Following on from Episode Four, which dealt with IGUs, Buccaneer’s Richard Bate turns his attention to fabricators.
Let’s assume that the IGU’s you purchase are light sabre sharp. Your supplier has even had a visit from the Empire and, from what they have seen, they consider the units to be compliant and well controlled (not that the Empire would officially endorse products of course – conflict of interest and all that).
You order your units as per normal, the DoP looks good, and you are happy with the product. What now?
As previously detailed, CPR and Harmonised Standards cover external windows and doors. In the window and door world this standard is BS EN 14351-1. You manufacture your external window and door frames from whatever material – all fall under the remit of EN 14351-1.
I manufacture my frame, put the hardware on, put my glass in the frame (or next to it on a stillage for delivery). Kits or loose units are generally fine under CPR provided the manufacturer takes responsibility for the complete product supplied.
So far, a similar story to IGUs: you must have ITT, FPC and a DoP. Well, yes and no. The basic building blocks are the same; however, there are some important differences.
Declarations
When selling your windows and doors, remember there are different essential characteristics to be declared. These differ between windows and doors, so you will need at least two DoPs – one for windows and one for doors. In practice, most fabricators will require more than two.
Under UKCA/CPR requirements, the declared essential characteristics should reflect the intended use of the product, and relevant Approved Document/Building Regulations requirements must be reported. UK minimum declared characteristics are as follows.
Windows:
- U-value
- Load-bearing capacity of safety devices
- Dangerous substances
Doors:
- U-value
- Load-bearing capacity of safety devices
- Dangerous substances
- Ability to release (panic/emergency escape hardware where applicable)
It is easier, and more common, to cascade or share ITT evidence for U-values and safety device testing on windows and doors.
IGUs are a totally different situation. Personally, I would say it is incredibly difficult – and far less common – to legitimately achieve cascading for EN 1279 Parts 2 and 3. And before anyone mentions Annex D of 1279, I have yet to see a UK ‘club’ arrangement that genuinely appears to meet the spirit and requirements of that Annex.
PVCU or aluminium systems houses may provide the same Approved Body or test evidence to multiple fabricators, provided the specification they sell genuinely falls within the scope of that evidence.
The specification of the product you sell – and produce a DoP for – must match the relevant ITT evidence.
For example, there is an ultra-thin outer frame available in the market, but hardly anyone uses it because it does not really work once installed in a property due to blaster line and installation constraints. However, it achieves a better U-value result in testing because glass area is king.
If the specification used for the ITT does not match the product covered by your DoP – and is not representative of worst case – should you really be selling it at that claimed performance?
Also consider load-bearing capacity of safety devices.
From a previous solar system, I have seen a restriction stay tested in one PVCU frame system and pass. The exact same restriction stay was then fitted into a different but externally very similar looking PVCU system and repeatedly failed the test.
A successful test on one PVCU system does not automatically mean it applies to every other frame material or system in existence. Carbonite included.
There is clear guidance within the standards regarding what should be considered when product components, materials or specifications change. It could literally be the difference between somebody falling out of a window or not.
Bear in mind that if you fit a panic bar to a door (ability to release), it falls under System 1 AVCP. That means involvement of an Approved/Notified Certification Body and tighter control of the specification and production process.
If you do not want the additional Approved Body costs and audits, then perhaps do not sell them – or alternatively buy them in complete from a supplier who already has the correct certification and DoP in place.
Relatively straightforward then: sell the product that matches your test evidence.
Or, put another way: “Do. Or do not. There is no try.”