Legal Compliance for fire-resistant glazing

Steve Rice, director of technical affairs for the Glass and Glazing Federation (GGF), outlines the compliances and CE marking issues that impact all those responsible for making the glazing in a building fire-resistant.

Making Insulating Glass Units (IGUs) with a fire-resistance characteristic requires special processes to verify performance. Architects and specifiers should be aware that manufacturers cannot simply use a fire-resistant glass component such as a pane of fire-resistant glass (that has already been CE marked) in their production and assume it covers all other properties. The GGF has guided and advised all glass manufacturers and installers, responsible for putting a fire-resistant glazed unit on the market, that they need to make a separate Declaration of Performance (DoP) backed by fire- resistance testing of their complete IGU product.

Demonstrating fire-resistance

The manufacturer has to show that the IGU they produce conforms with the requirements of product standard BS EN 1279-5:2005 +A2:2010 Glass in Building – Insulating Glass Units, part 5: Evaluation of conformity. System 1 for the attestation and verification of constancy of performance applies. Under that system, Factory Production Control (FPC) applicable to the fire-resistance characteristic is required, which includes testing of samples taken at the factory to a prescribed test plant. A notified product certification body has to provide a certificate of constancy of performance for the product, based on:

  • type testing of fire-resistance to BS EN 1364-1 of a representative product sample taken by the notified body
  • initial inspection of the manufacturing plant and the FPC
  • follow up assessment and evaluation of the FPC

Following testing, the fire-resistance performance needs to be classified according to standard BS EN 13501-2, Fire classification of construction products and building elements – Part 2: Classification using data from fire-resistance tests, excluding ventilation services. Testing to BS 476 part 22 is not acceptable. And testing to BS EN 1364, when the product has not been formally sampled, can only be used as supporting data.

Further requirements

When the product certificate has been received, the manufacturer can draw up a formal DoP and prepare the CE marking label. However they have to ensure that the declared performance is maintained. That requires recording relevant technical documentation and steps taken to monitor the product. The keeping of a complaints register of product non-conformance and recalls is also required. The technical records and DoP have to be held for at least ten years after placing the product on the market. Product traceability is important, and there are therefore requirements for product labelling and identification of production units with unique batch or serial numbers.

There is also an obligation to ensure that the product is accompanied by appropriate instructions and safety information concerning its use. That would be expected to include guidance for handling, glazing and installation, including naming of the components of the required glazing system as established by fire-resistance testing.

Cascaded evidence (or sharing Initial Type Testing)

There is an alternative approach. The manufacturer can choose a path already followed by another where an IGU product has already been successfully CE marked. But the manufacturer must follow the associated product system and process description for the CE marked IGU. The associated fire-resistance test results and product classification may be used with agreement from the owner of the original type testing. However the manufacturer has to separately achieve certification by a notified inspection body for their FPC. Placing the product on the market still requires a DoP under the name of the manufacturer.

To read the full GGF Guidance Document on sharing cascaded evidence or initial type testing, please see:

Getting it right

There is a great deal for an IGU manufacturer to get right in claiming fire-resistance and those responsible for fire safety and fire-resistance in a building should also take not that:

  1. Formal classification is essential
  2. Product performance has to be established by rigorous procedures
  3. The steps in the process cannot be sidestepped
  4. And if not careful, manufacturers could easily breach CE marking rules and the Construction Products Regulation (CPR). Such breaches can mean heavy fines and in extreme cases, imprisonment

If you are responsible for making the glazing in a building, fire-resistant, make sure your supplier and installer are doing it correctly otherwise it can defeat the point of installation.