Caution! – BS EN 17235:2024 Permanent anchor devices and safety hooks
This long-awaited harmonised standard was finally approved on the 23rd May 2024 under the Construction Products Regulations and provides a pathway to successfully test and CE mark fall protection products that are installed permanently into structures.
Prior to 2010 permanently installed fall protection products were CE marked to EN 795 1997 Personal fall protection equipment — Anchor devices, harmonised under the PPE Directive 89/686/EEC. In April 2010 a test case took place to decide whether BS EN 795 Class A (eyebolts) products should or should not be classified as PPE. The decision of the court was that Class A products should not be PPE and that they should come within the scope of the Construction Products Directive 89/106/EEC.
In March 2011 a British Safety Industry Federation (BSIF) Test and Certification Association meeting took place at which the Dept of Business Innovation & Skill (BIS) was present.
At that meeting it was decided that:
Notified Bodies would no longer carry out CE marking assessment on new BS EN 795 products within classes A (eyebolts), C (flexible life lines), and D (rigid life lines)
Existing CE approval certificates for products within classes A, C and D would be maintained by the Notified Bodies, unless specific instructions were received from BIS to remove approvals.
Since 2010 reputable manufacturers of such products have continued to test their products to the requirements of EN 795 & CEN/TS 16415 Personal fall protection equipment — Anchor devices — Recommendations for anchor devices for use by more than one person simultaneously, as well as the Magenta Books 1 & 2 of the Advisory Committee for Roofsafety (ACR). Unlike EN 795 the magenta book required manufacturers to test their products in substrates that they subsequently approved their product to be installed into or onto.
In 2017 BSI produced BS 8610:2017 Personal fall protection equipment, Anchor systems — Specification, and this provided manufacturers in the UK with a standard that supported products being tested in range of substrates the manufacturer approved their product to be installed into or onto.
Although BS EN 17235:2024 has now been approved and theoretically manufacturers will have the ability to test and CE mark their product against this harmonised standard via a notified body, caution may be prudent at this time!
BS EN 17235:2024 has been approved with a recommendation for a three-year transition period. This will provide time for the notifiable bodies to apply and be approved to conduct such testing and issue certification. This transition period also gives manufacturers time to review their products and complete any required re-engineering in order to fulfil the new standards requirements.
One of the new standards requirements is to test to destruction or conduct static testing to a maximum of 27kN. Manufacturers would select a substrate and test seven different configurations dynamically (up to three times for a three-user system) and statically (up to three times for a three-user system). The final static test of each configuration would be to destruction in each case. The manufacturer would then take the worst performing configuration and subsequently test this configuration in further substates that they require a CE approval against this standard.
Although the above considers different substates, it appears to fall short to consider the different fixing method used in different substates, e.g. tech screws or rivets for metal deck roofs, clamps for standing seam roofs and toggles for flat roofs. It may be that on different substates different fixing methods may result in different product configurations performing differently, so extremely challenging to establish the configurations that performed worse.
Unlike the PPE Regulations the Construction Product Regulations require the product to be tested to destruction and this is a high-risk testing regime when considering loads of up to 27kN. There is a possibility that this safety concern may be used by a Member State to raise a “Formal Objection” to the new standard, and this would subsequently change the standards status to “non harmonised” which would remove the ability to CE mark any product against this standard. Hence there is a possibility we may still not have the ability to CE mark these permanently installed safety products. A “Formal Objection” can be issued by any Member State up until twelve months following the standards approval, hence up until 23rd May 2025.
The Construction Products Regulations require harmonised standards to be written about the product alone and do not include further information regarding the test procedure that will ensure repeatability between notifiable bodies. Hence in September 2024 a further meeting of the Working Group is expected to agree to write a non-harmonised part two of the new standard to include content such as:-
Information on anchor devices not permitted in EN 17235, e.g., rope access (Class AR),
Information for installation
Information for inspection
Information -on competency for installation
Information for user instructions
Design criteria/guidance –
Additional test information, e.g., test sample can be bigger, roof sample test rig could be framed.
Examples of product marking
Examples of evaluation (avoiding factors of safety on factors of safety)
The part two document is essential to provide the further guidance and information for both notified bodies and manufacturers. Once this is published and the initial twelve-month period, to raise a formal objection, has passed, manufacturers can then begin the process of possibly retesting their products over the remaining couple of years during the transition period.
Graham Willmott BSIF (HSG) Chair & BSI PH5 Committee Member
Tim Bissett BSI PH5 CEN/TC 128/SC9/WG1 Liaison