Standards

Do you know the difference?

Unfortunatly, you cannot always tell by looking. This creates some additional confusion, since one cannot assume that a badly-shaped "CE" mark indicates a fraudelent Chinese mark. According to Wikipedia,

In 2008, a logo very similar to CE marking was alleged to exist and to stand for China Export because some Chinese manufacturers apply it to their products. However, the European Commission says that this is a misconception. The matter was raised at the European Parliament in 2008. The Commission responded that it was unaware of the existence of any "Chinese Export" mark and that, in its view, the misunderstanding had arisen because a producer had failed to respect the precise dimensions and proportions of the mark as prescribed in the legislation. The Commission was also aware of fraudulent misuse of the mark on products that did not comply with the standards, but that this is a separate issue. It had initiated the procedure to register CE marking as a Community collective trademark, and was in discussion with Chinese authorities to ensure compliance with European legislation. Chinese (and other non-EU) manufacturers are permitted to use the CE mark provided that the goods have been manufactured in accordance with the relevant EU directives and regulations.

Nevertheless, and despite the Commission's assurance that it is without foundation, this urban myth continues to be available on many websites.

For example, I have some Czech devices that seem to have "China Export" marks rather than Conformité Européene marks. These Czech devices are numbered 1019. The legitimate Notified Body #1019 is VVUÚ, a.s. in the Czech Republic, and they are also legislated for Regulation (EU) 2016/425 Personal protective equipment. In these cases, the CE mark is legitimate (see the VVUÚ, a.s. PPE List), but the printed mark is distorted. By extension, identical devices by the same manufacturer but sold under other brand names would also have legitimate CE approval.

China produces some devices with fraudulent CE certification. For example, all Chinese Notified Body #1282 marks on vertical equipment are fraudulent. Ente Certificazione Macchine is Notified Body #1282, and they do not certify this type of gear.

In recent years, manufacturers are printing extensive reading material on their devices, and it isn't to relieve boredom. Much of the excessive writing refers to device certification to some standard. Most users probably don't have a clue what these cryptic standards really mean. If you guess that lawyers are involved, you may very well be right.

As I see it, there are two extreme types of users:

• Those who know what they are doing, care very much about how well a device works and don't care at all about the device’s certification.
• Those who don't know what they are doing, don't care at all about how well a device works, and only care about the device’s certification.

No intelligent person is quite at either of these extremes, but I think that recreational users are best served by views closer to the first bullet, and professionals are required by legal concerns to think closer to the second. These professionals might be surprised if they knew who prepared some of these standards.

I am a recreational user who is more concerned about how well a product performs in the field than I am about how well it tests in the lab; however, I agree that some testing is essential. As a registered professional engineer with more than four decades of experience, I understand the value of well-designed standards. As a vertical caver who started more than five decades ago, I have yet to be convinced that the existing standards are well-thought-out or that they address the most appropriate factors. My engineering mind sees the current standard situation as a contorted mess. Maybe I'm missing something and maybe I'm wrong, but I'm not impressed and so I tend to dismiss them. My comments should be viewed in that context.

Anyone who cares at all about certification ought to at least have an idea what the certification means, so I've prepared the following summary of some of the standards:

• EN 353-1:2014:
  Personal fall protection equipment — Guided type fall arresters including an anchor line
  Part 1: Guided type fall arresters including a rigid anchor line
  • This European Standard specifies the requirements, test methods, marking, information supplied by the manufacturer and packaging for guided type fall arresters including a rigid anchor line.
  • Multi-user applications, i.e. rigid anchor lines that allow more than one user to be attached at any one time, are not addressed in this document.
  • The line part of a rigid anchor line shall be made of a rail or a wire rope.

Prepared by: Technical Committee CEN/TC 160 “Protection against falls from height including working belts”

Comments:

• Except for via ferrata, these do not normally appear in recreational caving and climbing.

• EN 353-2:2002:
  Personal protective equipment against falls from a height —
  Part 2: Guided type fall arresters including a flexible anchor line
  • Specifies the requirements, test methods, etc. for guided type fall arresters including a flexible anchor line which can be secured to an upper anchor point.
  • A flexible anchor line shall be a synthetic fibre rope or a wire rope.
  • Refers to other standards for defining the test methods.
  • Requires the manufacturer to provide 20 pieces of information

Prepared by: Technical Committee CEN/TC 160 "Protection against falls from a height including working belts"

Comments:

• These do not normally appear in recreational caving and climbing.

• EN 564:2014:
  Mountaineering equipment - Accessory cord - Safety requirements and test methods
  • Requires kernmantel construction 
  • Defines allowed diameters for accessory cord
    • The standard only allows 4, 5, 6, 7, and 8 mm. accessory cord
    • Defines how to measure the diameter
    • Allows a rather large variation: -0.2 mm. to +0.7 mm about the nominal diameter
  •  Defines a minimum tensile strength for each permitted diameter.
    • Only requires testing one sample
  • Requires measuring the mass per unit length
  • Requires labeling the packaging with six different pieces of information,
  • Requires supplying a leaflet in the destination state’s language containing 15 pieces of information.

Prepared by: Technical Committee CEN/TC 136, "Sports, playground and other recreational facilities and equipment."

Comments:

• Really, only one sample test, ever? From an engineering perspective, a single strength test is essentially useless. I would like to see several samples tested and, as a minimum, the mean, standard deviation, and range reported. I would like to see some requirements for retesting at appropriate intervals.
• The manufacturer is required to report "the tensile strength that the manufacturer ensures at the time of manufacturing" but not necessarily the results of any tensile strength testing.

• EN 567:2013:
  Mountaineering equipment — Rope clamps — Safety requirements and test methods
  • Requires a locking device, normally known as a "safety," that, when closed around a rope, prevents the unintended removal of the rope from the rope clamp. [I smell a lawsuit coming since nothing can "prevent" successful stupidity.]
  • When tested, the clamp must have a 13 mm. or larger attachment hole, with specified edges.
  • When tested, rope clamps shall not completely break the rope or accessory cord.
  • Defines a strength test with specified limits.
    • The clamp cannot detach under a specified load.
  • Defines a "pushing test."
  • Defines a "pulling test."
  • Specifies four items to be marked on the device

Prepared by: Technical Committee CEN/TC 136 “Sports, playground and other recreational facilities and equipment”

Comments:

• We call normally these rope clamps "ascenders"
• This European Standard applies to rope clamps used with dynamic mountaineering ropes according to EN 892 or accessory cord according to EN 564 and low stretch kernmantel ropes according to EN 1891.
• Two strength tests: one with the maximum rope size (determined by the manufacturer) and one with the minimum.
• Allthough the damage cannot be visible, clamps can severly damage the rope and still pass, they just cannot break it.
• The "pushing test" does not seem to correlate with any normal usage. It is merely ascender abuse.
• The "pulling test" is also an abusive test, but could have some relavence when using fixed lines in mountaineering.

• EN 892:2012
  Mountaineering equipment - Dynamic mountaineering ropes- Safety requirements and test methods
  • Defines:
    • Single rope (informally, capable of being used singly to arrest a leader’s fall)
    • Half rope (informally, capable of being used in pairs to arrest a leader’s fall)
    • Twin rope (informally, capable of being used in pairs run parallel (together) to arrest a leader’s fall)
  • Requires kernmantel construction
  • Defines how to measure the diameter
  • Defines allowed sheath slippage when tested with a rather specific apparatus that does not match typical climbing equipment.
  • Defines a standard drop test for each type of rope (single, half, twin)
    • Defines allowed peak force
    • Defines minimum number of drops
    • Defines allowed elongation on first drop.
    • Requires testing three samples.
  •  Defines a minimum tensile strength for each permitted diameter.
    • Only requires testing one sample sample
  • Requires measuring the mass per unit length
  • Requires labeling the rope with five pieces of information
    • including an icon indicating whether it is:
      • single rope 1 ("1" inside a circle)
      • half rope ½ ("½" inside a circle)
      • twin rope ∞ (two linked circles inside a third circle)
  • Requires supplying 20 pieces of information along with the rope 

Prepared by: Technical Committee CEN/TC 136, "Sports, playground and other recreational facilities and equipment."

Comments:

• The drop test is the most important one for me. While the standard drop is not a realistic representation of falls in the field, it is reasonably conservative.
• The danger in reporting the number of drops before failure is that many users don't interpret this correctly - ropes should be retired after sustaining any hard fall, and only experience can define what constitutes a "hard" fall.
• The peak forces allowed during the drop test (nominally 12 kN or 2700 lbf for single ropes and twin rope pairs, 8 kN or 1800 lbf for half ropes) are high enough to severely injure a person; however, the test arrangement is not representative of field conditions and should not be used to infer what a person would sustain. I think that these limits are reasonable in the sense that they are consistent with the goal of the rope not being the weak link in the chain.

• EN 1891:1998
  Personal protective equipment for the prevention of falls from a height - Low stretch kernmantel ropes
  • Defines:
    • Type A rope (informally, designed for general use in rope access, rescue, and caving)
    • Type B rope (informally, lower performance than type A, requiring greater care in use)
  • Requires kernmantel construction with virgin synthetic fiber with melting point > 195 °C
  • Defines tests and limits for
    • Rope diameter
    • Knotability
    • Sheath slippage
    • Elongation
    • Percent of material in core and sheath
    • Fall arrest peak force
    • Drop test
    • Static strength
  • Defines tests but no limits for
    • Shrinkage
    • Mass per unit length
  • Requires labeling the rope end with "A" or "B" and the number of the standard
  • Requires four pieces of information labeled every 1 m.
    • Requires supplying 25 pieces of information along with the rope 

Prepared by: Technical Committee CEN/TC 136, "Sports, playground and other recreational facilities and equipment."

Comments:

• My first issue with this standard is its title. My normal uses for static kernmantel ropes is as rappel lines, not as "personal protective equipment for the prevention of falls from a height." From the very start, this standard does not address my applications.
• In practice, protecting the rope from abrasion and cutting is far more important than anything tested in the standard; however, I see no practical and meaningful way to incorporate this need into the standard.
• The static strength test is the important test.
  • I think that the Type A limits in the standard (nominally 18 kN or 4000 lbf) are acceptable. Practical ropes are significantly stronger.
  • The type B limits (nominally 12 kN or 2700 lbf) are lower than the EN 564:2014 limits for 8 mm. accessory cord. I do not like the Type B rope provisions in the standard and would prefer to eliminate the idea of standardizing a low-strength alternative.
  • I am not a member of the "Bigger is Better" crowd. Once a rope has a certain minimum strength - and all reasonable quality nylon ropes larger than about 9 mm. will be strong enough - I don't pay much attention to the actual number.
  • I would like to see some requirements for retesting at appropriate intervals, the purpose being to ensure that the manufacturer continues to supply a quality product.
• The knotability test is pointless. It tells me nothing that I cannot better determine by having the rope in my hands.
• The sheath slippage test uses a rather specific apparatus that does not match typical climbing equipment.
• The melting point > 195 °C effectively rules out polyethylene, polypropylene, and similar fibers. My experience with ropes made from these fibers is that they glaze too easily on rappels that would not damage nylon ropes.

• EN 15151-1:2012:
  Mountaineering equipment - Braking devices
  Part 1: Braking devices with manually assisted locking, safety requirements and test methods
  • Defines and applies to four different device types:
    • Type 5: devices for abseiling without a panic locking element
    • Type 6: devices for belaying and abseiling without a panic locking element
    • Type 7: devices for abseiling with a panic locking element
    • Type 8: devices for belaying and abseiling with a panic locking element
  • Defines tests and limits for
    • Static load (nominally 2 kN or 450 lbf)
    • Static strength (nominally 8 kN or 1800 lbf)
    • Drop test
    • Static strength
  • Requires marking the device with six different pieces of information,
  • Requires supplying a leaflet in the destination state’s language containing 15 pieces of information.

Prepared by: Technical Committee CEN/TC 136, "Sports, playground and other recreational facilities and equipment."

Comments:

• I like breaking the EN-15151 standard down into eight types of devices, but I doubt that most end users know the category that their device was tested to and limit their uses accordingly. I'm just as guilty here as the next person.
• The test limits seem reasonable to me but they do not align with other standards.
  • These devices are tested to limits that are reasonable when the device is used to support a single person.
  • The static strength requirements are much less than the forces EN 892:2012 allows while catching a fall. In other words, ropes are permitted to generate higher shock loads than belay devices are required to survive.
  • There is nothing in this standard that addresses using the device to support multiple people (say, during pick-offs).
• The static strength test setups in EN-15151 parts 1 and 2 are quite different, so the results for devices tested to different parts should not be compared with each other.
• This standard is responsible for the book-with-an-"i" icon.

• EN 15151-2:2012:
  Mountaineering equipment - Braking devices
  Part 2: Manual braking devices, safety requirements and test methods
  • Defines and applies to four different device types:
    • Type 1: devices for abseiling without a function to adjust the friction
    • Type 2: devices for belaying and abseiling a function to adjust the friction
    • Type 3: devices for abseiling with a function to adjust the friction
    • Type 4: devices for belaying and abseiling with a function to adjust the friction
  • Defines tests and limits for
    • Static strength (nominally 7 kN or 1575 lbf for single ropes and twin rope pairs, 5 kN or 1125 lbf for half ropes)
    • Drop test
    • Static strength
  • Requires marking the device with six different pieces of information,
  • Requires supplying a leaflet in the destination state’s language containing 16 pieces of information.

Prepared by: Technical Committee CEN/TC 136, "Sports, playground and other recreational facilities and equipment."

Comments:

• I like breaking the EN-15151 standard down into eight types of devices, but I doubt that most end users know the category that their device was tested to and limit their uses accordingly. I'm just as guilty here as the next person.
• The test limits seem reasonable to me but they do not align with other standards.
  • The static strength test setups in EN-15151 parts 1 and 2 are quite different, so the results for devices tested to different parts should not be compared with each other.
  • These devices are tested to limits that are reasonable when the device is used to support a single person.
  • The static strength requirements are much less than the forces EN 892:2012 allows while catching a fall. In other words, ropes are permitted to generate higher shock loads than belay devices are required to survive.
  • There is nothing in this standard that addresses using the device to support multiple people (say, during pick-offs).
• This standard is responsible for the book-with-an-"i" icon.

Some other marks you may see…

CSA Group certification mark. CSA Group is recognized by ANSI and OSHA. This mark Indicates that the product was tested and has met the certification requirements. These include standards written or administered by the American National Standards Institute (ANSI), Underwriters Laboratories (UL), CSA Group (CSA), NSF International (NSF), and other North American and global organizations.

Eurasian Conformity mark (Russian: Евразийское соответствие), a certification mark to indicate products that conform to all technical regulations of the Eurasian Customs Union. For our purposes, the appropriate regulations are often those of TR CU 019/2011 "On safety of personal protective equipment."

Russian Conformity Mark. This mark was affixed to products subject to mandatory conformity assessment according to the Russian national standards (GOST R) or Russian technical regulations. Superceded by the Russian Market Circulation Mark in 2021.

Russian Market Circulation Mark. This mark is affixed to products subject to mandatory conformity assessment according to the Russian national standards (GOST R) or Russian technical regulations. Replaced the Russian Conformity Mark in 2021.

Ukrainian Conformity Mark. This mark is affixed to products that meet mandatory requirements of technical regulations for which the legislative acts of Ukraine established mandatory declaration.

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