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Building and Environment 69 (2013) 194e205

Contents lists avai

Building and Environment

journal homepage: www.elsevier .com/locate/bui ldenv

Assessing release of hazardous substances from constructionproducts e Review of 10 years of experience with a horizontalapproach in the European Union

Outi Ilvonen*

Federal Environment Agency, Unit III 1.4, Wörlitzer Platz 1, 06844 Dessau-Roßlau, Germany

a r t i c l e i n f o

Article history:Received 28 June 2013Received in revised form2 August 2013Accepted 4 August 2013

Keywords:Construction productHazardous substanceTest methodAssessment

Abbreviations: BRCW3, basic requirement for conshealth and the environment”; CPD, Construction Pstruction Products Regulation; DoP, declaration ofrequirement no 3 “Hygiene, health and the envirCoupled Plasma e Mass Spectrometry; ICP-OES, Indutical Emission Spectrometry; LCI, lowest concentratioCommittee Approval; WI, work item.* Tel.: þ49 340 2103 3538; fax: þ49 340 2104 353

E-mail address: outi.ilvonen@uba.de.

0360-1323/$ e see front matter � 2013 Elsevier Ltd.http://dx.doi.org/10.1016/j.buildenv.2013.08.010

a b s t r a c t

Aspects like compressive strength or fire resistance are familiar requirements for construction products,and have been addressed by product standard developers for decades. New requirements concerninghealth and environmental aspects of construction products have appeared gradually during the last twodecennia. The EU legislation for construction products has promoted the performance approach. Thismeans that it is not enough to list environmentally benign materials in administrative provisions andstandards. To assess a product’s emission performance reliable test methods are needed and any re-quirements must be backed up with test methods. This article reviews the development and harmoni-zation of assessment methods for the release of hazardous substances from construction products,presents the results achieved so far in standardization and makes recommendations regarding the futureuse of the new horizontal assessment methods.

� 2013 Elsevier Ltd. All rights reserved.

1. Introduction

In the European Union the political ambition of creating a singlemarket without barriers to trade generated the need for harmoni-zation legislation. For construction products the legislative aim ofthe Construction Products Directive [1] was to provide harmonizedproduct standards and test methods. The EUmember states remainfree to choose the level of requirements for common good for theirbuildings as they see fit, but they are obliged to accept theharmonized product standards and their test methods. This shouldmake sure that manufacturers do not have to test their productmore than once for any particular characteristic in order to enterthe market everywhere in the EU.

So far the users of construction products only seldom receiveany information on the release of hazardous substances from anyconstruction product before purchase. As soon as the test methods

truction works no 3 “Hygieneroducts Directive; CPR, Con-performance; ER3, essentialonment”; ICP-MS, Inductivective Coupled Plasma e Op-n of interest; TCA, Technical

8.

All rights reserved.

currently under validation are available the situation is expected tochange. Under the Construction Products Regulation [2] that hasreplaced the Construction Products Directive (CPD) from July 2013 adeclaration of performance (DoP) is introduced as a new prereq-uisite for CE marking and free trade in the EU. From 2014 onwardsall preparatory work is ready to include step by step all relevantinformation for hazardous substances into the DoP.

Test methods do not per se reduce the emissions of hazardoussubstances from construction products. However, the availability ofharmonized test methods supports transparent information onmaterial emissions and is a prerequisite for a reliable assessment ofthe emissions. When information on the emission performance ofconstruction products becomes available, architects, constructors,purchasers and consumers are able to choose products assesseduncritical for human health and the environment, if they wish to doso. The test methods allow for the product manufacturers to opti-mize a new product’s emission behaviour already during itsdevelopment. The legislators have a reliable instrument that doesnot lead to technical barriers to trade for a mandatory upperemission limit for the market. Both voluntary and mandatoryproduct labels can lean on test methods that make a comparison ofthe environmental and health benefits for consumers possible [3].The performance data that the test methods generate enable a faircompetition on the market with product characteristics related tohazardous substances.

Scheme 1. Scope of legitimate requirements regarding hygiene, health and the environment addressed at buildings and other construction works that must be taken into account inconstruction product standardization where relevant (as defined in the CPD (1) on the left hand side and to the CPR (2) on the right hand side e changed emphases marked red).(For interpretation of the references to colour in this figure legend, the reader is referred to the web version of this article.)

O. Ilvonen / Building and Environment 69 (2013) 194e205 195

This article reviews the horizontal test methods and guidancedocuments for release of hazardous substances from constructionproducts published so far; describes the status of current work andthe administrative constraints for it and makes recommendationsregarding future use of the methods. Beyond the test methods thework on a harmonized concept for the health assessment of theemissions from construction products is highlighted as a key issue.

2. The justification for the horizontal approach

The first product standard harmonized according to the rules ofthe CPD was published for cement in 2000 and acknowledged asharmonized by the European Commission the following year [4].After that over 400 further harmonized product standards havebeen issued [5]. The basis for the drafting of harmonized productstandards is given in the standardization mandates provided by theEuropean Commission [6]. Mandated product characteristics relateto the six essential requirements of the CPD, or in future, to the

seven basic requirements for construction works (BRCW) of theConstruction Products Regulation (CPR). One of the mandatedessential characteristics has been from the beginning the release ofdangerous substances corresponding to the essential requirementno. 3 “Hygiene, health and the environment” (ER3) of the CPD (infuture BRCW3 of the CPR, see Scheme 1).

Due to the lack of common test methods, lack of expertise onhazardous substances in the technical committees for products,lack of detail in the assignments in product mandates and interestin publishing product standards that entitle to CE marking quicklymost harmonized product standards barely implement ER3. Theyhave mostly implemented requirements for hazardous substanceswith a place holder. The place holder cites the database “CP-DS:Legislation on substances in construction products” of the Euro-pean Commission [7] and explains that the product has to complywith the requirements given there, when and where they apply.

From the point of view of the European Commission the interimsolution with the database was not satisfactory as a permanent

Table 1Standards and guidance documents harmonized by CEN/TC 351 “Construction products: Assessment of release of dangerous substances”.

Project reference Title Status

CEN/TR 15855:2009 Construction products e Assessment of release of dangerous substances e Barriers to trade PublishedCEN/TR 15858:2009 Construction products e Assessment of the release of regulated dangerous substances from construction products

based on the WT, WFT/FT proceduresPublished

CEN/TR 16045:2010 Construction products e Assessment of release of dangerous substances e Content of regulated dangeroussubstances e Selection of analytical methods

Published

CEN/TR 16098:2010 Construction products: Assessment of release of dangerous substances e Concept of horizontal testing proceduresin support of requirements under the CPD

Published

CEN/TR 16220:2011 Construction products e Assessment of release of dangerous substances e Complement to sampling PublishedCEN/TR 16410:2012 Construction products e Assessment of release of dangerous substances e Barriers to use e Extension to CEN/TR 15855

Barriers to tradePublished

FprCEN/TR 16496 Construction Products e Assessment of release of dangerous substances e Use of harmonized horizontal assessmentmethods

Under approval

FprCEN/TS 16516 Construction products e Assessment of release of dangerous substances e Determination of emissions into indoor air Under approvalFprCEN/TS 16637-1 Guidance standard for CEN Product TCs for selection of leaching tests appropriate for their product(s) e General

principlesUnder approval

FprCEN/TS 16637-2 Generic horizontal dynamic surface leaching test (DSLT) for determination of surface dependent release of substancesfrom monolithic or plate-like or sheet-like construction products

Under approval

WI 00351010 Generic horizontal up-flow percolation test for determination of the release of substances from granular constructionproducts

Under drafting

WI 00351012 Construction products e Assessment of release of dangerous substances e Terminology Under draftingWI 00351013 Construction products e Assessment of release of dangerous substances e Guidance on evaluation of conformity Under draftingWI 00351014 Construction products e Assessment of release of dangerous substances e Determination of the activity concentrations

of 226Ra, 232Th and 40K using gamma-ray spectrometryUnder drafting

WI 00351016 Construction products e Assessment of release of dangerous substances e Analysis of inorganic substances in digestsand eluates

Under drafting

WI 00351017 Construction products e Assessment of release of dangerous substances e Digestion of construction products by aquaregia

Under drafting

WI 00351018 Construction products e Assessment of release of dangerous substances e Analysis of inorganic substances in digests andeluates e Part 1: Analysis by Inductive Coupled Plasma - Optical Emission Spectrometry (ICP-OES)

Under drafting

WI 00351019 Construction products e Assessment of release of dangerous substances e Analysis of inorganic substances in digests andeluates e Part 2: Analysis by Inductive Coupled Plasma - Mass Spectrometry (ICP-MS)

Under drafting

WI 00351020 Construction products e Assessment of release of dangerous substances e Determination of dose assessment and classificationfor emitted gamma radiation

Under drafting

WI 00351021 Construction products e Assessment of release of dangerous substances e Analysis of inorganic substances in digests forcontent analysis

Under drafting

O. Ilvonen / Building and Environment 69 (2013) 194e205196

option. On the one hand the benefits of harmonization shouldbecome tangible for all stakeholders also with regard to health andenvironmental aspects of construction products. On the other handit is not acceptable in the long term that obligatory nationalmarkings can legitimately be required for construction productsalready carrying the CE marking.

The Commission Services called in 2002 the interested memberstates and stakeholder groups into an ad hoc working group onregulated substances and started preparing for a proper imple-mentation of ER3. In the preparatory phase a horizontal approachwas chosen as basis for further work. The horizontal approachmeans that test methods do not need to be developed for alldifferent construction products separately. Instead existing testmethods are harmonized to cover the most relevant release sce-narios for hazardous substances for most generic constructionproducts [8]. The approach is cost-efficient and also enables thecomparison of release performance between different productgroups. The assignment for the development of horizontal testmethods was elaborated in mandate M/366 sent to CEN in 2005. Inthe meanwhile the ad hoc group became an Expert Group onDangerous Substances and advises the Commission during theexecution of the mandated work on test methods.

2.1. Standardization work in progress

For the execution of the mandated work CEN established a newtechnical committee. So far CEN/TC 351 “Construction products:assessment of release of dangerous substances” has published aseries of technical reports as a basis for the standardization work.Thefirst testmethods for emissions into indoor air and leaching into

soil and water will be published soon, and a number of work itemsfor test standards and technical reports are currently under devel-opment. Topics covered include gamma radiation, analysis oforganic and inorganic substances in digests and eluates and diges-tion of construction product samples for subsequent determinationof the substances of interest. Table 1 gives an overview of the de-liverables of CEN/TC 351. So far CEN/TC 351 has not developed anyreally new methods, but has harmonized existing test methods.

During the 1990s the European Commission gave its first as-signments to address dangerous substances in construction prod-uct standards to CEN [9]. It turned out that the technicalcommittees were unable to specify, which dangerous substancesshould be addressed. Therefore the European Commission has inrecent years made the effort to develop a very detailed guidanceconcerning the substances for which performance declarations e

relying on CEN/TC 351 deliverables as reference methods e aremandatory.

2.2. Mandate M/366, database and indicative list

First in its mandate M/366 the European Commission made theprincipal choice to give the priority to release scenarios and not toindividual substances. The test methods harmonized for the releasescenarios emissions into indoor air, leaching into soil and water,radiation and for the supplementary scenario content analysisshould be able to cover all relevant substances. Both CPD and CPRrefer to dangerous substances: the broad understanding of the termis that all substances corresponding with the definition of theDangerous Substances Directive of 1967 [10,11] are in scope of thework. In the meanwhile the Dangerous Substances Directive has

Scheme 2. Transition of definitions from dangerous to hazardous substances (7; 8) in chemical legislation. The upper definition was given in the Dangerous Substances Directive in1967 and amended in 1992 [9]. The lower one is the currently valid definition of the EU Regulation (No 1272) from 2008.

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Table 2Overview ofmandate amendments on dangerous substances for product groups covered by European Commission standardizationmandates under the CPD (see also: ftp://ftp.cen.eu/CEN/Sectors/List/Construction/Guidance/TFN337.pdf).

Mandate no Mandate title Status of amendment ondangerous substances

CEN/TC involved

M/100 Precast concrete products Under preparation CEN/TC 177 e Prefabricated reinforced componentsof autoclaved aeratedCEN/TC 229 e Precast concrete Products

M/101 Doors, windows and related products Under preparation CEN/TC 33 e Doors, windows, shutters buildinghardware and curtain walling

M/102 Membranes Under preparation CEN/TC 67 e Ceramic tilesCEN/TC 254 e Flexible sheets for waterproofingCE/TC 361 e Polymer modified bituminous thickcoatings for waterproofing e Definitions/requirements and test methods

M/103 Thermal insulating products Issued/July 2010 CEN/TC 88 e Thermal insulating materials andproducts

M/104 Structural bearings No amendment for the time being CEN/TC 167 e Structural bearingsM/105 Chimneys, flues and specific products No amendment for the time being CEN/TC 62 e Independent gas-fired space heaters

CEN/TC 166 e ChimneysCEN/TC 180 e Domestic and non-domesticgas-fired air heaters and non-domestic gas-firedoverhead radiant heatersCEN/TC 297 e Free-standing industrial chimneys

M/106 Gypsum products Issued/December 2012 CEN/TC 241 e Gypsum productsM/107 Geotextiles Under preparation CEN/TC 189 e Geosynthetics

CEN/TC 254 e Flexible sheets for waterproofingM/108 Curtain walling No amendment planned for the time being CEN/TC 33 e Doors, windows, shutters building

hardware and curtain wallingM/109 Fire alarm/detection, fixed firefighting,

fire and smoke control and explosionsuppression products

No amendment planned for the time being CEN/TC 72 e Fire detection and fire alarm systemsCEN/TC 156 e Ventilation for buildingsCEN/TC 191 e Fixed firefighting systemsCEN/TC 192 e Fire service equipment

M/110 Sanitary appliances No amendment planned for the time being CEN/TC 163 e Sanitary appliancesM/111 Circulation fixtures No amendment planned for the time being CEN/TC 50 e Lighting columns

CEN/TC 226 e Road equipmentM/112 Structural timber products and

ancillariesIssued/December 2012 CEN/TC 124 e Timber structures

M/113 Wood-based panels Issued/December 2012 CEN/TC 112 e Wood-based panelsM/114 Cement, building limes and other

hydraulic bindersNo amendment planned for the time being CEN/TC 51 e Cement

M/115 Reinforcing and pre-stressing steel(for concrete)

No amendment planned for the time being CEN/TC 104 e ConcreteECISS/TC 104 e Concrete reinforcing andpre-stressing steels

M/116 Masonry and related products Issued/December 2012 CEN/TC 125 e MasonryCEN/TC 241 e Gypsum products

M/118 Waste water engineering products Under scrutiny CEN/TC 155 e Plastic piping systems andducting systemsCEN/TC 165 e Waste water engineering

M/119 Floorings Issued/July 2010 CEN/TC 67 e Ceramic tilesCEN/TC 129 e Glass in buildingsCEN/TC 134 e Resilient/textiles and laminatefloor coveringsCEN/TC 175 e Round and sawn timberCEN/TC 178 e Pavement unitsCEN/TC 217 e Surfaces for sports areasCEN/TC 229 e Precast concrete productsCEN/TC 246 e Natural stonesCEN/TC 246/CEN/TC 229 JWG “Agglomeratedstones”CEN/TC 303 e Floor screeds

M/120 Structural metallic sections andancillaries

No amendment planned for the time being CEN/TC 121 e WeldingCEN/TC 132 e Aluminium and aluminiumalloysCEN/TC 135 e Execution of steel andaluminium structuresCEN/TC 185 e FastenersECISS/TC 103 e Structural steels- gradesand qualitiesECISS/TC 109 e Flat products for coldworkingECISS/TC 105 e Steel for heat treatment, alloysteels and free-cutting steelsECISS/TC 111 e Steel castings

M/121 Internal and external wall and ceilingfinishes

Issued/December 2012 CEN/TC 67 e Ceramic tilesCEN/TC 99 e WallcoveringsCEN/TC 175 e Round and sawn timber

O. Ilvonen / Building and Environment 69 (2013) 194e205198

Table 2 (continued )

Mandate no Mandate title Status of amendment ondangerous substances

CEN/TC involved

CEN/TC 246 e Natural stonesCEN/TC 249 e PlasticsCEN/TC 277 e Suspended ceilingsCEN/TC 357 e Stretched ceilingsCEN/TC 128 e Roof covering, Wall cladding

M/122 Roof coverings, rooflights, roof windows& ancillaries

Issued/December 2012 CEN/TC 128 e Roof coverings products fordiscontinuous laying and products for wallcladdingCEN/TC 178 e Paving units and curbs

M/124 Road construction products Under scrutiny CEN/TC 227 e Road construction productsCEN/TC 254 e Flexible sheets for waterproofingCEN/TC 336 e Bituminous binders

M/125 Aggregates Issued/July 2010 CEN/TC 154 e AggregatesM/127 Construction adhesives Under preparation CEN/TC 67 e Ceramic tiles

CEN/TC 193 e AdhesivesM/128 Products related to concrete, mortar

and groutUnder preparation CEN/TC 104 e Concrete

CEN/TC 298 e Pigments and extendersM/129 Space heating appliances No amendment planned

for the time beingCEN/TC 46 e Oil stovesCEN/TC 130 e Space heating appliances withoutintegral heat sourcesCEN/TC 295 e Residential solid fuel burningappliances

M/131 Pipes, tanks & ancillaries notin contact with water forhuman consumption

Under scrutiny CEN/TC 47 e Atomizing oil burners and theircomponents e Function e Safety e TestingCEN/TC 69 e Industrial valvesCEN/TC 133 e Copper and copper alloysCEN/TC 155 e Plastic piping systems and ductingsystemsCEN/TC 193 e AdhesivesCEN/TC 203 e Cast iron pipes, fittings and their jointsCEN/TC 208 e Elastomeric seals for joints in pipeworkand pipelinesCEN/TC 221 e Shop fabricated metallic tanksCEN/TC 235 e Gas pressure regulators and associatedsafety devicesCEN/TC 236 e Non-industrial manually operatedshut-off valves for gasCEN/TC 266 e Thermoplastic static tanksCEN/TC 342 e Metal hoses, hose assemblies, bellowsand expansion jointsECISS/TC 110 e Steel tubes and fittings for steel tubesCEN/TC 265 e Metallic tanks for the storage of liquidsCEN/TC 165 e Waste water engineering

M/135 Glass in buildings Issued/December 2012 CEN/TC 129 e Glass in buildingsM/136 Construction products in contact

with water for humanconsumption

Addressed separately CEN/TC 69 e Industrial valvesCEN/TC 92 e Water metersCEN/TC 133 e Copper and copper alloysCEN/TC 155 e Plastic piping systems and ductingsystemsCEN/TC 164 e Water supplyCEN/TC 193 e AdhesivesCEN/TC 197 e PumpsCEN/TC 203 e Cast iron pipes, fittings and their jointsCEN/TC 208 e Elastomeric seals for joints in pipeworkand pipelinesECISS/TC 110 e Steel tubes and fittings for steel tubes

M/443 Power, Control and Communicationcables

No amendment plannedfor the time being

CLC/TC20 “Electric cables”

M/474 Sealants for non-structural use injoints in buildings and pedestrianwalkways

Under preparation CEN/TC 349 “Sealants for joints in building construction”

M/489 ETICS (external thermal insulationcomposite systems)

Not addressed yet CEN/TC 88 e Thermal insulating materials and productsMay be linked to other TCs.

O. Ilvonen / Building and Environment 69 (2013) 194e205 199

been repealed [12] and the term substituted through hazardoussubstances (see Scheme 2). In the context of CPD and CPR theearlier established term dangerous substances is used further. Inthis article the term hazardous substances is mostly used to high-light the still existing important interface of the work under CPDand CPR with developments in chemicals policy.

From the experience gathered in standardization work theCommission Services were aware that leaving the choice ofsubstances to product technical committees is not a practicableoption. Together with its Expert Group Dangerous Substancesthe Commission gathered the substances and parametersexplicitly covered in member states’ laws, regulations and

Fig. 2. Three horizontal release scenarios considered necessary to cover leaching intosoil and water in test standards for construction products.

O. Ilvonen / Building and Environment 69 (2013) 194e205200

administrative provisions for construction products into anindicative list [13]. This list was given to CEN/TC 351 toelaborate which substances the harmonized test methodsshould cover.

Additionally the Commission Services decided to amend thealready issued product mandates to includemore precise details ondangerous substances. As the normal CEN procedure is to checkproduct standards every five years to keep them up to date and inline with the state-of-the-art new assignments and guidance caneasily be dealt with at any point in time. The first three mandateamendments for aggregates, floorings and thermal insulationproducts were sent to CEN in 2010. Seven further product mandatesfollowed 2012/2013, and around five to ten further mandateamendments are still expected (see Table 2). The mandateamendments for dangerous substances list for each mandatedproduct standard the substances, the release scenarios and themember state provisions to be addressed. Until the requirementsfrom the amended mandates are implemented into product stan-dards the CP-DS database remains in place. As the first round ofmandate amendments does not necessarily cover all legitimaterequirements of member states the CP-DS database can be used as astopgap solution for the left over requirements still for a number ofyears.

3. Harmonization of assessment methods

The reference methods to be used in product standards, whenincluding performance requirements for hazardous substancescome from CEN/TC 351 (see Fig. 1). In the following, main prin-ciples of the so far finalized methods and the outline of themethods currently under development are described. All CEN/TC351 test methods run through a robustness validation beforepublication as Technical Specifications (CEN/TS). A second vali-dation step with round robin tests is planned as instructed byCEN guidance [14] before publication as European Standards (EN).The aim of the round robin tests is to be able to estimate therepeatability of test results within one laboratory and thereproducibility of results between different laboratories. It is ex-pected that the methods will also be overtaken by ISO once theybecome available as EN.

Fig. 1. Outline of the intended implementation route of the horizontal CEN/TC 351 methoEuropean Commission.

3.1. Leaching

CEN/TC 351 has drafted two generic horizontal testing standardsfor release of hazardous substances into soil and water [15,16].These are a dynamic surface leaching test (DSLT) for monolithic,plate-like or sheet-like construction products, prCEN/TS 16637-2(submitted to Technical Committee Approval), and an up-flowpercolation test for granular construction products, expected asprCEN/TS 16637-3 (under development). Both methods are inten-ded for construction products that come into contact with rain,seepage water, soil or groundwater in their intended use. Productsthat are always installed to be protected from weathering duringtheir service life are not addressed. Construction products fordrinking water installations are addressed elsewhere [17,18].

Although the choice of leaching test seems straight-forward atthe first glance at the titles of the methods, CEN/TC 351 provides aguidance standard for selection of the appropriate release tests forthe different products (CEN/TS 16637-1, submitted to TCA). PrCEN/TS 16637-1 elucidates the chosen release scenarios and specificinfluencing factors (see Fig. 2). Especially for borderline cases likebig aggregates (e.g. armourstones), that could be allocated to both

ds in construction product standards in response to mandate amendments from the

Fig. 3. European reference room defined in CEN/TS 16516 with the selected di-mensions, the corresponding set of product loading factors for the test chamber, andthe used climate and ventilation conditions, which represent the general indoorenvironment.

O. Ilvonen / Building and Environment 69 (2013) 194e205 201

methods, the guidance is important in order to ensure compara-bility and fair competition conditions between product groups.Secondary materials (construction and demolition waste) and in-dustrial by-products (e.g. slags) with a lower quality may fall underthe waste regime whereas high quality materials can reach a con-struction product status. Tomake sure that anymaterial would onlyhave to be tested once the possibilities of including compatible testoptions in prCEN/TS 16637-3 and the corresponding leaching testfor waste, CEN/TS 14405 [19], are currently scrutinized in a jointactivity of the CEN/TCs 292 and 351.

The DSLT (prCEN/TS 16637-2) determines the surface depen-dent leaching behaviour under dynamic conditions as a function oftime. The up-flow percolation test (draft CEN/TS 16637-3) de-termines the leaching behaviour as a function of liquid to solid ratiounder specified percolation conditions. Both tests produce eluates,which can subsequently be analysed by physical, chemical andecotoxicological methods. Metallic construction products like al-loys and their metallic and organic coatings are not included in theDSLT due to a different leaching mechanism. In future the valida-tionwork may lead to modifications and additional scope for use ofthe method. One special case is already specified in an Annex ofprCEN/TS 16637-2. This is a test for “Granular construction prod-ucts with Low Hydraulic Conductivity” (GLHC).

The methods for the analysis of eluates are currently underdrafting in CEN/TC 351. For the analysis of inorganic substances ineluates two horizontal methods have been prepared. These areanalysis by Inductive Coupled Plasma e Optical Emission Spec-trometry (ICP-OES) and analysis by Inductive Coupled Plasma e

Mass Spectrometry (ICP-MS). For the analysis of organic substancesin eluates the reference methods have not yet been selected.Available methods have been compiled in CEN/TR 16045 [20].

The leaching test in laboratory conditions is a convention usedto assess whether a construction product fulfils environmentalquality criteria in its intended use. The test results expressed e.g. asconcentrations in eluates are not directly comparable with regu-latory requirements for environmental quality expressed e.g. asconcentrations in soil or groundwater. A standard model is neces-sary in order to calculate from the test result into a predictedenvironmental concentration. Currently this modelling step has notbeen included into the CEN/TC 351 test methods. Therefore, the testresults cannot be directly compared with limit values [21]. How-ever, it is expected that the national regulations or any other

documents that will refer to the new test methods in future willevolve to express criteria which accord with the CEN/TC 351methods.

3.2. Indoor air

The chamber test, CEN/TS 16516 (to be published), harmonizedin CEN/TC 351 determines the specific emission rate of volatileorganic compounds from a construction product into indoor air. Inthe test chamber emissions occur under constant conditions andare subsequently measured. The results are expressed as chemicalconcentrations in the air of a reference room (see Fig. 3). A refer-ence room is needed, because it is too onerous to evaluate emis-sions by testing in all use conditions for which a product isintended. The selected reference room dimensions, the corre-sponding set of product loading factors for the test chamber, andthe used climate and ventilation conditions represent the generalindoor environment. The horizontal reference method combinesthe large amount of European experience [22e25] on chambertests into one emission scenario and one reference room. In thisway construction products can be evaluated under comparableconditions with regard to emissions into indoor air. Flexibility onchamber dimensions has been maintained to ensure that repre-sentative samples of different materials can be accommodated.

The appropriate analytical methods are specified in CEN/TS16516 for VOCs, SVOCs, TVOC and certain aldehydes. The methodfor VOCs, SVOCs and TVOC is based on ISO 16000-6 [26] but withfurther specifications for improving reliability. For formaldehyde,acetaldehyde, butyraldehyde, propionaldehyde, acetone and cro-tonaldehyde the appropriate analytical method specified in CEN/TS16516 is based on ISO 16000-3 [27]. For other aldehydes the samemethod as for VOCs in general is applicable.

CEN/TS 16516 is an adaptation of the ISO 16000 standard series.To improve the reproducibility and reliability of test results the ENISO 16000-9 [28] method has been complemented by furtherspecifications, especially for sampling and sample preparation. Theallowed variation ranges for the air change rate in the test chamberare tighter, the defined loading factors are normative and the Eu-ropean reference room is mandatory. CEN/TS 16516 has gonethrough a robustness validation that showed how small changes inkey testing parameters influence the test result. Based on a furthervalidation step e statistical evaluation of already performed roundrobin statistical intercomparison test e the TS is expected tobecome a fully validated European Standard in 2016.

3.3. Radiation from construction products

CEN/TC 351 addresses naturally occurring radioactive materials(NORM), which may be used in building materials under radio-logical constraints [29,30]. The main task identified in this contextis to develop a standardized measurement method for determiningthe activity concentrations of three naturally occurring radionu-clides using gamma spectrometry. The activity concentration index(I) is an established screening tool in Europe for identifying mate-rials that might be of concern. For the calculation of the activityconcentration index (I) measurements of Radium-226, Thorium-232 and Potassium-40 are relevant.

The activity from the gamma-emitting radionuclides present inthe test specimen is determined through an analysis of the energiesand areas obtained from the full energy peaks of the gamma ra-diation spectra. To enable this analysis the test method requiresaccurate energy and efficiency calibrations. The calibration is car-ried out with a material with a known activity that shows a similarchemical composition and density to the intended test specimen.The test is performed in a container with a predefined shape and

O. Ilvonen / Building and Environment 69 (2013) 194e205202

size, identical with the geometry used during calibration. Forradium-226 and thorium-232 the activity concentration is deter-mined using a progeny nuclide, whereas for potassium-40 theconcentration is based on the photo peak from the nuclide itself.

In addition to the test method for determining activity con-centrations a technical report on dose assessment and classifica-tions of emitted gamma radiation is prepared. It discusses existingapproaches on gamma dose assessment and presents a method forcalculating the external gamma dose from construction products.The results are intended to serve as a basis for development of aharmonized European approach for estimation of gamma radiationdoses caused by construction products in future. Work on a radonexhalation measurement and dose assessment method is currentlyon hold.

3.4. Content

The determination of the chemical content of constructionproducts is not the main goal of the current work on the harmo-nization of test methods for hazardous substances. The focus of thework is on release. Content test methods are considered necessaryas an additional tool for example for situations where it is tooexpensive or not practical to measure release. In CEN/TR 16045construction products have been divided into the following mate-rial groups: silica-based products; bituminous products; metals;wood-based products; plastics and rubbers; sealants and adhesivesand paints and coatings. For each material group existing methodsconsidered suitable for digestion, extraction and analysis of thesubstances of interest are listed. Substances addressed includemajor, minor and trace elements; anions; organic substances andparticles.

On the basis of the recommendations agreed upon in CEN/TR16045 further standardization work is under preparation. Draftstandards are available for digestion of construction products byaqua regia (WI 003510017) and for the determination of major,minor and trace elements in digests and eluates (ICP-OES, WI00351018 and ICP-MS, WI 00351019). Work items on extraction,

Fig. 4. Sketch of the tasks to be carried out by the different invol

clean-up and analysis for organic substances are underconsideration.

4. Implementation of test standards in product standards

The results from the work of CEN/TC 351 are becoming availableduring the next years. Important first mile stones are the publica-tion of CEN/TS 16516 and CEN/TS 16637-2.With these two technicalspecifications technical committees for construction products canstart implementing the mandated requirements for dangeroussubstances into test provisions in their product standards. Inaddition to the use of the new test methods in the legal context ofthe CPR the methods provide a good assessment tool for voluntarylabels and for Environmental Product Declarations (EPDs). EN15804 already contains a place holder for the CEN/TC 351 methods[31]. The broad involvement of experts representing differentstakeholders e scientific institutions, test laboratories, industry,authorities and NGOs e in CEN/TC 351 work has been important inachieving results that are generally accepted.

Before the declaration of performance attached to a construc-tion product can be expected to contain classes or levels for therelease of hazardous substances in addition to the availability oftest methods also other important preparatory work is needed (seeFig. 4). Test laboratories recognized as authorized bodies to carryout third party tasks in the process of assessment and verificationof constancy of performance according to the CPR rules have tobecome available. Also the conventions for summarizing theessential results from the test reports for communication in the DoPhave yet to be developed. Here it would be crucial from the userpoint of view to achieve horizontal solutions. It is not transparent, ifevery construction product communicates its release performancewith a different set of classes or levels.

In order to accommodate for a full harmonization of theessential characteristics related to hazardous substances the set oftest methods should be able to cover the parameters of the indic-ative list. At the moment some gaps are still conspicuous. Theseinclude VVOC and ammonia in context of emissions into indoor air,

ved parties in order to reach a full harmonization of BRCW3.

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the analysis of organic substances in eluates and the ecotoxico-logical characterization of eluates in the context of leaching as wellas content analysis of organic substances. Under the CPR the ne-cessity to address content issues becomes more pressing than un-der the CPD. Until now the clear focus of workwas on the use phaseof buildings and therefore on release. From now on also recyclingissues are addressed, where relevant. This asks for an appropriatesupport through content test methods for construction productsmade of e.g. recycling rubber [32,33]. Another extension of thescope of work under BRCW3 is the construction phase. For examplethe harmonized guidance for ecotoxicity tests should be able totackle the potential ecotoxic effects both during construction anduse.

In future appearing new issues like sensory evaluation [34] ornanomaterials [35] should be overtaken into the horizontal toolkitin a flexible manner. The typically experienced difficulties in givingup national solutions do not arise, when a CEN or ISO solution canbe developed before the need for different national ones hasbecome urgent. The development of the ISO standard for sensoryevaluation [36] is a good example of voluntary harmonizationwithout a formal mandate.

The BRCW3 as laid down in the CPR has a global character. In thecurrent implementation work the starting point has been definedvery strictly. Only those aspects that the EU member states havealready defined very precisely in their laws, regulations andadministrative provisions have been taken into account. Not quiteconsistent is that on the one hand the CPD/CPR expects memberstates to set their requirements on the level of buildings and otherconstruction works, but on the other hand for dangerous sub-stances only requirements set directly on product level have beenaccepted as precise enough. This approach has been clearlydifferent from the way in which other requirements have beentreated. For example for mechanical resistance and stability also aglobal way of setting requirements from the member states’ part(“The construction work must not collapse”) has been taken intoaccount in standardization mandates.

Currently the approach followed for BRCW3 is intended to fulfilthe existing requirements of the member states very closely. Adeclaration of release performance is mandatory only, if re-quirements exist where the product is placed on the market. Thisnitpicker approach has perhaps been the only one possible to getthe topic hazardous substances moving forward after the moregeneralist approach of the 1990s did not lead to any real progress.Now that the horizontal test methods are there, it seems that thetime is right for more harmonization. It would be appropriate, if thedeclaration of performance of construction products would containthe same information on release of hazardous substances for allEuropeans.

4.1. Future needs and options

Especially for emissions into indoor air there is a strong need forharmonization beyond the test method [37]. As the amount of in-dividual VOCs that may emit from construction products is quitelarge it is not considered helpful to report all measured concen-trations to the user. The R value is an established tool for commu-nicating the emission of all assessable compounds [23]. The R valueis not derived toxicologically, but has been chosen as a pragmaticapproach for health assessment for daily praxis. For the calculationof the R value the concentrations of the measured substances aredivided by their respective Lowest Concentration of Interest (LCI).At the moment the LCIs are partly different in different countries,but an EU LCI framework is expected to be published soon andbridge the way to harmonized reference values. For the Europeanmarket an EU R value would be more credible and easier to

communicate; after all human health is affected in the sameway indifferent countries.

National authorities that workwith LCI, organizations with theirown emission labels and industry associations have all workedtogether under the auspices of the EU Joint Research Center in or-der to publish a list of EU LCI for the advantage of all LCI users.Unfortunately financial constraints have led to an interruption ofthe work. Further support from the European Commission is ur-gently sought to be able to complete the EU LCI list. So far theprocedure for the derivation of LCI, as well as 86 LCI has beenagreed upon. For 90 remaining substances the goal is to provideharmonized LCI until the end of 2014 (unpublished observations).Once the EU R value becomes reality, also the rather inaccurate wayof evaluating TVOC with toluene equivalents can be discarded. If anR value is measured, it is easy to calculate a precise TVOC valueusing the individual response factors of each measured substancewith an LCI and resort to toluene equivalents only for substanceswithout LCI.

For release into soil and water a further harmonization of thelimit values for construction product evaluation would certainlyalso make it easier to communicate test results in a Europeanmanner. As the lists of substances to be declared are not quite aslong as in the release scenario indoor air it seems more easilypossible here to make a performance declaration for individualsubstances. So far experience is available especially for the leachingof inorganic substances from silica-based and bituminous con-struction products [21,38e40]. For testing and evaluating leachingof organic substances such as biocides from façade coatings andmecoprop or bisphenol-A from roof membranes conventions arenot yet fully established [41e43]. For organic substances also thetest methods for the analysis of eluates are yet to be harmonized[44]. For other substances than biocides it may often be more to thepoint and practical to look for the ecotoxic effects of the eluatesthan for the leaching of individual organic substances [45,46]. It isimportant that CEN/TC 351 completes its toolkit in this respect.Guidance is needed for combining the leaching tests with theexisting ecotoxicity tests and for deciding when to use the latter. Asimilar approach has been already developed for waste [47,48].

Not all construction products that may contribute significantlyto release of hazardous substances are covered by standardizationmandates. A large number of construction products have beenstandardized without a formal mandate and are not entitled to CEmarking. Newmandates to cover BRCW3 formally may be justified,if these product standards do not take the initiative to implementthe new horizontal test standards as a voluntary adaptation to thestate-of-the-art.

4.2. New legislative tools

So called delegated acts are foreseen as a new possibility for theEuropean Commission to make additions to the ConstructionProducts Regulation. This new procedure from the Lisbon Treaty[49] should make it easier to implement the CPR. In delegated actsthe Commission can for instance define the essential characteristicsof a construction product that a manufacturer always has to declarein his declaration of performance. The Commission may also laydown threshold levels or performance classes for essential char-acteristics on a high level of protection. In this way the credibility ofCE marking as a guarantee for compliance with legal minimumstandards can be improved.

If the European Commission does not lay down the essentialcharacteristics, the declaration of performance is drawn up ac-cording to a catalogue of essential characteristics in the area wherethe product is intended to be placed on the market. This option isinadequate for enhancing health and environmental protection:

O. Ilvonen / Building and Environment 69 (2013) 194e205204

the member states’ provisions take often only some, if any, healthand environmental aspects into account. Only if the Commissionreally does use the new competences delegated to it, will it bepossible to achieve a harmonized declaration of the health andenvironmental characteristics of construction products in the singlemarket.

Furthermore the CPR includes a significant improvement for theavailability of information on the use of substances of very highconcern in the context of CE marking. This is accompanied with anobligation to check whether the substance declaration should beextended in a while. From the user point of view the extendeddeclarationwouldbe a crucial help in certain situations. For examplein intended uses exposed to leaching priority hazardous substancesfor water policy (Annex II of the Environmental Quality StandardsDirective [50]) can be consequently avoided, if they are declared.Also, it is easier to design constructions, which can be recycled andre-used, if products with the status of hazardous waste after servicelife (according to the criteria of Annex III of the Waste FrameworkDirective [51]) can be installed for quick separation later on. Thiswould call for substances that render the treatment of a product ashazardous waste after its use phase to be declared.

4.3. Concluding remarks

Release of hazardous substances from construction products hasnot been addressed seriously in construction product standardi-zation in the past. Now all the tools for tackling the issue are or areabout to become available. There are no credible excuses left topostpone the new challenge any further. All construction productstandards should cover release of hazardous substances and deliverperformance data before another 10 years have gone. To achievethis not only the producers involved in standardization have to beambitious, but also the demand side e architects, constructors,purchasers and the do-it-yourselfers e has to learn to require thenew information and stop automatically accepting productswithout it. Certainly it will not be necessary to test all constructionproducts. Often approaches without testing can be well justified[52]. For a fair and transparentmarket the availability of data on therelease of hazardous substances should become a prerequisite.

Acknowledgements

I would like to thank Dr. Doris Kirchner and Dr. Johanna Wurbsfor their continuous support.

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