02 May NEWSLETTER No. 40 – 2nd May 2018
NEWSLETTER No. 40 – 2nd May 2018
Amongst the topics in this issue:
FIRA Meeting. PAS 7100.
FFR review update. FIRA Compliance Scheme.
The role of Trading Standards Organisations Consumer Safety
Co-ordinated Primary Authority Scheme FRETWORK Code Of Good Practice
FRETWORK initiative on CTR
There is one single issue that is emerging rather than being announced and much of the background reasons for highlighting it come from small things that have simply been noticed along the way. I hope to join these together in this Newsletter. Much by way of confirmation emerged during the FIRA meeting. I believe that a fundamental and significant shift in Consumer safety in the UK has taken place but without one single announcement or initiative appearing to define it. For instance, the policing of the Furniture Flammability Regulations (FFR) by Trading Standards Officers (TSO’s) will not necessarily change but the way things are done will drastically change. I’ll try my best to explain……..
Some of us were able to join a FIRA meeting in Long Eaton on 18th April titled as an ‘Upholstery Compliance and Flammability Session’. It set out the new FIRA scheme, described as being for: “Manufacturers, Upholsterers, Suppliers and Retailers”. The scheme offers an audited route to proving compliance to the regulatory requirements of the FFR. FIRA put the meeting into the context of explaining ‘obligations to due diligence’ and it is clear that things are going to change.
FIRA had invited representatives of the Trading Standards Officers community to join the meeting and it was extremely interesting to hear them discuss recall schemes and their degree of success in this context.
During the FIRA Compliance meeting Phil Reynolds of FIRA gave an brief update on his recent dealings with BEIS on the subject of the FFR Review. It was brief because there isn’t much to say. No actions are to be anticipated by BEIS on the FFR Review. However, it may be perhaps said that first they were there, then they weren’t and then they reappeared as:
Office for Product Safety and Standards (OPSS).
Most of the persons from BEIS are in the new department except those who were only there to deal with the response to the last set of review proposals. The new department is to implement the (NEW) policy on consumer product safety. There is a history of report and recommendation and subsequent actions if you are interested.
You could start here:
The main thrust of the new approach is the issue of product recall and that is described in PAS 7100.
The FIRA meeting was to some extent framed within the context of PAS 7100, more properly titled:
“PAS 7100: 2018
Consumer product safety related recalls and other corrective actions:
Part I Code of practice for business Part II Guidance for regulators”
This first appeared in draft form last year and a consultation process has taken place, followed shortly by a “launch”.
It costs £45 from the BSI and can be found at:
During the compliance meeting the problems of policing the FFR were mentioned. There have been criticisms of problems with funding, consistent application of the regulations and funding of their actions. Part of the story of the meeting is that FIRA have set up a Coordinated Primary Authority Scheme with Hertfordshire Trading Standards as part of their Compliance scheme.
Coordinated Primary Authority
This is a variation on the traditional Primary Authority agreement that is based on legal partnerships between a business and individual local or “home” authority. It means that a particular group of companies can be part of a Regulated Group that comprises the Manufacturers, Upholsterers, Suppliers and Retailers who have joined the FIRA Compliance Scheme.
The Regulated Group.
This will be the members of the FIRA scheme who must be audited by FIRA and can receive advice from a single nominated Primary Authority.
The compliance scheme puts great emphasis on the subject of traceability. The FRETWORK group involved with our Code of Good Practice (FCOGP) are well aware of this issue and perhaps the FIRA meeting did not do enough to make clear that marrying your traceability scheme to your suppliers and persuading your customers to do the same will be crucial if the supply chain is to respond to the requirements of PAS 7100 recalls. Traceability is now a very real and serious requirement.
This is clearly the main aim of the PAS 7100 approach and TSO’s present spoke of success rates in making recall actions. In other words if you need to make a recall, then achieving high rates of effectivity is how you will be judged. Efficiency in making recalls will be based on traceability and this leads to the other side of the need for traceability – being able to identify and isolate “contaminated goods” (my expression). The role of the TSO’s will not significantly change with the new approach to Consumer safety but the process of managing product safety and putting pressure on manufacturers to make it a (much) more serious issue will be important.
This almost seemed to be the elephant in the room at the meeting but there were TSO’s present. Traceability will be a company’s key to managing a recall – and it won’t necessarily be your recall – as a kind of damage limitation. There is a big difference between having all of your production put into question and isolating a smaller percentage that is “contaminated”. To repeat it (again) traceability will be more important.
FRETWORK Code of Good Practice scheme (FCOGP).
Overall it is clear that establishing the FCOGP in the new circumstances was a “good idea”. The scheme remains open to other processors. We are continuing to work on addressing issues such as chemical choice in treatments and bringing the formulators into the scheme will similarly be important.
The FCOGP was established after the Fake Britain Upholstery programme and those who have signed up and been audited so far are pleased with the results and what it means to them. The problems that we, as a group, could see during the development of the scheme are now made concrete in the new Consumer Safety scenario.
The FRETWORK Code of Good Practice scheme remains open to all who can recognise its potential and (today) its relevance. You can find details at:
Contact FRETWORK through the contact us link and we will be pleased to discuss your company’ position in relation to our scheme.
The new regime for product safety has the potential to significantly raise the stakes for the supply chain.
Due diligence will change.
Traceability will become essential to protect your company’s interests.
The new regime may provide new context for the FFR and the potential for industry taking responsibility with industry-led schemes to bring transparency to the supply chain gives added impetus to the review process.
As almost a side issue to the whole scenario there is a problem in the supply chain and, in believing that identifying it and giving it a name will be part of the process to addressing the issue.
I have called it “CTR”.
CTR stands for Conflicting Test Results. Most people involved in the supply chain will have met it at some time. It describes the situation where due diligence testing may lead to what should be the same piece or batch of fabric receiving different test results on what in some cases can be described as ‘the next metre’. There are a varying range of circumstances involved and at present these are generally dealt with as individual events and commercial means are used to resolve issues. The situation is not helped when influential figures describe the CTR’s as BOTH being correct – which commercially is not acceptable.
FRETWORK has started the process of setting up a database of these events where any and all background detail is collected and collated into an anonymous tables of results. The circumstances of the particular fabric are set into the context of all data relating to processing and performance are collected and that includes fabrics processed at the same time. It is important to note that we are not basing this on poor processing which will be identified and referred back to the FCOGP requirements but to problems that arise in the context of the often repeated question: “will it pass” to which the reply is always “It should”. SHOULD has become an overworked word in these circumstances and we will do our best to shine some light on these events.
Please contact us if you have experience or examples and more particularly if you want to take part in this project.
Web site changes.
This Newsletter will appear in the News section of the web site but you should also check out the new section titled FORUM. This will replace the Definitions as it is clear we have a greater role to play in raising awareness of issues rather than producing a Lexicon of facts about textiles. I hope you like it and keep checking it out.
Wednesday 2ndMay 2018