Dear Sirs You may have attended one of our seminars covering the changes to Building Regulations 2010 which have been presented by Giles Willson of the GGF and Andy Clegg from FENSA Training. We are now getting closer to changes in Regulations and we thought that it would be appropriate to write to all FENSA Registered Businesses to clarify the future way for compliance against Document L of the Building Regulations. Under Approved Document L1B, which covers the thermal performance requirements for replacement windows and doors, compliance is achieved for replacement windows by either having a product which has a WER Rating of C or better or a whole window U value of 1.6W/m 2 K and doors with a U value of 1.8 W/m 2 K. There will be a transition period for the new Regulations to be implemented; any orders taken after the 1st October 2010 must be installed and compliant with the new 2010 Building Regulations. Orders taken before the 1st October can be installed against the current 2006 Regulations, as long as installation work starts before 6th April 2011. FENSA will automatically assume that jobs installed after the 1st October 2010 up until 1st December 2010 will have had the order taken prior to the 1st October 2010, hence all installations up to the 1st December will be considered compliant against the current Regulations. It should, however, be noted that as a Registered Competent Person you are responsible for seeing that your declaration to FENSA is correct, i.e. you are complying to all Building Regulations associated with the product you have installed. If therefore you have taken an order post 1st October 2010 and the installation takes place before the 1st December 2010, then you do need to notify us by email of this fact enquiries@fensa.org.uk or fax FENSA on 02074078307. It is important that you also register your installations with us in the normal way. We shall also, at the point of inspection, be checking that there is no compelling evidence which dismisses our assumption, detailed above. 1) Window Energy Ratings (WERs) A means of showing compliance to Document L of the Building Regulations is that your product has a WER Certificate from either BFRC, or other authorised WER schemes, to show that your product is indeed energy rated. It will be necessary for the product to be permanently marked to aid on-site inspections. If you fabricate windows rather than buying fully glazed products and installing, then it will be possible for you to obtain a WER Licence and in the case of BFRC there are two licence formats, either the Simplified Energy Licence or the Detailed Energy Licence. An overview of these two licences is available from both the BFRC and FENSA websites (www.bfrc.org and www.fensa.org.uk). The type of licence which suits your business will be dependant upon the material type and how you wish to market your product, i.e. are you going to use the WER as a marketing tool or do you simply want the WER for compliance with a minimum of a C Band? Do not forget that as an Installer you can become a BFRC Authorised Retailer. The Authorised Retailer Scheme is particularly useful for those companies who wish to buy frames and glass separately. There are many other benefits outlined on the attachments. If you would like a pack from BFRC explaining the whole process associated with a WER installation, please either email Toby Blamey on tblamey@ggf.org.uk or telephone 02079399126 / 02074039200 or FENSA on 02076453700. FENSA Limited 54 Ayres Street, London SE1 1EU Tel: 02076453700 Fax: 02074078307 Registered office as above. Registered in England no 3058561 G:\Sheitlan\Sheitlan\FENSA\Others\BFRC\Compliance Letter - Aug 2010\1. RBs Aug2010gbhmit_Sep 2010 A.doc
2) Compliance against a Minimum U value a) Simple/Default Method If you are installing a PVC or a timber window and the frame is fitted with sealed units which make use of soft-coat Low E glass, warm-edge spacer (minimum 16mm) and 90% Argon gas, then FENSA will consider the U value of 1.6 W/m 2 K has been achieved, i.e. there will be no need to provide further evidence to the consumer or to the FENSA Inspector, providing there is no evidence to suggest that our assumption is incorrect. (In timber windows the depth of the frame front to back must be a minimum of 70mm). b) Calculated U values If you are not using the Simple Method you will need to have a whole window U value calculated for the window or door that you are installing. This can be supplied with the product by the Fabricator or determined by the FENSA U value Calculator (or an alternative approved industry calculator) or calculated by a BFRC Simulator. The FENSA Calculator will be available on line via the FENSA website from mid September. Our calculator will be able to cope with PVC-U, timber, aluminium and steel framing materials. Results from the FENSA calculator and other authorised calculators can be stored in the FENSA database under the allocated reference. These details will be passed to our Inspectors when you, at the point of registration, indicate that the installation conforms to a particular calculation held in our database. You may also record in our database calculations which have been undertaken by other calculators. In these circumstances you will not need to leave details of the U value calculation with your customer for our Inspector to access. c) Centre Pane U Values of 1.2W/m 2 K Approved Document L1B does contain a statement concerning the use of a centre pane U value of 1.2W/m 2 K to achieve compliance under the Building Regulations post 1st October 2010. The statement in Approved Document L1B is unclear and we have written to the CLG asking for clarification on this particular matter. As soon as we have this information we will be communicating it to you but in any case before the end of September. We do know however that the CLG intend this particular means of achieving compliance to have a very limited number of applications and therefore you should not be thinking that this represents the route to demonstrate compliance. We will come back to you with further details as soon as we have them from the CLG. d) CE Marking If your product is CE marked against EN 1435-1 with a copy of the signed declaration of conformity, this will be accepted as a method to demonstrate compliance with Approved Document L requirements for thermal performance. e) Doors Doors will from the 1st October 2010 be required to meet a minimum U value of 1.8 W/m 2 K. This can be achieved by either undertaking a U calculation using the FENSA Calculator or any other compliant calculator or having a BFRC Simulation undertaken. An alternative is to seek a CE Mark. Many doors are supplied by specialist manufacturers who will in most cases supply you with a detailed U value calculation or a Certificate confirming U value. For registration of doors under FENSA, only doors with a glass area greater than 50% need to be registered. f) U Value Documentation If your product does not conform to the simplified approach described above or the calculated U value has not been undertaken on the FENSA Calculator or an alternative calculation has not been registered with FENSA, then you will need, at the time of completing an installation, to leave documentary evidence, i.e. outline details of the calculations with your customer at the time of completion. It is suggested that this calculation is left with the product guarantee. At the time of the BBA inspection the inspector will request evidence from your customer of Document L conformance. Yours faithfully Graham Hinett Chief Executive FENSA Limited 54 Ayres Street, London SE1 1EU Tel: 02076453700 Fax: 02074078307 Registered office as above. Registered in England no 3058561 G:\Sheitlan\Sheitlan\FENSA\Others\BFRC\Compliance Letter - Aug 2010\1. RBs Aug2010gbhmit_Sep 2010 A.doc
Window Energy Rating Overview The approach to WER s within BFRC has changed enormously over recent months and we are now providing you with all the necessary information to either join the BFRC Rating Scheme or extend or change your approach to WER s if you are an existing Licence Holder. Detailed Energy Licence (Current Licence) The key to the Detailed Energy Licence is that the Licence Holder can obtain a licence with a particular WER energy index plus U and g value and Air Leakage Factor (Fig.2 overleaf). This is for companies who want to market WER rating strongly to consumers and believe that the consumer will want a product with the highest energy index. It is in effect the current solution, the solution that we have had in place since 2006. The basis of this solution is that the fabricator will choose a combination of components, frame, glass etc. which will give him the right solution for his business, either an A, B or a good C for the marketplace in which he operates. The fabricator requiring a licence under this scheme will need to obtain the simulation for the selection of components from a BFRC Registered Simulator. Simulations should be submitted to one of our four Independent Agents (see our website for details) and they will undertake an audit to check whether the manufacturing processes are capable of delivering the right WER window. It is not necessary for the manufacturing process to be covered by BS 9001. The IA s submit a report to BFRC to enable the BFRC Licence to be issued. Once the licence has been issued it will be possible to add to the licence using the Certificates of Addition (in accordance with BFRC Rules) and for components to be substituted, such as the IGU s or components within the IGU s (in accordance with BFRC Rules), the substituted product must have at least maintained the energy performance set out in the original licence. The Simple Approach to Window Energy Ratings - Simplified Energy Licence (SEL) If you manufacture windows from sections / profiles supplied by a systems house, whether it be in PVC-u, aluminium, timber or steel, you can take a very simple route to obtaining your WER rating, this will categorise your products as A, B or C rated (see Fig.1 overleaf). The Simple Route relies on you batching together a matrix of simulations (Fig.3) covering all the combinations of profiles and IGU s that you use. Simulations may be from your current product range or new simulations. These may come from a systems house or be separately calculated, you may already have them or you may wish to add simulations to those that you already have in your possession. Each licence covers one profile type and is from one energy band A or B or C. The matrix of products will be registered with BFRC and form the Scope of a Licence. Additions to the matrix of products can be made at any time. If a systems company has established a matrix, this can be cascaded down to their fabricators to obtain licences making use of the particular Licence Scope. No charge will be made for Additions to Scope for the Simple Energy Licence, this will be covered by the original fee. The fabricator having put together a matrix of products will need to be audited by an Independent Agency. It is not necessary for the manufacturing process to be covered by BS 9001. Once this is completed the WER Licence can be issued by BFRC. Substitution of sealed units can be undertaken in accordance with BFRC Rules; the only requirement is that the new window remains in the same band. We will have a WER calculator to aid this process. I attach overleaf a schematic which sets out the overall approach, whether via the Simplified Energy Licence (fig.1) or the Detailed Energy Licence route (Fig.2). We will shortly have a WER Calculator to aid this process. G:\Sheitlan\Sheitlan\FENSA\Others\BFRC\Compliance Letter - Aug 2010\2. WER Overview Aug 2010.doc
Figure 1 SIMPLIFIED ENERGY LICENCE Figure 2 DETAILED ENERGY LICENCE
BFRC Authorised Retailer The BFRC Energy Rating Scheme for windows was introduced a few years ago but has remained until the 1st September 2009 the domain of companies who wish to obtain their own licences for the product which they have been selling either as a Trade Fabricator or as a Fabricator / Installer. The relative cost of obtaining a licence has been high, both financially and in terms of time and effort, and there has been no reason for an Installer who purchases his completed product from a Trade Fabricator to obtain his own Licence. On the 1st September 2009 this situation changed completely with the introduction of the Authorised Retailer Scheme. This scheme now brings together Installers / Retailers who either buy the completed product from a Trade Frame Manufacturer or buy frames and glass separately. The Authorised Retailer Scheme will enable the Retailer / Installer to have his own label (shared with a Licence Holder) which can be attached to the glass at the point of delivery and used in advertising material. He will also have the benefit of being listed on the BFRC Website and will in the fullness of time be contacted by consumers who have searched the BFRC Website for their nearest supplier of Energy Rated Windows. It also gives the Authorised Retailer s Customer the benefit of having a FENSA Certificate which recognises that a Window Energy Rating has been installed and shows the Energy Label on the FENSA Certificate. There are also other benefits such as having access to the BFRC Marketing Toolkit and being able to purchase BFRC promotional materials. In short, the Authorised Retailer has all the benefits of a Licence Holder providing he is buying products from an existing Licence Holder. This also includes the ability to substitute components under the Substitution Rules which are now in the process of being issued. The low cost fee structure includes the need for some Installers to be able to register a number of different products which they install as well as the Installer who is only using one particular product. It also includes the annual audit. Find out more from: BFRC www.bfrc.org T:020 7403 9200 or FENSA www.fensaonline.com T: 020 7645 3700 Five Steps to BFRC Authorised Retailer Status Cost 140 Per Annum 1) Speak to your fabricator, they must be a BFRC Licence Holder if you wish to join the Scheme. 2) Complete the BFRC AR application form. 3) If you are going to be sourcing sealed units independently from the Licence Holder, let BFRC know who your supplier is going to be. 4) Upon payment of fees, BFRC will list you and your energy rated products on the BFRC website. You will receive copies of the BFRC Licence (energy labels) artwork and a copy of the BFRC Marketing toolkit. 5) There will be an annual audit which is included in the annual cost of 140. British Fenestration Rating Council, 54 Ayres Street, London SE1 1EU Tel: 020 7403 9200 Fax: 0870 042 4266 www.bfrc.org
BFRC FEES 2010 LICENCE FEES: (a) No sign-up fee (b) Licence Fee: (1) 200 / annum (2) 175 / annum pay for 2 years (3) 150 / annum pay for 3 years Maximum number of Licences (with a fee) = 10 off (c) Certificate of Addition DEL Licence = 50 each (one off) (d) Authorised Retailer (1) 140 / annum up to 10 Licences (2) 200 / annum 11-20 Licences (3) 500 / annum more than 20 Licences August 2010 G:\Sheitlan\Sheitlan\FENSA\Others\BFRC\Compliance Letter - Aug 2010\5. BFRC FEES 2010.doc