Using the Product Assurance Framework to Support Building Code Compliance A Guide for Manufacturers and Suppliers of Building Products

Transcription

1 Using the Product Assurance Framework to Support Building Code Compliance A Guide for Manufacturers and Suppliers of Building Products April 2010

2 Contents 1. Foreword 1 2. Introduction 2 3. Your roles and responsibilities Product Assurance 6 5. The Product Assurance Framework What is it? Introduction to the options Technical information Independent assessment Industry-based schemes Appraisals Product certification Product Technical Statement a new approach Demonstrating performance A decision tree Working towards compliance Evidence of compliance Case Study 1 Structural steel brackets Case Study 2 Bricks Choosing the best option for you Non-compliance and the law Appendices The New Zealand Building Code clauses Durability (clause B2) versus Product Warrant Sample Risk Assessment Framework The Building Regulatory Environment an overview Resources. 46 This Guide has been prepared by the Department of Building and Housing as general guidance only. It is not a substitute for professional, independent technical advice.

3 1. Foreword The Government is focussed on lifting New Zealand s economic performance for growth in a capital constrained environment. The building and construction sector plays an important role and has scope to lift its productivity, skills and performance. Reducing regulatory costs without compromising building quality for a streamlined building system is central to achieve progress. Manufacturers and suppliers of building products will be assisted by a clear system to demonstrate that their products are fit for purpose in New Zealand conditions. The introduction of a Product Assurance Framework is an important part of achieving that building quality system by making it easier and faster for building product suppliers and users to demonstrate compliance with New Zealand building requirements. The framework should result in efficient and effective options for assurance for current building products and for those products that are imported or launched into the market. Certainty about products helps with informed choice and better decision-making. The Product Assurance framework contributes to this certainty and provides better results on the ground with innovative and appropriate use of building products and systems. 1

4 2. Introduction The purpose of this Guide is to assist you, the manufacturers and suppliers 1 of building products in the New Zealand market, to understand the benefits and responsibilities around providing products that are Building Code compliant and therefore fit for purpose within the New Zealand building environment. The Guide suggests ways you might meet your responsibilities and gain general acceptance for your product. The Guide introduces a product assurance framework that outlines options for achieving product assurance and demonstrating Building Code compliance. Products that carry that level of assurance should inevitably gain greater market acceptance and recognition as building owners, designers, builders and building consent authorities will have greater confidence in the product and the technical information provided. A risk assessment tool has been included to help you determine the level of risk associated with your product. Case studies and other resources, including a decision tree, illustrate how product assurance and Building Code compliance relate to different situations. The Guide also explains New Zealand s building regulatory environment and compliance requirements. It is hoped this Guide will improve your general understanding of product assurance and how Building Code compliance leads to better decisions by everyone involved in the building process. Therefore the Guide will be of interest to other parties involved with selecting or assessing building products requiring Building Code compliance, including building designers, specifiers, builders, building owners and building consent authorities. 1 For the purposes of this Guide manufacturers and suppliers of building products also includes importers, distributors, direct marketers, trade merchants and retailers. The Guide uses manufacturers and/or suppliers as the general reference terms. 2

5 3. Your roles and responsibilities As manufacturers, you have a key role to play in ensuring your building products are Building Code compliant. As suppliers you need to ensure that the evidence to demonstrate Building Code compliance accompanies the product to market. The following audiences need to be kept in mind when demonstrating Building Code compliance, as they each have a decision-making role in the building process: Building owners Building designers (including architects, engineers and specifiers) Builders (and specialist trades) Building consent authorities (BCAs). A product s selection is likely to depend on easy access to sound technical information, enabling building designers to confidently specify that product as part of a building, and builders or specialist trades to adequately install it. Every building is unique, and is composed of many thousands of products. Even supposedly simple buildings are highly complex. It is important you understand how and where your product will be used in a building. Familiarise yourself with the Building Code so you can identify those clauses which are relevant to the products you supply. You should also understand whether they form part of an Acceptable Solution or an alternative solution for each of the relevant Clauses. (Section 10.1 contains a list of the 35 clauses of the Code.) Product promotional material and product warranties have their place, but building designers, builders, specialist tradesmen and BCAs require factually-based product performance claims and supporting technical information. This should include information about how your product performs in different New Zealand conditions (eg, wind zones, corrosion zones, and high levels of UV exposure) and the effect of these conditions on the life of your product. 3

6 These claims may be backed up by the results of independent product testing and/or certification; certification of Quality Management Systems (ISO 9001); and/or a history of successful manufacture, sale and use in relevant situations or markets. You should also look at your building product in the context of the system of which it forms part, not just the product in isolation. This approach is critical when determining which assurance option to choose. For example, for a plywood product, consider not just the plywood but also how it integrates with the building wrap, the cladding and the window system. A product s technical information should also cover the ongoing maintenance necessary for the product to continue to comply with its required durability period under the Code. This information needs to be suitable for use by the current and subsequent building owners. In some situations such as exposure to the elements, a product may require repainting, recoating or even re-application in order to achieve its stated life and to meet the durability requirements of the Building Code (see Section 10.2). If regular maintenance is important for the ongoing performance of your product, your technical information should make this very clear. 4

7 Before introducing a building product to the New Zealand market, first establish how your product will be used and whether it needs to comply with the New Zealand Building Code, then decide which Code clauses are relevant. Most building products have to satisfy at least three requirements of the Building Code the performance claimed (eg, G12/AS1 Water Supplies), Durability (B2), and Hazardous Building Materials (F2). At a minimum, any compliance claim must be supported by: Relevant technical information (as opposed to marketing material and product warranties) Clear technical installation information and support for design and build A Scope of Use stating any conditions and limitations relating to the product s use Clear information on how to maintain the product or system. Technical opinions and test reports may also be required to prove compliance. To prove Building Code compliance, all claims must be backed up by adequate technical information, including relevant reports and opinions. 5

8 4. Product Assurance As a manufacturer or supplier of building products, you may not be aware of the need for building products to comply with a performance-based Building Code, or Where to start? with ensuring product compliance is achieved. The term product assurance describes the overall system that product manufacturers or suppliers can use to establish and prove compliance with the performance requirements of the Building Code. Like all participants in the building process, those involved in manufacture or supply have two choices: 1. Provide products that perform according to the methods set out in a Compliance Document ie, as part of an Acceptable Solution, or, where your product does not fully comply as an Acceptable Solution 2. Look at other ways to show your product has met the performance requirements of the Building Code, ie, as part of an alternative solution. In both cases, evidence of compliance is required. CRITERIA: Performance requirements of the Building Code New Zealand Building Code CRITERIA: Compliance documents, cited Standards and other documents Assurance is all about providing evidence that is sufficiently reliable for anyone to use. Reliable evidence provides users with the confidence to make effective decisions. Evidence to demonstrate performance Alternative Solutions Evidence to demonstrate performance Acceptable Solutions Verification Methods 6

9 5. The Product Assurance Framework 5.1 What is it? The purpose of the product assurance framework is to describe the options available to building product manufacturers and suppliers to demonstrate a product s compliance with the Building Code. The framework shows five generic assurance options product technical information, independent assessment, industry-based schemes, product appraisals, and a product certification scheme (branded CodeMark). The New Zealand Product Assurance Framework Product certification Appraisals Industry-based schemes Independent assessment Technical information Demonstrate compliance with the New Zealand Building Code The options are not mutually exclusive, and you may need to pursue more than one to reach your ultimate destination - demonstrating compliance with the New Zealand Building Code. You may also find that your chosen option includes elements of other options. Technical information underpins all the options, and could include test results from an in-house or independent body eg, a testing laboratory. 7

10 The framework s triangular shape reflects the number of products expected to use each option. The majority of products should require less extensive forms of assessment (the base of the triangle) to prove Building Code compliance. This group may include products that have been in use in New Zealand for many years and which have a strong history of successful performance in the New Zealand building environment. It may also include products where the consequences of product failure have been assessed as low. In contrast, fewer products will require assessment using the options shown near the apex of the triangle (options such as appraisals and product certification) to prove compliance. These products may include new or innovative products, products where a manufacturer perceives a competitive marketing advantage by using a particular option or products where the consequences of failure have been assessed as high. There is always cost and time involved with each option and is part of the investment of gaining product assurance. These factors will vary depending on the product, existing technical evidence, newness to the market, etc. 8

11 5.2 Introduction to the options Product technical information Typically product information supplied directly by the manufacturer or supplier. It differs from advertising brochures and other marketing material, including product warranties, as it focuses on technical detail. Includes quality assurance systems, product specifications, scope of use, and installation requirements. It enables designers and builders to correctly specify and install your product. It also covers maintenance requirements, which is important information for building owners. Often includes test results for the product. Independent assessment The verification and endorsement of manufacturers product information by independent and competent product assessors eg, Chartered Professional Engineers or recognised testing laboratories. Industry schemes May be product-family based eg, ready-mix concrete or glass. Some schemes are sector based eg, the BCRS Building Code Review Service being developed by BOINZ (Building Officials Institute of New Zealand) Products are assessed by a recognised organisation against specified industry requirements. Industry scheme assessments are self-audited. Appraisals Involve extensive testing and verification by an independent third party. Testing and verification is independent of the product manufacturer or supplier. An appraisal examines all aspects of a product, including manufacture, supply and installation. The output of an appraisal is a technical opinion. 9

12 Appraisals require ongoing revalidation. All the above options provide support for building consent applications, but it is important to note that the evidence of compliance you supply may not be accepted by BCAs. Product certification (CodeMark) A statutory scheme. Products can be certified as compliant with one or more specific clauses of the Building Code. Only certified products can display the CodeMark brand. CodeMark certified products must be accepted as compliant by BCAs, where used according to any conditions and limitations on the Product Certificate. The options are explained in more detail on the following pages. 10

13 5.3 Technical information Good technical information for the New Zealand market addresses the needs of designers, specifiers, builders, building owners and BCAs. Key elements of technical information include: Description: a short description of the product what it is and its intended use. Language: instructions in plain English. Use clear sentences and diagrams. Design Instructions: clear statements to help designers successfully integrate the product with other products, producing a compliant building system. Construction Instructions: clear instructions to assist builders and trades successfully install the product. Clear statement outlining when an approved installer must be used. Maintenance requirements: guidance for the building owner to effectively maintain the product. Clear statements describing potential consequences if specified maintenance is not carried out. Test Results: details of any tests carried out on your product, and what those tests showed. Quality Assurance: information about any measures in place to ensure consistent production quality. May include a statement of acceptable variations. Product Support: contact details, ideally in New Zealand, for organisations able to provide product advice and support. Imported products may have an international pedigree, but they must be specifically assessed and/or tested against the performance requirements of the New Zealand Building Code to meet local conditions. 11

14 5.4 Independent assessment As a manufacturer or supplier, you will typically undertake your own product testing and analysis. The outcome of these investigations should be incorporated into your fact-based technical information for the product. An independent assessment reviews and verifies the technical information provided by the manufacturer. The assessment is carried out by a suitably competent or qualified person or organisation. The best way to record this independent assessment is for an endorsement to be added to the technical information you provide. 5.5 Industry-based schemes Industry-based schemes are voluntary, and work well for families of products. Manufacturers who belong to such a scheme are responsible for ensuring their products comply with the requirements of the scheme as assessed by the industry organisation. Products are assessed by the industry organisation against specified and audited industry requirements. Examples include ready-mix concrete by members of the NZRMCA 2 and glass certified by the IGUMA 3. Attributes of an effective scheme are: Publicly available rules which outline the framework of the scheme. A regular and publicly available programme of independent audits of compliance. Clearly stated penalties that will be applied should there be a breach of scheme rules, governance or expected quality of a product or system. 2 New Zealand Ready Mixed Concrete Association 3 Insulating Glass Unit Manufacturers Association 12

15 A governance structure consisting of industry, user and independent representatives who have a continuing role of ensuring the scheme s ongoing integrity. 5.6 Appraisals An appraisal is a technical opinion of a building product or construction system s fitness for purpose. Usually undertaken by an independent body, an appraisal assesses a product against a wide range of performance factors, including the requirements of the Building Code, performance under test conditions, in-service performance, New Zealand Standards specifications, accuracy of the product s technical information, and manufacturing procedures and quality control systems. Where a product performs over and above the performance requirements of the Building Code, a statement to that effect will be included in the appraisal. Appraisals generally include extensive testing and verification of Building Code compliance by a third party (ie, independent of the manufacturer or supplier). A product appraisal will include appraisal of any specific installation systems and/or processes relevant to that product, and will recognise limitations on a product s intended scope of use. An appraisal may follow a standard assessment process for products with few or no innovative features (such as window frames), or may be specifically designed to test an entirely or partially new or innovative building product, construction system or feature. An appraisal organisation will: Be independent from the product s manufacturer or distributor, so that test results and appraisal outcomes are completely unbiased and reliable. 13

16 Have thorough and validated (accredited) product testing procedures and processes in place, such as IANZ accreditation, and suitably qualified testing and analysis personnel, such as engineers and research scientists. Undertake or require regular inspections to ensure product conformity during manufacture, and conformity of product performance once in use. You may choose to have a product appraisal undertaken by an appraiser from outside New Zealand, but it is recommended that your product be tested against the New Zealand Building Code for compliance in the New Zealand market. 5.7 Product certification Product certification for building products in New Zealand was established by the Building Act 2004, and is administered by the Department of Building and Housing. Product certification has been jointly developed with the Australian Building Codes Board. This voluntary scheme operates under the brand name of CodeMark, which is recognised in both Australia and New Zealand. It is designed to streamline and speed up the building consent and inspection process by avoiding repeated assessment of products that have proven Building Code compliance. Product certification may be the best route for a manufacturer or supplier to take where a product is new to the market, is highly innovative or novel, or where there are significant consequences if a product fails. The product certificate issued by a Product Certification Body provides independent confirmation that a building product complies with the Building Code. Information contained in or referenced on the product certificate provides clear guidance about how to specify and install the building product or system to ensure it complies with the Building Code clauses for which compliance is claimed. 14

17 The scheme provides benefits across the industry for product manufacturers and suppliers, builders, designers and architects, engineers, building consent authorities (BCAs), and homeowners. These include: Proven compliance with the performance requirements of the stated Building Code clause/s. Assurance that the product is manufactured to a consistent level of quality. Confidence that ongoing product support is available. Acceptance of new or innovative products, and products with significant or major consequences should product failure occur. Confidence that a certified product or method will be accepted nationally by all BCAs. Streamlining of the building consent and inspection processes (improved efficiency). Ability to use the CodeMark brand as a marketing advantage. While a building consent will still be required, all BCAs must accept the product certificate as proof of Code compliance (where the product is being used in accordance with the certificate and its instructions). 15

18 6. Product Technical Statement a new approach oduct Technical Statement a In Section 5.3 of this Guide we listed the topics good technical information covers. However, this may not cover everything needed to demonstrate compliance with the New Zealand Building Code. To help bridge this gap, we recommend you create a Product Technical Statement (PTS). This new approach is intended to promote consistent and comprehensive product information for the New Zealand market. Using a PTS will assist all the audiences referred to earlier to select, specify and accept your product. A PTS is in addition to good technical information and should include the following: Statement of Building Code compliance: a clear statement of the New Zealand Building Code clauses that relate to your product and a selfdeclaration 4 of compliance with the performance requirements of those clauses. Scope of use: a statement using recognised New Zealand terms (eg, high wind, seismic and corrosion zones) that outlines the product s scope of use, including any conditions or limitations on its use. Consenting instructions: any statements useful to a building consent authority (BCAs) to assist it in making decisions about the compliance of building work that uses your particular building product or construction system. The PTS should accompany your technical information and cross reference any other documents that provide evidence to support: your compliance claims, such as test reports or technical opinions the use of your product, such as installation or maintenance manuals. 4 An internationally recognised term for a manufacturer s assertion of conformity 16

19 Ideally, supporting documents should be uniquely identifiable by date or version number to avoid any possibility of confusion. Gain the maximum benefit from your PTS by making sure it is readily available to everyone involved in the building process. Assertions about compliance and a detailed scope of use will assist building designers to specify your product and BCAs to assess building consent applications for work where your product has been specified. Easy access to supporting documents will allow builders to correctly install your product, and building owners to correctly carry out any maintenance required to ensure your product meets its compliance claims. 17

20 7. Demonstrating performance 7.1 A decision tree In order to systematically work through the process of demonstrating compliance against the Building Code there are a number of questions you need to answer. This decision tree assists by outlining those questions and shows where your answers might lead you. No Does my product need to comply with the Building Code? No further action needed. Consumer protection provisions found in other legislation (see Section 9) will still apply. Yes It is an Alternative solution. Identify and/or develop criteria to prove compliance with the Building Code No Does my product comply fully with a compliance document and associated cited Standards? Evaluate product against criteria which could include: - Compliance Documents - Standards - NZ conditions - International codes and standards Yes Present your evidence of compliance with those documents Does my product meet the criteria? No Yes Undertake product review/redesign Yes Do I have all the evidence I need to show the criteria have been met? No Provide evidence of compliance Obtain further evidence of compliance eg, test reports, professional opinions 18

21 7.2 Working towards compliance Does my product need to comply? The first question on the decision tree is Does my product need to comply with the Building Code? Examples of products that would not be covered by the Building Code include kitchen cupboard door handles, architraves, curtain rails and decorative wall coverings. If the answer is no, the consumer protection provisions found in other relevant legislation will still apply (see Section 9). If the answer is yes, you will need to work out if your product is an Acceptable Solution or an alternative solution, and then demonstrate how it complies with the Building Code Is my product an Acceptable Solution? If you are able to answer yes to the question Does my product comply fully with the requirements set out in the relevant Compliance Document or cited Standard within that Compliance Document?, your product is an Acceptable Solution. To answer yes, your product must align with all the requirements set out in the Compliance Document, and your evidence must demonstrate how it complies. Product Example 1 A company wants to import a range of backflow valves to New Zealand. They know there are several brands in the market already. Because this type of valve is widely used they expect there is a commonly accepted compliance method which might suit these imported valves as well. The company looked at the available Compliance Documents first to demonstrate these imported valves meet all the requirements of the relevant Compliance Document in this case G12/AS1 Water Supplies. 19

22 Product Example 1 illustrates a situation where the Acceptable Solution route is likely to be followed. A good place to start in this example is to compare all the available technical information with the Compliance Document for G12 (Water Supplies) which can be found on the Department s website. Expert assistance may be needed to do this comparison which is where an independent assessment could help. Case Study 1, found later in this section, explains in more detail how the Acceptable Solution approach works in practice, and how evidence is assembled Is my product an alternative solution? If your product does not comply fully with the relevant Compliance Document it is not an Acceptable Solution, therefore it is an alternative solution. You will need to identify or develop criteria that, if met, will demonstrate your product s compliance with the required performance clauses of the Building Code and then evaluate your product against those criteria. A useful approach for identifying existing criteria that may be suitable is to: Compare the product against an Acceptable Solution (AS) or Verification Method (VM) as a basis to show how any deviation is compensated for or otherwise justified Compare the product to another document this could include a New Zealand or overseas Standard, other technical information, test results or research Look at in-service history and performance (of a similar product) within New Zealand or in similar conditions Refer to building work previously accepted by a BCA some designs for building work using the same or a similar product may have been previously accepted (if used in the same way) by a BCA for a specific building consent. Identify relevant determinations issued by the Department is there a determination on a situation where a similar product is specified? Although 20

23 determinations are case-specific and therefore have a very limited application, they do provide sound guidance on application of the Building Act and Building Code at a particular point in time. (Examples include determinations 2009/104, 2009/96 and 2008/32 which are available on the Department s website.) Once you have completed this comparison you may find there are still gaps between the evidence you have and the evidence you need. It is likely you will need expert assistance to help you develop suitable criteria to fill the evidence gaps. The final step is to collate your evidence and make it easily available to the audiences referred to earlier. Do not overlook your existing technical information as some of it could potentially support your compliance claims and supplement the evidence gained from your evaluation process. Product Example 2 A company is starting to design and develop a brand new type of cladding that will be different to anything that is already available. Being new, it is probably an alternative solution. Chances are this product will need extensive technical evidence and information to convince people it complies with the Building Code. The company will need to prove compliance against a number of performance requirements of the Building Code and include all supporting technical evidence and information. The challenge for the manufacturer in Product Example 2 is to identify or develop suitable criteria that he can evaluate the product against and gain evidence of compliance. 21

24 7.3 Evidence of compliance Whether your product is an Acceptable Solution or an alternative solution you will need to provide evidence to demonstrate compliance with the Building Code. If your product is an Acceptable Solution, the criteria are clearly prescribed in the Compliance Document. If your product is an alternative solution you will need to include details of the criteria you used and how your product met those criteria. Remember, evidence of compliance is generally around: Product performance does the performance of my product comply with the performance requirements for that product type eg, a cladding that is weathertight? Manufacturing controls how can users be assured that every product made is to the same specification and quality? Limitations - where, when and how can the product be used so it is fit for purpose, and are these limitations clearly stated for designers, installers and builders? Maintenance what are the requirements and their impact on ongoing performance, particularly durability? 22