24 Jul “..modern manufacturing techniques…”
STUART keeps seeing references to any review of the FFR taking into account the use of modern manufacturing techniques. STUART thinks this first surfaced around 2014 in the ill-fated review edition and was used as the basis for the ‘NEED to CHANGE’ the test method.
The problem is that any evidence of the influence of so-called “modern manufacturing techniques” is more likely evidence of a profound lack of understanding of the existing test method and the principles upon which it is based.
First point: the FFR is based upon testing the main components i.e. the outer cover and the foam fillings and/or certain other types of filling materials. Any influence of changing selection of materials used in the final article is NOT TESTED.
Second point: Any data confirming such facts would have to come from whole item testing and be capable of comparing older methods and materials with so-called “modern materials” and the way they are used. THIS DOES NOT EXIST.
Third point: Any such changes will as a consequence have a definite effect on the severity of the test with the inevitable effect on the level of protection given by the required performance of the components.
FRETWORK did discuss this idea with BEIS officials after the 2016 review and did make the point, clearly represented in a wide range of responses to the 2016 review, that changing the test method could lead to using more or less flame retardants to achieve compliance and as such it failed to meet any of the criteria that had been set out (Greeness (sic), improved safety and etc.).
We are not opposed to changing the severity of the test but it should only be done with a full understanding of the implications for levels of protection. That in itself may not be a bad thing but the implications must but understood.
The effect of the EACOM pressure on the Regulators may only result in a further confused response and again show that the professionals in this business are not being listened to. We must hope that they are not putting pressure on the Minister Responsible to force through an ill-conceived change.