DOCUMENTS
 Country
Report Expertise Centre
COUNTRY REPORT 2006 - 2007
4.3 Workshop III: PED, SPVD, NHWBD
4.3.1 Introduction
Workshop III had 11 participants
apart from the moderator. The participants represented ministries,
manufacturers and conformity assessment bodies. The workshop
was aimed at discussing,
- Pressure Equipment Directive
- Simple Pressure Vessels
Directive
- New Hot Water Boilers
Directive.
The following items were
discussed
-
Level of knowledge of the internal
market
-
The expectations of the producer
and the consumer from the regulators
-
The expectation of the regulators
from the producer and the consumer
-
Notified bodies and the needs
of the market for notified bodies
-
Problems encountered during
market surveillance
4.3.2 Discussion
The results of the discussions have been summarised in the following
headings and bullet points.
4.3.2.1 Level of knowledge of the internal market
4.3.2.1.1 Level of knowledge of the producers
-
Producers are in general forced
to learn the rules while trying to export to EU countries.
However, for example hot water boilers are produced and consumed
in the domestic market.
-
Despite all that is said, these
fields are among those where the producer has the deepest
knowledge.
-
These subjects are not taught
in the universities and technical schools. This creates problems
both for producers and for consumers. Engineers graduate without
knowledge in the legislation concerning safety of products.
-
There is need to stop unfair
competition between producers which sell products with a certificate
and those which sell without a certificate.
-
Support to infrastructure has
to be given also outside the 3 big cities.
-
Building contractors very often
install boilers which do not have a certificate because these
are cheaper.
4.3.2.1.2 Level of knowledge of the consumers
-
Among consumers knowledge is
very limited and very shallow.
-
Due to lack of knowledge many
consumers buy products from producers which do not have traceability
for their products.
-
Consumers need to be informed
on the existence and the meaning of the CE marking. Often,
the consumer does not have the knowledge to differentiate
between performance and safety. Consumers do not know that
the CE marking only means that all regulations on safety are
fulfilled and that the marking says nothing about the performance
or the quality of the product.
-
The consumer is also in need
of information on how to make sure that products continue
to meet requirements during their lifetime, for example through
regular maintenance and inspection.
-
According to a recent investigation,
the number of consumers who know the meaning of the CE marking
is 4 per thousand.
-
The Ministry is convinced that
it is doing its job as far as informing the market is concerned.
It is now also planning to have press conferences where management
and experts from all levels will be given the opportunity
to inform.
-
There was also the opinion
that it is not very crucial for the general public (consumers
in general) to be informed as this is only one of the many
factors. The most important thing is to make sure that even
if the public does not have the necessary knowledge, all citizens
can be sure that the system guarantees safe products on the
market.
4.3.2.2 Expectations of the producers and the consumers from the regulators
-
It is difficult for producers
to respect the system when there are not any domestic notified
bodies available to help them meet the requirements.
-
For an efficient market surveillance,
the actors on the market need to be known. The ministries
should have a list of all the producers on the market and
the producers should be traceable.
-
The training provided within
the scope of the present project should be at a deeper technical
level now that the top level training has been provided.
4.3.2.3 Expectations of the regulators from the producers and the consumers
-
The Ministry of Industry and
Trade pointed out that the market has come a long way in implementing
the safety regulations.
-
There is a need for the producer
to retain its objectivity. Producers should not discriminate
between consumers. They should sell safe products to the whole
market and not only to those with knowledge of the safety
requirements.
-
The whole consumer chain needs
to be more knowledgeable. This in fact is a social issue.
4.3.2.4 Notified Bodies and the needs of the market for notified bodies
-
There is a need for the Turkish
Notified Bodies to have a national association. The technical
committees of the ministries do not and cannot serve this
purpose.
-
There is a concern that when
the market has an increased number of notified bodies there
may be difficulties in making them all work to the rules and
in an ethical way.
-
There is also a concern on
the activities of the foreign notified bodies in Turkey. They
need to be under surveillance as well.
-
There is a need to be able
to appeal or complain to the foreign notified bodies and to
the member states which have nominated these notified bodies.
However, this seems to create a political and diplomatic problem.
-
The market does not have a
sufficient number of notified bodies.
-
Candidate notified bodies and
possible candidates need to be encouraged and trained. Resources
are necessary for these activities.
4.3.2.5 Problems encountered during market surveillance
-
It is a difficult task to perform
market surveillance
-
In particular, hot water boilers
constitute a difficult field because each boiler is a unique
example. Certification is difficult and costly. Producers
do not have sufficient knowledge and as long as the market
keeps buying, they sell products which have not been proven
to be safe.
-
The geographical spread is
also important. The assimilation of knowledge depends on the
geographical area in question.
-
The producers do not believe
that market surveillance is difficult. However, the market
surveillance personnel have not yet had time to assimilate
sufficient knowledge and experience.
-
It should also be possible
for the regulators to subcontract market surveillance to competent
bodies in the private sector.
-
The statutes to which market
surveillance personnel should adhere are not yet clear. This
has to be clarified.
-
Both in the accreditation arena
and in market surveillance penalties should be of noticeable
and should prevent the misconduct through their size and nature.
-
Market surveillance should
become a tangible and regular process.
-
It is easier to make market
surveillance than to implement its consequences.
-
There are around 40-45% non-compliant
products. What measures are taken against these products and
their producers? Answer: There is need to think twice before
forbidding a product on the market and asking it to be collected.
Normally, the producer is given time to take corrective action
and given financial penalties.
-
Unfortunately, the Turkish
government does not show its market surveillance officials
the respect and support that their counterparts get in the
EU member states.
-
There is a lot to learn from
the implementation in other countries. One example is the
factory surveillance activities and inspection of production.
-
There are three main pillars
of market surveillance: Routine checks, complaints system
and the RAPEX system. When all three are efficiently active
in Turkey, there will be an efficient market surveillance.
4.3.3 Conclusions
It would be fair to conclude
that the manufacturers in the scope of these three directives
have knowledge of the regulations but may sometimes be reluctant
to meet the requirements of the regulations. The reasons for
this reluctance are both the lack of knowledge on the side
of some end-users and the very short history of market surveillance
in the area. As the end-users increase their knowledge on
safety issues and as market surveillance becomes a real tool
all manufacturers will be forced to meet the requirements
in the directives. An increase in the number of notified bodies
will also facilitate meeting requirements and this will in
turn promote a safety conscious market and safety devoted
manufacturers.
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