Bounding

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For other uses, see bound.

Bounding is the activity of adhering to all the requirements of installing and/or using safety-related products and items in conformance with an active certification listing that has been issued by an organisation that is nationally accredited both for testing and product certification. It is the exclusive means to establish due diligence for goods and services whose use is mandated by a building code or a fire code. The term is most commonly used in North American fire protection and has originated in the construction and maintenance of nuclear reactors in the United States.

1 New safety-related inventions without standardised test and certification regimes
2 The role of testing versus product certification
3 Bounding in structural fire protection
4 Accredited testing and certification organisations
5 See also
6 External links

[edit] New safety-related inventions without standardised test and certification regimes

Products whose use is not mandated by any building codes or fire codes often lack a consensus test method, such as ASTM E119, which is used to test the fire-resistance of walls and floors. Unless there is a test standard in existence to prove the functionality and reliability of such a product, there can be no certification listings and thus no bounding. Such new products may be seen as optional, or going above and beyond the requirements of a code. The absence of an established test regime for a new invention can be an unfortunate and formidable obstacle to commercial success for any new safety product because of the inertia required to assembly a consensus standard through an accredited standards writing organisation, which must, in turn, assemble a group of volunteer industry experts who must commit to time spent and expenses in coming together at one location, repeatedly, to devise and ratify a standard, which must then still be nationally approved by a national authority. This takes years. Apart from the time this takes, it also puts all potential competitors on alert to a new opportunity or potential threat to existing technology. On the flipside: without a certification listing, it is extremely challenging to market any safety related item - even if there are no others like it, as there is no widely recognised proof of its functionality and thus insurance coverage in the event of failure of the product or its installation. The inventor's or vendor's or customer's or contractor's own test results are not typically persuasive, no matter how well intentioned, as they have a vested interest, but most importantly, lack the national accreditation for their testing to be taken seriously by any authorities or insurance companies.

[edit] The role of testing versus product certification

[edit] The significance of governmental accreditation of the laboratory

National, governmental accreditors, such as Germany's DIBt (Deutsches Institut für Bautechnik = German Institute for Building Technology) or Canada's SCC (Standards Council of Canada) can "accredit" laboratories, meaning that such laboratories must conform to national standards and rules of conduct in the discharge of their duties. Compliance is routinely tested by the accreditor through inspections, where random client files are audited to see that the laboratory followed all appropriate procedures. Accreditors can accredit laboratories for testing, as well as for product certification. In product certification regimes, the laboratory and/or the accreditor (as in the case of Germany) become involved in witnessing the production of test materials, get copies of process standards, including chemical formulas and all details necessary to manufacture a product. Once the test product is made, it is shipped "under seal" to the laboratory for incorporation in the test. Certification listings and/or approvals that follow a successful test are subject to the maintenance of continuous factory auditing to make sure that what was tested is identical to that which was made, and/or documented proof that the products made continue to meet quality control standards set out as a function of the approvals process.

[edit] The value of testing by laboratories who hold no national accreditation

Testing by organisations or laboratories who hold no national accreditation for testing purposes are not subject to mandatory governmental audits of compliance with applicable requirements. Even an organisation that is nationally accredited for testing purposes may not necessarily issue test reports that provide assurance that commercial products tested by it are the same as what is being sold or used by the public. For instance, one may choose to have one's domestic water tested to see if it is safe to drink. That is fine for the individual test submittor. Testing water for the purpose of selling it commercially to the public is another matter entirely, as the results have wider implications for the public at large. Safety related products generally have to undergo product certification to enable their use by the public. Therefore, the value of testing by organisations without accreditation for product certification is based on faith in the organisation or its ethics, or culpability. Apart from this, manufacturers of products routinely test their own products and competitors' products simply for their own purposes. For instance, it makes good fiscal sense to test in one's own lab before incurring the costs of a third party facility.

[edit] Testing for the purpose of achieving product certification

While testing alone is perhaps interesting, product certification involves a whole regime whereby before anything is tested, a test standard must exist that has been authored by an organisation that has been accredited by a national accreditation body. For instance, in the case of a firestop, ULC-S115 is the test method that must be used by any laboratory whose tests are to have any legitimacy in Canada. In this case, ULC stands for Underwriters' Laboratories of Canada, an affiliate of Underwriters Laboratories. ULC is nationally accredited in Canada to write standards, test products and to certify products. If an organisation tests a firestop in or for use in Canada, in accordance with the right standard, ULC-S115, but is not accredited by the SCC, the test results are of no consequence in Canada and cannot be deemed to result in any approvals of field installations on Canadian construction sites. If, on the other hand, the test laboratory is also accredited for product certification, then before the test takes place, a follow-up or certification agreement is anticipated between the certifier and the submitter of the test who desires a rating or a listing. The certifier/tester then dispatches an inspector who witnesses the manufacture of the product or products to be tested. He or she also checks the manufacturing procedures against the process standard that is in place and by then on file with the certifying organisation. The process standard includes all information necessary to manufacture the product or products, including equipment descriptions, tolerances, chemical formulas and purchasing specifications for ingredients or components. The manufactured goods are sealed by the inspector and then shipped to the laboratory. When the seal is broken in the laboratory, the contents are used to build the test specimen. The fabrication of the test specimen is closely scrutinised to ensure that no cheating takes place, which is not entirely uncommon. Cheating in fire protection test assembly construction may include but not be limited to substitution of materials and components by the manufacturer, adding of additional safety measures to make sure that the assembly passes the test. As an analogy, perhaps a 10 Dollar product is substituted for the 5 Dollar product, just for the test, unbeknownst to the laboratory. If the item is consumed or obscured in the test, a post-mortem investigation may or may not reveal an unannounced change in the test assembly by the manufacturer. Presuming the test passes, the product certification laboratory then issues a confidential test report. The manufacturer is not obliged to share this test report with anyone. The items in the test that passed are given a certification listing, which describes the product(s) that were tested, the application, and maximum and minimum tolerances for all components. In the case of a firestop, for instance, this includes the wall or floor type and thickness, size of the opening, any penetrating items, their tolerances and spacing, the thickness or thicknesses of the firestop materials, any insulation being used, etc. Typically, there is also a drawing. Certification listings are short versions and interpretations of the test results. For instance, if the largest power cable that can penetrate a cable penetration firestop is a 250MCM cable, then a 500MCM cable is inadmissible and would be a code violation. If the largest hole that can be firestopped using a certain certification listing, is 1 ft², then a 1.1 ft² opening is not allowed and will be both a building code and a fire code violation. Bounding simply means that safety related products must be used within the tolerances of certification listings. Just because a product has a certain certification listing, that does not mean that one can extrapolate from there. When a certification listing is used, this serves as legal evidence not only that the test has been properly conducted and that the tested systems passed, but also that a follow-up agreement is in effect between the manufacturer or submitter and the certifier. This means that in addition to the original inspection where the test materials were produced, the certifier is authorised and obliged to make unannounced inspections of the manufacturing facility to ensure that what is being manufactured and sold is still the same as what was originally tested. In the event that irregularities are discovered here on the part of the manufacturer, such as substitutions of cheaper ingredients or components, the listing can be de-activated and the manufacturer can be made to remove all logos of the certifier from product literature, promotional materials, packaging, etc. In such a case, logos would have to be removed from stock on hand as well as from stocks of products already in distribution or on construction sites. There have been cases of de-listings. Sometimes it may be deliberate irregularities leading to this, or, an ingredient or component of a tested system may no longer be available in acceptable quality. Part of bounding, therefore, is to ensure that the listing being used for a field installation, is indeed active with the certifier.

[edit] The confidentiality factor

Testing a new and proprietary product in a third party facility can make manufacturers nervous, as a poker player likewise does not wish to "tip his hand". While some laboratories engage in elaborate systems to disguise the construction of test specimens, submittors who know their ways around usually have a sense of what their competition may be up to. Some manufacturers are extremely reluctant to share their proprietary process standards with any third parties. It is for that reason, that Germany's system is such that formulas and process standards are shared with the governmental accreditor: DIBt [1]. DIBt still uses the laboratories to audit the factories. However the audits are restricted to quality control tests of the finished products - not their chemical compositions or exact process standards. In North America, manufacturers are obliged to share their process standards with the laboratories, as there is no national accreditor that issues "approvals". This has resulted in the use of "fingerprinting" procedures, where manufacturers will permit their laboratory inspectors to conduct infrared spectroanalysis and other QC tests, in place of the process standards. However, this is not always granted. There have been no known cases of unauthorised disclosures by BIBt. The German labs who are accredited by DIBt could not divulge any formulas because they don't have them in the first place. Their QC tests, however, have resulted in further audits and corrective actions for some manufacturers. North American laboratories are usually private sector companies, though some of them are non-profit organisations, such as Underwriters Laboratories. There have been migrations of private sector laboratory engineers to manufacturers, which have resulted in the emergence of new products. Concerns over such events and future repeats are mitigated through the use of "fingerprinting" the products, rather than audits of the applied process standards. Both methods work to assure the end-user customer that significant documentation exists for each batch of certified product made.

[edit] Bounding in structural fire protection

Bounding is the exclusive means by which structural Fire protection systems and other safety-related products can be evaluated for code compliance inside and outside of buildings.

All safety related products are typically required by law to be subjected to testing and product certification by an organisation that is nationally accredited for testing and product certification.

Evidence of bounding forms the cornerstone of both building code and fire code compliance. In the event of an accident and claims to an insurance company, insurance adjusters will seek evidence that bounding has generally occurred. Any evidence to the contrary will be used to make the responsible party appear negligent and culpable. An example would be where a fire investigator may discover that a 30A fuse was used in a 20A electrical circuit. The use of the wrong fuse can lead to an overload and then a fire. The party who installed the wrong fuse is then deemed responsible for the resulting damage and casualties. The fuse in this case, was not bounded. Its certification listing did not allow its use in the wrong circuit.

A spectacular case of the lack of mandatory bounding in US and Canadian nuclear power plant construction was the Thermo-Lag scandal, which was exposed by whistleblower Gerald W. Brown. The disclosure of the inadequacy of fire testing employed in the circuit integrity product led to widespread and costly remedial work for licensees of the Nuclear Regulatory Commission