Response to CENSolutions

Sir,

We read with interest the email from Giles Wilson of the GGF responding to an ill informed commentary by CENSolutions on EN 14351. We would also like to set straight comments made by CENSolutions that certification bodies are not keeping customers informed.

Chiltern Dynamics and our sister company BM TRADA Certification fully realised the significance of EN 14351-1 to door and window manufacturers, so much so that we published a technical information sheet about it long before the standard was published in 2007. Both Chiltern Dynamics, through its testing and consultancy services, and BM TRADA through certification services, are regularly in touch with a large number of window and door manufacturers. There has been considerable demand from clients and others for this four-page information sheet - to the extent that it is currently being updated and reprinted.

Even before that, however, we staged our 'European Openings' seminars in London in October 2005 and in Leeds a month later, to outline the implications of CE marking for manufacturers. This was widely reported in the Glass & Glazing press, including the Gl@zine.

While recognising the serious implications of EN 14351-1 ourselves and having taken, we feel, firm and constructive steps towards galvanising the industry to be ready, we have been slightly disappointed by some manufacturers' reactions. There is, we fear, a touch of that old saying regarding 'taking the horse to water' about the situation.

We are offering detailed technical information free of charge and have been for three years, giving manufacturers the opportunity to measure the requirements against their existing business practices, to see for themselves how much consultancy they actually need.

And progressive window and door manufacturers have, in fact, been testing their products with us to the relevant EN performance standards mandated in EN 14351-1.
This initial type testing (ITT) is the only part where a Notified Body has to be involved. All other aspects of the CE marking process to EN 14351-1 can be done by the manufacturer, without any external cost to themselves. The straightforward process is explained in the technical sheet mentioned above, T1 - 0607 CE Marking doors and windows.

Similarly with prEN 14351 Parts 2 and 3. Even though the product standards are not yet published, the relevant performance standards are. Clients are testing their products against the EN standards and will therefore be ready to CE mark their products when the product standards are eventually published.

Yes, EN 14351-1 has been making its painful way towards us for some time and yes the industry needs to show a greater sense of urgency in preparing for it. But we believe there is - as yet - no need to panic. The following product standards are still in committee and, while work is ongoing, there is no definite date when they will be published (so much for the conspiracy theory):

* prEN 14351-2 Internal pedestrian doors (non fire resistance) and
* prEN 14351-3 Products with fire resistance.

Yours etc

Vincent Kerrigan
Deputy Technical Manager
Chiltern International Fire/Chiltern Dynamics