By Mike Speziale
Concerns regarding the difference between ‘testing’ and ‘listing’ (or ‘certifying’) continue to be discussed and debated across Canada. Both the National Building Code of Canada (NBC) and the various provincial and territorial codes mandate products meet test standards designed to provide specific levels of product quality and performance. This article attempts to highlight and clarify some of the misconceptions regarding product testing and listings, why listings are necessary, and how to avoid potential liabilities.
With the growing number of new buildings products that have entered the marketplace, it has become increasingly important to determine the consistency of product performance and quality. Therefore, in an effort to provide a monitoring mechanism that will ensure the product quality we require, the Standards Council of Canada (SCC) has approved numerous listing agencies that are deemed qualified to perform the required procedures to satisfy the existing standards.
The debate regarding this issue is whether a listed product offers a level of safety and performance over a tested and unlisted product. Therefore, we should examine the differences between products that are ‘tested’ versus ‘listed’ to uncover some of the important factors that may potentially compromise public safety and the objectives of the codes. Unfortunately, some manufacturers are claiming ‘tested’ is the same as ‘listed,’ despite knowing the two terms are not synonymous.
Manufacturers can test products in their own facilities or they can hire a laboratory to perform the work. Some labs are SCC-accredited, while others are not. There is nothing wrong with manufacturers performing their own testing or hiring a lab to do the testing, but either way it may not provide enough assurance the standard has been—and will continue to be—met. Continued compliance with the standard can only be attained through independent testing and listing, as detailed in the next section.
If a product is submitted for the purpose of ‘test only,’ the agency or manufacturer has the liberty to perform the procedure as directed by the client (i.e. manufacturer). In other words, it would not be strictly required to follow the specific testing procedure identified by the actual standard. On completing a test, the agency provides the client with documentation identifying the results; this documentation states the results are based on a test, but does not imply the product is ‘listed.’ In some cases, the manufacturer takes these test results and provides them to customers and regulators as ‘proof’ the product complies with the standard.
The problem is when a product is submitted for ‘test only,’ the results are based solely on the products or materials that have been tested for that report. They will not be subjected to any follow-up examination to determine subsequent material quality, performance, or consistency. This means there is no way of determining any changes in material consistency or product performance that may occur between the time of testing and that of production.
On occasion, manufacturers have distributed excerpts of ‘test’ documents several years old—unfortunately, some authorities have been led to believe the tested product was equal to that of a ‘listed’ product.
For example, the values obtained in an isolated flame and smoke test for a product is not indicative of the values that form part of a listing. The listed product undergoes ongoing examination by the listing agency, while the one-time test is just that. Recipients of test data should be aware the data may only be a snapshot in time and may not be a true or up to date reflection of the current product.
When a product is submitted to a testing agency with intent of receiving a ‘listing,’ the agency is then required to be much more diligent in determining the material characteristics and performance capabilities. To list a product or material, the agency would be compelled to follow the precise testing methods identified by the test standard. In doing so, the agency is required to monitor and record all the pertinent data throughout the testing program to determine the product’s compliance with the standard. This includes witnessing production and testing to ensure it is the same material.
Once the testing process has been completed, the agency provides the manufacturer with the results. If the product receives a positive result (i.e. it satisfies the requirements stipulated within the standard), it is then eligible to be listed. In the event the client elects to have its building product listed, it would then be subject to ongoing follow-up production and performance examinations determining the consistency of compliance.
By listing a product, the manufacturing facility, material compound, and product performance faces random testing by the listing agency. If any changes are identified when the testing takes place, it could result in product recalls and loss of the listing. Further, the companies that provide listings are SCC-accredited; they are required to maintain this status, and answer to the Standards Council of Canada if they fail to operate by the rules.
The cost of listing a product is substantially higher than that of testing due to the procedure; further, each time the agency visits the manufacturing facility to confirm the product stability, there are associated costs charged for the service. However, the cost is outweighed by the value of the listing, which ensures continued compliance to the standard and protection of those using the product.
When a third-party testing agency publishes a listing, the documentation indicates requirements for specific identification markings on the product—for example, the agency’s name and logo, along with the required test standard. Additionally, in most cases, it will require the product bear a summary of the test results (e.g. Flame Spread Rating and Smoke Classification or pressure and temperature ratings).
Undoubtedly, the issues explored within this article will require increased scrutiny on the part of inspectors—however, it will be for the betterment of public safety. Products tested to particular standards, and listed as such, have been proven to be safe to an ongoing requirement—there is value in third-party listing. (A list of accredited agencies can be found at www.scc.ca.) Design/construction professionals need to know exactly what they are specifying to ensure compliance.
Mike Speziale is a code specialist with IPEX Thermoplastic Piping Plumbing Systems. He has more than 30 years of experience in the industry, working with contractors, plumbers, inspectors, and engineers. In the mid 1980s, he helped introduce a polyvinyl chloride (PVC) drain, waste, and vent system that was the first ‘combustible’ piping capable of meeting the flame-spread rating required for ‘noncombustible’ construction. Speziale received a special recognition award from the Ontario Building Officials Association (OBOA) for his contributions to education, which include writing numerous articles. He can be reached at firstname.lastname@example.org.