There is a lot more to fire protection regulation than simply following the rules – helping shape them is important as well. Len Swantek, Director of Global Regulatory Compliance at Victaulic, takes readers through the regulatory process from design to post production, and explains the importance of sharing responsibility in the industry.
Getting the groundwork right
Regulation is a highly complex process for every company involved. With nearly 100 different projects in the approval cycle at any given time plus follow-up examinations, a company such as Victaulic must remain sharply focused on market priorities in order to hold its competitive edge. The company must also manage over 230 annual audits each year by external agencies to maintain its certification status.
Given the critical applications where the company’s components are applied across such a broad range of systems around the world, it is not surprising that there should be so much scrutiny – but it does require considerable management and coordination to meet both agency and customer requirements.
Before regulatory procedures even begin, a tremendous amount of time is put into research and development. Since Victaulic invented the grooved piping system more than 90 years ago, it has pioneered new designs to solve market problems and make products more robust and yet economical to install.
Victaulic is a design-focused company that drives industry trends, and its engineers are continuously involved in research and development, evaluating new ideas, working on prototypes and addressing technical modifications driven by changes in global fire safety codes and standards.
Development of a new product is lengthy – often taking well over a year. Concurrent with this is also process development to assure consistency of global manufacturing to a wide range of international agency auditing procedures.
Once a new product is ready for market and the company is certain that every unit shipped will perform identically, rigorous internal pre-qualification testing is carried out in anticipation of regulatory requirements. Victaulic replicates known scenarios that could be encountered, applying process technology and even re-engineering products as necessary.
Making the global grade
Fire protection industry regulations are constantly changing and a clear understanding of the most up-to-date requirements is vital to the successful completion of the approval cycle and managing time to market.
The level of regulatory involvement varies from one market to another, but fire protection is one of the most regulated industries and the product testing carried out is among the most exacting of all market segments. While heavily influenced by the insurance industry, fire protection and fire safety also are amongst the most widely recognized areas of public concern globally, irrespective of cultural or demographic influence.
For its fire protection line, Victaulic refers to the five most commonly specified regulatory authorities in the world as “platform agencies” and submits new products to these as a first step in building an official third party record of performance validation. The agencies in this group are FM Approvals (FM), and UL, LLC, in the US, the Loss Prevention Certification Board (LPCB) in the UK, VdS Schadenverhütung GmbH (VdS) in Germany and China Certification Centre for Fire Products (CCCF) in China.
Take a product such as a Style 009N FireLock EZ® coupling – one of the most popular Victaulic products and part of their patented “installation-ready” line of couplings. This product consists of two ductile iron housings, an elastomeric gasket, two bolts and two nuts. The 009N was subjected to a wide range of internal and external performance testing and examination by these major global agencies.
Victaulic initiates the testing process by sending a confidential data “package” to each agency, containing approval objectives along with a product performance outline with detailed specifications, as well as internal test data and technical drawings. The components of this package must be accurate and complete, and can take weeks to compile.
Life long assessment
In order to facilitate the actual performance testing, product samples, pipe of various specifications and other related equipment must be organized and shipped to applicable agency facilities globally. This is another time-critical operation – as any delays on the part of a manufacturer could result in a lost position in the testing laboratory’s queue. At this stage, documentation must already be available in multiple languages for examiners to assemble equipment themselves based on an assumed level of skill equal to that of the end user. On average, the testing process can take three to six months to complete.
The approval authorities also are concerned with the manufacturing and assembly locations of specific finished parts or sub-assemblies. Those parts that are most critical to the overall performance of the finished assembly will have greater regulatory oversight. Victaulic manufactures in multiple locations globally to optimize supply chain logistics, but this can greatly increase costs as each location must be certified and audited on a regular basis.
In the event of a non-conformance at this late stage, a manufacturer risks losing valuable time to market and must resubmit for the evaluation process again, but only after design alterations have been finalized and documented. Upon successful completion of all platform certifications, the next segment of regional approvals can be initiated with similar steps involved.
With over 32 regional agencies throughout North America, Europe, the Middle East, Africa, India and Asia-Pacific, and each having individual jurisdictional authority over specific systems or applications, approvals for the remaining market segments can take another six to nine months to complete.
Manufacturers like Victaulic can only go to market when they have secured all applicable certifications and each product or package carries the appropriate agency markings. Once complete, only then can results be reviewed and data fed back to the research and development teams. Finally, all project correspondence is archived and manufacturers move on to the audit management process.
Audit management is the final phase in the regulatory cycle. This phase starts when a product certification is officially released and only ends when the product is no longer produced. Through various follow-up procedures and factory production control systems, products are retested annually as a minimum requirement. Some regulatory authorities re-examine products quarterly – and some even on a weekly basis – to ensure high-quality performance to regional agency codes and standards and to verify manufacturing processes remain unchanged.
Auditing is important because codes are constantly evolving to improve health and safety as a result of real-world factors. Witness, for example, the on-going efforts to improve the quality of drinking water globally, and the regulatory scrutiny involved with the products used within these systems. Additionally, changes are frequently driven by trends in construction techniques – some for instance are prompted by the push towards lighter-weight and more disposable materials – but also by situations and events that occur in the field.
Victaulic views its role in the regulatory process as going beyond simply respecting the rules. The company has a department dedicated to regulatory compliance with regional representatives across the globe, and sees regulation as an area of social responsibility where it can participate to benefit the communities in which it conducts business. An example of this is its dedication and support of fire safety research, and direct participation within many local and global codes and standards development committees.
The company works with regulators as well as other manufacturers to overcome problems encountered in the various industries and to improve the protection of lives and property. Victaulic aims to learn from real-life situations and effect change where needed – whether this means collaborating in committees with competitors and regulatory bodies to create the most well-rounded and effective regulations, or joining with contractors and end-users to help solve real-world problems and build on shared learning to develop a new generation of high-value products.
Working together is important – the safety of our communities is after all, the number one consideration of everyone in this business.
Published November 2015