16 11 07 AGA Forum 2016 - GM Slides FINAL

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AGA Forum 2016

Copyright © 2016 BSI. All rights reserved.

Graham McKayGlobal Head of Gas & Electrical Products

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Graham McKayGlobal Head of Gas & Electrical Products

• Chartered Gas Engineer• Graduate in Electronic Engineering• Founder member of GAD-AC• Previously with British Gas, Advantica etc.

Contact: [email protected]


mailto:[email protected]


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• The UK National Standards Body: The source of British Standards

• Experienced: The world’s first National Standards Body established

in 1901

BSI Overview

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• The UK National Standards Body: The source of British Standards

• Experienced: The world’s first National Standards Body established

in 1901

• Specialist Focus on Standards Creation, Training and Certification

• Global Network: 72,000 clients in 150 countries worldwide • Thought Leaders: Shaped the most adopted standards, incl. ISO

9001, ISO 14001, OHSAS 18001

• Trusted: A Royal Charter Company, reinvesting profits back into our

business

• Our Kitemark brand is one of the oldest Trust Marks

BSI Overview

5Copyright © 2016 BSI. All rights reserved.

“RAPEX” – EU Rapid Alert System (non-food products)

93 Unsafe Gas Appliances Listed

Problem Statement


Problem Statement

IT’S NOT ABOUT THE FUEL




Problem Statement

Fixed (NG & LPG)Portable & Mobile (LPG)82%


CE Marking Overview – Gas Appliances

• Regulated by “Gas Appliances Directive” (GAD)• Fully in force across EU since 1996• Regulates compliance with “essential requirements”• European Standards important but not mandatory• Conformity Assessment “Notified Bodies” appointed• Mandatory two-stage compliance process:

• One-off laboratory “Type Examination” plus• Ongoing Production Surveillance




2,002 Unsafe Electrical Appliances Listed

4,876 Unsafe Toys Listed

Problem Statement


1) Regulations

2) Standards

3) Notified Bodies

So why is there a problem?


1) Regulations

2) Standards

3) Notified Bodies



Just ONE prosecution in the UK under GAD in 20 years


Regulations - Installation

• Gas Industry thinks in terms of piped gas…• Implied assumption of a competent installer

Examples from GAD:• Appliances only have to be safe when “correctly

installed and serviced according to their instructions”

• Essential requirement 1.2.1 covers “The technical instructions intended for the installer…”

These concepts are not valid for mobile appliances


Regulations

• Compliance duties are placed on the “manufacturer”• Shift from EU to Asia in last 20 years• No way to enforce when manufacturer outside EU

• Production Surveillance not being performed…• Law requires “annual” activities• Relevant for batch-produced product?• Seasonal goods?


Typical GAD process flow

Factory Surveillan

ce(QMS)

(Optional)Product

Audit Test

Initial Type Test

Initial Factory

Inspection

Ongoing “Annual” CycleOne-Off Processes

But… what happens when the standards

change?Tends to be focused on:

“Has the product changed?”


Regulations – State of the Art

• Standards are not mandatory, so little driver to improve or modify products when standards do change…

L̵Flame supervision on gas cooker hob burnersL̵Pierceable LPG cartridges on camping stoves

“If it was safe back then – it must still be safe

now”


Regulations – State of the Art

“If it was safe back then – it must still be safe

now”


1) Regulations

2) Standards

3) Notified Bodies



Weak Standards

• Standards are not mandatory but still important• Reliant on committees of “volunteers”• Self-interest tends to dominate• Maintaining status quo commercially attractive• Diminishing local expertise?• Process too complex (30+ countries)?


Weak Standards?


Weak Standards – Key issues for mobile products

• Over-reliance on warnings rather than design solutions• Poorly thought-out product instructions

• No allowance for lay-person assembling product• Too much jargon• “Install in accordance with the rules in force”• Reliance on details contained in installation

standards?

• Not covering the “reasonably foreseeable use” of products


GAD Essential Requirement 1.1

“Appliances shall be so designed and constructed as to operate safely and present no danger to persons, domestic animals or property, when normally used.”

Normally used… “…used in accordance with its intended purpose or in a way which can be reasonably foreseen.”


Foreseeable use?

EN 521 found to be defective for these products

Butane Table Cookers


Foreseeable use?


Foreseeable use – Space Heaters

Standard Safety Tests:• Covering with material• Placing close to a wall• Overturning• Blockage of air inlets• Thermostat failure

Maybe there is something to learn from electric products?


1) Regulations

2) Standards

3) Notified Bodies



Conformity Assessment Bodies• Grown to 58+ active bodies

• Competition has brought great benefits to industry

• May now just be a race to the bottom…?• Manufacturers do not bear the cost of low

quality… Time

Cost Quality

Who Decides?


What competition actually looks like in this space…

Notified Body #1• New feature – new risk• New risk not covered by EN 521• So devise a life test of some sort

Notified Body #2• Test to EN 521• Nothing more is needed

Who do you think won the business?


http://ec.europa.eu/DocsRoom/documents/10825/attachments/1/translations/en/renditions/native








Notified Bodies are not all the same…

- 25% of NBs- 8 Countries


2016 - New GAR Published


New CE Marking – Gas Appliances

• GAD will be replaced by a new piece of legislation called the “Gas Appliances Regulation” (GAR)

• When? 21 April 2018

• All gas appliances and “fittings” will have to be re-certified• All Notified Bodies will need re-appointment

• GAR addresses all the weaknesses discussed

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GAD to GAR… Key Changes in this context


RESPONSIBILITIES FOR ALL ECONOMIC OPERATORS

• Duties for “Manufacturers”

• And for “Importers” – significant new responsibilities to ensure all stages of certification process followed

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• Type Examination certificates now valid for a maximum period of ten years.

• Products must comply with acknowledged “state of the art”


New GAR process flow

Factory Surveillan

ce(QMS)

(Optional)Product

Audit Test

Initial Type Test

Initial Factory

Inspection

Ongoing “Annual” CycleOne-Off Processes

Standard changed?

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• Type Examination certificates now valid for a maximum period of ten years.

• Products must comply with acknowledged “state of the art”

• New requirements for Notified Body operations • Extensive changes from GAD• Mostly in place already in some Member States• Little or no impact for BSI• Already some resignations

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Generally only relatively minor technical changes… but couple of new requirements for manufacturers:

• To perform a risk assessment for all products placed on the market – must consider foreseeable misuse

• To implement hazard/risk reduction techniques• Remove / Guard / Warn – in that order

Intention is these will help deal with weak standards etc.

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Risk Assessment Requirement

CUSTOMER DEMAND, EDUCATION AND SKILLS- Should be documented- Use any model you are comfortable with…

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Risk Assessment Requirement

CUSTOMER DEMAND, EDUCATION AND SKILLS- Should be documented- Use any model you are comfortable with…

- Which risks to consider…?- Assembly & production errors- Installation errors- Component failure- User or operator error (foreseeable use)

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Summary

CUSTOMER DEMAND, EDUCATION AND SKILLS- GAD has generally worked well- Type Testing + Surveillance = Solid model

- Some operational issues with:- Standards and Notified Bodies

- GAD will be replaced by GAR in April 2018- Addresses the major weaknesses

- Making economic operators accountable- Ensuring 2-stage process is always followed- Compliance with “state of the art” requirements- Mandatory risk assessment


Finally… That “Risk Assessment” Issue Again


“Use only on a firm level base”…


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Thank You & Questions

Contact: [email protected]


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