GD 07 indications

It is important to provide a summary including BWRs, essential

characteristics and the corresponding performances for the assessed

product(s), using a table(s) to provide this information

When necessary for a characteristic performance, a complementary table can be used (e.g. in an Annex)

The table proposed in GD 07 should be used, when possible

The given information should, as far as possible, facilitate the DoP

elaboration by the manufacturer.

NPD option

Characteristics for which the NPD option is not allowed in ETAGs are

relevant for technical coherency with the declared intended use (e.g.

Resistance to fire for fire protective products).

To advise the manufacturer on this issue

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ASSESSMENT OF THE FITNESS FOR USE (5)

Methods of verification

Relevant details on the applied methods to be included as

foreseen in GD 07

Assessment and expression of product performance

Threshold values and pass/fail criteria will be taken into

account

For products not complying with threshold values or pass/fail

criteria, the elaboration of an EAD will be necessary to assess

these products and to define the intended use in appropriate

terms.

Manufact. should be informed about this issue a.s.a.p

Whenever possible, threshold values or pass/fail criteria in

essential characteristics will be expressed by means of levels,

classes, categories or a description (Examples in doc.CPR5.1.2) 14

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ASSESSMENT OF THE FITNESS FOR USE (6)

D. Criteria to be taken into account

a. Consideration of durability and serviceability aspects as

essential characteristics: result expression depending on

ETAG approach

b. No need to mention BWRs and characteristics which are

not relevant for the intended use.

c. Need to mention all characteristics for which NPD is

applied; also for BWR7 – see CPR Art 6(3)b

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EVALUATION AND A&C AND CE MARKING (1)

A. What you can find

1. System of attestation of conformity

2. Tasks and responsabilities of:

2.1 the manufacturer

2.2 the notified body

3. CE marking and accompanying information

B. Applicability

1. Applicable.

2.1 Applicable.

2.2 Applicable, new terminology to be used (Note: CPR Annex

V Revision pending)

3. Is not to be considered in the ETA

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EVALUATION AND AoC AND CE MARKING (2)

C. Handling in the ETA elaboration

1 Assessment and verification of constancy of performance (..)

system applied, with reference to its legal base

System definitions, as given in CPR Annex V, should not be repeated

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EVALUATION AND A&C AND CE MARKING (3)

2.1 Technical details necessary for the implementation of the AVCP system, as provided for in the applicable EAD

General conditions/responsabilities are not to be repeated, only specific issues (e.g. table of FPC)

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EVALUATION AND A&C AND CE MARKING (4)

D. Some criteria to be taken into account

a. Minimum information in clause “Technical details necessary for

the implementation of the AVCP,…”:

- the reference to the control plan deposited in the issuing TAB

- following text based on Annex V amendment proposal or similar

(to be used until proposal is published):

Assessments of performance presented in the ETA should be

used as the base for the subsequent tasks of verification of

constancy of the performances by notified bodies and

manufacturers.

- FPC table information is to be considered in the control plan. No

need to include the corner stone FPC table, already in the ETAG.

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EVALUATION AND A&C AND CE MARKING (5)

b. Inclusion of information on the NB tasks in the ETA:

It is up to each TAB to solve it by means of the Control Plan (only)

or to also indicate some relevant criteria in the ETA, in combination

with the Control plan.

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ASSUMPTIONS UNDER WHICH THE FITNESS FOR THE INTENDED USE IS ASSESSED (1)

A. What you can find

1. Manufacture of the product

2. Packaging, transport, storage of the product

3. Installation of the product in the works

4. Use, maintenance, repair

B. Applicability

1. Applicable when relevant in relation with the ETAG scope

2. Applicable when the non fulfillment of such provisions can

influence the declared performances

3. Applicable

4. Applicable

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ASSUMPTIONS UNDER WHICH THE FITNESS FOR THE INTENDED USE IS ASSESSED (2)

C. Handling in the ETA elaboration

1 Technical description of the product or Technical details

necessary for the implementation of the AVCP, as provided for

in the applicable EAD, as appropriate

2 To be taken into account by TAB, but to be given in the

“Instructions” or “Safety information” (CPR, Art. 11 (6)), when

the non fulfillment of such provisions can influence the declared

performances; reference to this may be included in the ETA

3 Specification of the intended use(s) in accordance with the

applicable EAD in so far they are relevant for the declared

performances of the product

4 Same as 3

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ASSUMPTIONS UNDER WHICH THE FITNESS FOR THE INTENDED USE IS ASSESSED (3)

D. Some criteria to be taken into account

a. Possible use of an Annex for installation instructions, if agreed

with the manufacturer, linked to “Specification of the intended

use(s) in accordance with the applicable European Asessment

Document (…)”

b. Possible incorporation of design criteria in the “Specification of

the intended use(s) in accordance with the applicable European

Assessment Document (…)” or in an Annex to this point

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IDENTIFICATION OF THE CONSTRUCTION PRODUCT

A. What you can find

1. Means of identification

2. Product characteristics which are relevant for identification

checking

B. Applicability

1 and 2 are applicable C. Handling in the ETA elaboration

Aspects for the identification of the product by the user

“Technical description of the product” (Marking)

Aspects for the identification checking (Annex, Control Plan?)

D. Some criteria to be taken into account

a. It is not advisable that the identification test results are

disclosed in the ETA. It is up to the TAB how to deal with this

information, e.g. confidential Annex. 24

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TERMINOLOGY

A. What you can find

1. Common terms related to the CPD

2. Specific terms used in this ETAG/CUAP

B. Applicability

1. Not applicable in general

2. Applicable

C. Handling in the ETA elaboration

To use terms from 2 in the ETA drafting

D. Questions and issues for discussion or confirmation ./.

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REFERENCE DOCUMENTS

A. What you can find

1. Reference Document list

B. Applicability

1. Applicable, if updated

C. Handling in the ETA elaboration

To use these references in the ETA drafting, except some

referring to the CPD or to CPD related documents not accepted

under the CPR

D. Questions and issues for discussion or confirmation

./.

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ANNEXES (1)

A. What you can find

1. Definition of verification methods or details of some verification

methods. But also, depending on the ETAG:

2. Identification tests

3. Calculation criteria

4. Design criteria

5. Format of the ETA

6. Others

B. Applicability

1. Applicable

2, 3 and 4 Applicable

5 Not applicable

6 Applicable if relevant for the assessment and the declared

performances 27

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ANNEXES (2)

C. Handling in the ETA elaboration

To use the applicable Annexes, where relevant, for the ETA

elaboration

D. Questions and issues for discussion or confirmation./.

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PRODUCT TYPE DEFINITION

A. What you can find

1. No information

B. Applicability

C. Handling in the ETA elaboration

Minimum, for the DoP elaboration (possible criteria):

The information on the performances for the different

product(s)/kit(s) must be univocal

No performance pending of determination

D. Criteria to be taken into account

a. It is advisable to follow the above criteria, as far as possible.

To note that Annexes III and V amendment are on-going.

See extracted texts from Annex III and V amendment proposals,

as follows: 29

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PRODUCT TYPE DEFINITION – SOME NEW POINTS

1. Delegate Act Proposal for the ANNEX V amendment • Clause 1 on Systems of AVCP:

“The manufacturer shall draw up the DoP and determine the product-type on the

basis of the assessments and verifications of constancy of performance carried

out under the following systems:”

2. Delegate Act Proposal for the ANNEX III amendment

Whereas (6)

“In order to unequivocally identify the product covered by a declaration of

performance in relation with its performance levels or classes, manufacturers

should link every single product to the respective product-type and to a given set

of performance levels or classes by the unique identification code referred to in

Art.6(2) of Regulation (EU) Nº 305/2011”

Other criteria in the “ Explanatory Memorandum” (e.g. no use of

calculation formula is allowed in the DoP, no reference to other source

doc. when expressing the performance,..)

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USE OF ETAGs AS EADsFOR

EUROPEAN TECHNICAL ASSESSMENTs

Santiago del Pozo

ITeC

www.itec.cat

Workshop ETA process under CPR

EOTA , 30 January 2014

31