British /EN Standards and British Agrement Board

Since 2003, I have been involved in a case that is specifically related to two things.

• The use in buildings of a glass that is not described in relevant ‘BS/EN’ text or tables.

• Approval for use of a window in the UK, tested by the ‘BBA’ incorporating a glass not described within relevant British Standards, Codes of Practice or EN Standards



There seems to be a propensity for’ interpretation’ or ‘assumption,’ from what is written or include what is not written in documentation to get a result. We should be basing advice or answers on what is actually read, what is actually stated or described within a document to formulate a judgement/answer. It is an area that does need to be seriously looked at and resolved urgently.



Example

In America 2mm, 2.2mm and 2.3mm glasses in annealed format are used in double glazed units for use in buildings- Domestic for the purposes of this discussion.



A company has introduced this glazed format into the UK via the Certification processes of BBA- specifically ,British Board of Agrément ( BBA ) assessment under their Agrément Certificate No. 92/2840 dated 20 November 1992.

It should be noted that BBA do not test individual components. In this case, a whole window was tested with the 2mm glass insitu to gain Certification.



If we take, for example British Standard 5713, or BS 6262 formerly CP152, or indeed any other BS/EN document relating to glass in building, 2mm glass is not referred to at all. The minimum is 3mm.



The industry generally, has accepted that 2mm glass is not appropriate for use in Domestic buildings in the UK and EC.



Why is it being allowed to be freely marketed and used via this’ loophole’, which clearly circumnavigates BS and EN advice.



The advice that BS//EN provides should be considered sacrosanct and must sit above other ‘recognised’ methods of acceptance/ testing.



By not mentioning 2mm glass in Standards, it should be readily accepted that it should not be used and is thus ‘unsuitable for purpose’. I provide a passage from British Standards and their views concerning their Standards and how they should be addressed.

……..

It is BSI’s policy that it will not offer informal advice on the application or interpretation of the standards that it publishes. There are two main reasons for this:



The first is that a standard exists to standardise, i.e. to set out a set of common benchmarks available to all. If, in response to an enquiry, we offer advice that expands upon, or differs from what might readily be inferred from the text, it could well have the effect of undermining the commonality that the standard exists to provide.



There is risk that the enquirer would be encouraged to believe that the standard might mean something different from what can be assumed, on the part of all other users, to be the intended meaning.



This could lead to confusion or dispute and might be damaging to the whole principle of public standards. However sound the advice might be, we have no means of communicating it to all users of the standard. In fairness to all, the responsibility for the correct application of a standard has to rest with its users, guided, where appropriate by professional advice.



The other reason is that the text of a standard is arrived at by consensus through an extensive process in which the views of the experts on the technical committee are informed by consultation, research and public comment. This gives a standard its strength and authority but it is not feasible to employ this process for each enquiry that might arise.



Those are clear statements, which importantly make clear that experts with particular interests and skills have taken considerable time, effort and research before formulating the tables and words in the Standards.



Why are we not reading the Standards and using or implementing what is written and described, instead of allowing interpretation to befuddle the issue and allow unsuitable products to be considered or used?

Quite bluntly, my considered view is:

1. If something is not described or written into a Standard, then it is not conforming or compliant with the Standard.

2. British Standards and EN documentation are the most important documents and should overrule other testing methods, or is taken as the ‘final arbiter’ in the decision/ advice process.



Comments are most welcome.