Following a mandate from the European Commission, CEN/TC 350 “Economic performance assessment of buildings” is tasked with developing standards for the sustainability assessment of buildings and building products. ANEC has repeatedly expressed its opposition to this work and stressed that the standards will be of limited use, not only in B2C transactions but also for other purposes, such as public procurement. We have submitted detailed proposals for modifications to the approach that have been rejected on the whole. Despite the unproven value of this work, a further set of criteria for buildings has been developed under the European Green Public Procurement (GPP) initiative.
According to several past ANEC research projects on environmental product information, it has become clear that indicators based on life-cycle assessment (LCA) methodology may not be the best means to characterise and declare the environmental performance of a product. In many cases, significant production or use-phase indicators (e.g. energy efficiency, indoor emissions) derived from a variety of tools (e.g. chemical risk assessment) are a better choice for product labeling and differentiation among similar products compared with LCA indicators. The purpose of the ANEC study was to develop a set of environmental indicators, and corresponding minimum and excellence criteria, primarily for new residential buildings. The scope included provision of information to consumers on ways to achieve energy savings, for example.
The study results were released in September 2011 together with an ANEC position paper “Sustainable construction – a building site without end. Alternatives to flawed standards”. ANEC urgently calls for decision makers to initiate a broad debate including all interested parties in order to work together and develop a stringent European concept for sustainability issues in the construction area. A European Green Paper from the Commission could be a good first step.
ANEC is pleased to note that the draft Reference document on best Environmental Management practice in the building and construction sector, drafted by Joint Research Centre, took the ANEC study report on "Environmental and health related criteria for buildings" into account.
Requirements for acoustics in European toy safety standards
Market surveillance authorities have received many complaints and reports from consumers and audiologists about noisy toys that could present hazards to hearing. Indeed, reports from audiologists show that noisy products can cause hearing damage in children and that temporary tinnitus among school children is increasing. Noise-induced hearing loss is often permanent and can cause considerable problems when the individual reaches middle age. As children are at the start of a lifetime’s exposure to noise, they deserve particular protection.
The present keystone European standard on the safety of toys, EN 71-1: 2005 does not offer satisfactory protection against hearing impairment as it lacks requirements for continuous noise emitted by all toys. As a result, there are toys on the European market that might harm hearing if placed close to the ear for less than one minute. According to the new Toy Safety Directive (2009/48/EC), revised noise limits for children’s toys are to be incorporated in toy safety standards. In order to contribute to the work under Mandate M/445 “Safety of Toys” issued to this end, ANEC commissioned a study about the scientific background that resulted in the elaboration of better and more comprehensive European standards on noise emitted by all toys. ANEC used the results, due in to influence the revision of EN 71-1 currently taking place.
Internet is a pervasive technology, useful for everyday life as a source of information, as a communication tool, to access and deliver services, including public services and services of general interest, to benefit from education, training, jobs and leisure activities. It is becoming a crucial instrument to be fully integrated in society.
Since 2001, e-Inclusion has become a key objective of the overall European Social Inclusion Strategy. However, consumers with disabilities are still excluded from accessing the Internet because of inaccessible and unaffordable technologies. Indeed, the vast majority of websites and software technologies cannot be used by people with disabilities. ANEC has been calling to bridge this gap for many years now.
Web accessibility levels can be assessed either by a self-declaration of conformity or by a Third Party Declaration against relevant standards (e.g.: Web Content Accessibility Guidelines of W3C). Within the framework of Mandate 376 in support of European Accessibility requirements for public procurement of products and services in the ICT domain, there is a strong debate between industry and consumer representatives on which assessment method is the most appropriate model for ensuring the accessibility of web sites. ANEC decided to research how many websites claiming to be accessible according to relevant standards were in reality complying with these standards; and to specify how many of the compliant and the non-compliant web-sites self-declare their conformity and how many declare their conformity through an assessment by an independent third party.
Many of the tested web-sites, especially commercial ones, failed to meet accessibility guidelines. These included basic issues affecting perception such as text equivalence and operability such as keyboard only input with a total of five or less failures identified. Therefore, consumers and public authorities should not completely trust claims about website accessibility for people with disabilities. Only 3 websites out of 76 certified by a third party were really accessible, while none of the commercial websites out of 24 which self-declared, could be considered to be fully accessible. The study results further show that finding websites which self declare their accessibility is difficult since there is no directory for them unlike for certified websites, offered by the certification body. Lastly, bearing in mind that both certification and self declaration of accessibility are important strategies for promoting best practice and improving access opportunities by people with disabilities, the study report recommended that more positive action was needed to increase the number of leading commercial organisations to demonstrate a commitment to accessibility.
ANEC launched the study results at public event organised on 11 May 2011 by the European Standards Organisations about European Accessibility Requirements for public procurement of ICT products and services. ANEC will use the study results to contribute to the current work on web accessibility standardisation for the benefit of all consumers (M 376 standardisation mandate to CEN/CENELEC/ETSI in support of European Accessibility requirements for public procurement of products and services in the ICT domain).
In addition, the study results were also presented at the European Commission (EC) Workshop on eAccessibility and assistive technologies on 20-21 June 2011. Furthermore, ANEC contributed to the Commission Impact Assessment of a Web-Accessibility Act based on the results of our R&T study and other available studies.
Moreover to further follow up with our R&T study and to also investigate concretely on the problems websites could potentially have in terms of accessibility ANEC carried out a small survey in 2011. We contacted in October and November 2011 the websites tested and submitted to them a questionnaire by email and/or when an email address was not available, by completing a question form directly on the websites. ANEC queried whether taking into account accessibility standards meant additional costs and if it resulted in benefits. We also investigated on the reasons that motivated the websites to comply with accessibility standards and the problems they have encountered in doing so. The ANEC survey shows that the trigger behind accessibility is mandatory legislation and that most of the work is done in house.
Although we did not get evidence about the cross boarder aspects of web accessibility, we sent the results of our survey to DG INFSO as qualitative data and we received good feedback from them.
To raise international awareness and to present the work of ANEC to the research community, as well as to determine future directions of activity in web accessibility, ANEC attended the 9th Internationational Cross-Disciplinary Conference on Web Accessibility in April 2012 in Lyon where the Communications Paper: Keith S., Floratos N., Whitney G. (2012). Certification or conformance: making a successful commitment to WCAG 2.0., was presented by the study contractor on behalf of ANEC.
Requirements needed in European household appliance performance standards to improve the ease of use of certain appliances by older and disabled people
Although technology is improving access to many products, in the home it still falls short of enabling increased independence for disabled and older people. Domestic appliances should be easy to operate by the widest range of users, and even though ‘easy to use’ mainstream appliances are unlikely to meet the needs of severely disabled people, designs that address the needs of the majority of disabled people will be easier to use by non-disabled people too. An effective way to address the issue would be to include in the standards, requirements for the performance of the most commonly used electrical household appliances so as to improve the aspects that present problems. ANEC therefore suggested a project to determine the necessary values needed by older and disabled people for the use of household electrical appliances This project is to be seen as complementary to ANEC’s long-standing work on the revision of several Parts 2 of EN 60335 “Safety of household appliances” with respect to the safety of children and older persons and persons with disabilities (“exclusion clause”).
The ANEC study includes data indicating the forces and grip strengths needed by various groups of people to operate knobs, levers etc. of household appliances such as washing machines, dish washers, microwave ovens, irons, and small kitchen appliances. The October 2010 meeting of CEN/TC 122 “Ergonomics” heard first results from the ANEC R&T project and a similar presentation was made at the WG 11 of IEC TC 59 ‘Performance of Household Electrical Appliances’. As a consequence, the equivalent ISO Committee (TC 159) established a liaison status with ANEC.
One of the recommendations from the ANEC R&T project was to confirm its proposed values with panel testing comprising of a range of older and disabled users and various floor-standing and hand-held household appliances. The Loughborough University from UK is actually undertaking this follow up project which should be finalised and submitted to ANEC at the end of June 2011. The result showed that all of the users tended to prefer larger controls but because there were only 8 users surveyed and the data was qualitative with no anthropometric measurements, it was felt that the student research could not confirm the values. A second follow up project aiming to investigate the optimum ratio between the size of controls and the space between them to reduce errors when using appliances was conducted.
It was determined that all users have difficulties when the proportional distance is very low. Aesthetics were also taken into account, and it was recognized that the proportional distance between controls had a significant effect on the perceived attractiveness for each of the controls tested.
It is believed that the test method can be improved and recommended to look more in details at how the proportional distances related more closely to size controls and how the grip type is affected by size of control and how this affects the distance needed between controls.
The Project Contractor, who is also the ANEC representative in CEN TC 122 “Ergonomics” has also been invited to present the final R&T study results and the follow-up projects at the plenary meeting in April 2012.
Simpler rules for global toy safety?
In September 2010, ANEC published a position paper and the results of a R&T project on the possibility to streamline the legal and standardisation frameworks for toys.
Following the infamous “summer of recalls”, which exposed problems with toy safety caused by global supply chains, we commissioned a research project in October 2008 aimed at comparing the requirements of toy legislation in certain markets with the provisions of the ISO/IEC, ASTM and CEN/CENELEC standards for toys. In November 2008, we learned that a similar study was being conducted by the International Council of Toys Industries (ICTI). To avoid duplication, ANEC and ICTI agreed that ANEC would carry out a “peer-review” of the ICTI study to identify gaps and make proposals for improvement as needed. The study highlights that there are sufficient similarities among the standards, especially in requirements for mechanical and physical properties, for first steps towards a closer convergence to be possible. However, it notes the difficulties in achieving closer convergence beyond these first steps must not be underestimated. The convergence of the standards is dependent upon greater coherence of legislation which governs the production and sale of toys.
In the ANEC’s position, based on the study results, we note that not all countries accept the “precautionary principle” as a key element of their legislation, and see deep-seated differences in the application and scope of chemicals legislation. However, in making the report of the study publicly available, we (in association with ICTI) intend to provide a useful resource on the opportunities and challenges presented. The conclusions were presented to regulators at a meeting of the International Consumer Product Safety Caucus held in Brussels on 2 December 2010.
Pointing the way to more legible signs (Word version | PDF version)
More and more people are living to be older. Unfortunately, this trend is associated with a growing incidence of problems for people with impaired vision. Many signs in public buildings and public areas feature fonts that are too small or suffer from poor lighting and low contrast.
As access for consumers of all ages and abilities is a cornerstone of ANEC philosophy, we initiated a study to collect the scientific data needed to elaboration of a future standard for public signs. Forty-two volunteers (forty people with impaired vision and two controls) participated in the study. In a first experiment, participants had to identify signs, with different character sizes and contrast intensities, presented at the same location in their central visual field. In a second experiment, they had to search for a specific sign in a mixed visual environment and identify it. The response times and response accuracy were measured.
We will use the results of the study to lobby for the formulation of guidelines on the legibility of signs in public buildings as well as the elaboration of new standards.
Against a background of battling climate change and aiding sustainable consumption, increasing reference is made to the carbon footprint of products and services.
However, most carbon footprint schemes tend to ignore the environmental impacts of energy generation (e.g. nuclear power, non-sustainable renewable energy).
Building on the results of our 2008 study on benchmarks for environmental labels and declarations, we commissioned another study to determine the requirements for consumer information on Product Carbon Footprint (PCF or CO2). According to the preliminary findings, current CO2 labels fail to meet the need for easily understood information. One example is that they do not include a rating scheme which allows a consumer to see whether a product bearing the Carbon Footprint Label has a low level of greenhouse gas emissions or not. Consumers need to be able to choose the most environmentally-friendly product in order to contribute to reducing their impact on climate change. In addition, although PCF is a key indicator for some products or product groups, our study shows a comprehensive sustainability assessment cannot be carried out on the basis of the PCF alone. Tools such as life-cycle assessments, eco-efficiency and sustainability analyses are needed to complete the picture.
Younger children will climb on almost anything that attracts them. Hence it should be no surprise that falling is a major cause of injuries to children. In many standards for products associated with children, the risk of climbing is a safety issue that needs to be addressed. Since 2004, ANEC has been studying the climbing skills of children in order to gain a clearer understanding of how children learn to climb and what are their precise abilities. The study has shown the design of certain barriers, intended to prevent falls, may actually encourage falls through providing a framework on which a child can climb.
One of the most important functions of a child-safety barrier is to increase the time before a child is put at risk and to leave adults enough time to intervene. Until the ANEC study, it was thought that a simple barrier of 1,1m in height provided sufficient safety for children up to 5 years of age. However, the latest ANEC study has shown that a simple barrier of this height stopped less than half of the children tested.
A new design of barrier, different in design from most commercially-available today, is required. However, we will use the findings of the study in the immediate future to seek to improve the safety requirements of existing standards.
The delicacy of their skin and/or slower reaction times leave children, the elderly and people with disabilities at increased risk of burns in the household environment. The potential risks peak when the handles and knobs of household appliances (such as irons and toasters) are too hot. In 2007, CENELEC Guide 29 ‘Temperatures of surfaces likely to be touched - Part 1: Temperatures of hot surfaces’ was issued, at the request of the European Commission, to tackle the problem of hot surface temperatures. The first occasion to implement Guide 29 occurred in the framework of work in CENELEC TC 61 WG 4, set up to deal with the use of domestic appliances by vulnerable consumers. However, this group did not agree to lowering the surface temperature limits in existing standards in line with Guide 29.
In order to overcome the objection, ANEC commissioned a study where a total of 16 people tested six appliances. The adult participants all had at least one physical impairment to their hands (such as arthritis) which mildly affected their ability to use domestic products. During the tests, hot surface temperatures in some products were recorded but participants did not tend to touch those parts. Interestingly, the ANEC project demonstrated that the lower temperature limits of Guide 29 were respected on the whole by the products tested. Therefore, the lowering of the limits in the existing standards should not cause a problem for manufacturers.
Our findings were presented at an open session of the LVD-ADCO meeting on 1 December 2009 in Luxembourg. Member States welcomed the study results and asked that their concerns about the high temperature limits in existing European Standards be conveyed to CENELEC.
Previous Child Safety, Design for All and Domestic Appliances projects included proposals for the revision of the Part 2 standards to the EN 60335 series in order to address the safety needs of children, the elderly and people with disabilities.
The EN 60335 series of standards is used to support legislation on the safety of domestic appliances. The proposed changes cover both safety issues that are common with those previously raised in reviews of other Parts 2 standards and further safety issues which are specific to these particular standards.
The study prepared ANEC proposals for revision of these Part 2 standards: -15 on kettles, -24 on fridge freezers, and -30 on room heaters. These were submitted to the CENELEC TC 61 WG 4 meeting on 30 June - 2 July 2009.
Our 2009 study additionally prepared hazard tables for the Part 2 standards: -27 on skin exposure to UV and IR; -40 on air conditioners and heat pumps; -43 on clothes driers and towel rails; -55 on electrical appliances for aquariums and garden ponds; -75 on commercial dispensing and vending machines; -82 on amusement machines and personal service machines; -8 on hair clippers and shavers). The hazard tables aim at developing standardisers’ understanding and ability to identify the main hazards that vulnerable people might face when using the appliances.
For example, young children would not be expected to use air conditioners without supervision. However, as these appliances are often located at floor level and tend to run continuously or for long periods, it has to be taken into account that young children may come into contact with them. Hence it is important for manufacturers to take into account the risk of a child’s finger entering the appliance. Noise levels should also be addressed as the noise (or vibration) of such appliances can affect those with hearing or neurological difficulties.
ANEC research project on Environmental product indicators and benchmarks in the context of environmental labels and declarations
The goal of the study was to investigate Life Cycle Assessment (LCA) methodology with respect to its suitability for labeling, product differentiation, and benchmarking, and to give proposals as to how its inherent shortcomings could be solved. Further, the study looked at the basic problems related to carbon footprinting.
This ANEC study shows that indicators based on LCA methodology may not be the best option to suitably characterise and declare the environmental performance of a product. ANEC has for long questioned the usefulness of so-called Environmental Product Declarations in facilitating consumers’ purchasing decisions and has therefore developed alternative concepts. While LCA methodology offers unique advantages such as comparisons of system alternatives or providing orientation, it also suffers from serious limitations including omissions of many relevant environmental aspects (e.g. site-specific emissions such as noise, or non-quantifiable impacts such as biodiversity) and low accuracy and reliability of data. Hence, in many cases significant production or use phase indicators (e.g. energy efficiency, indoor emissions) derived from a variety of tools (e.g. chemical risk assessment) are a better choice for product labelling as these allow for differentiation of similar products compared to LCA indicators. A process for the identification of all relevant environmental aspects on a product by product basis, and involving all relevant stakeholders, is proposed. The study also identifies some of the particular challenges posed by carbon footprints, including disregarding other environmental aspects, and overlooking efficiency or the various energy mixes.
The objective of this project was to review the EN 60335 series of standards used to support legislation on the safety of domestic appliances in order to make them safe for children and older and disabled people, who are currently excluded from these standards (“exclusion clause”).
This project prepared six revised Parts 2 of EN60335 (-2 vacuum cleaners and water-suction cleaning appliances, -3 Irons, -7 -6 Cooking Appliances, -23 appliances for skin and hair, -52 oral hygiene appliances) which were circulated to CLC TC 61 National Committee for comments. ANEC also submitted tables with hazards, risks and requirements that are specific to children, elderly people and disabled people, and that may have not been covered by the safety requirements within the EN 60335 Parts 2 standards. As an example, the ANEC study suggests that entanglement should be considered within the standards. Indeed, although this may present a low risk and adults should avoid the situation from occurring, the hazard is relevant to very young and young children who may manage to wrap a connected main cord around their neck. Tripping hazard from feet entanglement was also included in the study. Moreover, the contractor was asked to review and propose improvements to seven other parts of EN 60335 (2-5 Dishwashers, 2-11 Tumble driers, 2-13 Deep fat fryers, 2-15 Kettles, 2-24 Refrigerators, 2-30 Room heaters, 2-80 Fans) to make these standards more accommodating towards the safety of children and older or disabled people.
Executive summary of joint ANEC, BEUC, Defra, EST, NCC research on consumer perceptions of the EU Energy Label layout
Full summary of joint ANEC, BEUC, Defra, EST, NCC research on consumer perceptions of the EU Energy Label layout
The aim of this joint research project, released in October 2008, was to collect consumer views in Member States on the extent of consumer recognition of the current EU Energy Label, and on whether they prefer the current A-G layout to a numerical label proposed by the industry (a 7-1 scale and a 9-3 scale given as examples). The research was carried out in the context of the ongoing revision of the EU Energy Labelling scheme and, in particular, the discussions on possible changes to the familiar A-G layout. The market research was carried out in seven Member States (Denmark, France, Germany, Italy, Netherlands, Poland, UK) in May 2008, with the results clearly showing that an overwhelming majority of consumers across all studied Member States preferred the A-G layout.
The purpose of this research project, issued in June 2008, was to explore the potential of standardisation in order to address the threats and opportunities presented to consumers by Radio Frequency Identification (RFID). The research showed the majority of European consumers know very little about RFID. The study found many of their concerns surrounding RFID were the same: privacy, security and transparency of deployment. It may be that standards are needed to make RFID deployment both secure and compatible with this legislation, but a first step is to ensure the law is applied to RFID systems in a way that best defends the consumer interest.
Dimensions and design of swimming pool fences and balcony and stair barriers to protect children from falling and from passing through, below or above (Part 1, Part 2, Part 3)
Often fatal accidents result from children falling through these barriers and fences. There are a variety of regulations and standards in different EU countries covering these products. ANEC commissioned a research project on the dimensions and design of balcony barriers and swimming pool fences. Following desk research, tests were carried out with around 100 children, the main purposes being to determine the height requirements related to the age of the child; testing some of the most common solutions used to discourage a child’s ability to climb and determining the main factors associated with a child’s ability to fall or pass through a barrier or fence.
Benchmarking and additional environmental information in the context of Type III Environmental Declarations and Annex
Considering the efforts underway to promote sustainable consumption and production at the EU level, it is crucial to ensure that consumers are given the tools to make informed choices. This research project, published in June 2008, shows alternatives to the present Environment Product Declarations (EPDs) by adding consumer-relevant information and presenting the data in a new format. The proposed new format displays life cycle indicators by normalising the environmental impacts of an average product to the impacts caused by an average citizen. This information is shown using a graded, colour-band scale similar to the EU Energy Label. Reference is also made to the criteria used in Type I eco-label schemes, where these are available, and a simple green-red colour code shows whether the criteria are fulfilled or not.
This research project, released in June 2008, was meant to improve the understanding of how children aged three years or less are best restrained in cars. The study examined the hypothesis that keeping children rearward facing until they are four years old would be the best method of improving protection for this age group. To this end, US, Swedish and UK data were analysed and showed that children in forward-facing seats suffer head, neck, chest and abdominal injuries in circumstances in which a rearward facing restraint would have provided much better protection. The study concludes, together with all other researchers who have examined this topic, that the rearward-facing restraints offer a higher level of safety over forward-facing restraints to children until they are four years of age, and many fatalities could have been prevented had the use of rearward-facing restraints been more widespread.
ANEC has been promoting (under the umbrella of Consumers International (CI)) the superior protection of children travelling rearward facing in cars until they are 4 years old at the UNECE (United Nations Economic Commission for Europe) Working Party on Passive Safety (GRSP). It was further to the proposal by France and ANEC/CI to set up a new group (Informal Group on child restraint systems (CRS)) in May 2007 that the GRSP kicked off the informal group officially in December 2007. The conclusions of the ANEC study were presented to the Informal Group to lobby for increasing the age of rearward-facing transport of children. In November 2012, the UNECE World Forum for the Harmonisation of Vehicle Regulations (WP 29) adopted the new regulation on CRS (i-size), which the Informal Group on CRS had developed in more than 30 meeting over 4 years. The i-size regulation to which ANEC contributed actively will be implemented as of mid-2013 and requires the mandatory rear-facing transport of children up to 15 months of age.
Web Accessibility in context: an investigation into standardisation issues (Word format)
Web Accessibility in context: an investigation into standardisation issues (PDF format)
The purpose of this study, released in April 2008, was to examine the gap between design practice and the guidance offered through standardisation. Against the background of a very low rate of accessible commercial websites - especially ones owned by small companies such as hotels and restaurants - the study recommends that further action be taken to work with the standardisation bodies in order to harmonise guidance from the most basic level of creating small non-interactive websites, both in relation to the authoring tools used by the developers and the user agents used by the consumer (including assistive technology tools and the browsers). It is also recommended that action is needed to evaluate and certify web-authoring tools and user agents to ensure that companies have the opportunity to buy tools that help to deliver accessible content and reduce uncertainties.
• Swing impact test in EN 71-8 (round-robin test)
• EN 1177: Round-robin test for impact measurement on playground surfacing material (Annex 1, Annex 2 and Annex 3)
• Services standards: defining the core consumer elements and their minimum requirements
• Review of the state of knowledge regarding the safety, access and usability of needs of children with disabilities
• Review of the range of activity throughout member states related to compliance with the EU energy label regulations
• Exclusion clauses in electrical product standards (revision of standards) Conclusions and Appendixes (Appendix 1, Appendix 2 and Appendix 3)
Reports of studies from previous years (as listed below) are available upon request from the ANEC Secretariat:
• Exclusion clauses in electrical product standards (revision of standards) Conclusions and Appendix 2 Bibliography
• Battling Spam through standards:
-Executive summary of main findings
-Report on ’The Standards for Requirements for Consumer Internet Filtering Tools’
-Report on ’Internet Content Filtering: A Case for Standardisation’
• Exclusion clauses in electrical product standards (legal assessment)
• The suitability of eco-label criteria to derive environmental baseline requirements applicable to all products on the market: Part II: specific requirements for dishwashers
• Climbing skills of children– part 1 and Appendix
• The child exclusion clause in electrical product standards (data collection)
• Review of the CEN Environmental Helpdesk
• Child protective products
• The suitability of eco-label criteria to derive environmental baseline requirements applicable to all products on the market: Part I
• Strength of car rear seats
• Packaging of medicine and the safety of children