NB-CPR 15-639r1 Sampling in Systems 1 and 1+ PDF

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GNB-CPR

AG

Co-ordination of the Group of Notified Bodies


for the Construction Products Regulation
(EU) 305/2011

NB-CPR/15/639r1
Issued 07 April 2015

Approved Guidance

POSITION PAPER: Sampling in AVCP systems 1 and 1+


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FOREWORD
When the assessment and verification of constancy of performance is done by means of
testing, sampling is an activity of utmost importance for the credibility of the assessment and
verification.
The sampling is considered the only link between the testing and the continuous production of
the construction product.
Whereas the test results form basis for the assessment of performance of the construction
product, the sampling information forms an important part of the basis for the continuing
verification of constancy of performance performed by the notified product certification body.
The sampling procedure is expected to ensure that the samples originate from the
manufacturing plant for which the manufacturer holds or applies for a certificate of constancy
of performance and that the samples are suitable to represent the on-going production1.
To ensure that the samples are suitable to represent the on-going production, the sampling
procedure shall provide sufficient documentation regarding the origin of the samples and
regarding any basic property and any stage of production process with a potential to influence
the performance of the product.
Which basic properties and which stages of the production process that may have potential to
influence the performance will very much depend on as well the type of construction product
as the performance characteristics to assess.
Without a properly conducted and properly documented sampling procedure, the testing and
the test report cannot be linked to the continuously manufactured construction product and will
not allow for the verification of constancy of performance of the continuously manufactured
construction product.
The importance of the sampling is underlined by the fact that CPR Annex V explicitly includes
sampling in the work of the notified product certification body under AVCP systems 1 and 1+.
CPR Annex V assigns the task of sampling to the notified bodies in the below cases:
-

Sampling for testing as basis for assessment of performance of the construction product
(both AVCP systems 1 and 1+)

Sampling for audit-testing (only AVCP system 1+).

This does not exclude the application of appropriate technical documentation in accordance with CPR Article 36.

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SCOPE
This paper aims at giving general horizontal guidance to notified bodies regarding how to
conduct and document sampling for testing under AVCP systems 1 and 1+.
Harmonised standards may include specific rules or circumstances to take into account for
specific products. Such provisions shall always be respected and may prevail in case of
conflicts with this guidance.
This horizontal guidance may also be supplemented by specific GNB guidance for specific
products, product families, and/or for specific performance characteristics. Such specific GNB
guidance may include information regarding which basic properties and which stages of the
production process that may have potential to influence the performance of the construction
product.
In this paper, distinction is made between selection and sampling (see Terminology).
Selection is not covered by this paper.
Neither does this paper cover situations where the notified product certification body is
requested to let testing (including sampling) already conducted by another body form basis for
a certificate of constancy of performance.

REFERENCE STANDARD
EN ISO/IEC 17065 should be the preferred accreditation standard2 for notified product
certification bodies under AVCP systems 1 and 1+ once EN 45011 is superseded.
In EN ISO/IEC 17065, sampling is considered an evaluation task (see note of clause 7.4.3).
Particular attention is drawn to the below clauses:
7.4.1 Plan for the evaluation activities
7.4.2 Assignment of personnel
7.4.3 Availability of information
To meet the requirements of EN ISO/IEC 17065, the notified product certification body needs
to have documented procedures in place covering for example the conduct of sampling
activities (including reporting) and the qualification of personnel conducting sampling.
If sampling activities are subcontracted, a documented procedure for the subcontracting must
be in place.

Other accreditation standards, such as ISO 17020 (inspection) and EN ISO/IEC 17021 (management system
certification) can be used as evidence of compliance with requirements of CPR Article 43 in order to be
designated as a notified product certification body. Irrespective of which standard a notified product certification
body is accredited against, the notified product certification body shall also comply with the relevant parts of EN
45011 / ISO 17065

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TERMINOLOGY

4.1

Selection
Selection is understood as the selection of the part of a product group from which samples
shall be drawn for the purpose of covering the entire group of products.
The purpose of the selection is to ensure that the selected part of the product group is suitable
to represent the product (to be) placed on the market. Normally, a worst-case approach is
applied for the selection.

4.2

Sampling
Sampling is understood as the taking of samples from the selected part of the product group.
Sampling is normally done by random within the selected part of the product group (see 4.1).

TRACEABILITY
The sample shall be traceable back to its origin(s) in the production, and to records of tests
and inspections during the production process.

5.1

Records of test and inspections during manufacture


The notified product certification body shall verify that records of tests and inspections are
available and that all relevant product and process parameters are in conformity with the
requirements of the harmonised technical specification and the documented FPC system
operated by the manufacturer3.

SAMPLING LOCATION
Some harmonised specifications have provisions regarding the age of samples, sampling
locations etc. Such provisions shall always be respected.

6.1

Sampling for assessment of performance


When testing for the purpose of assessment of performance, CPR Annex V does not require
the sampling to be done at any particular location.
Normally, for the purpose of ensuring the traceability (see clause 5) sampling is done at the
manufacturing plant.

This verification may be done in connection with an inspection of the manufacturing plant and the factory
production control; not necessarily in connection with the sampling.

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The notified body may decide to conduct the sampling at other locations only if it can justify
that the traceability is not put at risk4.

6.2

Sampling for audit testing


For audit testing, CPR Annex V explicitly requires that the samples shall be taken by the
notified product certification body at the manufacturing plant or at the manufacturers storage
facilities.

6.3

Non-conforming products
Products marked by the manufacturer as non-conforming shall not be subject to sampling
unless it is specifically justified and with the agreement of the manufacturer.

6.4

Sampling directly from the production


With the agreement of the manufacturer, the notified product certification body may choose to
sample directly from the production unit/line and not from the storage facilities. This is an
option for as well assessment of performance testing as audit testing.
To sample directly from the production will often be advantageous:
-

Less burdens for the manufacturer as it will not require any opening of larger sales units.

Possibility to witness the production and thereby obtain detailed and secure real-time
information about the production process.

No doubt possible about the origin of the samples.

Notified product certification bodies should however be aware that sampling directly from the
production will only allow for sampling of products from a very limited time span.

6.5

Sampling from the manufacturers storage facilities


The most common sampling location is the warehouse of the manufacturer. When sampling
from stock, the notified product certification body shall consider if the amount of material
available is sufficient to allow for sampling by random.
The notified product certification body shall verify the origin of any sample with regard to
production unit/line and time of production. The manufacturers traceability system may be
used for that verification.

Notified product certification bodies should be aware that they have the full responsibility for ensuring the
traceability of the samples back to their origin.

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6.6

Sampling at other locations


When sampling from other locations than the manufacturing plant or the warehouse/storage
facilities of the manufacturer, the notified product certification body shall pay particular
attention to the verification of the origin of the samples and to the traceability to records of
tests and inspections.
For the purpose of audit testing, sampling from other locations than the manufacturing plant or
the manufacturers storage facilities is not allowed.

MARKING OF SAMPLES
All samples to be used for testing purposes need to be suitably marked to allow a subsequent
verification of the identity of samples.
The marking shall be indelible. In particular, if the notified product certification body itself is not
taking care of the transportation, appropriate measures shall be taken to avoid that the
markings are moved to a different sample.
The marking of the samples shall normally at least comprise the below information:
-

A unique sampling code or number of the sample

Date of the sampling

Signature or initials of the representative of the notified product certification body


conducting the sampling.

NOTE: For the purpose of verification of the identity of the sample, it may be helpful to take a
photo of the sample after marking. Notified bodies should be aware that many manufacturers
have strict rules on the use of cameras at their premises.

SAMPLING SHEET
A sampling sheet shall be filled out during the sampling and shall at least include the following
information:

Manufacturer and manufacturing plant

Place of sampling

Traceability information, e.g. date/time of production, production unit, batch number, shift.

Number or quantity of the samples

Marking of the product by the manufacturer

Marking of the samples by the notified body (see clause 7)

Place and date of the sampling

Signature of the representative of the notified body

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Counter signature of the representative of the manufacturer

It may be also be relevant to include the below information:

stock or batch quantity from which the samples have been taken

Results of tests and/or inspections during manufacture

Essential characteristics to be tested

Photos of the samples taken after marking

SHIPMENT OF SAMPLES
Appropriate measures shall be taken to ensure that the samples are not deteriorated or
changed during the transportation from the sampling location to the laboratory.
The notified product certification body itself may take care of the transportation and thereby
make sure that the samples remain unchanged. Normally, this would only be possible for
samples with a limited physical size or over limited distances.
If shipment of the samples is done by the manufacturer, a clear agreement should be made
with the manufacturer on the below:

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Address of the laboratory (or other agreed location) to which the samples shall be sent

Time frame for the shipment

TEST REQUISITION
The notified product certification body shall draw up a written requisition for testing5.
The test requisition presumes that the laboratory is assessed by the notified product
certification body as meeting the requirements of CPR Article 43 and that a written agreement
subcontracting agreement has been made.
Moreover, it is presumed that the notified product certification body assumes full responsibility
for the testing and that the agreement of the manufacturer is obtained.
The requisition shall be sent to the laboratory and shall at least include the below:
- A request to verify that the samples received by the laboratory correspond to the
information in the sampling report, in particular with regard to the marking of the sample
(see clause 7), signature of the person who conducted the sampling, and with photos
enclosed with the requisition (if relevant)
- A specification of which tests to conduct
- The time frame for the testing
5

Some certification bodies prefer to combine sampling sheet and test requisition into a single document.

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- That all reporting is sent directly to the notified product certification body
- That the test report shall include reference to the requisition and/or the sampling sheet
For the sake of transparency, the manufacturer should receive a copy of the requisition.

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SUBCONTRACTING
According to CPR Annex V, the notified product certification body itself conducts both
sampling and testing. This does however not exclude the possibility to subcontract the
activities to other bodies. Subcontracting shall always be in accordance with CPR Article 45.
Subcontracting can only be done with the consent of the manufacturer and to subcontractors
assessed by the notified product certification body as meeting the requirements of CPR Article
43.
To subcontract sampling, testing or any part thereof to the manufacturer would not be an
option as the manufacturer would not meet the independency requirement of CPR Article
43(3).

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