Britain has just witnessed one of the most shocking failures in Building Safety and the likely cause is the UK’s current building procedure — be that what was specified, what was installed or how it was installed.
What happened isn’t a random incident and, as subsequent product testing has revealed, it could happen again. Its repercussions are likely to be felt throughout the building product sector for years to come.
For many years Britain’s once thriving cable industry has fallen foul to substandard cable product — left to infiltrate the market and undercut the quality products that once made Britain great. Poor market surveillance has also taken its toll.
Construction Products Regulation (CPR), an EU piece of legislation, could be the UK cable industry’s saviour and be a template for how building products should be categorised and market surveillance implemented. Yet a lack of desire to embrace the principle of the CPR, monitor the market, enforce the CPR and apprehend those who abuse it will be its downfall.
For cables CPR came into force on 1s t July, yet the EU hasn’t been prescriptive in specifying or even recommending which classification of cable performance should be used for a building. Instead it is the responsibility of each Member State regulator — in the UK this is the Department of Communities and Local Government (DCLG). DCLG has decided not to specify which class of cable for which building and instead requires all electrical installations in buildings to comply with BS 7671 with a minimum performance requirement. Despite industry being fully aware that Euro Class E is almost the lowest classification for cable, by stipulating compliance with BS 7671, this is the recommendation of the regulator.
Not only this but for some classes the system allows the manufacturer to self-test and classify or to supply its own selected samples for testing — a process that is open to abuse.
The UK is destined to remain a key market for distributors of counterfeit and substandard electrical cable. This one lapse of judgement means the UK is no closer to having a safer building environment.
Tratos, a cable manufacturer with production facilities in Merseyside, has announced that all of its CPR Reaction to Fire cables will meet the higher Euro Class of Cca. The company does not see this action as the introduction of a gold-standard, rather, the introduction of a higher minimum standard; one everyone can be confident in.
In addition, the company is calling for Regulator intervention to mandate for the same minimum class of performance (Cca) for all reaction to fire cable in the UK.
CPR is the greatest opportunity to bring about safer cable products. The cable supply chain and Regulator are failing to understand that adequate isn’t enough. The UK Regulator must stipulate a minimum requirement of Euro Class for CPR — Cca; and a robust programme of market surveillance for CPR compliance must be established and adopted as best practice throughout the construction and building industry.
Britain has the opportunity to be exemplary. To squander it will add insult to tragedy.
Root and branch fire safety failures in the UK’s building stock are shocking. But a blinkered approach to remedial work now could prove just as dangerous. While cladding materials have been proven inadequate, we cannot and must not stop there.
If Britain’s housing (and commercial) stock is to be guaranteed safe, we must go beyond buildings’ exteriors.
Buildings’ nervous systems (cabling) as well as their skins (cladding) can be either friend or foe to fire. Our task now is to ensure both play their part to create the safest environments.
Shelter, safety and freedom from fear are basic human rights. Britain has an opportunity, and an obligation: Industry HAS to help.
The forthcoming Construction Products Regulation (CPR) for cables exists to ensure cable manufacturers set aside competitive advantage, and, in the absence of any Government directive, unite under an industry safety recommendation. The recommendation is for a higher classification of cable to be installed in all permanent building installations; a procedure that should be adopted in each and every building product category.
Government can no longer distance itself from vital market surveillance — industry cannot and will not police itself subjectively — product failures happen because of inadequate surveillance.
British Standards, whether for cable or any other building product, need to be of the highest level. ‘Adequate’ is not sufficient. British Standards and installation practice must achieve the highest safety level — it is called ‘best practice’ for a reason.
Now, more than ever, people need to be confident that new build and refurbishment projects will only use the best possible materials, installed by those best qualified to do so.
Regaining its place as a proud, quality producer should be a countrywide goal for the UK. To those who weigh cost over consequences — as the saying goes “if you think safety is expensive, try having an accident”.
In a country that used to be synonymous with the manufacture of quality products, it is shocking to listen to the debate over the causes of the Grenfell Tower fire. Whether the final outcome will rest heaviest on the quality of materials, how they were installed or a combination of both is yet to be seen.
Such stories sit uncomfortably with a nation that has a long history of manufacturing safe, reliable, quality products. ‘The long list’ of British-manufactured quality products doesn’t really exist anymore. Quality and safety costs. Time for another saying: Buy quality, buy once, buy safety!
Britain’s cable industry was once thriving, but there are now just a handful of UK cable companies left. The demise of the industry has been variously blamed on substandard cable product and an overall decline in UK manufacturing linked to the country joining the EU. Competitiveness, when safety matters, shouldn’t be limited to price.
"EU rules were often such that UK cable industry was badly damaged by the shock of joining and the continued shock of staying in as the rules increased and tightened. When the UK joined the EU we had a 45 million tonnes a year steel industry. Today we are battling to save an 11 million tonnes industry. When we joined the EU we had a 400,000 tonnes a year aluminium industry. Today we have just 43,000 tonnes of capacity left... The October 2013 government “Future of Manufacturing” Report shows that between 1951 and 1973 metals output rose 3% a year. Since joining the EEC/EU it has declined by more than 6%".
It is ironic that a piece of EU legislation could be the saviour for the remainder of the UK’s cable industry. But only if, as a market sector, we follow, embrace and enforce the legislation rigorously and monitor and apprehend those who chose to flout the process.
Construction Products Regulation
Construction Products Regulation (CPR) for cables came into effect across the EU on 1s t July and is the most significant step in decades for cable product safety.
The CPR is a system and framework of consistent rules for managing the marketing of construction products; a consistent technical language allows a construction product’s performance to be measured and compared throughout the EU.
Many EU countries have their own national fire regulations, containing valuable product requirements but they are not consistent with each other. That means it prevents free movement of products in Europe. CPR changes all this allowing for clear interpretation of the regulation by each member state.
Under CPR all reaction to fire3 cables supplying electricity, used for control and communication purposes and installed permanently in a construction works4 must meet European Standard EN 50575. This standard specifies the expected performance requirements of the cable, as well as the test and assessment methods to be used. In time resistance to fire cables will also be included5 — a date is yet to be announced.
Since 2016, UK cable manufacturers have been working to ensure their relevant cable products are tested and classified as, of 1st July, only products which have a European Classification under EN 50575 are acceptable for sale in the EU. Cables which don’t cannot be legally sold.
A cable’s 'reaction to fire' performance is defined using a common seven-tier European Classification (Euro Classes) system from the highest performance (effectively non-flammable) to the lowest (easily flammable).
There are three further classification methods which deal with the amount of smoke produced when a cable burns (s1, s1a, s1b, s2, s3), the level of acidity of the smoke (a1, a2, a3) and flaming droplets (d0, d1, d2).
Some cables will deliver the best results in terms of their release of smoke, acid gasses and flaming droplets. Where there is a specific sector safety requirement — for instance in the rail sector — there will be a clear cable specification, from the customer, to meet the appropriate classification for the application.
While the CPR is comprehensive, the EU hasn’t been prescriptive in which classification of cable performance should be used for a building.
Instead it is the responsibility of the Regulator of each Member State or equivalent; in the UK, this is the Department for Communities and Local Government (DCLG).
It is the Regulator’s task to decide if a particular class of product is required to meet a specified class of performance when installed in a designated building or construction works.
In the UK, DCLG has decided not to make any such recommendations to define the minimum classification to be installed in a designated building or construction works for cables. Instead it requires all electrical installations in buildings to comply with BS 7671 with a minimum performance requirement.
The new rules also intend to introduce market surveillance by Trading Standards and penalties for putting product on to the market that is not CPR compliant.
CPR — The reality
What this means is that, despite industry being fully aware that Euro Class E is almost the lowest classification for cable, it is, by stipulating compliance with BS 7671, the recommendation of the Regulator.
For an industry already blighted by substandard cable product, CPR should be a welcome friend, yet by opting for the low level of Euro Class E, the regulator is leaving the door wide open for further abuse of the system.
We have to ask ourselves, do we have to accept this?
As far as Euro Class testing goes manufacturers have a choice when categorising their cable:
- for Aca through to Cca — a Notified Body must audit Factory Production Control (FPC) system, select the samples for and carry out Type Testing
- for Dca and Eca a manufacturer can send the selected samples it chooses to a Notified Body or a Notified Testing Laboratory
- for Fca, a manufacturer can select its own samples, perform a Classification Eca and, if the cable fails, declare it as Classification Fca. The manufacturer should keep a report and record of all of these “Fails to meet Eca tests” and produce them on demand if a regulator asks.
- Any system which allows a manufacturer to self-test and classify or to supply its own selected samples is open to abuse
- The UK is destined to remain a key market for distributors of counterfeit and substandard electrical cable; it is already seen as an easy target in that there is a lack of enforcement to stop rogue importers. This one lapse of judgement means the UK is no closer to having a safer building environment.
- What we are left with is very little regulation over what manufacturers and importers will say about their cable; opportunities for falsification of a Declaration of Performance (DoP), fake CE Markings, use of Golden Samples for Euro Class testing and still no market surveillance.
- Step across the channel and The German Cable Makers’ Association has taken a different stance in its recommendations.
- It has decided: “in order to lift an entire building’s fire safety level, the cable makers’ industry recommends the use of low fire-hazard cable. Thus it is highly recommended to use class B2ca cables in buildings with very high safety requirements (e.g. in hospitals, nurseries) as well as in escape routes, and class Cca cables in buildings with high safety requirements (e.g. in administration and office buildings)”
The White Paper 'Low Fire-Hazard cables improve safety' also proposes that high rise buildings, construction works, buildings, sales outlets, office administration, buildings with single rooms, places of assembly and restaurants/hotels follow Euro Classes Cca, s1, d2, a1 for the main building and B2ca, s1, d1, a1 for escape routes.
Other countries’ cable associations have made similar recommendations that are reassuringly robust. The table below details these (column 3). The known official regulatory requirements are shown in column 2 which also demonstrates the national differences that exist with variation based upon the type of construction and safety requirements.
Europacable, whose members include the largest cable makers in the world, has also said that “it is recommended to use at least class B2ca cables in buildings and civil works with very high safety requirements (tunnels, Metro, hospitals, nurseries) as well as in escape routes and at least class Cca cables in buildings with high safety requirements (e.g. in hotels and office buildings”.
In France, Czech Republic, Italy, Finland and Sweden there is a Regulator-driven approach to safer cable specification and installations.
What is the solution?
Tratos, an Anglo-Italian cable manufacturer with production facilities in Knowsley, Merseyside, doesn’t believe such system failings should be accepted and announced on 13th July that all its Reaction to Fire cables which are subject to CPR criteria, will meet the higher Euro class of Cca s1, d1, a1.
The company doesn’t see its action as the introduction of a gold-standard, rather, the introduction of a higher minimum standard; one everyone can be confident in. The UK shouldn’t accept less. There are confidences to be restored and the cable industry must play its part.
More than this the company is calling for Regulator intervention to mandate for the same class of performance for Reaction to Fire cable in the UK.
The UK cable industry already struggles to police instances of substandard and counterfeit cable. Such important legislation needs to be introduced and policed thoroughly or it is destined to fail.
Market Surveillance — The Approved Cables Initiative?
The UK’s domestic cabling industry has long been a world-leading centre of high-quality, safe cabling product, yet the UK cable industry has shrunk to a handful of manufacturers — over 31 producers have been forced out of business over the years.
The UK cabling sector is already threatened by ineffective safety standards — voluntary not mandatory British Standards and the acceptance of non-compliant cable product as still safe.
The debate concerning substandard cable has been raised at the highest level of Government since 2010 by The Approved Cables Initiative (ACI): "... reports examples of sub-standard cable and failures in UK market surveillance. Using existing legislation, it works with the Health & Safety Executive and Trading Standards, yet primarily manages the problem itself"
Funded and supported by UK cable manufacturers and electrical industry associations, the Initiative has received full industry and regulator support and took a proactive and hard-hitting approach to educate the electrical supply chain. Early success in 2011 led to many millions of metres of substandard cable being removed from the market place.
Other suspected importers, manufacturers and distributors were investigated and reported to Trading Standards and the Health & Safety Executive, but with Trading Standards enduring major budget cuts, investigations into cable complaints tended to take second place to more high-profile consumer issues.
Taking this up with Government in 2012, it was suggested that industry should police the matter itself.
And so it comes full circle to where we are today — the Approved Cables Initiative although ready to police and report issues of non-compliance has no intervention power. It can only report instances to an already over-stretched Trading Standards.
The ACI has taken part in numerous consultation processes for improved product recall and better market surveillance, yet nothing changes. A recent Radio 5 live interview with consumer safety campaigner Lynn Faulds Wood about alleged failings in the recall system for domestic appliances highlighted that the government is not doing enough to protect consumers from faulty products that can cause fires and that a review into product safety she carried out for the government had been ignored.
How is this relevant now?
CPR is perhaps the greatest opportunity to bring about best safe cable products. But the cable supply chain and the Regulator is failing to understand that adequate isn’t enough. Promises of inspection and verification are shallow and we have yet to establish a mechanism by which the UK can carry out successful market surveillance.
- UK Regulator to stipulate a minimum requirement of Euro Class for CPR — higher than where it currently stands;
- A programme of market surveillance for CPR compliance — but other areas of cable compliance too;
- This process to be seen as the template and to be adopted throughout our construction and building industry;
- There is absolutely NO excuse not to tackle this issue, this time. Grenfell Tower sickened the nation. The post-mortem has brought it to its knees. Cable safety is a live issue and corners are being cut, with the cutters unchecked. Now is the time to act to avoid the avoidable — and the unthinkable.🔷
Further information about Tratos, the Healthy Homes Project and CPR is available at:
https://thehealthyhomesproject.com/ www.tratosgroup.com www.bragagni.uk