3 Transposition of the Essential Requirement No. Hygiene, health and the
3.2 Approach for transposing the Essential Requirement No. 3 into technical
In terms of the Essential Requirement No. 3 "Hygiene, Health and the Environment", the Construction Products Directive and the more specific Interpretative Document No. 3 require that building users and the immediate environment shall not be endangered by the construction works.
A tiered approach should be taken in order to take full account of the Essential Requirement No.3 in the technical specifications. In order to evaluate the possible release of dangerous substances, this requires knowledge on both the chemical composition and structure as well as on the planned use of the products in construction works (e.g. direct or no contact with the indoor air). For instance, it is quite possible for a product classified as "critical" to be used in application areas that present no risk to health or the environment.
Taking into account the composition and area of application, the mandated construction products should be classified into products that, due to existing experience, can be deemed as obviously harmless and for which no additional tests are required (WFT products – Without Further Testing) and products for which the health and environmentally relevant effects can only be evaluated by using specific individual tests as part of approval procedures. For products falling between these two cases, which are therefore subject to standards, stipulations should be made in the standards that ensure that a risk for users and the environment can be excluded with a sufficient degree of certainty.
WFT products (Without Further Testing)
Construction products whose constituents are known and which, based on many years of experience, are not expected to release any dangerous substances should be included in a list of WFT products (Without Further Testing) for which no additional requirements are made in terms of testing for release behaviour. The corresponding product standards should indicate that they are WFT products. The composition and areas of application for the corresponding construction product should be precisely specified in the standards. As has already been described in Section 3.1.2, the new Mandate for horizontal test methods for dangerous substances includes the elaboration of a technical report to specify criteria for classifying WFT products.
Standardised products
Construction products that are not suitable for inclusion in a WFT product list should be tested within the domain of standardisation as far as they fulfil specific prerequisites. Even the manufacturers themselves are often insufficiently aware of the chemical composition of their respective products; when specific raw materials are used, this information is often only known to the suppliers, i.e. the producers of the individual substances. Furthermore, in terms of the materials used, the standards generally provide either very generalised information or none at all. It should be required in this context that the respective construction products are described in the product standards as precisely as possible in terms of their chemical composition and that, if necessary, the range of substances be reduced. The longstanding experience with the standardised products means that the release of dangerous substances should be known and in many cases also regulated. The dangerous substances that can be released from construction products, or whose content is problematic, must be listed in the product standards together with the corresponding harmonised test methods. In order to enable evaluation by the Member States, levels, classes or declared values should be given in the CE marking for these pollutant parameters.
The current mandates for construction products provide either insufficient or no information as to which dangerous substances can be released from construction products or are contained in them. In order to specify the substances to be considered, a list should be drawn up of dangerous substances that can be released from construction products or whose content is classified as problematic. It is important to note here that it cannot be assumed that the list of dangerous substances is exhaustive and that if corresponding information becomes available, other dangerous substances must be taken into account in the technical specifications. The specification of substances deemed to be dangerous should be subject to intensive discussion. However, it will not be sufficient to consider just regulated substances as described in Section 3.1.3.
Depending on the complexity of the respective product, a comprehensive evaluation of all substances will always be very difficult in the field of standardisation. For this reason, and as is already practised in the German approval procedures, more extensive testing and evaluation schemes should be drawn upon such as the DIBt Guideline: "Assessment of the effect of construction products on soil and groundwater" [20] or the "Health-related Evaluation Procedure for Volatile Organic Compounds Emissions (VOC and SVOC) from Building Products" [21] (see also sections 5.3 and 6.1). The DIBt Guideline also prescribes biological testing procedures and requires compliance with insignificance thresholds for the release of heavy metals and organic substances to soil and groundwater. By testing the ecotoxicological effects, it is also possible to draw conclusions as to the potential risk to the environment of the construction products without having precise knowledge of the substances contained.
Products subject to approval
Test for construction products for which there is no experience concerning the release behaviour of dangerous substances should be harmonised within the framework of European technical approvals. This generally concerns innovative and, in terms of health and environmental protection, product groups that have not yet been comprehensively described and which contain a diverse range of substances. Construction products should also be subject to approval that use wastes whose composition cannot be defined and for which there is no long-term experience available.
As technical approvals are issued for defined construction products, it is both permissible and realisable for the respective approval body to demand details on the chemical composition of construction products submitted for approval so that it can evaluate the constituents. Whether products are to be subject to standards or approval should be determined by the European Commission at the mandate level.
The following diagram illustrates the approach of dividing the diverse range of mandated construction products into various groups. This division is applied by using the example of
"concrete constituents" and "floorings", which are examined in detail as part of this research project (see also sections 5.7 and 6.3).
Fig. 1: Approach for transposing the Essential Requirement No. 3 into technical specifications
WFT products
(Without further testing)
Mandatierte
Consideration of the composition and the field of application