Please form an orderly Q
June 2015

While us Brits are notorious for our love of queueing, will we love the new “Q” that is forming? That is, Approved Document Q concerning the requirements for the security of new homes, which takes effect on 1 October 2015 for use in England. Will the introduction of AD Q be orderly?

The requirement set out in the Regulation is that reasonable provision is made to resist unauthorised access to new homes and any part of a building which provides access to a flat. It is applicable to easily accessible doors and windows, which will meet the requirement if they can resist physical attacks by either casual or opportunist burglars by being both sufficiently robust and fitted with appropriate hardware. The Approved Document guidance is that one route to compliance could be using doorsets and windows that are manufactured to a design that has been shown by test to meet the security requirements of PAS 24 (with products that satisfy other standards, such as STS 201 and LPS 1175, that provide similar or better performance also being acceptable).

Hopefully, when putting this into practice we will learn some of the lessons from the implementation of CE marking. The concept of “cascading” test evidence from the systems company to the fabricator, preventing unnecessary testing, was established in CE marking and our understanding is that this approach will be accepted here, where evidence can be provided that the design has been shown by test to meet the requirements of the new security regulation. CE marking also established which tests should be carried out by Notified Bodies – akin to but not the same as laboratories with UKAS accreditation. AD Q notes that laboratories that have UKAS accreditation (or a European equivalent) should have the necessary expertise to conduct the relevant tests and, while it does not rule out testing by non-UKAS accredited facilities, clear evidence needs to be provided that the testing is sufficient to meet the requirement.

How could confirmation be provided that the manufacture and installation of each doorset or window relates directly to the product test report provided? CE marking introduced the concept of Factory Production Control (FPC) which provides evidence that a fabricator is manufacturing to the exact same specification as the products originally tested by their supplier. The manufacturer’s FPC system for CE marking needs to consist of documented procedures, regular inspections and tests which set out how you control incoming materials or components, equipment, the production process and the product. A similar approach could be taken with AD Q and this need not be an onerous process. Accreditation to ISO 9001 is deemed to comply with FPC requirements for CE marking.

One further lesson from CE marking is the marking of products. When claiming compliance with PAS 24, each doorset and window must be permanently marked with: the number and date of the relevant PAS (e.g. PAS 24:2012), the date the product was manufactured, the identifying name or mark of the manufacturer and the PAS 24 product classification.
No doubt this will give rise to other questions and CAB will be providing further guidance to members and responding to their enquiries.