EN 14041:2018 – (part 2) Emissions and Dangerous Substances

Lucy Cove explains the changes made to the EN14041 standard for 2018

The European Standard EN 14041:2004 detailed the health, safety and energy saving requirements for resilient, textile and laminate floor coverings and was used to evaluate the conformity of products for CE marking and labelling, as required by The Construction Products Regulation (EU) No 305/2011.  In February 2018, an updated version of the standard was published.  One of the key changes implemented in this revision is the expansion of Clause 4.2 to include a wider range of restricted chemicals. This clause has now been re-named “Content of dangerous substances” to reflect this. Changes have also been made to Clause 4.3, which covers requirements for emissions of volatile chemicals into indoor air. This article will discuss these amendments and their importance for suppliers.
Clause 4.2- Content of dangerous substances

The substances restricted under the revised Clause 4.2 are listed in Table 4 of EN 14041:2018, and are summarised in Table 1. These are all chemicals which are known to have detrimental effects upon human health.

In some cases, such chemicals may be deliberately added to a material to serve a specific purpose. An example of this is the use of phthalate plasticisers in the manufacture of flexible PVC. Studies have shown that phthalates can be absorbed through skin contact over time, and they are suspected of causing disruption to the endocrine system. This can have severe effects upon the development of young children.

Other substances which may be intentionally added during manufacture include lead and cadmium, which can be used as stabilisers or pigments in plastics. These metals are highly toxic if ingested, with children being particularly vulnerable to the effects of lead poisoning. Dangerous substances can also be present in the raw materials from which a product is made, or even be applied to the final product itself. For instance, the restricted chemical pentachlorophenol (PCP) is a highly effective anti-fungal treatment which is widely used as a preservative for wood. However, long term exposure to even small concentrations of PCP can cause damage to the liver and kidneys.

Whilst many of the substances listed in Table 1 can be deliberately introduced to the product, a select few can be present unintentionally, either through degradation of chemical constituents or contamination. One example is the breakdown of some azo dyes, which are frequently used to colour textiles. Under certain conditions, these can react to form aromatic amines, several of which are known to be carcinogenic. Other carcinogens which can be present in polymeric flooring are polycyclic aromatic hydrocarbons (PAHs), which can arise from carbon black fillers or pigments, and from contamination of extender oils during the manufacture of plastics.

Table 1 also specifies the different types of flooring that each substance is applicable to, as some chemicals will not be present in certain materials, due to the manufacturing processes used. For example, laminate flooring has no requirement for azo colourants, as these dyes would not be used on plastic materials.

Ensuring compliance
EN 14041:2018 outlines a number of ways to demonstrate compliance. One approach is to use declarations of conformity from manufacturers. To ensure traceability, such declarations must be provided in writing, and should include the name of the supplier and material, along with details of its use in the finished product. The document should state whether each of the substances listed in Table 4 of EN 14041:2018 is known to be present, and specify the amount in mg/kg. If declarations prove that none of the constituents contain dangerous substances, and that these have not been added during the production process, the product may be declared as “compliant- not actively added”.

Where declarations indicate that restricted chemicals have been added, this information can be used to determine whether the finished product will comply with the requirements of the standard.  By multiplying the amount of a given substance present in a material by the amount of that material used, it is possible to determine the amount of the substance incorporated into the final product. Where the substance is present in multiple materials, the amount in the finished product is equal to the sum of their contributions. A similar technique can be used where substances are introduced during the manufacturing process, though in this case, the amount of the substance which is consumed during the process must also be accounted for. Where information about the use of restricted substances is available, this can be supplied to a notified body such as SATRA to evaluate whether the product meets with the requirements of the standard. If this method is used, the product may be stated to be ‘compliant- actively added’.

The use of declarations to show compliance requires a detailed knowledge of the supply chain, and excellent communication throughout all stages to ensure their accuracy. An alternative is to conduct chemical testing on the finished product. This also has the added advantage of proving that dangerous substances are not present as a result of contamination. However, it is important to consider that changes to both the composition of the product and the manufacturing process could affect the performance, rendering previous test results invalid. For this reason, if any such changes are made, the modified product must be tested again to ensure that it remains complaint. Products should also be subjected to regular check testing to demonstrate ongoing conformity to the standard. EN 14041: 2018 states that products must be tested for content of dangerous substances once every five years.

Clause 4.3- Emission of dangerous substances into indoor air
The 2018 revision has also amended the requirements concerning the emission of chemicals into the air. Formaldehyde and other volatile organic compounds (VOCs) can be released from materials over time, circulating in the air, which can be breathed by individuals. Formaldehyde is a particular cause for concern, as this chemical can trigger or aggravate respiratory problems such as asthma.

Under Clause 4.3, a product can be classified as either E1 or E2 for formaldehyde emissions, with E1 having less than 0.12mg/m3 released when tested to in accordance with EN 717-1 or EN 16516. Any materials which exceed this level would be classified as E2. If it is known that formaldehyde is not present in any raw materials, and is not used at any stage of the manufacturing process, the product may be declared as E1 without the need for testing. As with the dangerous substances listed in Clause 4.2, this requires declarations to be made in writing to maintain traceability. However, this manner of classification cannot be applied to VOCs, due to the broad range of compounds that the term encompasses. According to EN 16516:2017, a VOC is defined as a substance which elutes between n-heptane and n-hexadecane when analysed by Gas Chromatography Mass Spectrometry (GC-MS) using a specific separation column. Whilst a list of substances classified as VOCs is included in EN 16516: 2017, this is not comprehensive.

Therefore, the emissions of VOCs from a product can only be determined by testing. This is carried out using the method specified in EN 16516: 2017, in which a sample of the flooring is placed into a test chamber of standardised dimensions and maintained at 23°C and 50% relative humidity to replicate an indoor environment. After 28 days, samples of the chamber air are collected and analysed by GC-MS to quantify any VOCs emitted. The analysis for formaldehyde is conducted in a similar manner; however, in this case, high performance liquid chromatography is used as the detection technique.

Unlike the substances specified in Clause 4.2, there are no specific requirements for formaldehyde or VOCs; however, the emissions of these substances must be declared. This is because the results of the formaldehyde and VOC emissions apply only under the conditions of the test method, which in many cases are not a true reflection of how the product will be used.  However, the results can be used to estimate the effects of the product upon the indoor air quality of a building, by performing calculations which take into account factors such as the size of the room, as well as the ventilation of the building. This allows informed choices to be made about the suitability of the product for its intended purpose.

When chemical testing is required, whether for VOCs emissions or content of dangerous substances, careful thought must be given to the selection of products for testing. It is often the case that a number of products will have similar characteristics and compositions, and in such cases, it is often impractical to test each one as a separate entity. Instead, parameters on the selection of items for testing are listed under Annexes D.2 and D.3 of EN 14041: 2018. These are designed to ensure that the testing is conducted in the most onerous way. For example, if there is a variation in the thickness across a product range, the standard states that the product with the maximum thickness should be tested. In cases where the composition may vary, for example, laminate flooring with different backing layers, each composition must be tested.

The revisions to EN 14041 have made significant changes to the requirements for chemical testing, adding new restrictions for hazardous substances such as aromatic amines and PAHs. The standard also introduces the option to declare compliance without chemical testing, though this requires careful regulation of the supply chain, and a detailed knowledge of the manufacturing process.
Lucy Cove is a chemist at SATRA