GNB-CPD

SG04 Guidance from the Group of Notified Bodies

for the Construction Products Directive 89/106/EEC

NB-CPD/SG04/10/075 Issued: 17 February 2010

APPROVED – GUIDANCE

GNB-CPD position paper from SG04 - EN 12899-1:2007 Fixed, vertical road traffic signs — Fixed signs

General scope, limitations and aim of this guidance for Notified Bodies (NBs)

This position paper contains guidance for Notified Bodies (NBs) involved in the attestation of conformity of Fixed vertical traffic signs according to EN 12899-1:2007. The purpose is to help NBs work equivalently and come to common judgments. This guidance contains informative material (which NBs should or may follow) and normative guidance (which NBs shall follow or at least work equivalently to as circumstances demand).

This guidance is thought necessary to provide clarity and completeness for NBs so that they can work equivalently. It supplements and makes practical for NBs the harmonized standards EN 12899-1:2007, approved AG guidance, and Standing Committee guidance in the form of GPs, which also apply - unless otherwise explicitly stated in this guidance. This position paper should not contradict nor extend the scope of the work and role of a NB, nor impose additional burdens on the manufacturer, beyond those laid down in the CPD and EN 12899-1:2007.

This guidance should be considered valid until the relevant standards are amended to include the guidance (as thought fit by the CEN/TC); or until guidance from Commission, SCC, and AG has changed on relevant matters. Whereupon, the paper should be considered for withdrawal/revision and be replaced by new guidance as necessary.

This position paper was considered approved by SG04 on 30 September 2009 and by Advisory Group (AG) on 16 January 2010.

1 Initial inspection of factory and of factory production control

1.1 General

The applicant for CE marking shall be the organization placing the product on the market. During the initial assessment of the factory all units, lines and departments covered by a single FPC, shall be inspected individually. This shall include those outsourced or operated by subcontractors unless their FPC is certified by a Notified Body for the scope of the work being undertaken.

If the applicant does not manufacture the product, initial inspection of the factory and initial assessment of the FPC shall be executed in the producing plant (see NB-CPD/AG/07/008 “GNB-CPD AG position paper - Guidance to NBs on their duties in certifying (system 1+, 1, 2+ and 2) own brand labelled products and those involving significant subcontract manufacturing”.

The initial inspection of the factory and initial assessment of the FPC shall include the plants operated by any subcontract component supplier, etc, unless the manufacturer has a sampling

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procedure to check the key characteristics of these incoming components (e.g. tubes, clamps, substrates). The manufacturing of raw material is not within the scope of the certification.

The contractual relationship between the manufacturer and subcontractor shall be examined to ensure that the obligations to inform the NB of changes in FPC, factory equipment etc are safeguarded at all times.

1.2 Manufacturing process documentation

The NB shall check that the manufacturing process is fully documented by the producer. Manufacturers are required to have a written FPC that meets the requirements of the CPD and the harmonized part of EN 12899-1:2007. Much of this work may also be used to meet the documentation requirements of other QM-Systems e.g. ISO 9000.

1.3 Assessment of the production facilities

The initial inspection shall check that the factory has the necessary process equipment to achieve conformity of products (see annex checklist).

1.4 List of suppliers

The producer shall provide a list of those suppliers, who supply the following materials and/or parts of the product:

Sheetings producer: beads granulate adhesive pigments

Supports producer: tubes pipes sheets

Sign producer: substrate material sign face material ink for screen printing clamps

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1.5 Responsibility for product parts

Product parts Steel tubes steel tubes are considered as raw material

supplier confirms material grade support producer evaluates raw material (material grade, dimensions) ITT of the characteristics of Annex ZA of the harmonized standard: supports, posts executed by support producer

Sign substrate sign substrates are considered as raw material supplier confirms material grade sign producer evaluates raw material (material grade, dimensions) ITT of the characteristics of Annex ZA of the harmonized standard: signs, executed by sign producer

Ink for screen printing process

ink is considered as raw material supplier declares material grade (identification code) sign producer evaluates raw material (material grade, identification code) ITT of the characteristics of Annex ZA of the harmonized standard: signs, executed by sign producer

Clamps clamps are considered as components supplier confirms material grade sign producer evaluates material grade, dimensions ITT of the characteristics of Annex ZA of the harmonized standard: signs, executed by sign producer

Profiles sign substrates are considered as raw material supplier confirms material grade sign producer evaluates raw material (material grade, dimensions) ITT of the characteristics of Annex ZA of the harmonized standard: signs, executed by sign producer

Sign face1) sign faces are considered as a component supplier is normally responsible for ITT and FPC supplier provides sign producer with the relevant test results

Light sources, electrical equipment External lighting units

supplied products shall be in compliance with Low Voltage and/or EMC Directives whatever is relevant sign producer evaluates supplied components sign producer is responsible for ITT / FPC related to the complete assembly

Retroreflective sheetings

this part of a sign assembly is within the scope of EN 12899-1:2007, hence the original sheeting producer is responsible

1) The semi-finished or finished surface affixed to the substrate

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1.6 Assessment of factory production control (FPC)

1.6.1 Laboratory

The testing facilities shall be included in the assessment. The capability of the laboratory shall be demonstrated to the Notified Body by one of the following procedures:

• direct check of the performance of the producer's own laboratory within the scope of the FPC;

• accreditation of the laboratory under ISO/IEC 17025 or equivalent accreditation; the accreditation shall be specific for the tests carried out;

• assessment of an external laboratory by the Notified Body.

1.6.2 Test equipment

The following test equipment must be available and in a proper condition, although the manufacturer need not own the equipment. Calibration shall be documented if applicable. If the test equipment is owned by other organizations, the calibration process shall be verified:

Sheeting producer The sheeting producer shall be able to test chromaticity coordinates, luminance factors, coefficient of retroreflection and durability.

Post and support producer The post and support producer shall be able to test stability and durability.

Sign producer The sign producer shall be able to test chromaticity coordinates, luminance factors, coefficient of retroreflection, stability and durability.

1.6.3 Test plan

Frequency of testing shall be in accordance with EN 12899-4.

NOTE: If the batch cannot be defined in the terms of the definition within EN 12899-4, the samples tested should equate to at least 0,5% of the annual production. Testing should be evenly distributed throughout the production year. Test samples shall be representative of all product types and colours.

2 Initial type testing

The notified body is responsible for all tests according to EN 12899-5 and evaluates them. Tests shall be recorded.

A cascaded ITT shall be acceptable for all sign face constructions. For screenprinted sign faces, the ITT shall be completed by tests to verify the capability of producer to use this type of production process. For each class of retroreflective sheeting and each colour used by the producer for screenprinting (relevant colours are normally chosen according to local specifications), visibility characteristics and durability shall be tested. If the supplier of retroreflective sheetings provides the producer of screen printed sign faces with test results of his own ITT, and the producer follows the

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supplier’s rules for the screen printing process, the number of angle combinations to be tested in the ITT of the producer may be reduced to the angle combination given by EN 12899-1:2007 §4.1.1.5.1 (test range after weathering). Durability is not tested at ITT in that case but later at FPC.

If a digital printing technology is used, the cascaded ITT of the producer shall include testing of the visibility characteristics equivalent to the requirements for testing screenprinting, in compliance with the instruction manuals of the sheeting manufacturer. The ITT of the sheeting manufacturer shall be available.

Certificates including products with retroreflective material with ITT based on accelerated artificial weathering tests shall be valid for only 4 years. In the meantime accelerated natural weathering tests shall be executed for 3 years. The results replace the results of the accelerated artificial weathering tests. The validity of that certificate shall be undated, in accordance with Commission Guidance Paper ‘D’ §5.10.

The temperature measurement during accelerated artificial weathering (EN 12899-1:2007 §4.1.1.5.3) shall correspond to EN ISO 4892-2 and EN ISO 4892-1. Either a black-standard or a black-panel thermometer can be used subject to the thermal conductivity of the substrate of test samples as described in EN ISO 4892-1. The thermometer used shall be stated in the test report. (CEN/TC 226 WG3 decided to abandon the requirement to use only the black-standard thermometer.)

Testing of impact resistance (EN 12899-1:2007 §4.1.2): This test only needs to be done once for each different substrate.

NOTE: This test is considered by the sector group as giving only information on cracking of the substrate and is not appropriate for testing delamination of retroreflective sheeting. CEN/TC 226 WG3 will be asked to define a new testing method for delamination of retroreflective sheeting.

3 Continuous surveillance

The effectiveness of the FPC shall be assessed and approved by the notified body at least once a year. If the product or the manufacturing process has been modified, the Notified Body shall decide the actions to be taken to demonstrate that the products maintain conformity. The validity of the ITT may need to be reassessed.

The producer shall demonstrate final testing that is part of the FPC process to the notified body.

Although the retroreflective sheeting producer is responsible for executing the natural weathering test on his products, the converter of retroreflective sheetings who uses the screenprinting process is responsible for executing the natural weathering test for screen printed sign faces concerning visibility and durability requirements according to EN 12899-4 Factory production control. The converter may contract a test house to execute this test, if he himself has no opportunity to do it.

Continuous surveillance shall cover all production units within the FPC, whether operated by the organization placing the product on the market or another organization. This does not include units where the FPC is certified independently by a NB, or units making parts that are subject to a sampling procedure as incoming components. The criteria for inclusion of plants within continuous surveillance are the same as those set out for the initial assessment of the factory and FPC in §1.1 of this document.

If an organization has multiple sites producing the same product and covered by a single FPC, it is not necessary to inspect all sites each year. However, the operation of the FPC in every unit, line

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and department covered by a single FPC shall be included in a surveillance visit at least once every three years.

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Annex A (informative)

Factory inspection document

Producer:

Application for certification according to the Construction Product Directive and the requirements for CE marking products according to EN 12899-1:2007.

Date of initial inspection:

Representative of the producer:

Factory address:

Result of the initial inspection:

The producer

• is able to manufacture signs consistently yes no

• is able to screen print yes no

• is able to manufacture laminated signs yes no

• is able to prepare screen printing by manufacturing films and screens yes no

• is able to manufacture mounting devices yes no

• employs the necessary qualified employees and workers yes no

Name of representative for quality assurance:

Remarks:

date and place representative of NB representative of producer

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Form - Record of initial inspection

1. Range of production

Part of product Type Class 1 Glass beads technology Class 2 Glass beads technology Class 2 microprismatic Class 3 microprismatic

Sheeting

Transilluminated

Part of product Type Steel Aluminium Timber Posts

Post and supports materials

Supports

Part of product Type Standard shape signs Directional signs Transilluminated signs External illuminated signs Sign face Posts and supports Sign plates

Aluminium Plastics Steel Wood

Substrate materials

Painting Plotted sheeting Screen printing

Symbols and lettering materials

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2. Plant equipment

Division Part of Production Equipment, process

Maker

Sheeting Cutting devices for rolls and sheetings Glass beads Stock (air

conditioned) Liner

Sheeting production process

Division Part of Production Equipment, process

Substrate sheet production Cutting device

Bended frame Profile reinforced frame Riveting Pin riveting Pressed connection Welded connection Knurling connection

Reinforcing of substrate

Edging Substrate treatment

Substrate production process

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Division Process step Equipment Rolls Sheets Stock Air controlled

Hand applicator Roll applicator Application Applicator with take off roller

Die cutting Plotting Symbols and

lettering Printing

Printing By manual device Semiautomatic Three quarter automatic Pass through drying device Air drying with ventilation Compartment drier Oven drier

Sign face production process

Division Process step Equipment Posts manufacturing

Steel frame manufacturing

Mounting devices for directional signs

Clamps

Mounting device manufacturing

Division General Equipment Standard shape signs

Stock

Directional signs

Specifications EN 12899-1, -4, -5 EN ISO 1461 Quality assurance ISO 877