Release of dangerous substances from Construction products - The Difficulty of harmonizing Methods in Europe

Indoor air quality is as important for human health as quality of food or drinking water. Most of us are spending a high percentage of our living time in closed rooms. If, during work time, we are exposed to concentrations of dangerous substances, released from the working process, measurements are mandatory which ensures that these concentrations do not exceed given MAC-values (maximum allowable concentration). At home we may be exposed to a large number of substances known as carcinogenic or toxic, which are released from different construction products like paints, glue, sealing materials, or carpets and other floor coverings. Despite the large amount of potentially dangerous substances around us in our homes, no regulation requires regular measurements. A suitable way out of this problem is to regulate the construction products prior to their introduction to the market.

In Europe the CE-mark of conformity is mandatory for every manufacturer or importer of a certain product, if this product is to be introduced into the European market. Herein the manufacturer or importer claims the product is developed and manufactured in accordance with the product related European Norms (EN).

The basic description in how construction products should be handled is part of the European Legislative Process. The European Community has governed the certification of construction products by the "Construction Products Regulation" (CPR - former CPD - Construction Products Directive).

CPR defines basic requirements for construction works (BWR3) as follows:

“...the construction works must be designed and built in such a way that they will, throughout their life cycle, not be a threat to the hygiene or health and safety of their workers, occupants or neighbours, nor have an exceedingly high impact, over their entire life cycle, on the environmental quality or on the climate, during their construction, use and demolition, in particular as a result of any of the following

a) the giving-off of toxic gas; b) the emission of dangerous substances, VOC, greenhouse gases or dangerous particles into indoor or outdoor air; c) the emission of dangerous radiation; d) the release of dangerous substances into ground water, marine waters, surface waters, or soil; e) the release of dangerous substances into drinking water or substances which have an otherwise negative impact on drinking water; f) faulty discharge of waste water, emission of flue gases or faulty disposal of solid or liquid waste; g) dampness in parts of the construction works or on surfaces within the construction works.”

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Based on this CPR regulation European Norms are developed by Technical Commitees (TC) related to a specific construction product, e.g. CEN/TC 134 "Resilient, textile and laminate floor coverings", responsible for "Standardization of definitions, requirements, classification and test methods and provision of guidance documents and reports for resilient and textile floor coverings and for laminated floor coverings".

It is the task of these TC's to harmonize existing National Normings and develop a harmonized European Norm (hEN) which specifies the named construction products. The CPR/BWR3 is one of the great challenges to the TCs which also have to harmonize national ideas of construction products with these basic requirements.

Being part of such a complicated process, TCs often develop their own methods and standards, even if similar behaviours are surveyed, e.g. the release of Volatile Organic Compounds from different construction products. Since indoor air quality is determined by the behaviour of all different construction products, one of the big challenges for the European Community is to standardize tests and analysis methods between different TCs. This process is called "Horizontal Standardization".

The process of Horizontal Standardization starts with Expert Groups of the Member States of the European Union, organized in one of the Commission's "Directorate-General (DG)". For the regulation of construction products the most involved Directorate-General would be the DG Enterprise and Industry. However, since we are talking about risks stemming from the release of dangerous substances into the environment, the DG Environment and possibly also the DG Energy have to be involved.

These DGs will decide to give a mandate to the European Norming Commission (CEN), and then to a leading TC, to horizontally standardize the norms describing the different construction products. The mandate for Horizontal Standardization and Harmonization of the considered European Norms (EN) for construction products is named M/366 and it was assigned to the CEN/TC 351, responsible for construction products.

The full name of this mandate is: "Horizontal complement to the mandates to CEN/CENELEC concerning the execution of standardization work for the development of horizontally standardized assessment methods for harmonised approaches relating to dangerous substances under the Construction Products Directive (CPD)"

During this process of Horizontal Standardization and Harmonization the people in charge had to handle:

• Over 65 product TCs and environmental TCs
• European Commission: SCC, DG Enterprise, DG Environment
• 27 Member States / 30 CEN Members
• Industry, industrial sectors
• CEN bodies: CMC, CSN, CSNPE, SABE
• Regulators, experts from various fields
• Liaisons with interest groups

To keep workload of the acting people manageable, TC 351 has decided to divide the work into 5 Working Groups (WG).

Working group	Title
CEN/TC 351/WG 1	Release from construction products into soil, ground water and surface water
CEN/TC 351/WG 2	Emissions from construction products into indoor air
CEN/TC 351/WG 3	Radiation from construction products
CEN/TC 351/WG 4	Terminology
CEN/TC 351/WG 5	Content and eluate analysis in construction products

Table 1: Technical Bodies of CEN/TC 351 - taken from the homepage of CEN - European Committee for Standardization. Https://www.standards.cen.eu

As a company of chromatographers, Restek is mostly interested in the results of the Working Group 2 (WG 2) "Emission into Indoor Air" and how the classification of construction products are realized for this approach.

During the last years WG 2 has developed a horizontal testing standard for the emission of volatile compounds from construction products. This CEN/TS 16516 now has to be adopted into the product standardizations by the TCs of the specific construction products. Until now the CEN/TS 16516 is not a European Norm, but a Technical Specification (TS), seen as a preliminary stage of a European Norm. The complete norming process is promised to be finished during 2015/16.

The CEN/TS 16516 is described as follows:

"This Technical Specification specifies a horizontal reference method for the determination of emissions of regulated dangerous substances from construction products into indoor air. This method is applicable to volatile organic compounds, semi-volatile organic compounds, and volatile aldehydes. It is based on the use of a test chamber and subsequent analysis of the organic compounds by GC-MS or HPLC." The quoted text was cited from the CEN Homepage.

One of the big International Laboratory Associations, the Eurofins Group, announced in January 2014: "CEN/TS 16516 will become the "mother of all VOC emissions testing standards" for construction products in Europe within the next months and years. It will form the basis of VOC emissions testing for CE marking as soon as the criteria for CE marking have been specified in near future." (Eurofins Homepage).

Unfortunately, in Europe the situation for the regulation of products is a bit more complicated than in other economic areas. Responsiblity for the risk assessment of dangerous substances lie with the National Authorities (e.g. for Germany the National Authority is the Federal Institute for Risk Assessment (BfR) in Berlin).

National Authorities may choose different ways of assessing the risk of the release of dangerous substances from construction products. Up to now several quality rating systems are established in Europe. The following parameters are included for testing:

Formaldehyde and acetaldehyde are mandatory for all EU countries. In France a "Compulsory VOC emissions labelling" is installed with 10 VOCs and TVOC (Total Volatile Organic compounds) as basic testing values to run into an ABCD label, classifying the construction products. Germany bases his classifying system on a List of more than 200 compounds, published by the Committee for Health-Related Evaluation of Building Products (AgBB), latest version in 2012. This LCI-list (Lowest Concentration of Interest) includes VOC and SVOC compounds as well as a maximum TVOC value. The Belgium classifying system, at the moment, is referring to another list, the EU-LCI-list, including 177 VOC and SVOC compounds of interest. All other EU countries, at the moment, do not have any classification system.

In a country without regulation on VOC emissions, a CE marked product can be sold with the NPD option ("no performance declared"), in a country with existing regulation on VOC emissions this product only can be marked with a CE label if the declaration of performance includes VOC emissions test data, in conformity with the national regulation.

Regarding the production of reference materials, the situation is not easy to overcome. A certified Multi Parameter Reference Material Kit, as Restek has done for VOCs in water or Pesticides in Food (MegaMix) could be possible but a clear European strategy about which components should be targeted and how many countries will participate on a common European LCI list is needed.

Separating and determining VOC's and SVOC's out of air is a well-known and well used application at Restek. If someone needs assistance, everybody is welcome to discuss their challenges with our Technical Service group.