Exchange of PPE conformity assessment experiences
SeminarsATS representatives and a German Expert (Karl-Heinz Noetel) attended a meeting at the ATS premises in the period between 3rd and 4th December 2015 as part of the activities of the PTB bilateral project entitled “Support of the Quality Infrastructure in Serbia”.
The purpose of this meeting was to exchange information and experiences in the PPE conformity assessment (as ATS permanent employees and external experts participated therein) arising from the existing ATS’s experience in this sector with a special emphasis on:
- Detailed information regarding the new EU PPE legislation and situation in the PPE sector (as the new PPE Regulation will be passed by the EU Parliament on 19th of January 2016 it was essential to highlight the possible changes regarding PPE Directive 89/686/EEC)
- Conformity assessment procedure (type examination (Article 11) and type conformity assessment (Articles 12 and 13 of the PPE Regulation, Official Gazette of the RS, No 100/11) or B, C, C2 & D modules as quality conformity assessment procedures will change)
- Coordination of Notified Bodies in the PPE sector (work of the European Coordination of Notified Bodies for Personal Protective Equipment and its organs - Horizontal Committee and Vertical Groups, Recommendation for Use) – additional information can be found at: www.nbcoordinationppe.eu/home
- Questions on daily work of ATS regarding the accreditation procedure.
The said issues were discussed as it was necessary to:
- harmonise interpretation of the provisions in the Directive/Regulation
- discuss differences in the working procedures for notified bodies
- ensure uniform certification procedures
- ensure comparability of test results.
The European Commission signed a contract with the European Coordination of Notified Bodies for Personal Protective Equipment in order to form a platform for discussion on a horizontal (general) as well as vertical (PPE-specific) level, and offer advice to all parties involved. It consists of a Horizontal Committee, an Ad Hoc Group and Vertical Groups. Solutions are proposed on technical issues and recommended for use by all notified bodies in the form of “Recommendations for Use”.
The Horizontal Committee consists of representatives of all notified bodies in the area of PPE, Vertical Groups, national coordination groups, representatives of the candidate countries, observers/guests from DG Enterprise and DG Social Affairs‘ of the European Commission, PPE Expert Group, the EFTA Secretariat, CEN/CENELEC and manufacturers‘ associations. The Horizontal Committee has a task to report on all questions of a horizontal nature relating to the information on current developments that affect the work of the notified bodies (new legislative framework, new Directives, etc.) and on the interpretation of conformity assessment in accordance with the PPE Directive.
Members of the Vertical Groups are Notified bodies / testing laboratories in the relevant PPE field, and sometimes representatives of manufacturers. Their task is to discuss application of standards, conformity assessment procedures when there are no harmonised standards, Round Robin tests to verify test methods.
The Vertical Groups are as follows:
VG 1 Head Protection
VG 2 Respiratory Protection
VG 3 Eye and Face Protection
VG 4 Hearing Protection
VG 5 Protective Clothing, Hand and Arm Protection
VG 6 Cancelled
VG 7 Protective Clothing against Hand-held Chain Saws
VG 8 Lifejackets
VG 9 Protective Clothing for Motorcycle Riders
VG 10 Foot and Leg Protection
VG 11 Protection against Falls from Height
The abovementioned shows that the EU Coordination of Notified Bodies in the field of PPE is essential as the results thereof are necessary for the work of the parties involved in the conformity assessment process.
As the participation in the EU Coordination of Notified Bodies in the field of PPE is restricted to Notified Bodies and specific EU stakeholders the following should be taken into consideration:
• participation of the Serbian CABs in the Horizontal Committee is not yet possible
• participation of the Serbian CABs in the Vertical Groups could be possible if the Convener of the specific Vertical Group is contacted to approve of the said participation.
It is necessary to emphasise that the valid PPE Directive 89/686/EEC will be repealed and replaced by the PPE Regulation, whereas the changes will relate to the following:
- Specific transitional provisions for products manufactured and certificates issued under the PPE Directive 89/686/EEC
- Transitional period for the PPE Regulation will be two years from the entry into force of this Regulation
- provisions on Notified Bodies shall apply six months after the entry into force of the PPE Regulation.