CPR: Just a noble ambition?

Prysmian UK’s Martin Boorman considers the issue of CPR six months after it became mandatory.

In common with most reputable cable manufacturers, we welcomed the introduction of the Construction Products Regulation. For the first time, it placed a legal obligation on manufacturers, importers, distributors and wholesalers to ensure cable supplied into the UK market met declared performance levels for reaction to fire, a breakthrough that we welcome.

For decades we have had to stand by, knowing that substandard cable was being used in the UK, but were limited in the action we could take as it was not necessarily illegal to import or sell the products.

We saw CPR as a game-changer and ensured that all of our cable types covered by CPR were CPR compliant in advance of the July deadline. Six months on from the date at which CPR became mandatory we can see how the system is working and are in a better position to take a view as to whether the whole endeavour is worthwhile.

Onerous

As has become evident, the administration around the legislation is relatively onerous. It is now clearly the distributor’s and wholesaler’s responsibility to ensure that any cable being sold for permanent installation in a building has a valid Declaration of Performance, that it is correctly CE marked and that this information is available to the customer when making a sale.

At any stage in this process there is the potential for error or misuse and, according to the Approved Cables Initiative (ACI), up to 20% of cable currently on sale through UK wholesalers is not compliant with the documentation requirements of the regulation.

There are various ways in which the documentation can be incorrect. Examples include DoPs referring to the wrong standards: one example of cable imported from China, for example, quoted a reference which turned out to be a performance standard relating to flooring tiles! More commonly, the DoPs have simply been filled out incorrectly. Such errors hardly inspire confidence.

There is also some inconsistency in the precision with which compliance is described: in our view it is not sufficient to quote a single performance standard for a range of cables, we believe that it should be made clear which individual products within a range are covered by the standard. This is important as performance can vary between individual cables of different sizes.

Errors

All of these issues can be resolved over time and may be due to simple error rather than any attempt to mislead. The fact that the DoP needs to be filled out in the language of the country of destination may account for many of the errors, focusing our attention on the difficulties involved in creating a unified global manufacturing industry.

More problematic is the issue of enforcement. There is no organisation with specific responsibility to police the cable industry and enforcement is down to Trading Standards – whose will take action only when issues are brought to their attention.

Enforcement requires the industry to get involved to help ensure compliance – checking documentation, reporting flagrant non-compliance and generally being active in ensuring the legislation is supported.

Prysmian is playing its part. We test cable regularly and part of this process is focused on testing questionable cable to see if mistakes in documentation are likely to be indicative of a broader issue with product performance. Our logic is that if cable is being supplied without the correct paperwork then that might indicate an attempt to pass off cable that does not meet the performance criteria outlined in CPR. Samples are regularly supplied to our laboratory and we are in the process of conducting tests, the results of which will be reported to Trading Standards if appropriate.

It will take more than the vigilance of a few large organisations to ensure widespread compliance, but if everyone involved in the supply chain plays their part then enforcement can be achieved and the overarching ambition – to eliminate dangerous cable from the supply chain – can be realised.

We regard CPR as an important step forward and hope that it is the first towards ensuring cable performance can be clearly identified with confidence throughout the supply chain. Prysmian will continue to call for better legislation across the board until substandard cable has been eradicated completely from the supply chain.

https://uk.prysmiangroup.com/