Environmental and health related criteria for buildings - ANEC

IBO - Environmental and Health related Criteria for Buildings
With the Construction Products Regulation (CPR) 104 a new regulation will replace the existing
Directive, but the goals and concepts stay the same as those of the CPD.
CPD and CPR do essentially not establish product requirements. This is also true for the
“essential requirements” and the corresponding interpretative documents. Consequently,
also chemical requirements are missing.
ER3 “Hygiene, health and the environment” specifies that “the construction works must be
designed and built in such a way that it will not be a threat to the hygiene or health of the
occupants or neighbours, in particular as a result of any of the following:
• The giving-off of toxic gas
• The presence of dangerous particles or gases in the air
• The emission of dangerous radiation
• Pollution or poisoning of the water or soil
• Faulty elimination of waste water, smoke, solid or liquid wastes
• The presence of damp in parts of the works or on surfaces within the works.”
The Interpretative Document of the European Commission to the ER 3 “Hygiene, Health and
Environment” (1994) explicitly mentions that indoor pollutants, e.g. volatile organic
compounds (VOC), shall be avoided and controlled.
Meanwhile, in Annex I of the CPR the entire life cycle of the construction works is mentioned
and it is specified that emissions of dangerous substances, volatile organic compounds,
greenhouse gases or dangerous particles into indoor or outdoor air are not wanted. But still
concrete requirements are missing.
Additionally, the specification of requirements is up to the Member States. If a Member State
has no requirements on a specific parameter, the values will even not have to be declared
(“No performance determined”). If e.g. a harmonized testing and declaration scheme on
indoor air emissions from building materials is provided by CEN/TC 351 (see next chapter
concerning European regulations concerning VOC-emissions), this will have no
consequence in most Member States since only Germany and France have defined
corresponding requirements yet.
Conclusions (POULSEN et al, 2010): “Neither the CPD nor the proposed CPR is an
instrument to set requirements for chemicals in construction products, as they only are
instruments that provide the framework for ensuring harmonised testing and declaration
schemes. Furthermore, as the requirements themselves have to be prepared by the
individual Member States, the CPD/CPR is not an instrument to ensure common European
requirements for chemicals.”
European Commission: “The objective of the CPD (and the CPR alike) is thus not to define
the safety of construction products, but to ensure that reliable information is presented in
relation to their performance. This is achieved by providing, mainly in standards, a common
technical language, to be used not only by manufacturers, but also by public authorities when
defining their requirements on construction works, directly or indirectly influencing the
demands placed on the products to be used in them”.
(http://ec.europa.eu/enterprise/sectors/construction/construction-products/index_en.htm)
104 COM(2008) 311 final (proposal of 23 May 2008); the proposal has been approved while finalising the study
Final Report 131 31 03 2011