Mark Norcliffe’s email last week referred to “new guidance from the GGF” regarding the supply of low sightline IGUs (LSIGUs) without the required certification. For the avoidance of doubt, there is no new guidance, the statements issued are merely reiterating the position to members and industry that in order to satisfy the legal requirements of the Construction Products Regulations (CPR) any LSIGUs placed on the market must have test evidence to EN1279 parts 2 & 3 with a corresponding system description under EN1279-1 ensuring the test reports furnished are indeed for the reduced sightline units being supplied and not for standard units – a ploy that is used by some firms to trick customers for commercial gain. The statements are also clear in confirming that derogations cannot be claimed under article 5 for any IGUs, not just LSIGUs.
Mark also states “the GGF’s new guidance is a positive contribution to the debate.” There is no debate – this is the law. In simple terms any firm supplying LSIGUs is either complying with the law or breaking it and a successful prosecution for breaching CPR can carry a three month custodial sentence and a £5,000 fine or both. Our greater group operates in the transport industry which is also regulated and I can’t help but draw the following comparison: You are driving an 18 tonne lorry and waved into a VOSA inspection point by a traffic cop and asked for your licence but you only have a licence to drive a car, would any of the following responses be entertained?
- I thought my car licence would cover me
- I’ve been driving for over 30 years and have had very few accidents
- I’m always extra careful when driving the lorries
- A planning officer at the council asked me to drive the lorry so I thought that would be ok
Of course they wouldn’t, so why should policing of our industry be any different? Staying in the same vein, we’ve heard some companies try and further cloud the issue by saying “are you glazing your heritage units correctly?” A bit like asking “have you checked your wheel nuts are securely tightened after fitting baldy tyres to your vehicle?” What difference does it make how well they’re fitted if the units or tyres are illegal in the first place?
To quote the title of Mark’s email from last week: “Don’t push your luck with low-sightline heritage IGUs!”