Total Fabricator has previously reported on the Office of Product Safety and Standards taking a closer look at the glass and glazing industry, with worrying results.
Buccaneer’s Richard Bate explains that there needn’t be a disturbance in the force if the correct protocols are followed.
Let’s assume that all you Jedi out there know all about CPR, UKCA/CE marking, DoPs, Initial Type Testing, AVCP systems? I live in hope.
Basically, a lot needs to be in place before you sell your products, and it crosses your factory threshold. The question then becomes: do you actually understand what the requirements are for the product you are selling into the market?
If you are manufacturing IGUs, I think you need to read on.
Responsibility
Firstly, there is no debate as to who is responsible for the product and the performance claims. It is the manufacturer and the person who signs the DoP (declaration of performance) on behalf of the manufacturer. (Yes, importers and distributors may also carry some responsibility but let’s keep it to manufacturers for the moment.)
It is NOT the responsibility of:
- The initial type testing (ITT) from your Ukas-approved body (or equivalent) test house
- Your Ukas-approved product certification body (where required)
- The consultant who looks after your Factory Production Control (FPC). Yes, you do need an FPC, but it does not need to be ISO 9001
- Or your client
- A Jawa
It is yours as the manufacturer. Full stop. The MD or the authorised person signing off the DoP carries that responsibility.
Now we’ve established that, what do you actually need to do?
- Create your product description
- Get your ITT for EN 1279-2 for air-filled units and, if gas filled, EN 1279-3 for the exact specification of IGU specification that is in your product description
- Have an FPC in place and produce the correct DoP
- Actually sell the correct specification of product that is covered by your DoP. You can have more than one
Let’s tackle ITT first.
Once you have settled on the specification of the IGU you want to sell, you usually test it using the size units specified by the standard and through a Ukas-accredited and approved body test house for those testing methods.
So, let’s say it is:
- Aluminium spacer bar
- Bent with a join along one straight edge, a drop of PIB on the joint and no corner keys
- Molecular sieve desiccant
- Primary seal of PIB
- Polysulfide secondary seal
- Argon filled. Not krypton, because it’s far too expensive
We get a good pass on EN 1279-2 and EN 1279-3 gas retention squeezes through. Still a pass. The force is with you, off to Mos Eisley Spaceport with my wares.
Not so fast. Firstly, how was the unit made?
By hand? Absolutely fine. On a very expensive automated line? Absolutely fine also.
As long as the unit is made using the exact method employed for your normal production process, and using the same specification of materials and suppliers for spacer bar, sealant, desiccant etc, then all good.
What is not really acceptable is the units magically appearing on a bench ready to go for ITT via Obi-Wan Kenobi (or an ITT report, not related to your specification, delivered by him), or Greedo from next door finishing off the QC check because your normal QC man has been detained by the Empire.
No. The normal everyday production process needs to be adhered to for the test unit. Because if the Obi-Wan unit passes, the force may not be as strong with the normal everyday units off the line. And Greedo’s quality check may not be quite as good as your normal guy’s.
I jest, but the process of manufacturing the units must be controlled, and it must reflect your actual day-to-day production process.
Because if that normal process works during testing, then the unit should function for many years as intended. If the process and products within the unit do not pass, then things need looking at to understand why.
FPC and DoP
You can actually write your own FPC – no need for ISO 9001 etc. There is guidance within the standards and CPR itself. The FPC can be very simple and reflect both small and large business perspectives.
For standard System 3 products (unlike certain fire-rated products under System 1 which we will not go into here), there is generally no requirement for any ongoing third-party audit surveillance by an approved body or other non-approved body, although the manufacturer still retains full responsibility for FPC and compliance.
You will also need various other supporting test data, such as EN 1279-4 for the sealants, which your supplier should provide, plus information relating to spacer bars and, of course, you will have to carry out your periodic testing to EN 1279-6.
Sell the IGU
Once all this has been done, you can sell the product. Or will there be a disturbance in the force?
Say your client wishes to have a warm edge spacer instead of your lovely aluminium spacer bar. Can you just use the aluminium spacer reports with the same sealants and process?
No. In most cases, you cannot.
In the vast majority of cases, the standards are unlikely to permit this without further assessment and supporting evidence, particularly with the varied types of warm edge systems, sealing products, single seal and dual seal constructions now available.
Basically, if you:
- change the type of sealant
- move to single seal
- change spacer bar type
- alter significant componentry (corner keys?)
… then in the vast majority of cases you will need to go through the whole ITT process again or validate with other test or performance information and may have a separate DoP to cover those component changes.
If you do not go through this process, and understand the effect those changes have on the IGU (does it retain any argon after five minutes?) through proper testing and rigour, then you should not be loading the products into the smuggling compartments of the waiting YT-1300 light freighter.
There is talk of the Empire taking a closer look at our star system and there are whispers that they have special scanning equipment and will be looking at IGU manufacturers and not a long time ago in a galaxy far, far away.
I appreciate the frustration from IGU manufacturers who may look across the market and see competitors operating without the same level of documentation and controls. The question they ask is understandable: why should I invest in something that others appear to ignore?
My answer is: Who’s the more foolish? The fool, or the fool who follows him?