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The HARP database allows Building Energy Rating assessors to enter real performance data for heating appliances when calculating Building Energy Ratings rather than low default scores - but few renewable appliances are listed, and the industry appears confused and deterred by the application process. Lenny Antonelli investigates.
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The HARP database lists over 3,000 gas, oil and LPG boilers, many of them transferred from SEDBUK, the UK's database of boiler efficiency. However, just three heat pumps are listed. Various industry figures that Construct Ireland spoke to said the application requirements were impractical and overly stringent
Responding in writing to questions from Construct Ireland, SEI said:
"Self-certification is acceptable where a notified body has confirmed
that the test results are valid and generated according to the
appropriate standards. For example, a notified body may be in a
position to accept a manufacturer’s 'self-certification laboratory' as
providing correct test results to the appropriate standard... Regarding
'self-certification', this has a very specific meaning under
legislation (i.e. 'Manufacturer declared values'). In order for a
manufacturer to self-certify an appliance, they must test in accordance
with the appropriate standard in an appropriate facility and there must
be oversight to the testing procedures and declared results...
Self-certification in this form is a long established mechanism for
product certification."
By "notified bodies", SEI simply means laboratories accredited to the
relevant European standard (EN17025 - general requirements for the
competence of calibration and testing laboratories) that use
appropriate European testing procedures (EN14511-2 for heat pumps,
EN303-5 for solid fuel boilers, EN12975-2 for solar thermal panels, and
the boiler efficiency directive for gas and oil boilers.) Speaking to
Construct Ireland, Peter Murphy of heat pump supplier Glen Dimplex said
SEI's procedure for self-certification is impractical. "When you drill
down behind the practicalities it's unworkable. When you start looking
at the conditions and all the paper work and auditing it becomes
unwieldy. It's very bureaucratic and unwieldy to do it in practice."
"Most companies do some self-regulation,” Murphy continued. “They do
testing, they have results on file, they can be audited and
checked...There's a much more practical way of addressing the issue of
quality and control in the sector, and that's self-certification. Other
countries have embraced and developed it, why not follow their example?
And it terms of how they've done things it's cheaper, faster and
effective - and it will help them achieve their goal in terms of
developing the sector."
Murphy stressed that he strongly supports high standards - he just
wants meeting them to be practical for the industry. "I'm not
suggesting anybody can self-certify. We agree with proper
certification. We believe there should be standards and proper
certification to prevent poor standards being adopted in the industry,
but it's about striking a balance."
Many industry figures Construct Ireland spoke to said SEI's
requirements make it difficult for a 'family' of products - a line of
similar appliances that differ only by size or external appearance - to
be HARP-listed based on the testing of one or two appliances in the
line.
However, there would appear to some confusion in the industry on this
matter. Various industry figures told Construct Ireland that, as far as
they understand, SEI is demanding individual test data for each
appliance.
Techbase in Vienna, the headquarters of prominent test house Arsenal Research. Heat pump suppliers told Construct Ireland that Arsenal will certify the performance of a range of heat pumps based on testing a sample of the range
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Issue 2, Vol 5 Out Now
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