Engineers Sign-Off on Structural Insulated Panel (SIPs) Structure Imported from Lithuania

Glenntheman

I have a full SIPs design ready to be manufactured in Lithuania (EU) factory for supply and installation by the manufacturers own team in the Republic of Ireland.

My local Engineer has requested a ETA (European Testing Assessment) or similar from the manufacturer for the SIPs panels which the manufacturer does not hold/possess. ETA certificates are, according to the manufacturer, not required in Lithuania. The local Irish Engineer insists on this before he can provide sign-off on the as-built structure.

The Lithuanian manufacturer does however hold the required certificates for the materials that are used in the making of the panels (glue,OSB,Insulation).

Is there a solution or alternative work-around to this issue? Can the manufacturer provide his own Declaration of Performance (on manufacturers headed paper) that he meets the EN (European Standards) for his product?

Can I proceed with the build and seek local engineer sign-off after completion?

any guidance from anyone who has encountered this issue before on this subject would be most helpful.

muffler

As Lithuania is a member of the EU the manufacturer should have all the EU regulatory documents in place. Did you not research this before placing an order?

Glenntheman

Thanks Muffler.

The manufacturer claims it is not a “regulatory requirement” to provide these documents in Lithuania and is not obliged to carry ETA certs, CE Markings or equal. Therefore, is it actually a ‘mandatory and regulatory EU requirement’ elsewhere within the EU to have a ETA, CE Marking or equal? Or is it merely a ‘good practice’ testing regime by a manufacturer to allow them to better sell and stand by their products which in turn facilitates ease of local Engineer sign-off? If the component materials conform to EU standards and the project specific drawings and project specific calculations comply with Engineers review then why can the Local Engineer not sign off on that information?

I have only developed design with the manufacturer which I can utilise elsewhere but that’s an aside.

Thanks again for your input

muffler

All building products within the EU must bear a CE marking and comply with the Construction Products Regulation. Google the latter and you should find information on the EU standards requirement.

I can certainly see why your engineer is reluctant to sign off on something that he has no knowledge of, has most likely never dealt with before and a manufacturer that doesn't appear to be able to produce proper documentation. His insurance and reputation are on the line in this instance. Since 1990 (and updated in 2014 with BCAR) every building product and service has to comply with strict regulations and every individual and company/business have to accept responsibility for said products and services and produce the required documentation when requested.

I can only suggest you discuss this again with your engineer. Other people here might be able to add to the discussion.

Gumbo

Agrement Cert from NSAI possibly required as it’s a “system”.

Muffler is very much correct above. Have a read of Technical Guidance Document Part D.

sydthebeat

your lithuanian factory are incorrect to say the Construction products Regulation does not apply to them.

https://www.ssva.lt/cms/en/services/statybos-produktu-eksploataciniu-savybiu-pastovuma-vertinancios-paskirtosios-istaigos/pagrindiniai-statybos-produktu-tiekima-rinkai-reglamentuojantys-teises-aktai

lithuanian legislation in link above, look at section 2:

Declaration of performance

1. When a construction product is subject to a harmonized standard or when it complies with the European technical assessment that has been issued to it, the manufacturer, when placing such a product on the market, prepares a declaration of its performance.

2. When a construction product is subject to a harmonized standard or when it complies with the European technical assessment that has been issued to it, any form of information on its performance related to the essential characteristics of construction products, as defined in the applicable harmonized technical specification, may only be provided if it is included or specified in the declaration of performance, except for cases where the declaration of performance was not prepared in accordance with Article 5.

3. When preparing the declaration of operational properties, the manufacturer assumes responsibility for ensuring that the properties of the construction product correspond to such declared operational properties. In the absence of objective evidence that these conditions are not met, Member States shall presume that the manufacturer's declaration of performance is accurate and reliable.

SIP construction is subject to ETA as it is a system build, including and not limited to, european standards such as:

EN 1995-1-1, EN 1990,

EN 1991

EN 14081-1

EN 15497

EN 336

EN 13501-1

plus loads others

Glenntheman

excellent comments from Muffler and Gumbo above. I do agree with these comments as I am very keen that compliance to EU products regulation (hence this post) are adhered to and the provision of an ETA and Declaration of Performance certainly allow the Local Engineer in Ireland to certify/sign-off with ease/confidence.

However, I believe sysdthebeat has raised a very good piece of relevant legislation in Article 4 of the Lithuanian Legislation around ETA and Declaration of Performance (Article 4 as shown above). It is also interesting when Article 5 is read in conjunction with Article 4 (see below extract thanks to systhebeats link).

So in my case (as mentioned in my opener) my Lithuanian manufacturer is also the on-site constructor/erector using his own approved design Engineer. Therefore, 5(a) can be seen to apply. This is given that the “custom made” nature of the build and “non-series” (no one panel being the same - mostly), is in response to a “specific order” and is installed in a single identified construction work” by a manufacturer who is “responsible for the safe incorporation into the construction work” etc, etc.

Interested to know if this changes any opinions so far?

it would also be beneficial if the manufacturer could be convinced to declare under a Declaration of Performance his adherence to the EN harmonised standards on company headed paper. Can I be compliant given the below Article 5(a) in addition to self DoP declaration by the manufacturer to the EN standards and a relaxation / acceptance by local Engineer?

Thanks guys

muffler

The first 3 lines in Article 5 above are important particularly the wording in line 1 where it states "in the absence of". In a nutshell if the country in question or the EU don't have specific regulations in force then the manufacturer can ease up. But there are regs in force so that's a non runner. That's my take on it.

Glenntheman

Valid point Muffler. So, given these specific ENs for SIPs apply within the Union, then the manufacturer could prepare his own Declaration of Performance to those ENs as applicable to his “custom” kit one-off house product without specific ETAs being in place. However, only if a local Engineer would accept this declaration…..assume you might say…. ‘unlikely’.

mrbrianj

If a local Engineer was inclined to accept the responsibility in the absence of DOPs /ETAs their insurance wont. It would be simply too much risk and too much hassle for them to undertake.