There’s a concerning discrepancy between the EU and the UK. The Construction Product Regulation (EU no. 305/2011) requires ‘the business placing the product on the market, or the manufacturer’ to issue a CE mark and a Declaration of Performance. Where fi re retardant treated timber is concerned, the EU interprets this as the treater, whereas the UK literally believes it’s the business selling the end-product.
But the seller is one step removed. They don’t have the treatment records. And many don’t know what should have been done.
As a result, some fire-treated timber products entering the supply chain might not have been correctly treated. And there’s no system to monitor and police this in the UK.
In my opinion, morally, and in terms of fire safety, this is wrong.
Specifiers, architects, and contractors must educate themselves to understand the evidence behind the documents they’re supplied. Whilst we’re always happy to talk through the detail, asking your fi re-retardant timber supplier these three questions will uncover many facts:
1. Does the treater issue the CE mark and Declaration of Performance?
Aside from WJ Timber Treatments, this is rarely the case. So, how can your provider sufficiently understand the testing and third-party auditing required to create these documents?
2. Is the Declaration of Performance specific to the timber species?
Reputable treaters will have a Constancy of Performance certificate that summarises the Fire Classification Report for each species. Robust auditing by the notified body that issued the fi re classification report on behalf of the fi re-retardant chemical supplier will be in place. A generic Declaration of Performance is, quite frankly, dangerous.
3. If you’re supplied with a Factory Production Control document, was it audited against the correct harmonised standard?
For example, that would be EN14915/2013 for cladding. The CPR does not make this clear. So, it’s easy to have a disconnect between an irrelevant standard and the control document. This is another risky situation.
Believing it’s our moral responsibility to do so, we provide a CE mark on our Burnblock fi re treatment process in addition to a species-specific Declaration of Performance. We’re regularly audited by a notified body (Finotrol) ensuring a Constancy of Performance on our treatment process.
We don’t have to do this. The CPR says we’re not the business placing the product on the market. Nor are we the manufacturer. But by fire-treating the timber like cladding, we’re significantly changing its properties and are therefore in scope of AVCP system 1. We should be doing this to provide total confidence and traceability.
Our CE mark and Declaration of Performance covering INT1, INT2, EXT fire retardant treatments and decorative coatings is backed by a chain of testing and auditing to prove the fi re-retardant timber is fit for purpose. I firmly believe the UK should interpret the CPR as the EU does and fully control a life-protecting treatment process.
