Hello,

The construction product directive is one of the most recent directives
affecting fire detection devices. Currently if you  have a smoke detector
you would like to sell in the EU then you have to go through all the local
national agencies (ANPI, VdS LPCB etc) in Europe to obtain approvals. As of
next March (when the first standard get published in the OJ for the CPD )
the manufacturer can now go to any one of those agencies ( provided they
have been listed as a certification body under the new scheme)  and be
approved across the EU. Hooray say I!  Chop tens of thousands of Euros off
my testing bill! Unfortunately it is not all as it seems! The CPD writers in
their wisdom have a provision in the directive that not only does the
notified body have to do type testing and regular auditing but they must
also certify the quality plan!. The certified bodies take this to mean that
they must do something like an ISO9000 certification and audit plan.  I'm
wondering why the directive was written this way. If one already has a
quality plan in place that is registered, why do we have to do it again? It
seems to be counterproductive to say on one hand that a particular agency is
qualified to assess quality plans and then have a directive that says
otherwise. 
This also has the effect that if I choose one certification body to test
something then I must choose them again and again or else face re evaluation
of my quality plan by yet  another certification body. What a convenient
clause for non competition amongst the certification bodies!

Is there anyone out there that may have contributed to the Construction
Product Directive that might shed some light on this subject? Am I missing
something? Was that the intent of the directive or perhaps this wasn't
foreseen?

Grumbling complete


Best Regards,


Kevin Harris
Manager, Approvals and CAD Services
Digital Security Controls
3301 Langstaff Road
Concord, Ontario
CANADA
L4K 4L2

Tel: +1 905 760 3000 Ext. 2378
Fax +1 905 760 3020

Email: kevinharr...@dsc.com


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