Regulation 4 compliance clarification
Building Services consultants and other water equipment specifiers are encouraged to get fully up-to-speed with the Water Supply (Water Fittings Regulations 1999) with particular focus on the requirement of Regulation 4.
Promoting the efficient use of water, safeguarding water supply, setting legal requirements, and of course, protecting public health is a top priority for the British Pump Manufacturers Association (BPMA), whilst ensuring a fair and level playing field for its members. Unfortunately, and for quite some time, the BPMA has been receiving feedback from member companies that there has been a degree of misunderstanding in the water sector regarding certification for products for use in the water supply. As such, it has been actively pushing for change in this sector by lobbying the UK Government and other interested parties.
In essence, there are currently three (3) relevant approval/certification schemes operating in the UK for Regulation 4 compliance in relation to water fittings and components. These are NSFreg4, WRAS, and KUKreg4, with the latter being a member of the BPMA. All three schemes provide the legally required testing and certification demanded by Reg 4, and therefore offer the exact same levels of product approval, and with it the much-valued level playing field. The BPMA, therefore, approves the use and adoption of each and any of these approval/certification schemes, and their full acceptance by customers.
The advantages of the KUKreg4 route
All certification decisions are made within Kiwa, so they can deliver an immediate certification decision, with no cut-off dates for approvals or application submissions, and with no hidden external fees. A particular benefit is that in some circumstances the testing can be cross-referenced with existing Kiwa certificates or equivalent BS and EN standards to demonstrate compliance with Regulation 4 enabling a KUKreg4 certificate to be issued without the cost and time of repeat testing. Additionally, there is an option under KUKreg4 1+ Certification for avoiding cyclic 5-year full retests by means of annual surveillance of the manufacturing facility.
This more efficient route to compliance means new high-efficiency products can be launched to the market far quicker, without the delays previously associated with the approvals process, allowing the all-important energy savings to be realised much sooner by both the end-user and the environment.
For many years, M&E consultants and other water equipment specifiers have been saying to BPMA members, and other suppliers, that the pumping equipment being provided must be WRAS approved. This is simply not the case. WRAS is just one of the three certification schemes available in the UK and any one of them can offer the same level of compliance certification with Reg 4. Manufacturers are under no obligation to be WRAS approved. It should also be noted that within the WRAS scheme, the decision-making of the final approvals no longer involves the water companies, which again helps to ensure a level playing field for all parties.
In keeping with this clear guidance, it is good to see that many manufacturers are now correctly highlighting that their products meet the requirements of Regulation 4 Compliance, rather than simply citing the certificate issuing body. We can only hope that more companies will follow suit, ensuring the market becomes better advised, and the resulting brand awareness helps to increase Water Regulation 4 compliance across the sector. It is a matter of compliance being the key requirement, ahead of any approval/certification body being used to certify that compliance. Some will remember the evolution of Corgi to Gas Safe, or even the Hoover/vacuum cleaner situation, and in many ways, this has not been dissimilar – branding vs attainment.
Just to be clear, the water supply (water fitting) regulations require that:
4.(1) Every water fitting shall be of an appropriate quality and standard and be suitable for the circumstances for which it is used.
4.(2) For the purposes of the regulation, a water fitting is of appropriate quality or standard only if:
A) It bears an appropriate UKCA or CE mark,
B) It conforms to an appropriate harmonised standard,
C) It conforms an appropriate British Standard,
D) It conforms to a specification approved by the regulator.
The enforcement of the Water Regulations is a statutory responsibility of the water authorities, and they employ water regulation inspectors to attend sites and examine water systems to ensure compliance. Water authorities are now stating that products must be compliant with Water Regulation 4, not simply WRAS approved.
So going forward, it is no longer appropriate to make any reference to products or materials being compliant with WRAS approval. It should be stated that products are Regulation 4 compliant or where appropriate Reg 31 compliant.