MCS Roofing Issues Working Group Final Minutes for 6 th September 2016

Transcription

1 Meeting of: Date: 6 th September 2016 Time: 14:00 17:00pm Attendees: Name Stuart Elmes (SE) (Chair) Carl Reynolds (CR) Charlie Greenaway (CG) Cathal Murphy (CM) Frank Thiollay (FT) Lionel Doudaine (LD) Will Clemson (WC) Paul Blackmore (PB) Tom Raftery (TR) Sarah Colwell (SC) (part) Jon Sturgeon (JS) ( ) Sean Young (SY) ( ) Mark Lewitt (ML) ( ) Louise Evans (LE) Gaurav Joshi (GJ) Representing Viridian Solar Solar Limpets Clenergy Sunfixings Limited IRFTS Solar Solutions IRFTS Solar Solutions Helios Energy BRE Global BauderSOLAR BRE Global Solar Century BBA Kiwa Gemserv Gemserv Apologies: Name John Holden Laura Critien Ben Gosling Kevin Ley Jason McCabe Nigel Blacklock Martin Butcher Nigel Cherry Ella Carpenter Representing BRE Global BRE Global K2 Solar Mounting Solutions Limited Monier Renusol GmbH BauderSOLAR Vaillant Monier Sunfixings 03/04/2017 Page 1 of 14

2 Meeting Agenda: No. Item 1. Welcome to the meeting 2. Minutes and actions from the previous meeting 3. IET Guide update 4. Review of pren 15601:2006 to PD CEN/TR 15601: Proposed MID Changes 6. MCS 012 Explanatory note v Review of the standard for component testing 8. Bespoke installations pitched roof definition 9. AOB 10. Dates for next meetings 1. Welcome to the meeting SE welcomes attendees and introduced himself as the new Chair of the WG. LE introduced GJ to the group as the new MCS Delivery Manager. 2. Minutes from the last meeting The minutes were approved to be an accurate reflection of the meeting subject to the following amendment: To include a post-meeting note from BauderSolar beneath ACTION 012WG_ to say: The relevant test is a system test of the whole roof build up including the deck and focuses on both penetration and spread of flame. (Member of FSH/22/8 mirror group). 03/04/2017 Page 2 of 14

3 TR requested the circulation of the CENELEC/BSI document which highlights the shortfalls of the current fire test method for flat roof membranes with Solar PV systems and recommends that different test methods should take place. ACTION 012WG_ : MCS Administrator to circulate CENELEC/BSI document to the Roofing WG. The WG reviewed the outstanding actions: ACTION _06: JS informed the WG that he visited BRE in August to meet with JH, SC and Sunghan Koo (SK) to discuss progressing the project. SC and SK will produce a proposal for the next step of the project, which will be in phases for the WG to approve. The intention is to provide a public update before Clean Energy Live at the beginning of October, however, this will be dependent on the completion of the novation process. LE provided an update on novation which is expected to be completed in October. The final Steering Group meeting took place on 20th April and it has been agreed that the group will continue to exist as an entity but in a dormant capacity until novation is completed in order to allow the Management Panel to continue to operate in the interim period. ACTION 012WG_ : JS noted that a meeting with SC has not yet taken place to seek clarification on whether it was necessary to amend A5.1.1 Note 2 in regards to the use of a roofing membrane in MCS /04/2017 Page 3 of 14

4 SE provided some context to the group explaining that the note is intended for situations where a fixing system relies upon the solar panel for its fire rating, it can t be guaranteed that the same results will be achieved when that fixing is tested with another manufacturer s panels. A fire proof backing is required if the roofing kit/module combination does not have a declared fire rating. It was noted that membranes provide flame penetration resistance but it is not clear how this will affect the spread of flame and this was the issue that the WG was seeking an opinion on. At this point SC joined the meeting. SC is Director of Fire Suppression Testing and Certification at BRE Global, Chair of FSH/022/0-/08 Fire resistance tests for external fire exposure for roofs and a Member of UK delegation to CEN TC 127/WG5 External fire exposure for roofs. The Chair welcomed SC to the meeting. SC explained that the thought process in the fire safety industry at the moment is that the impact of solar panels on the fire performance of roofing is an issue which needs to be addressed. SE sought SC s view on the current limitations placed by MCS 012 on fire ratings for systems that work with interchangeable PV modules and rely on the presence of the module for the fire performance. SC s view was that such fixing systems cannot achieve a fire rating unless the modules come from the same family of which the kit was tested with and that the current MCS position is correct until further research can confirm that families of panels with similar construction can be treated as interchangeable. Whether the note in A5.1.1 allowing such systems to be installed so long as additional steps are taken to ensure that the roof achieves an AA rating without the solar fixing kit in place was safe, given that it deals only with fire penetration and not surface spread of flame. 03/04/2017 Page 4 of 14

5 SC explained that the Dorset model in Approved Document B was created to prevent the external spread of flame across thatch roofs after the Great Fire of London. The WG reviewed Table 16 of the Fire Safety Approved Document B of the Building Regulations and it was noted that the equivalent European classes do not monitor spread of flame, but rather penetration. It was therefore SC s opinion that the inclusion of the interim guidance provided in MCS 012 A5.1.1 is the only safe measure that could be taken by the Scheme given the current industry understanding of the fire performance of solar panels. SC raised that membrane may not be the correct phrase to use as membrane also referred to another roofing material (the secondary weather proofing layer) and that this could lead to confusion. The WG agreed that in the next round of changes to MCS 012, page 24 roofing membrane should be amended to barrier material and that ACTION 012WG_ should be closed. The WG thanked SC for her contribution. ACTION 012WG_ : MCS Administrator to amend roofing membrane to barrier material in the next draft of MCS 012. At this point SC left the meeting ACTION 012WG_ : At the last meeting, the WG agreed that trapezoidal clamps should be tested in accordance to the requirements of MCS 012 as they are a component and this could be completed in a worst-case scenario basis over a thin sheet. JS requested that the MCS Administrator forward the original query and agreed to follow up with the CB who raised the issue. 03/04/2017 Page 5 of 14

6 ACTION 012WG_ : LE confirmed that there has been an allocation of budget for MID changes and a further update will be provided under agenda item IET Guide update LE reminded the WG that the funding request to conduct the gap analysis between the Solar PV Guide and IET Guide was declined due to a lack of available funding. It was agreed at the last Roofing WG meeting that the WG agree in principle that the IET Guide could be adopted and any missing information could be included in the Solar PV Guide. The MCS Administrator have been informed that this item will feature highly on the agenda of the first Board of Directors meeting to take place following the completion of the novation process. The main issue to be considered is that IET documents are not freely available and MCS will need to consider the additional cost installers would incur. 4. Review of pren 15601:2006 to PD CEN/TR 15601:2012 LE informed the group that PB completed the review of pren 15601:2006 and PD CEN/TR 15601:2012. PB confirmed that there are no material changes between the versions of the standard which are essentially identical in content. The WG agreed that the references should be amended during the next update to the MCS 012 ACTION 012WG_ : MCS Administrator to amend the references from pren _15601:2006 to PD CEN/TR 15601:2012 in the next round of changes to MCS /04/2017 Page 6 of 14

7 5. Proposed MID Changes The Chair explained that at the last 22 nd June Roofing WG meeting, the WG considered proposing further amendments to the MID by including the addition of a dropdown box to allow the Installer to select which MCS 012 approved product was used and if an MCS 012 product hasn t been used, to specify the reason why the installation is exempt e.g. ground mounted, flat roof or existing contract to assist with the auditing process. SE circulated a presentation to the group for comment after the last meeting and no comments were received. LE informed the WG that therefore a Change Request was raised to establish a quote for implementing the following: 1) Amend Please confirm the use of MCS 012 pitched roof installation kit as part of the installation to Is the installation on a pitched roof? 2) Amend Not Applicable e.g. the installation is on a flat roof, it is a ground mounted system to, Not Applicable (e.g. the installation is on a flat roof, it is a ground mounted system, an existing quote is in place or an existing contract is in place) 3) To allow Installers to select which Roofing Kit has been used, this will need to be added as a technology to the MID so that users are able to select which Solar PV, Solar Thermal or Solar Keymark product has been used and then separately, which kit has been used to attach the system to the roof via a drop-down box. 4) The bulk spreadsheet will need to be updated to include an additional column called Does the installer need to provide additional fire proofing?, a yes or no answer would be provided by the Certification Bodies. 03/04/2017 Page 7 of 14

8 5) If an installer selects a Roofing Kit product where yes has been indicated to the previous question in the data for that product, a message and checkbox option should appear stating: The module/roofing kit combination you have chosen is not rated for external spread of flame, please check the box to confirm that you have made alternative arrangements to provide the roof with a sufficient fire rating: The proposal was considered by the Management Panel at the 1 st September meeting who agreed not to proceed with implementing the changes at this time on the basis that the changes would cost approximately 81% of the scheme s budget for MID changes and the recommendations could be provided in a guidance document rather than an update the MID. LE explained that the change proposed to allow Installers to select the pitched-roof mounting kit used requires significant amendments to the functionality of the MID, for example, to allow a roofing kit to be selected, they must be added as a new technology to the bulk upload template but only be available when selecting Solar PV, Solar Thermal or Solar Keymark products. It must also be ensured that the option to select multiple technologies on a certificate is restricted to only these circumstances. The WG expressed their disappointment regarding the decision not to proceed with the proposal and challenged the MCS Administrator around potentially looking at a new database contractor. The group reaffirmed that the changes would: Help to promote the MCS 012 approved kits Acknowledge the significant contribution made by industry in developing the standard Contribute to a robust auditing process Recognise the testing undergone by MCS 012 approved product manufacturers 03/04/2017 Page 8 of 14

9 JS noted that whilst the scheme s activities must reflect the new revenue model and budgetary constraints, it is one-off cost and would be a sensible use of income reserves rather than operating income. The WG unanimously agreed to feedback to the Management Panel the dissatisfaction with the decision taking and request that the proposal be reconsidered. ACTION 012WG_ : SE to draft a letter to the MP feeding back the WG s views on the decision not to proceed with the MID changes. MCS Administrator to circulate to the WG for review and provide to the MP. 6. MCS 012 Explanatory note v0.2 At the last 22 nd June Roofing WG meeting, the WG reviewed V0.2 of the MCS 012 Important Information document which had been updated to include the different contractual circumstances spanning the MCS 012 kit mandatory implementation timeline. LE noted that since the meeting, the MCS Administrator had completed a review of the document to ensure it is clear and updated the issue numbers and dates. The Chair invited any further comments from attendees and it was agreed that the document should be published following the meeting. ACTION 012WG_ : MCS Administrator to publish the latest version of the MCS 012 Important Information document. 7. Review of the standard for component testing SE explained that a CB has queried why the wind resistance of a roof hook was being given as a pressure rather than a force for a certain number of brackets. 03/04/2017 Page 9 of 14

10 MCS 012 (Clause A4.2.1 Method) states that the units declared should be in Pascals (kpa), however, it was written predominantly for a test system and has since been extended to work for components. The WG agreed that a force declaration (kn) would be far more meaningful for a single fixing. It was agreed that A4.2 Test criteria should be reviewed to see if this change can be made and ensure clarity of definitions. WC and SE volunteered to complete the review. ACTION 012WG_ : WC to complete review of MCS 012 with regards to kpa and wind uplift resistance and circulate to SE via the MCS Administrator. 8. Bespoke installations pitched roof definition At the 22 nd June Roofing WG meeting, feedback provided by the Solar PV WG on the bespoke text was discussed. Pitched Roof Definition The WG proceeded to review the pitched rood definition as suggested by the Solar PV WG. SE invited comments on whether the definition should specify an angle of greater than 10. JS noted that >10 to the horizontal was originally drafted in order to exclude ballasted systems. The intent of the definition was that if manufacturers wanted to declare intent at 5 then they would be able to, as it would be permissible as part of an overlapping range. TR suggested adding a note to clarify that the definition does not apply to a membrane roof and CG noted that a roof hook could be applied and then a membrane could be fitted on top of this. 03/04/2017 Page 10 of 14

11 SE clarified that the purpose of reviewing the definition is to define what a pitched roof is rather than the requirements for testing a range of products because the PV Guide specifies that an MCS 012 approved kit must be used if the roof is pitched. ACTION 012WG_ : JS to provide some pitched-roof examples to aid discussion of the definition. ACTION 012WG_ : MCS Administrator to check if the pitched roof definition has been circulated and, if so, for what purpose. Bespoke Text At the 22nd June Roofing WG meeting, the WG agreed: To avoid creating a loop-hole for installations There will inevitably be situations where this occurs, and this should be catered for in the application of the standard Bespoke installations can affect structure, weather tightness and fire. A view needs to be taken by an independent and qualified 3rd party. The WG wish to create enough of a dis-incentive for installers to use the route for every installation but don t wish to apply a disproportionate burden on a unique project. JS proposed the below amendments to the bespoke text which was reviewed by the WG. The text focuses on the custom design required on a unique project. Where a custom design is required on a unique project where no MCS 012 certified system will be suitable, a new system may be used that meets the following requirements: An impact assessment is conducted to evaluate which areas of the proposed installation require evaluation. 03/04/2017 Page 11 of 14

12 Affected performance areas are subject to calculation and approval by a suitably qualified and independent 3rd party. The manufacturer must warranty the system and calculation for at least 10 years. The installation is unique, multiple usage requires type approval by a CB. ACTION 012WG_ : SE to feedback a summary of changes to the proposed bespoke text to JS. JS to amend the text to reflect the changes. ACTION 012WG_ : MCS Administrator to circulate the amended bespoke text to the Solar PV WG for comment. 9. AOB Flat roof mounting solutions TR explained to the WG that as the market moves, there are more and more Solar PV systems being installed on flat roofs but no substantial guidance on best practice which results in a lot of poor installations simply due to the mounting system always being procured with the cheapest possible solution. This is a high risk from a health and safety/building structure viewpoint. It was therefore proposed that MCS 012 should expand to incorporate flat roof mounting solutions and that MCS should issue guidance on best practice in the short term. The Chair invited comment from the group on the appetite for including flat roof requirements in MCS 012. It was noted that MCS is primarily a consumer protection scheme and the focus of the standard was to mitigate risk to the consumer. It was therefore initially agreed that the scope 03/04/2017 Page 12 of 14

13 of MCS 012 should cover pitched roofs as installations are most frequently on pitched roofs and therefore pose a higher risk. The WG agreed that MCS 012 could be reviewed and that a Change Request should be proposed to include flat roof mounting solution requirements in MCS 012 to be discussed at the next WG meeting. ACTION 012WG_ : MCS Administrator to circulate BSI doc on behalf of TR to the Roofing WG. ACTION 012WG_ : TR and CM to review MCS 012 and propose a Change Request to include flat roof mounting solution requirements for review by the WG and consideration by the SMG. Database administration JS enquired as to whether the products that have not been certified to Issue 2.1 of MCS 012 have been removed from the database as of 2nd August. LE explained that the MCS Administrator to do not remove products from the MID, however, if a CB enters an effective to date for the product, an installer will not be able to register it on the MID. The MCS Administrator relies on Certification Bodies to enter this effective to date in accordance with updates to the standards. The pitched roof mounting kit product numbers have reduced from 132 to 127 but there are no reason codes provided for this so these could be certification renewal dates. As the product performance data is now featured on the product search pages, LE agreed to circulate a communication to CBs: 03/04/2017 Page 13 of 14

14 Reminding them that the transition period for v2.1 of MCS 012 has ended and noncompliant products should receive an end date in the weekly product data Informing them that product performance data is now visible on the product search pages for MCS 012 products Requesting that CBs provide the MCS Administrator with this data It was agreed that roof mounting kit manufacturers should also chase their Certification Bodies to provide MCS with this data. ACTION 012WG_ : MCS Administrator to circulate a communication to CBs reminding them that the transition period for v2.1 of MCS 012 has ended and non-compliant products should receive an end date in the weekly product data. The communication should also remind CBs to provide product performance data for the MCS website. 10. Dates for next meetings The working group agreed that the MCS Administrator should look to arrange the next meeting in January ACTION 012WG_ : MCS Administrator to circulate a doodle poll with dates for a working group meeting in January 2017 with the draft minutes from the meeting. 03/04/2017 Page 14 of 14