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Published for the first time in Construction & the City newspaper – issue: 44/2004-11-15
Two years have elapsed since the certification of the products of the first construction companies. The certification in question is carried out according to the requirements of the Ordinance on the essential requirements and construction products conformity certification (OERCPC). By the implementation of this Ordinance, the so-called new approach as laid down in the EEC Construction products Directive is being applied in Bulgaria. This period is sufficient to make a preliminary assessment of the results from its practical implementation by the Bulgarian construction companies in their activities.
There are three main elements that underpin this analysis. Immediate observations, made in the course of the last two years on the activities performed by more than 30 companies in the sector concerned, which have introduced or are in process of introducing the factory production control (FPC) systems including the ISO 9001 quality management systems (QMS), are the first source of information. The second element is the competitive positions of the companies studied compared to similar companies in the regions concerned. The third element is the observations on the users directly related to the companies, which are being certified, and the construction products/services suppliers.
The first problem, which has been identified and is related to the factory control system is factory production control system or management production system.
In the course of the analysis of the problems related to the product certification, two tendencies have been identified, which are the result of two different opinions on the purpose and the contents of the required factory production control systems respectively.
The first tendency, which for convenience shall be shortly called control tendency, extrapolates the opinion on the control as a one-time act (or a series of one-time acts) establishing the condition of a given process/product. When applied to the development of the factory production control systems, this opinion is the source of a number of obstacles in the implementation in particular with respect to the compliance with the requirements in the transition to the product European standards. The superficial study of the standards and of the ordinance lead, finally, to the FPC creation, implementation and certification, mainly focused (and in a number of cases only) on the control – scheme, frequency, methods.
As far as the implementation is concerned, the combination of traditional opinions, the access to technical and technological experience and … the habit to regard the normative requirements to the quality as useless administrative restrictions, which have nothing to do with the real business, made a number of companies apply a formal approach to comply with the requirements of the product standards. Thus, through the control approach, requirements have been introduced to a great extent in the FPC, which are circumventing or cover only formally the European product standards. The most flagrant example of this tendency is the certification of the products only under the Bulgarian State Standard, whereby, at least the OERCPC requirements are formally and temporarily met. The analysis shows that the maximum, which the companies for FPC developed under this method may offer, is a conformity certificate/declaration respectively.
The second identified tendency is the management tendency. It is based on a more complex analysis. At the first place, it should be taken into account the different meaning of the English term “control”, which in Bulgarian covers to a larger extent what the notion of “management” implies. The analysis of the Construction product directive, including the rules for its implementation, clearly outlines two elements, which are interconnected but relatively autonomous elements in the product certification – the technical assessment of the product as such (methods and ways for testing, determining and evaluation of the results obtained) and assessment of the factory production control system in question. A series of harmonized European standards of the new approach are also taken into account. This analysis was necessary due to the fact that the groups, developing such standards are relatively new and the relevant experience has not been systemized sufficiently yet. Therefore, a standard taken alone could be hardly taken as a model.
This complex analysis shows clearly that when speaking of a FPC, it is, in fact, production management system for a specific product, which is involved. Therefore, the task is defined as a management one i.e. type of production management.
If we continue this analysis, we may conclude that the term of “conformity”, which replaces the notion of “quality” cannot be understood unequivocally. Moreover that the key to the correspondence required is the compliance with the client’s requirements, while the aim of the standard is to facilitate the relations between the producer and the client. The contractors, by defining a given product only as “product X, class Y, quality Z, reference standard U”, have contracted also the method for testing the product concerned, the valid determination methods and the ways for assessment of the results. In that respect, the conformity declaration does not represent a sort of general document for quality but a precise instrument, which provides guarantee to the user that the product delivered has the qualities and the properties as required by the same user. This means in practice, that the client’s order-specification should be taken into consideration during the product development stage. This is of great importance for products like concrete, additive materials, etc. Thus for example, within a specific class of compressing strength, the standard provides for a delivery of at least four consistency classes for four different groups of conditions for operation with five different classes for freezing and unfreezing and five different classes of impermeability. This means in practice that the manufacturer, in order to issue not only de jure but also de facto the declaration of conformity, should know what exactly the client wants from him. In this specific case, the key to understand this is the process of making as exhaustive as possible specification of the product since the manufacturer CANNOT guarantee in practice more than what has been specified and ordered!
The task which the companies have to accomplish in the certification process is, in its essence a managerial one. This means that the requirements provided for in the product standards lay down the conditions, which are necessary but insufficient for the development of an efficient specific management model. In this context, we may consider the requirements for the respective standard as a series of verification criteria of PMS (production management system) operation, which, however, proved not to be sufficient for creating a business efficient system.
The understanding of FPC as a PMS implies the need of ensuring the model applicability and sustainability within real conditions.
“Applicability” shall mean the model ability to be applied in practice within company’s activities taking into account the actual existing educational and qualification level of the staff, its culture and management habits including the technical and technological schemes applied. This means that the fulfillment of the requirements should be ensured through a model with definitions and formalization, which are acceptable to the manufacturer considering the minimum amount of expenditure required.
Taking into account the real conditions of the operation of the construction companies, the PMS developed should meet obligatorily the sustainability criterion. “Model sustainability” shall mean the ability of the system to operate efficiently under conditions of sudden changes in the environment (instability of the indexes of the inputs, loading peaks, coefficient of breakdown of technological machines and equipment, range of the product requirements specified, etc.). The sustainability requirement implies the existence of certain “excess” of control (i.e. the insurance of a permanent operation of the system with peak fluctuations), easy maintenance of PMS under real operational conditions, optimal distribution of the expenditure for control by type of activities in view of their optimization, etc.
Under the management approach the companies inevitably realize the need to protect the issued declaration of conformity from abuse by unscrupulous clients and/or unfair competitors (for example to use 10 units from the certified company’s product and on the basis of the certificate obtained to get some more 100 certified) for reasons of keeping company’s image and preventing economic losses. In the same time, the documents accompanying the product provide, in many cases, valuable information for the user. For example, following an attentive reading of the shipping notes concerning concrete, the investor may acquire a precise idea of the level of organization of the concrete works on the construction site.
Another important point in the adoption of the management logic of the obligatory FPC systems is the possibility to use to the maximum extent the information provided in the product standards. The familiarization with the product standards from management point of view seems to make “suddenly” the companies confident to be able to fulfill the purely technical requirements to the product concerned. In that case, the manufacturer focuses on the permanent nature of the results and the cost-effectiveness of the production, which the PMS should guarantee. This is absolutely logical, since from economic point of view it is of great importance for every manufacturer to ensure not only conformity of product with client’s requirements, but also to take into account the cost-effectiveness of such conformity. For example, a number of concrete manufacturers guarantee the results desired at the expense of considerably increased security coefficients. According to our data, the product conformity was guaranteed through unjustified high concrete consumption in more than 70% of the companies surveyed before the introduction and during the first year following the introduction of the production management system,. After the production management system became stable, it was possible to optimize the recipes without any risk for the production conformity.
Furthermore, the familiarization with the standards gives an idea of the average technical and technological level of the companies from the EU Member States, which allows making a self-assessment of the competitiveness in the context of our forthcoming accession to the EU.
The application of the management approach proved to be very useful, especially for the manufacturers due to the actual possibilities for production optimization and its cost-effectiveness ratio improvement. It is important also for the sharp increase of their attractiveness to the serious investors and hence to their competitiveness. Our survey shows (similar product in three regions in the country) that in over 75% of the cases the tenders, organized by major investors including foreign investors are won and awarded to such companies, which have certified their product by using the management approach. This means that, in practice, FPC system as a PMS is an instrument, which increases company competitiveness.
The major problem encountered in the application of this approach is the introduction into practice of the systems concerned, which usually requires time (depending on the specific product), while the key requirement being the good will of the company’s senior management to introduce the system. The time required for the introduction is defined by two components: the time required for the accomplishment of the tasks resulting from the preliminary organization and technical preparation and the time required for the accomplishment of the tasks resulting from the introduction of the PMS. The analysis of the experience acquired (surveys conducted, including the two final requirements i.e. with respect both to the available staff competence and the existing technical and technological production equipment) shows that in over than 90% of the cases the decisive factor is the will of the senior management. Even the slightest doubts and hesitations clearly expressed by the management (before the staff) with respect to the introduction and use of PMS, lead inevitably to strong increase in the introduction time required. We consider this to be normal insofar as the benefits from PMS and FPC under ISO 9001:2000, are mainly and exclusively for this management. With respect to the medium management and the employees, such management models require much more accuracy and mean unequivocally assumption of responsibility for the performance of the tasks assigned to them. It is the precise description of the requirements to the staff and the clear definition of the responsibilities in different moments, which give rise to more or less open resistance during the introduction process.
This problem becomes a major one in case of information available on formal certification of a similar company in the region concerned. This leads to a decrease in the staff motivation during introduction, makes slower the process and as a result of it – costs additional resources. In such cases, the average time required for the PMS statistically increases twice than the average time required for the introduction of a given product.
CERTIFICATION PROCESS, Issue No. 45
The key function in the certification process is conferred to the conformity assessors (CA) and the first such conformity assessors have been working for more than three years already at the market. During their practice, the two approaches, in particular the control and management ones have been identified. Unfortunately, presently the number of the control approach adherents seems to be higher. It is enough to compare the number of the certified persons for EN ISO/IEC 17025:2000 conformity certification (laboratory activities) and those certified under EN 45011 and 12.
Widespread practice
is the “certification only under BSS”. This means that these are the companies, which should draw the attention of the manufacturers on the need of full compliance with the requirements of the respective product standards, that considerably underestimate the factory production control (FPC) systems as production management systems (PMS). Here should be mentioned the same reasons for the increased application of the “control” approach as those identified in the first part. In that case we would not like to consider that unfair trade practice is involved, the aim of which is to make the manufacturers pay double for a service, which is one and the same by nature (today under BSS and tomorrow under BSS EN).
The traditional objection in that case is the assertion that the respective BSS EN hasn’t come into force yet. This reason, though based on certain formal grounds, is in fact inconsistent, because the processes are very dynamic. For example we witnessed situations in our practice when colleagues of ours start working on their certification based on a standard, which at a final draft prEN stage (preliminary ЕN), few days after the certification the EN standard has been adopted and during the first current audit the relevant BSS EN standard was already available! The second reason is that these are the manufacturers who are not ready to pass to the assessment of the conformity (tests) of the product concerned entirely according to the EN standard due to the need of change and additional purchase of laboratory equipment. This reason also, which is in fact an important one, shows uniquely the “control” concept, which implies the underestimation of FPC as PMS. Considering the existence of an European standard, which hasn’t come into force in Bulgaria, the manufacturers attention should be drawn on the possibility to create their PMS in compliance with this European standard, while the product concerned should be assessed (the so-called test and determination methods) in accordance with the effective BSS.
Formally, the “BSS certification“ is possible and admissible within the literal meaning of the Ordinance on the essential requirements and construction products conformity certification (OERCPC). However, the manufacturers who have undertaken this step, postpone the fulfillment of the requirements of the respective EN standard insofar as it is a question of time (and a short time) that the old BSS be replaced. This means that the use of the potential possibilities for increasing their competitiveness upon Bulgaria’s EU accession in 2007 is also postponed.
The second important point related to the conformity assessment, is the reliability, the competence and the objectiveness of the relevant conformity assessors. Even a rapid reading of the manual for the implementation of the EU directives of the new approach defines as an essential and privileged instrument of the conformity assessors their ability to cover the requirements and to be certified in accordance with the EN standards of the 45000 series and/or EN ISO/IEC 17025:2000. In that respect the pure technical requirements, related to the laboratory activities, are rather well mastered.
The other basis i.e. that the conformity assessors should cover the requirements of EN 45011 – is underestimated to a considerable extent. The percentage of the persons who have been authorized by the Ministry of regional development and public works (MRDPW) to perform conformity assessment and who are also certified for EN standards 45011 and 45012 is very little, which is very little and subject for concern. Such a passivity of the conformity assessors puts at a serious risk their survival in a medium term because our accession to the EU will mean an automatic passing to a
new quality level of competition
among the assessors concerned.
The analysis of the systematic problems related to the introduction and assessment allow making the following conclusions.
The implementation of the construction products directive and the related to it OERCPC advances well in practice. The evaluation of the accumulated practical experience shows that there are no serious obstacles in front of our companies to cover the European standards of the new approach. Moreover, the development and the introduction of the PMS in full compliance with the requirements are very useful not only for the construction products users, but also for the manufacturers in several respects:
* aligns their everyday practice with the practice of EU similar undertakings, which prepares them from now to withstand and develop within the conditions of EU competition at the domestic and for the domestic market;
* sets up structured databases, which allow the increase the cost-effectiveness of their production within medium term.
* mobilizes, structures, systemizes and creates a basis for development of the proprietary know-how.
A critical point in this aspect is the product test, necessary for the full conformity with the European standards, requires a thorough change of the laboratory equipment, which entails additional expenses in the average of BGN 20000.
The second conclusion, which may be drawn up, relates to the management systems. Treated as production management systems, the FPC developed and introduced in compliance with the requirements of OERCPC, represent a serious instrument to increase the competitiveness of the companies from the construction sector.
It should be underlined that presently those Bulgarian manufacturers, who apply “management” approach to the fulfillment of the product European standards requirements, should solve in principle the same problems as those encountered by their colleagues in the EU Member States, which means in practice that they are dealing already with the problem related to their competitiveness level in 2007.
A key factor in the practical implementation of the construction products directive are the conformity assessors (AC) due to at least three reasons:
*the number of AC, certified under EN 45011 and 12, is still under the critical minimum to ensure the required reliability of the Bulgarian certificates at European level;
*the serious misunderstanding and the underestimation of the FPC importance as production management systems of the respective products do not contribute to raise the users confidence in the suppliers certified;
*the formal certification of manufacturers “under BSS” postpones their preparation for the forthcoming competition at our domestic and for our domestic market. Another aspect of this process is the difficult introduction of adequate FPC.
The non-uniform criteria for assessment of the certified PMS in the different companies lead to different results in their practical operation. In this context, the compromised quality of the produce of some of these companies would make the foreign investors bring the certification process under question including the available certificates. This situation has not reached its critical point yet, but it is enough upsetting. Therefore, we propose
several corrective actions.
The manufacturers’ branch organizations jointly with the specialists from the Bulgarian Standardization Institute, Market surveillance and specialists from the practice should undertake a stronger campaign both among the manufacturers and the users of construction products and construction consultants (supervisors) with respect to the essence and the characteristic requirements of the European standards and their implementation into practice considering the local conditions, in particular with respect to features of the FPC as products production management systems.
The branch organizations should help their members with respect to the criteria for selection of a conformity assessor to avoid the risks for the manufacturers related to acts performed by the conformity assessor due to insufficient competence.
It should be appropriate that the CA align their criteria with respect to the conformity assessment of the construction products, in particular with respect to the assessment of PMS (FPC). It would also be reasonable that the respective branch and other professional organizations propose specific measures to the respective state authorities aimed at finding adequate solution of the problems related to the control to be performed at much earlier stages. Such control would curb significantly the unfair competition, which in certain regions is almost a rule. In addition, this would result in reducing the amounts of the damages inflicted and of the lost profits. Encouraging effect on the fulfillment of the requirements of the Ordinance concerned and on the full preparation of Bulgarian companies to cope with the competition level upon Bulgaria’s accession to the European Union, of the Ministry of the economy and/or the Ministry of regional development and public works implement programs funded by the European funds or otherwise, which should reduce by at least 50% of the expenses of the certified companies in the change of their laboratory equipment. It is in this way that the requirements of the product standards can be fully met. As a whole, the amounts are not large (in the range of BGN 1.5 -2.0 million), while the effect of such kind of programmes would be significant in view of increasing the competitiveness of the Bulgarian companies.
In conclusion, I would like to stress that we do not underestimate at all the efforts made by a number of colleagues in the technical and technological field of the product certification. It is because these results are good enough that we should focus our attention on the problematic issues – the assimilation of the production control systems as production management systems. In that connection we should highlight the practical efforts of the colleagues from the Bulgarian Standardization Institute and BEA, which work hard in this field.
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