When launching new gas appliances and fittings, manufacturers must maintain quality and reduce cost and time to market while also ensuring their products are safe and comply with local market requirements.
National and local standards and regulations evolve quickly, and noncompliance can result in delays, product recalls and potential safety risks. Today we meet Roberto Bigoni, senior engineering associate for Appliances, HVAC and Lighting at UL, to learn more about the challenges for gas appliances manufacturers who are trying to enter the market more safely.
What are the main standards and regulations that gas manufacturers must consider before launching their products on the market?
Depending on the markets they want to enter, and the gas products they want to test and certify, the main standards for North America are:
• ANSI Z21.1/CSA 1.1 for household gas cooking appliances;
• ANSI Z83.11/CSA 1.8 for commercial gas cooking appliances;
• ANSI Z21.58/CSA 1.6 and ANSI Z21.89/CSA1.18 for outdoor gas cooking appliances.
For Europe, the main regulation to place gas appliances and their fittings on the market and into service is Regulation (EU) 2016/426 (GAR). The scope of the GAR is restricted to appliances burning gaseous fuels used for cooking, heating, hot water production, refrigeration, lighting and washing.
In addition, in Europe, we have several EN standards to consider:
• EN 484, EN 497 and EN 498 for outdoor gas cooking appliances and hotplates;
• EN 30 for domestic cooking appliances burning gas (hob and gas cooking);
• EN 203 for gas heated catering equipment (professional gas cooking and fryers).
Regarding U.K. market access, does a U.K. regulation replace the Gas Appliances Regulation (GAR) (EU) 2016/426?
Yes, the Product Safety and Metrology, etc. (Amendment, etc.) (EU Exit) Regulations 2019 amends safety laws, including:
• on Jan. 1, 2021, the U.K. was classified as a non-EU country (known as a third country) and no longer fell within the EU product compliance regime;
• distributors importing products from the EU are considered importers of products into the U.K. They can be held liable as producers for personal injury or property damage arising from any unsafe products that they supply in the U.K;
• the definition of producers changed to cover U.K. manufacturers of products or “a person established in the U.K. that places a product from outside the U.K. on the market”;
• the UKCA marking came into effect on Jan. 1, 2021. However, to allow businesses time to adjust to the new requirements, you will still be able to use the CE marking until Jan. 1, 2023, in most cases. The U.K. Conformity Assessed (UKCA) marking system is the new U.K. product marking used for goods placed on the U.K. market, which previously required a CE mark.
When talking of gas appliance testing and certification, we often hear of National Recognized Testing Laboratories (NRTL), Notified Bodies (NB) and Approved Bodies. Can you explain what they are and what they do?
While the responsibility for conformity assessment always rests with the manufacturer, a number of other stakeholders play a critical role in ensuring products fulfill essential requirements related to safety and ensuring a level playing field for the economic operators.
Nationally Recognized Testing Laboratory is the term used by the U.S. Occupational Safety and Health Administration (OSHA) to recognize third-party organizations that have the necessary requirements to perform safety testing and certification of products covered by OSHA.
The requirements include:
• using technical standards recognized and accepted in the U.S.;
• having a follow-up service after certification;
• maintaining an accredited certification body.
Notified Bodies (NBs) in Europe, or Approved Bodies in the U.K., are specific types of conformity assessment bodies that are officially designated by the national Notifying Authorities. Once those authorities have determined that a conformity assessment organization complies with the GAR’s requirements, it is notified to the European Commission. This notification is recorded in the appropriate publicly available database called NANDO. The U.K. government has its own parallel system with a database for those Approved Bodies well aligned with the EU’s database.
The tasks and responsibilities of the Notified Bodies, and equally of the Approved Bodies in the U.K., are:
• provide conformity assessment services in accordance with their notification scope;
• operate in a competent, non-discriminatory, transparent, neutral, independent and impartial manner;
• retain the necessary personnel who have sufficient and relevant knowledge and experience to carry out conformity assessment in accordance with EU harmonization legislation;
• ensure confidentiality of the information obtained in the course of conformity assessment.
To verify that the NRTLs or the NBs are able to deliver on these tasks, they have to demonstrate their compliance with specific requirements related to competence, consistent operation and impartiality.
What value do NRTLs, NBs and Approved Bodies bring to the market?
Their primary value is helping gas appliance manufacturers address the needs of consumers, users and, more generally, all interested parties by giving them confidence and to demonstrate that the products have met the specified requirements by an impartial third-party body.