CEN/TR 16496:2013

SLOVENSKI STANDARD
01-december-2013
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Construction Products - Assessment of release of dangerous substances - Use of
harmonised horizontal assessment methods
Bauprodukte - Bewertung der Freisetzung von gefährlichen Stoffen - Verwendung
harmonisierter horizontaler Bewertungsmethoden
Produits de construction - Évaluation de l'émission de substances dangereuses -
Utilisation de méthodes d'évaluation horizontales harmonisées
Ta slovenski standard je istoveten z: CEN/TR 16496:2013
ICS:
13.020.99 Drugi standardi v zvezi z Other standards related to
varstvom okolja environmental protection
91.100.01 Gradbeni materiali na Construction materials in
splošno general
2003-01.Slovenski inštitut za standardizacijo. Razmnoževanje celote ali delov tega standarda ni dovoljeno.

TECHNICAL REPORT
CEN/TR 16496
RAPPORT TECHNIQUE
TECHNISCHER BERICHT
October 2013
ICS 91.100.01
English Version
Construction Products - Assessment of release of dangerous
substances - Use of harmonised horizontal assessment
methods
Produits de construction - Évaluation de l'émission de Bauprodukte - Bewertung der Freisetzung von gefährlichen
substances dangereuses - Utilisation de méthodes Stoffen - Verwendung harmonisierter horizontaler
d'évaluation horizontales harmonisées Bewertungsmethoden

This Technical Report was approved by CEN on 23 March 2013. It has been drawn up by the Technical Committee CEN/TC 351.

CEN members are the national standards bodies of Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia,
Finland, Former Yugoslav Republic of Macedonia, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Lithuania,
Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, Switzerland, Turkey and United
Kingdom.
EUROPEAN COMMITTEE FOR STANDARDIZATION
COMITÉ EUROPÉEN DE NORMALISATION

EUROPÄISCHES KOMITEE FÜR NORMUNG

CEN-CENELEC Management Centre: Avenue Marnix 17, B-1000 Brussels
© 2013 CEN All rights of exploitation in any form and by any means reserved Ref. No. CEN/TR 16496:2013: E
worldwide for CEN national Members.

Contents Page
Foreword .3
1 Introduction .4
1.1 General .4
1.2 Mandate amendment for BRCW 3 and the product TC’s answer .5
1.3 FAQs on mandate amendments for dangerous substances .6
2 Harmonised horizontal test methods for the assessment of the release of
regulated dangerous substances and the possibilities and limitations of their use .8
2.1 Release into soil, groundwater and surface water .8
2.2 Emission into indoor air .9
2.3 Radiation from construction products . 10
2.4 Content of regulated dangerous substances and analysis of eluates . 11
3 Integration of harmonised horizontal test methods into harmonised Technical
Specifications (hEN and EADs) – Issues for product TCs and EOTA . 12
3.1 General issues . 12
3.2 Issues specific for release into soil, groundwater and surface water . 13
3.3 Issues specific for emissions into indoor air . 14
3.4 Issues specific to gamma radiation from construction products . 16
3.5 Issues specific for content of regulated dangerous substances (only when legally
required or deemed practicable) . 18
4 Implementation of the system of Assessment and Verification of Constancy of
Performance (AVCP) prescribed by the European Commission (COM) and the
Standing Committee on Construction (SCC) for BRCW 3 in the harmonised
product standard (hEN) . 18
4.1 General . 18
4.2 Responsibility of manufacturer and notified body (NB) . 19
4.3 Use of NPD option for BRCW 3 . 19
5 CE-marking . 20
Annex A (informative) Example of a possible application of a CEN/TC 351 test method in a
hEN for a generic product in an intended use with contact with soil, groundwater
or surface water . 21
Annex B (informative) Example of a possible application of a CEN/TC 351 test method in a
i
hEN for a generic flooring product in an intended use with contact with indoor air . 27
Bibliography . 34

Foreword
This document (CEN/TR 16496:2013) has been prepared by Technical Committee CEN/TC 351
“Construction products - Assessment of release of dangerous substances”, the secretariat of which is
held by NEN.
Attention is drawn to the possibility that some of the elements of this document may be the subject of
patent rights. CEN [and/or CENELEC] shall not be held responsible for identifying any or all such
patent rights.
This document has been prepared under a mandate given to CEN by the European Commission and
the European Free Trade Association.
This Technical Report gives guidance for the selection and integration of the recommended horizontal
product testing protocols on dangerous substances harmonised by CEN/TC 351 into hENs and EADs.
Since the work in CEN/TC 351 in cooperation with the European Commission and its Expert Group on
Dangerous Substances (EGDS) and the product TCs is a work in progress, some subjects and issues
remain open for the time being. However, the results of the work of CEN/TC 351 are now mature
enough for practical implementation in product standards and EADs.
This document takes into account relevant information that had become available by March 2013
through the activities in the working groups and task groups of CEN/TC 351 as well as the guidance
provided by the European Commission.
This document is intended as easy-to-use guidance especially for product TCs and EOTA Working
Groups (or equivalent groups under the Construction Products Regulation). Where reference is made
to ‘Product TCs’, EOTA WGs are also meant where appropriate.
1 Introduction
1.1 General
The Construction Products Directive 89/106/EEC (CPD) contained six essential requirements for
works that gave rise to a number of 'essential characteristics' for products that had to be covered by
European Technical Specifications (ETS) for construction products (harmonised European Standards
(CEN) and European Technical Approvals (EOTA)). As derogation from this rule, essential
requirement No 3 “Hygiene, health and the environment” (ER3) was dealt with via a convention in the
ETS which did not take it directly into account, mainly due to the absence of European harmonised
test methods. In order to solve this problem, the European Commission gave CEN, the European
Committee for Standardization, a mandate (M/366) in 2005 to develop European harmonised test
methods for the assessment of release or emission of dangerous substances from construction
products.
From July 2013 the CPD has been replaced by the Construction Products Regulation (Regulation (EU)
No 305/2011, CPR). The fundamental principles of the CPR are the same as for the CPD. The CPR
now refers to basic requirements for construction works (BRCWs) instead of ERs, but the same six
functional requirements as for the CPD are still there, supplemented by a seventh, the “Sustainable
use of natural resources”, and BRCW 3 is extended to the construction and demolition phase.
However, it is expected that the work in CEN/TC 351 according to mandate M/366 will be carried out
under the terms and conditions of the CPD with a focus on release and emission in the use phase of
construction works.
Mandate M/366 requires that CEN develops horizontal test methods that, as far as possible, are based
on existing test methods. This means that European harmonised test methods will not be developed
for each construction product separately. The methods should be preferably applicable to all
constructions products as defined in the CPR as far as they are covered by BRCW 3. The intention is
to avoid the unnecessary and onerous development of product specific test standards for a multitude
of construction products and to minimise the amount of costly testing. The horizontal approach is
described in detail in CEN/TR 16098.
Furthermore, according to the guidance of the EC (Decision 192, CEN/TC 351 meeting in Berlin on
2013-02-11/12), CEN/TC 351 is asked to provide horizontal methods reflecting the state of the art.
Different test methods or testing options can be considered by CEN/TC 351 when technically justified
because of different conditions of use, different end uses or product characteristics, but not because of
differences in regulations.
In order to apply the horizontal test methods correctly to individual construction products, some
product specific additions remain necessary. For example, aspects such as pre-treatment and
preconditioning of test specimens cannot be completely specified horizontally but require product
specific additions. The necessary product specific additions to the horizontal test standards must be
included in the harmonised product standards for the implementation of BRCW 3.
The European Commission has recently amended ten and is currently amending some further existing
construction product mandates issued to CEN to include detailed requirements for BRCW 3. The
updated mandates include the requirements for each harmonised product standard. For each hEN or
mandated prEN, the relevant release/emission scenarios and the relevant regulated dangerous
1)
substances are listed. The CEN product TCs are obliged to amend their product standards using the
mandate amendments as a checklist for including BRCW 3-related requirements.
This Technical Report (TR4 of mandate M/366) gives instructions on which aspects related to the
horizontal test methods are important to address when amending product standards. The report is
intended as guidance for CEN product TCs for the revision of product standards in regard to
dangerous substances. The report focuses on the use of the harmonised test standards. The

1) The term regulated dangerous substances refers to dangerous substances for which performance criteria
have been defined in notified regulations in the EEA.
possibilities to avoid testing through the use of e.g. descriptive elements like positive or negative lists
in product standards are not covered by this report. With respect to this issue, the product TCs may
consult the guidance given by the European Commission including the amended product mandates.
The examples described in Annex A and Annex B show how the guidance given in this Technical
Report can be adopted in a product standard. They illustrate a possible way to implement the
horizontal test standards of CEN/TC 351 into product standards by product TCs. The examples are
inspired by work in progress on existing harmonised product standards. Their intention is to provide
generic, non-product specific assistance; they are not the only possible solution confirmed by the
powers that be.
1.2 Mandate amendment for BRCW 3 and the product TC’s answer
The European Commission describes in the amendments to the various product mandates for
dangerous substances the tasks the product TCs are expected to carry out, when preparing an
answer to the mandate amendment. Hereunder, as an example, the relevant text from mandate
2)
M/103 rev.1 on Thermal Insulation Products is cited the specifications in the other amendments are
comparable.
Description of the mandated work
The attached annex provides an overview on national notified regulatory requirements that have been
linked by several experts of the Commission’s expert group on dangerous substances to products
covered under mandate M/103.
CEN/TC 88 has to assess the list and to take it completely into consideration when describing and
justifying its selection of substances and their relevance in its work programme, in particular on the
following aspects:
− If these substances may be present in products covered by mandate M/103 and in all existing
harmonised product standards or harmonised product standards under development;
− If these substances are likely to emit from the above mentioned products and if these emissions
6)
are close to existing limit values in regulations referred to in this document ;
− If there is available data, particularly where the above mentioned products have been tested in the
7)
past on either content or emission of these substances by national authorities/bodies .
NOTE The work programme of the product TC will be used for further discussion in the EGDS between the
Commission, national experts and experts of the product TC and CEN/TC 351.
CEN has to provide in existing harmonised product standards or harmonised product standards under
development either
8)
− clear and transparent definitions of products that will make further requirements for testing for
dangerous substances obsolete or/and
− a set of clear and transparent requirements for products which will be laid down in product
standards for these specific product families or relevant sub-families.
Execution of the mandate
The standards resulting from this amended mandate will have to be delivered by no later than 12
months after the adoption of technical specifications developed under the mandate M/366.

2) See: http://ec.europa.eu/enterprise/standards_policy/mandates/database/index.cfm?fuseaction=
search.detail&id=455#
After formal acceptance of the mandate, CEN will present to the Commission within 2 months a
detailed proposal for the Work Programme. Having regard to the scope of this mandate this Work
Programme will include
− a selection and clear indication of substances and materials indicated in the annexes of this
mandate which are considered as relevant in products covered by mandate M/103, or a justification
for excluding substances or materials of the attached annex from standardization work in the
relevant product TC;
− a list of all product standards considered to require declaration categories for the potential release
or content of regulated dangerous substances to enable fulfilment of regulatory requirements;
− the timetable for the development and the publication of each amended standard; if not all
regulated dangerous substances can be dealt with in one phase or generation of the standard, it
should be explained how and when to handle the other substances and which steps still need to be
taken.
6)
The possibility of excluding products, components or substances from testing will be dealt with in detail in
another document describing a system of defining products “Without Testing” or “Without Further Testing”.

7)
If products have not been subject to testing for dangerous substances (or specific substances now mentioned in
this document have not been assessed in the past), it will be helpful to assess the priority given by regulators or
the lack of useful technical instruments for the assessment, but does not necessarily indicate that Member State
authorities might not insist on these specific requirements during the development of a standard or after it has
been finalised. Therefore, each substance should be assessed carefully by the TC and in case of doubt
clarification should be requested from the Commission.

8)
If necessary with regard to materials, constituents, admixtures, etc.

1.3 FAQs on mandate amendments for dangerous substances
These questions on mandate amendments were posed in the CEN/TC 351/TG2 workshop on 8 March
2011 by the representatives of product TCs. The answers have been provided by the Commission
Services and updated afterwards to reflect the position in June 2012.
1. Can a product TC incorporate the forthcoming TS test methods from CEN/TC 351 into its
harmonised product standard(s) or should the product TC wait until a fully validated EN test
method from CEN/TC 351 is available?
The mandate amendments ask for the technical specifications of CEN/TC 351 to be incorporated
within one year of their availability (i.e. until end of 2014 at the latest according to the current time
table of CEN/TC 351). All product TCs with relevant mandate amendments are expected to
incorporate the TS test methods into their hEN, where relevant, after acceptance by the European
Commission of the work programme to the mandate amendment. The TS test methods can first
be added to the voluntary part of the standard if the product TC wishes to wait for fully validated
EN test methods before incorporating clauses on the new test methods into Annex ZA.
Conversely, the product TC may incorporate clauses into Annex ZA which directly refer to the
TS methods, if it wishes to do so.
If the fully validated EN test methods of CEN/TC 351 should not become available until the
second half of 2016, the TS methods are considered established enough to be called up by
Annex ZAs as a mandatory basis for declaring the performance of a product in regard to
dangerous substances. This deadline is intended to ensure that a potential delay of the full
validation of the CEN/TC 351 test methods does not further delay the implementation of the
mandate amendments. As soon as the EN test methods become available, they must be used.
For the change from TS to EN test method in a hEN product standard, a corrigendum is adequate
and a full revision of the hEN is not necessary.
2. Which system of attestation of conformity/assessment and verification of constancy of
performance will be applied to BRCW 3?
The AoC/AVCP system(s) will remain the same as in the original product mandate. Member
States may ask the Commission to introduce another AoC/AVCP system via a Commission
Decision (legal act). So far such requests have not been made.
3. When will notified bodies become available for the new test methods for dangerous
substances?
A sector group for dangerous substances has been set up in the Group of Notified Bodies. It is
expected that member states will be able to nominate notified bodies for the new test methods as
soon as they are available as CEN/TS (from end of 2013). According to Annex V of the CPR a
reference to a harmonised product standard is not necessary when nominating notified bodies for
horizontal characteristics such as dangerous substances.
4. What should the product TC do, when new national regulations for dangerous substances
concerning its products emerge after the TC has received its mandate amendment?
The product TC may deal with any additional requirement in its draft answer (work programme) to
the mandate amendment. Furthermore, a product TC could inform the Commission about new
national requirements that come to its attention at a later stage. However, the product TC is not
obliged to take any new requirements into account formally before the Commission Services have
revised the mandate amendment for dangerous substances accordingly.
5. Is it foreseen that a TC may create its own classes or levels for the declaration of test results
according to the new CEN/TC 351 methods?
For the performance declaration of emissions into indoor air the Commission Services have
already provided a framework for classification, which is expected to be finalised in the course of
2013. A supporting activity is currently being carried out by the DG JRC with the aim of providing
harmonised reference values for VOC emissions from construction products (so called Lowest
Concentrations of Interest, LCI). As soon as the harmonised LCI become available, they will form
the basis for the classification of emission performance within the technical framework provided by
the DG ENTR Construction Unit. For release into soil and water, the possibility of creating
horizontal declaration formats is currently being scrutinised by the Commission. The classes of
convenience for indoor air or other declaration formats of convenience for release into soil and
water that reflect the relevant national requirements are a possible future addition to the horizontal
tool kit provided by CEN/TC 351, which may become available e.g. as informative annexes in the
CEN/TS or EN test methods. If a product TC has identified the need for specific classes or levels,
it should contact the European Commission for further guidance and a decision.
6. The scope of BRCW 3 (under the CPR) is wider than the scope of ER 3 (under the CPD). Has
this been taken into consideration in the amendments of the product mandates? If not, how
should a product TC address any additional requirements under BRCW 3?
The amendments of the product mandates are based on the requirements under the CPD and
each product TC is expected to start work under the framework of the CPD. The Commission (with
the input of the EGDS) will assess in the course of 2013 if there is any need for additional testing
under BRCW 3 for each product group. Only if the Commission concludes that additional
requirements have to be fulfilled, the relevant product mandates will be amended, which would
require additional work within specific product TCs. In this case, the methods developed for
assessment of the in use phase by CEN/TC 351 may also be suitable to assess other phases of
the life cycle, if considered necessary.
2 Harmonised horizontal test methods for the assessment of the release of
regulated dangerous substances and the possibilities and limitations of
their use
2.1 Release into soil, groundwater and surface water
2.1.1 Horizontal test methods
CEN/TC 351/WG 1 has drafted two generic horizontal testing standards for release of substances: a
dynamic surface leaching test (DSLT) for leaching from monolithic, plate-like or sheet-like construction
products (WI 00351009, prCEN/TS 16637-2) and an up-flow percolation test for the release of
substances from granular construction products (WI 00351010, expected as prCEN/TS 16637-3).
In early 2013, the technical work on prCEN/TS 16637-2 was completed and this draft standard
submitted for TC Approval. It is foreseen to be published as a Technical Specification at the beginning
of 2014. It then will be subject to round robin validation. In March 2013, prCEN/TS 16637-3 was still
3)
under development.
In addition, CEN/TC 351/WG 1 is drafting a Technical Specification for CEN Product TCs and EOTA
experts for selection of the appropriate release tests for their product(s) (WI 00351008,
prCEN/TS 16637-1). PrCEN/TS 16637-1 gives background information on release scenarios and
specific influencing factors. The general part of this Technical Specification and its content regarding
prCEN/TS 16637-2 have been completed, including robustness validation, and submitted for TC
Approval. Once prCEN/TS 16637-3 becomes available, prCEN/TS 16637-1 will be updated with the
remaining part and the revision will be submitted for TC Approval.
PrCEN/TS 16637-2 (DSLT) determines the surface dependent leaching behaviour of monolithic or
plate-like or sheet-like construction products under dynamic conditions (as a function of time). The test
(DSLT) produces eluates, which can subsequently be characterised by physical, chemical and
ecotoxicological methods. Organic coatings for metals are not included in the scope of the DSLT, but
the validation work may lead to modifications and additional scope for use of the method. Metals and
metallic coatings are so far excluded from the scope and this Technical Report (CEN/TR 16496)
4)
A special case of the DSLT is a test for
cannot therefore provide any guidance on this subject.
“Granular construction products with Low Hydraulic Conductivity" (GLHC). The test for GLHC is
specified in an Annex of prCEN/TS 16637-2.
The prCEN/TS 16637-3 (up-flow percolation test) determines the leaching behaviour of non-volatile
inorganic and organic substances from granular construction products (with or without size reduction).
Granular construction products are subjected to percolation with water as a function of liquid to solid
ratio under specified percolation conditions. The resulting eluates can subsequently be characterised
by physical, chemical and ecotoxicological methods. Results are presented as a function of the liquid
to solid ratio. The test is not suitable for substances that are volatile under ambient conditions.
These test procedures can be used for assessing release from construction products in different
release scenarios. To compare test results expressed e.g. as concentrations in eluates with regulatory
requirements expressed e.g. as concentrations in soil or groundwater under construction works, a
modelling step is necessary. This modelling step may be different in different regulations and is not
covered in the CEN/TC 351 test methods. Therefore, the test results are unlikely to be directly
comparable to limit values. However, it is expected that the national regulations will evolve to express
criteria which accord with the CEN/TC 351 methods.

3) Details on the availability of the standards and reports of CEN/TC 351 can be found in the CEN/TC 351
secretary's report which is updated regularly (latest version N0465. 2013-01-10).
4) Guidance could be offered if the regulatory requirements linked to BRCW 3 make it necessary. So far, no
European or notified national provisions that require the determination of the leaching performance of metal
products have been identified. CEN/TC 351/WG 1 has not yet harmonised any test methods for metals and
metallic coatings, because mandate M/366 covers only test methods required by existing regulations.
In prCEN/TS 16637-2 and prCEN/TS 16637-3 all aspects for determining release from construction
products are specified. These cover:
a) general aspects of taking laboratory samples for testing;
b) general aspects of preparing test specimens from the laboratory sample;
c) general aspects of equipment and apparatus;
d) general aspects of the leaching procedure (e.g. type of leachant, temperature, L/A ratio; collection
of eluates and total duration of the test);
e) expression of test results and calculation of release;
f) general aspects of taking product laboratory samples for testing;
g) general aspects of making test specimens from the laboratory sample.
The methods for the analysis of eluates are under development in CEN/TC 351 WG 5 (see 2.4).
2.1.2 Implementation of TSs in harmonised technical specifications
It is foreseen that all relevant harmonised Technical Specifications (hEN and EADs) specify the most
appropriate of the two test methods according to the rules given in prCEN/TS 16637-1 and then
provide product-specific detail such as:
a) taking product laboratory samples for testing;
b) making test specimens from the laboratory sample.
2.2 Emission into indoor air
2.2.1 Horizontal test method
CEN/TC 351/WG 2 has drafted a harmonised horizontal test method for emission into indoor air
(CEN/TS 16516). This method has gone through robustness validation and will be published as a
Technical Specification in 2013. Based on another validation step (statistical evaluation of already
performed round robin intercomparison test), the TS is expected to become a fully validated EN in
2016.
The method specifies all aspects of emission into indoor air testing that are generic. It is not expected
that product specific deviations from the generic specifications will be necessary. The following
aspects are covered:
a) general aspects of taking product laboratory samples for testing;
b) general aspects of making test specimens from the laboratory sample;
c) European Reference Room for which all test results are calculated, including a selection of four
different product loading factors (walls, flooring or ceiling, small surfaces such as doors, very
small surfaces such as sealants and sealings; see also 3.3.3);
d) operation of test chamber;
e) taking air samples from test chamber, and analysis;
f) reporting;
g) quality requirements.
2.2.2 Implementation of TS in harmonised technical specifications
It is foreseen that all relevant harmonised Technical Specifications (hEN and EADs) specify this
method and then provide product specific details such as:
a) taking product laboratory samples for testing;
b) making test specimens from the laboratory sample;
c) selection of the most appropriate loading scenario.
Deviations from the generic parts of the method are not expected unless its direct application would
not be meaningful with respect to the intended conditions of use for a specific product.
2.3 Radiation from construction products
CEN/TC 351/WG 3 “Radiation from construction products” is developing, as its main task, a
standardized measurement method for determining the activity concentrations of three relevant
naturally occurring radionuclides (gamma spectrometry). A specific convention for expressing results
in the form of an activity concentration index (I), as defined in EC guidance Radiation Protection
RP 112, is included in the re-cast version of the ”Council Directive laying down basic safety standards
for protection against the danger arising from exposure to ionising radiation” (Basic Safety Standards,
5)
BSS) and in Austrian, Czech, Finnish and Polish regulations. This index is a screening tool for
identifying materials that might be of concern. For the calculation of the activity concentration index (I)
measurements for Radium-226, Thorium-232 and Potassium-40 will be required.
Work on a TS "Construction products — Assessment of release of dangerous substances —
Determination of activity concentrations of Radium-226, Thorium-232 and Potassium-40 using gamma
spectrometry" was approved as an active work item in the CEN/TC 351 plenary meeting in June 2011.
The title clearly describes the objective but the method will also specify sampling, test sample
preparation, and the execution of the test. It includes background subtraction, energy and efficiency
calibration, analysis of the spectrum, calculation of the activity concentrations with the associated
uncertainties, the decision thresholds and detection limits, and reporting of the results. The method
described in the standard is applicable to samples from products consisting of single and multiple
6)
material increments.
7)
In the CEN/TC 351 Workshop of 30 October 2009 possible work on radon exhalation was also
discussed. Radon exhalation is currently addressed only by the Austrian regulation by an indirect
determination. As it’s not addressed by the other identified regulations on radiation under the scope of
the CPD, it was decided not to start developing a radon exhalation measurement and dose
assessment method at this stage. However, CEN/TC 351/WG 3 has been asked to deliver a state of

5) The draft of the revised version of Basic Safety Standard Directive (BSS) was published by the European
Commission in September 2011 (COM(2011) 593 fin). The draft will be discussed in the Council's Atomic
Questions Group in 2013. Considering the complexity of the issues, implementation of the Directive is expected to
take place not earlier than 2014-2015.
6) From the CEN/TC 351 document on Terminology, prEN 16687:
3.1.2
increment
individual portion of product collected by a single operation of a sampling device which will not be tested as a
single entity, but will be mixed with other increments in a composite sample
7) The CEN/TC 351 Workshop on Radiation from Construction Products was held on 30 October 2009 in
Brussels to discuss how to implement the mandated work on radiation from Mandate M/366 and to clarify how the
revision of the European Basic Safety Standards Directive for radiation protection (BSS) by EURATOM interfaces
with CEN/TC 351 work. Some 25 experts attended including authorities from the member states that regulate in
this field, experts on construction products and on the technical aspects of radiation as well as civil servants from
DG Enterprise and DG TREN. This resulted in five recommendations that were adopted by CEN/TC 351 Plenary
and by the EGDS in 2010 and into the establishment of CEN/TC 351/WG 3 “Radiation from construction
products”.
the art report on this issue. As this work item was considered by WG 3 experts not to have top priority
and to have many uncertainties associated with it, it has been postponed and no further steps have
been decided so far.
In its meeting of February 2013, CEN/TC351 decided to register the new work item "Construction
Products – Assessment of Release of Dangerous Substances – Dose assessment and classifications
of emitted gamma radiation" (WI 00351020) in its active programme of work, with the scope "This
Technical Report discusses existing approaches on gamma dose assessment. It also presents a
method for calculating the external gamma dose from construction products that could be a basis for
development of a harmonised European approach for estimation of gamma radiation doses caused by
construction products."
CEN/TC 351/WG 3 has limited its work to naturally occurring radioactive materials (NORM), which are
also referred to in the EC guidance Radiation Protection RP112, in the revision of the European BSS
directive for radiation protection and certain Member States’ notified regulations.
2.4 Content of regulated dangerous substances and analysis of eluates
Requirements for content are included in many mandate amendments for dangerous substances, and
can be covered in product standards either through a test (content determination), when the
substances in question are used actively or are known to be possible impurities, or through a product
description (use of the substance is excluded).
Additionally, the use of content determination is sometimes possible and useful in factory production
control, as described in 4.2.2, as an indirect method for the evaluation of release into soil and water, or
of emissions into indoor air. The challenge then is to establish a clear connection between the
reference method for the release into soil and water or emissions into indoor air, and the indirect
(content) method.
If the mandate amendments for product standards include requirements on content, for the time being
reference should be made to the appropriate existing standards for content determination, if available.
A list of standards and recommendations on how to incorporate them into a harmonised Technical
Specification (hEN and EADs) is available in CEN/TR 16045, Content of regulated dangerous
substances - Selection of analytical methods.
In the future for construction products harmonised CEN/TC 351 content test methods are expected to
become available for substances covered by the mandate amendments for dangerous substances.
These include the test methods mentioned in Table 1.
Table 1 — Methods under development in CEN/TC 351/WG 5
Eluate analysis Content analysis
WI 00351017: Digestion by aqua regia for
subsequent analysis of the major, minor and
trace elements
WI 00351016: Analysis of inorganic substances
in eluates
WI 00351021: Content of inorganic
substances - Methods for digestion and
analysis
WI 00351018: Analysis of major, minor and trace elements in digests and eluates by Inductively
Coupled Plasma - Optical Emission Spectrometry (ICP-OES)
WI 00351019: Analysis of major, minor and trace elements in digests and eluates by Inductively
Coupled Plasma - Mass Spectrometry (ICP-MS)
Content of organic substances - Methods for
Analysis of organic substances in eluates
extraction and analysis
Four general 'domains' are distinguished and for each domain a governing (supervising; 'umbrella')
standard is being developed to direct and indicate the choice for the proper analysis standard to be
used.
WG 5 has prepared a draft standard on digestion of construction products by aqua regia
(WI 00351017) and two analysis standards for construction products for the determination of major,
minor and trace elements in digests and eluates (ICP-OES, WI 00351018 and ICP-MS, WI 00351019).
The latter two standards are intended for eluate analysis as well as for content analysis and are
referenced in the appropriate governing standard.
3 Integration of harmonised horizontal test methods into harmonised
Technical Specifications (hEN and EADs) – Issues for product TCs and
EOTA
3.1 General issues
3.1.1 Definition of product types
Products covered by a hEN can be divided into different product types. The existing product standards
often already contain provisions which differentiate product types. It may be useful to re-categorise/re-
group existing product types to take aspects related to dangerous substances into account more
easily.
Product types, newly created or re-categorised to facilitate standardization under BRCW 3 should
allocate products that have the same intended use (identical release/emission scenario) and which
show a similar release/emission behaviour (not identical emission ratios) into the same product type.
In addition, the broad chemical composition of products in the same product type should be
comparable (e.g. organic or inorganic).
New product types should only be created if the products covered by a hEN are affected in different
ways, or to differing degrees, by BRCW 3 (e.g. when different release or emission scenarios are
relevant) or if not all the products can or need to be tested in the same way.
3.1.2 Criteria for Without Testing/Without Further Testing (WT/WFT)
The product TCs may include criteria for WT/WFT in the hEN on the basis of a revised mandate, if the
Commission has not established binding WT/WFT conditions elsewhere.
The exact procedure for the use of the possibilities of reducing testing (WT/WFT - Without
Testing/Without Further Testing) against BRCW 3 has not yet been officially communicated by the
European Commission. The product TCs should however use the possibility to start collecting existing
data on the content and release of dangerous substances of their relevant products. This would speed
up the WT/WFT request once the formal procedure has been initiated by the European Commission.
This data collection would also support the work of CEN to establish WT/WFT conditions in
harmonised standards.
3.1.3 Selection of horizontal Technical Classes compatible with national requirements
The declaration of release or emission performance of the construction product should be easy for the
user to understand. In order to simplify the communication of test results, it is helpful to create
technical classes that are able to incorporate the requirements of the member states.
So far, technical classes have not been established for dangerous substances with the exception of
formaldehyde. It is expected that the European Commission will notify CEN if it is able to provide
technical classes corresponding to the new test standards of CEN/TC 351 before these become
formally available. Concerned product TCs should check the current status of the work on technical
classes before they hand in an updated product standard for CEN enquiry/formal vote. If technical
classes are not available, country codes could be used to show compliance with the requirements of
different EU member states.
3.1.4 Product sampling, packaging and transport
CEN product TCs need to specify the details on product sampling, packaging and transport in the
product standard. If such clauses have already been included in the product standard there needs to
be a check on whether these are also appropriate for the testing regimes instituted under BRCW 3.
Instructions on how to deal with the relevant aspects are included in CEN/TR 16220 "Complement to
Sampling".
3.1.5 Preparation and conditioning of test specimens and portions
CEN product TCs need to specify in the product standard the details for the preparation and
8)
conditioning of test specimens and portions, taken from the laboratory sample for the release or
emission test, for the purposes of the laboratory. Instructions can be found in the CEN/TC 351 test
methods (prCEN/TS 16637-2 and prCEN/TS 16637-3 for leaching, CEN/TS 16516 for emissions.)
3.1.6 Assessment of constancy of performance (“Statistical issues”)
CEN product TCs should check whether the procedures currently applied for the assessment of
constancy of performance of each product appropriately cover the BRCW 3 characteristics.
TG 7 of CEN/TC 351 is harmonising methods relevant for the assessment of constancy of
performance for dangerous substances. The TR of TG 7 (WI 00351013, work in progress) on
statistical issues is anticipated to include further guidance to product TCs. The main issue of the TR is
to show, how the (statistical) variation between products that are covered by the same Declaration of
Performance can adequately be dealt with in the testing. The reference method for assessing whether
the product conforms to the information on the release of dangerous substances as provided in the
Declaration of Performance is described and justified.
3.2 Issues specific for release into soil, groundwater and surface water
3.2.1 Selection of the appropriate test method (prCEN/TS 16637-1)
In prCEN/TS 16637-1, advice for CEN Product TCs and EOTA experts on how to select the most
appropriate available release test for specific products is given. The following steps are considered:
a) Identification of products fo
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