Solutions for manufacturers. Thomas Neuhaus

Transcription

1 Solutions for manufacturers Thomas Neuhaus from : Head of the VOC certification body at Eurofins Consumer Product Testing GmbH, Hamburg / Germany 1

2 VOC emissions testing Which tests do I need? EU: Compulsory for almost all interior products in France Compulsory for several interior product groups in Belgium, Germany Market advantage for low emitting products in market segments, especially with EMICODE & GUT (professionals), Blue Angel (DIY markets), M1 (Finland, Scandinavia), Indoor Air Comfort GOLD (most ambitious markets) Market advantage for low emitting in products for sustainable building projects, especially LEED, BREEAM, DGNB, Green Star, "Indoor Air Comfort GOLD" combines most of these requirements in one label USA: No regulations on VOC emissions, only VOC content and formaldehyde emissions Market advantage for low emitting products in products for sustainable building projects, especially LEED in schools (CHPS) in buildings following other programs, such as IgCC (International Green Construction Code) 2

3 VOC emissions testing: Differences VOC emissions testing: EU: Loading of test chamber and calculations for European Reference Room Air change rate ½ per hour Testing after 28 days, in Germany also after 3 days Recently ISO 16000, in future (pr)en (earlier EN does not exist any longer) USA: Loading of test chamber between 0,3 and 0,7 m²/m³ Calculation for several different exposure scenarios Air change rate 1 per hour during testing; 0,5 to 0,7 for calculation Testing after 11, 12 and mainly after 14 days; for furniture after 3 and after 7 days CDPH v1.1, BIFMA M7.1, ASTM D5116 and more ASTM standards Combination: Take the worst-case 3

4 Possible solutions - I Representative sample Worst-case approach: Select a final, ready-to-use sample with expected highest emissions. Criteria can be e.g.: Chemical composition Thickness Diffusion tightness (and contribution to emissions) of surface coating Single testing of VOC emissions and of VOC content Have it done separately per country / per rating scheme Needing tests for several purposes? Then you receive several reports and several invoices. Or plan it in a more efficient manner See next slides 4

5 Possible solutions - II Combine testing, save costs - VOC emissions Normal in Europe: Main test after 28 days storage in ventilated test chamber Parameters: VOCs, SVOCs, volatile aldehydes Normal in Germany: Additional test after 3 days Normal in USA: Main test after 14 days Additional test after days (furniture: after 3+7 days) Combine all your needs in one test setup: Test after 3 & 28 days storage in ventilated test chamber Add days for US test (CDPH) Add ammonia, odour, methanol test if required by some labels (M1, Blue Angel) Apply worst-case conditions if the test methods differ in detail 5

6 Possible solutions - III Combine testing, save costs - VOC content of coatings Normal in Europe: High VOC content (> 15%) and reactive coatings: Weight difference of ready-to-use coating after 1 hour at 110 C. ISO VOC content below 15%: Dilution with a solvent, then gas chromatography. ISO SVOC content: Can be determined with a modified ISO test (see a separate later presentation) Normal in USA: Weight difference of ready-to-use coating after 1 hour at 110 C. e.g. SCAQMD rules and methods. Subtract water fraction and exempt compounds (such as acetone). Combination (if accepted): Use weight difference test (if applied) and calculate in US and in EU mode 6

7 Application of self-declaration Self-declaration is accepted by: Regulations in Belgium and France EU Decopaint Directive But always needed: Documentation shall be available why you declared what you declared. Self-declaration plus recent test report: LEED, BREEAM, Self-declaration plus test report plus re-test after some years: EMICODE, GUT, Blue Angel, M1, EU ecolabel, Austrian ecolabel, Application, approval, continuous external surveillance: DIBt approval / Ü mark Indoor Air Comfort GOLD All US based product certification programs Indoor Air Comfort GOLD: Combines all these requirements 7

8 Present situation in Germany with DIBt DIBt required approval of product before entry into German market. For most floorings and wall coverings For flooring adhesives and parquet coatings Basis: Compliance with the emissions limits set out by AgBB Approval normally valid for 5 years. This includes: Continuous external surveillance With annual site inspection on-site and re-testing Goal: Ensure that the manufactured product conforms with the approved product. This is NOT required for: Laminates Flooring adhesives Parquet coating 8

9 AgBB / DIBt German VOC limits AgBB = basis for German low VOC regulation for construction products comply or fail, no classes After 3 days: 10,000 µg/m³ TVOC, 10 µg/m³ each carcinogenic VOC After 28 days: "Health-related evaluation": Restriction of emission of TVOC 1,000 µg/m³ 100 µg/m³ formaldehyde, 1200 µg/m³ acetaldehyde 1 µg/m³ each carcinogenic VOC LCI values, R value, VOC without LCI 100 µg/m³ TSVOC (total semi-volatile organic compounds) 9

10 Challenges - I DIBt approval system will phase out for CE marked products by 15 October 2016 The underlying "Bauregellisten" will be set out of force. Unclear is: What will follow? Voluntary "DIBt label"? Criteria for acceptance of private tests or labels? Clear seems to be from earlier DIBt communication: Any alternative system must not include any obligations before placing the product on the market other than those for CE marking (if available), must not be the only and exclusive way to approve products for us on the German market, must relate to the construction site and its impact on human health (maybe require that a building must be raised with low emitting products of certain characteristics). 10

11 Challenges - II DIBt approval system will continue for "non-regulated" products that cannot be CE marked Example: Flooring adhesives. The underlying "Bauregellisten" probably will continue to exist. Normally, until now, these products need approval and testing, but NOT annual surveillance of conformity with the approved product, including annual site on-site inspection or re-testing. But the approval as such is a must. Other non-ce-marked products may be included in such national regulation in the future. 11

12 Challenges - III What this can mean for CE marked products Proof of AgBB compliance possibly can be shown in different ways. In a transition phase until 2020, the market will see competing products that have an abz approval and carry an Ü mark valid until 2020, after application before 31 and approval before 15 October 2016, that have an abz approval and carry an Ü mark valid until earlier, because they got approved earlier, that are new and had no chance to apply for abz approval and Ü mark before 31 January Problems in the transition phase after 15 October 2016: Unclear whether external surveillance continues - probably not possible. Unclear whether and how changes of existing approvals still can be made by DIBt - probably no longer possible. Unfair competition between products in marketing is predictable. 12

13 What could satisfy DIBt needs? What are the key features of DIBt approval process Hand-over and storage of recipe. Compliance with AgBB requirements. Testing in line with detailed DIBt specifications. Test report in a data format ("ADAM") that allows storage and statistical analysis of test data by DIBt. Annual surveillance of conformity of manufactured with approved product by site inspection with sampling and re-testing (for most, but not all products). Tests and surveillance performed only by DIBt approved labs and certification bodies. Continuous quality management of the approved labs and bodies. Comparable systems might find sympathy at DIBt, or? 13

14 Which regulations / labels compare? Key features of DIBt approval process Hand-over and storage of recipe: NONE Compliance with AgBB requirements: (TVOC is different with some labels) Indoor Air Comfort, EMICODE EC1 PLUS, GUT, some Blue Angel criteria Testing in line with detailed DIBt specifications : Indoor Air Comfort, EMICODE EC1 PLUS, GUT, some Blue Angel criteria Test report in data format "ADAM": GUT, some Blue Angel criteria Annual surveillance of conformity, site inspection, sampling re-testing: Indoor Air Comfort Tests performed only by especially approved labs: Indoor Air Comfort, GUT, some Blue Angel criteria, M1 Surveillance performed only by DIBt approved certification bodies: Indoor Air Comfort, GUT, some Blue Angel criteria Continuous quality management of the approved labs and bodies beyond ISO accreditation: NONE 14

15 The future with German VOC requirements First we have to know the official requirements for the future Compliance by labels (Indoor Air Comfort, EMICODE, GUT, Blue Angel): Compliance with AgBB requirements can be evaluated. Testing in line with detailed DIBt specifications (with few deviations). Compliance by a certification programme (Indoor Air Comfort): Compliance with AgBB requirements can be evaluated. Testing in line with detailed DIBt specifications (with few deviations). Annual surveillance of conformity, site inspection, sampling re-testing. Tests and surveillance performed only by DIBt approved labs and bodies. And on top with Indoor Air Comfort: Required information for all VOC regulations in European countries is included in testing - no separate testing / evaluation is needed. Additional testing needed for Finland, old LEED and old BREEAM versions can be added to the testing - at more favorable costs than separate tests. 15

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