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28 January 2021
We, at the FIA, have been in constant communication with the government over the last year voicing the concerns of the fire safety industry on the impact of implementing the new UKCA mark. Thus far, we have sent several letters to Governmental departments and have voiced our concerns at many meetings with the Government.
After the Government’s latest response, the FIA held our second Special Interest Group meeting to gauge the opinions and tap into the expertise from the fire and security industries. Through working with a variety of stakeholders we have identified areas where we can better represent our industry’s concern on the implementation of the UKCA to those that need to hear it.
Rest assured this is a priority of the FIA. It is vitally important that the Government understands the impact that changing to the UKCA regime will have not only for businesses from the fire industry whose task it is to keep buildings safe; but also, for the thousands of business owners that rely on their buildings being compliant so that they can remain open. Whilst we are lobbying to extend the transition period that our industry has been given, it must be noted that this might not be successful as such businesses should make plans for that instance.
In the meantime, it is important for end-users/consumers to know that the UKCA is not required until 1 January 2022 and until then CE marked products are still able to used in the fire industry. Products that are bought before 1 January 2022 will be not be required to be retrospectively marked as UKCA for more information see here.
Our work with Government:
Our primary concerns are that (full letter below - 1):
- it is clear the current implementation of the UKCA is estimated to cost our industry sectors in the region of £20m for product re-certification plus an estimated timeline of over 36 months to realistically carry out the process.
- dual product certification will cause major disruption to companies that make/sell products across the UK, EU and global markets, which, subject to any unknown divergence, will add significant costs to the process.
- This process does not add any value or quality to the product at a time when businesses are already stretched with Brexit and Covid-19.
As a result, we have requested on two occasions to the Government that (full letter below - 2):
- should a reciprocal agreement not be acceptable, the specified 12 months’ timeline be extended to a minimum of 36 months to allow sufficient time for manufacturers to prepare and apply the UKCA mark – this would also give test houses enough time to process these changes.
- exceptions should be made for fire and security products given that exceptions have already been granted for medical devices – both are focussed on life safety.
Prior to Christmas, we received a response where the Government has stressed that (see full letter below – 3):
- ‘we cannot indefinitely accept EU certification and CE marked goods on the market in Great Britain on a non-reciprocal basis beyond the end of the Transition Period on 31 December 2020’
- ‘we see no reason that UK conformity assessment bodies cannot start conformity assessment procedures for the UK market before the end of the Transition Period in their current capacity as notified bodies and conclude it once they have become a UK approved body’.
- ‘the UK has proposed a comprehensive Mutual Recognition Agreement for the acceptance of results of conformity assessment across sectors’ although ‘this is of course still subject to ongoing negotiations'.
In 2021, the FIA UKCA SIG has been busy voicing our continued concerns to the Government. We wrote a very detailed letter on how the UKCA is and will continue to negatively impact the overwhelming majority of our members and the fire industry (see letter full letter below - 4). Unfortunately despite speaking to the UK AB like the government recommended and despite including hard evidence from our surveys, the Government responded with a letter filled with copy and paste responses and concluded with a factually incorrect statement to end the letter (see full letter below - 5).
As a result, of this unsatisfactory, we have written to Lord Stephen Greenhalgh, the Fire Minister, to request that the Minister assist us in explaining to the correct Government individuals the current and future damage that the unachievable timeline for transitioning to the UKCA mark will have on the fire safety industry and potentially the safety of the public (see full letter below - 6).
Our work with approval bodies:
We met with the previous chair of the UK Approved Body association in January of 2021 to let him know of our survey that we would put to the approval bodies asking how they would act as a collective with the transition to the UKCA mark. They said that he would help reword questions and provide clear answers where possible. This fell through from their side due to unforeseen non-work-related issues.
In the same conversation, they said on the topic of the approval bodies mutually recognising and acceptance of testing and certification that for them, as a collective body, to officially agree to act as a collection of UK bodies it would take until September 2021 because they have to elect a new chair, meet, create the document and agree to it. This would leave our industry 3 months to know how the transition would really work and would not give our members the flexibility they need
As a result of the two points above, we began pursuing other alternatives. One of these alternative ideas that proposed was self-certification, but this was just an idea and it was decided our best course of action was to launch a survey to our members and to the industry and relay the results to the approval bodies who we met with on Friday 26th February.
The meeting went well and the results of the survey were acknowledged by the approval bodies.
In our latest meeting (26/02/21) with the majority of the relevant UK Approved Bodies (UK ABs), we asked key questions that were answered clearly and provided much-needed clarity on the UKCA mark alongside the processes required to affix the mark.
We hope that this document should serve as a summary of that meeting and we hope it can allow the fire industry to make more progress in being able to affix the UKCA marking. This document has been made in collaboration with a well-informed UK Approved Body that have tried to answer the questions that have been put forth by FIA members.
For any comments or questions please contact Adam Richardson, FIA Business Liaison on [email protected]
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