GEN – 917.00. On 12 June, the website of the INTAS project has been complemented with a set of draft documents analysing applicable regulations and testing best practice of transformers and fans. Unrelated, but worthy of note is that the State of California has also produced a study on fans.
Fans in INTAS
The INTAS-testing website has been updated on 12 June 2018 with draft publications concerning the effective legislation. Other than Ecodesign, related to testing of the transformers and large fans, as well as MSA and industry best practice in the conformity assessment of the two respective product categories.
The four reports that should interest fan manufacturers and manufacturers integrating large fans in their products are:
Report about the screening techniques available for product/supplier targeting (65 pages)
This document proposes conformity verification screening methodologies that would enable products, which have been placed on the market to be selected for conformity verification prior to their placement into service. It is recognised that the conventional conformity verification procedure post placing the product on the market is problematic and more an option of last resort. For large fans, risk assessment based on interceding with the manufacturer and checking design software and product records could likely be a part of the process. For some select end-use markets, witnessing factory acceptance tests could have a role. The proposed screening methodologies would be used to decide if laboratory verification testing would be required.
Analysis and report on other applicable regulations on fans (86 pages)
This document looks at voluntary certification schemes. These schemes are limited to those of ISO EN 9001, ISO EN 14001, ISO EN 50001 and ISO EN 26000.
Graphical flow chart of the methodological process, taking into account all tasks (12 pages)
This document indicates that large industrial products, such industrial fans, are likely to be poorly suited to the product selection techniques that MSAs established and deployed for Ecodesign conformity verification. As a note, it mentions that INTAS is exploring the possibility of a mandatory notification for the MSAs, to know if a fan has been installed (or produced). However, currently there is no obligation for suppliers to inform MSAs that they have placed products on the market.
Best practice and experiences of both MSAs and industry regarding testing of fans 89 pages)
This report found that the standard Ecodesign market surveillance conformity verification approach based on selecting a product for 3rd party verification testing is not very well adapted to large fans because:
- Large fans are customised made-to-order products that are procured under private B2B commercial arrangements. Hence, they are not produced in series, are not ordinarily available at manufacturers premises for sampling, and are not advertised. This means that MSAs cannot employ usual market research methods to establish whether a product is placed on the market or not, and to sample and test the product.
- Even when it is established that a product is placed on the market, conducting 3rd party testing once a product has left the factory premises is costly to conduct and is liable to be disruptive to the business who has procured the product. This is mostly due to the delay it would cause in finalising the larger project the fan is a part of, but also in terms of lost operational value.
Market surveillance conformity verification witnessing factory acceptance tests (FATs), could be much less costly and disruptive for cases where FATs have been ordered by the client. However, MSAs may not have the authority to insist on being present and to impose conditions on the FATs. Critically, the current Regulation 327/2011 has no provisions for mandating this activity, unlike in other some other regulations (e.g. for power transformers).
The INTAS project runs until February 2019. As mentioned in GEN – 911.00, the validation of the market surveillance methodologies for fans runs until September 2018.
Manufacturers of or using large fans would do well to consider the four reports, in advance of the consultation phase by National Focal Point meetings in 10 countries (!). These meetings are likely to happen over the summer holiday period and will be organised by INTAS partners to collect their feedback. The National Focal Point meetings have not yet been announced on the INTAS website.
Manufacturers of or using large fans would do well to consider the four reports, in advance of the consultation phase by National Focal Point meetings in 10 countries (AT, BE, CZ, DK, ES, FI, IT, PL, PT, RO, not DE, UK …!).
These meetings are likely to happen over the summer holiday period and will be organised by INTAS partners to collect their feedback. The National Focal Point meetings have not yet been announced on the INTAS.
The Product Groups within Eurovent dealing with large fans would do well to prepare comments or a position paper on the proposed documents.
Additional information – State of California
Commercial and Industrial Fans and Blowers Staff Report – Proposed standards for commercial and industrial fans and blowers
The State of California has just released this 89-page report. If adopted the proposed standards (American definition) for commercial and industrial fans and blowers, which would result in a “rule” (legislation) that would take effect on 1 January 2020, or one year after the Energy Commission adopted the standards. The standards would apply to all commercial and industrial fans and blowers with a shaft horsepower (HP) of 1HP but no more than 150 air HP.
Additional information – Product factsheet Europe fans 2016
Axial and centrifugal fans in Europe
The CBI, Centre for the Promotion of Imports from developing countries, that is part of the Netherlands Enterprise Agency publishes various documents to contribute towards sustainable and inclusive economic development. In 2017 a useful 14-page report prepared by the Globally Cool consultancy on axial and centrifugal fans was published. It includes an overview of the European fan industry and looks at two market-entry strategies merit further investigation: supplying to European importers and supplying to European fan producers.
Related documents and links
All related documents and articles can be found in the respective sections in the right sidebar.
- Analysis-applicable-regulations-and-testing-best-practice (the link to the fan documents figures in the text above too)
- INTAS progress report 2018-05-31
- Presentation of INTAS project on 6 June 2018 during EUSEW in Brussels
- INTAS progress report period 1
- INTAS 2nd Half-yearly progress summary: October 2016 – March 2017
- National focal points
- GEN – 917.01 – State of California – Commercial and Industrial Fans and Blowers Staff Report
- GEN – 917.02 – CBI product factsheet Europe axial and centrifugal fans 2016 fans
- GEN – 911.00 – Previous update in INTAS