A certifiable minefield
The Australian plumbing industry is highly regulated, yet incidents of non-conforming or non-compliant products being used in installations still occur and have prompted changes to the WaterMark certification scheme. Adelle King explains the changes and what plumbing contractors need to know about the product certification process.
On 1 July 2016, the updated WaterMark certiﬁcation scheme was launched by the Australian Building Codes Board (ABCB) following an extensive review of the existing scheme. The review was in response to concerns about growing incidents of non-conforming and noncompliant products in Australia.
WaterMark is a mandatory third-party certiﬁcation scheme that applies to products and materials manufactured both in Australia and overseas. Products and materials accredited under WaterMark are recognised nationally as being compliant with speciﬁc requirements of the National Construction Code, Volume 3 – Plumbing Code of Australia (PCA).
In 2014, a senate inquiry into non-conforming and non-compliant products lead to a review of the WaterMark scheme. In 2015, following the review, the Building Ministers’ Forum (BMF) made the decision to amend WaterMark to improve its eﬀectiveness.
Although the amended scheme was launched in 2016, implementation didn’t start until 1 August 2017 and there will be a further transition period to allow the industry time to adjust.
The ABCB says most of the changes made to WaterMark are administrative and procedural in nature, including a revision of the scheme’s objectives and scope to realign more closely with the objectives of the ABCB and the goals of the PCA.
The biggest change is the consolidation of WaterMark into a single level scheme based on ISO/IEC 17067 from a two level scheme based on the requirements of systems 1b and 5 of ISO/IEC Guide 67. NB: ISO/IEC Guide 67 was replaced by ISO/IEC 17067 in 2013 This means there will now be a single level of certiﬁcation for all products evaluated to prescriptive requirements and a single term for WaterMark Certiﬁcation of ﬁve years.
“While the scheme has been launched, it’s still in an interim phase at the moment because none of the WaterMark Conformity Assessment Bodies (WMCABs) have been accredited by the Joint Accreditation Scheme of Australia and New Zealand (JAS-ANZ) to the new single level WaterMark Scheme (as of writing). As a result, we’re still issuing WaterMark Level one and WaterMark Level two licenses,” says IAPMO Oceana technical manager Glenn Tate.
Another change to WaterMark has been in the risk assessment process, which has been revised and tightened, and now comprises two stages. The ﬁrst determines the inherent risk associated with the product and assesses whether it should be included in, or excluded from, the improved scheme. The second stage determines the nature and propensity for the product failing to be ﬁ t for purpose and what the product speciﬁcation needs to include to mitigate these risks.
The WaterMark Scheme rules have been consolidated into a single document, The Manual for the WaterMark Certiﬁcation Scheme (Manual), which outlines the operating structure of the improved scheme, as well as the process and procedural requirements for certiﬁcation.
Other changes include a simpliﬁed fee structure, the appointment of an expert speciﬁcation drafter(s) and an update to the function and capacity of the WaterMark Product Database.
The ABCB has given WMCABs until 31 July 2018 to include the improved WaterMark scheme in their scope of accreditation.
The ABCB will continue to own, manage and administer WaterMark but it has agreed to start investigating the possibility of outsourcing the management and administration, as well as possible point of sale product compliance by the BMF.
THE CERTIFICATION PROCESS
The ABCB manages the WaterMark scheme in Australia but JAS-ANZ is the scheme accreditation body, meaning it assesses and accredits WMCABs, which then evaluate and certify plumbing and drainage products.
As of writing there were eight WMCABs in Australia; ApprovalMark, Australian Certiﬁcation Services, Australian Gas Association, CertMark International, Global Mark, IAPMO, DNV GL Business Assurance and SAI Global.
The eight WMCABs are responsible for assessing individual products and materials, and providing WaterMark certiﬁcation if all requirements have been successfully met.
To gain WaterMark certiﬁcation the product or material must be tested by a recognised testing laboratory, comply with an approved speciﬁcation, be manufactured in accordance with an approved Quality Assurance Program and carry a warranty.
Although WaterMark certiﬁcation is mandatory, not all plumbing products require WaterMark certiﬁcation, depending on the level of risk associated. All products proposed to be used in plumbing and drainage installations require a risk assessment to be undertaken and this has already been done for a number of products and materials. Those products pre-determined as requiring WaterMark certiﬁcation are listed in the WaterMark Schedule of Products, while those predetermined as not requiring WaterMark certiﬁcation are listed in the WaterMark Schedule of Excluded Products.
If a product is not listed in either of these documents but is proposed to be used in a plumbing or drainage installation, then an assessment is required, including a risk assessment conducted by a WMCAB to determine whether WaterMark certiﬁcation is necessary.
“In the WaterMark Schedule of Speciﬁcations, there is a list of all the plumbing products and what the relevant Standard is that the product must comply with, including material and performance requirements that WMCABs assess against,” says Glenn.
“The standards also outline what the testing requirements are, which must be undertaken by an independent and NATA accredited testing laboratory. As a WMCAB, we ensure that these test reports cover the full range of products that the importer or manufacturer want to gain WaterMark certiﬁcation for, which is quite involved and requires a lot of technical expertise to do correctly.”
Products must meet the minimum certiﬁ cation standards that are set out in the WaterMark Governance Rules and if a product is deemed high risk, such as those in contact with drinking water, then qualiﬁed and trained WaterMark inspectors must also conduct an inspection of the manufacturing site.
Under the new WaterMark scheme, WaterMark licenses will have an expiry period of one year and a maximum term of ﬁve years. WMCABs will review the manufacturing processes and examine the raw materials being used once a year to ensure manufacturers and importers are still meeting their obligations under the scheme and manufacturing products that comply with Australian standards.
Products and materials that have met WaterMark certiﬁcation requirements will display the WaterMark certiﬁcation trademark and will be listed on the ABCB WaterMark database.
“What WaterMark does is basically identify that a product has had thirdparty accreditation and assessment to ensure it complies with the relevant Standard,” says Glenn.
“However, this does not guarantee that every WaterMark certiﬁed product is fully compliant because it’s impossible to guarantee that unless you undertake 100% testing. The WaterMark certiﬁcation process aims to make sure the product is ﬁ t for purpose and authorised for use, which endeavours to ensure Australia’s safe drinking water and waste water systems.”