COMMITTEES
for continued sale in the future EU 27 are both key topics for
the sector, and a full resolution to these challenges in the most
economic way remains unclear. Also, the possible use of the
new ‘UK CE Mark’ requires further thought and discussion, as
the group needs to handle both EU 27 concerns as well as the
future independent UK requirements for 3rd party certification.
This committee has now met four times since it was reinstated
in October 2017, and a panel has now been set up to address
the need to revise and create new standards as a result of
REACH and the continued availability of key substances. The
standards that are affected include BS 2X 32 and BS 2X 33
(which both have Cr(VI) compositional requirements), and the
Def-Stans 80-206,-207, 208 etc. (which have now been replaced
with Def-Stan 80-225, according to the MoD). This committee is
well-supported by several key BCF members who are active in
the sector.
Intumescent Coatings Group
Chaired by Roger Williams, Sherwin-Williams Protective & Marine
Coatings
The Intumescent Coatings Group (ICG) held two meetings
during the course of 2018, along with four meetings of a special
sub-group dedicated to revising the BCF Guidance Document
IC 008, based on the CEPE QC Fire Test Regime document
that was published in 2011. This document is a key reference
for manufacturers and certification bodies / test houses, setting
out the best practice and expectations when third party are
certifying intumescent coatings for use in the UK market. Some
significant changes were needed to the original CEPE document
(both the section on qualifying a new product and as part of
factory production control and auditing programmes), reflected
by the number of drafts and efforts made by the sub-group to
try and come to a consensus on the wording and approaches
taken.
This sector has a particular concern with regard to Brexit and its
impact on trading and certification. The issue of CE marking and
the status of the Construction Products Regulation post-Brexit in
case of a ‘no deal’ scenario is very likely to have a major impact
on the testing and certification of the products developed and
manufactured in the UK by the group members. The status of
existing certificates that have been issued by UK-based test
houses in the past, and the way forward for certifying products
BCF ANNUAL HANDBOOK 2019/20
The actions taken as a result of the Grenfell tragedy continued
to have an impact on the group’s activities. Connections with
industry representatives through both the Association for
Specialist Fire Protection (ASFP) and the CPA have been of
considerable assistance, to keep members informed as to what
the government is considering to address the issues that have
been raised as a result of Dame Judith Hackitt’s review of the
tragedy. The introduction of a ban on the use of combustible
materials for buildings above 18m height in December 2018
was one example of this, where intumescent coatings complying
with Approved Document B Part 1 were included in the list of
products that are exempted from this new legislation.
The group also has several specific key substances that are being
tracked through their regulatory pathways – the borate salts and
boric acid, ammonium polyphosphate and melamine. Discussions
on the progress with TiO 2 , isocyanates and Bisphenol A were
also a key part of the meetings. Regular attendance and support
from the ASFP at the meetings has been very much appreciated
by the group.
Marine Coatings Group
Chaired by Geoff Mackrill, Teal and Mackrill
The MCG met on two occasions during 2018, primarily focussed
on the issues arising from the BPR requirements relating to
antifouling paint product dossier submissions (for Copper-
based antifouling paints), and the need for further action on
environmental protection and best practice when carrying out
antifouling activities.
It became clear early in the year that there was still considerable
confusion and misinformation circulating in the market about
product registration and availability after the June 2018 deadline
(when products without a dossier submission would need to
be withdrawn from the market). The BCF information note
G026 (first published in November 2017) required an update
to provide further clarification, with version 2 subsequently
published in August 2018, and widely promoted across the
supply chain by members. However, instances of non-registered
product sale and use are still occurring in the sector. The BCF
are not in a position to police this situation, but instead have
encouraged members to report any clear breaches of the
legislation to the authorities (principally the HSE, which has the
responsibility for enforcing the BPR).
Several discussions took place on the further developments
within the EU on the risk assessment of antifouling paints,
including the concerns over the scenarios being used to assess
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