CEN/TC 229 – N 2218

Secretariat CEN/TC 229 « Precast concrete products »

Your contact:
Yann ROUILLÉ - Secretary
Line: + 33 (0) 2 37 18 48 43
email: bnib@cerib.com

Assistant :
Bernadette GARRIDO

The French National Body:

Date: 2021-10-01

CEN/TC 229
Collated comments further to the circulation of 1st WD - EN 13369

COMMENTARIES Dear Members,

Following the circulation of the first Working Draft for the revision of
EN 13369 asking for comments before the 1st October 2021, please find
attached hereafter the comments received from NSB.

CEN/TC 229/WG 4 members will meet before the end of October to

deal with this comments.

Best regards,

Yann ROUILLÉ
CEN/TC 229 Secretary

FOLLOW UP For Information

Bureau de Normalisation de l'Industrie du Béton, on behalf of AFNOR

1 rue des Longs Réages, CS 10010, 28233 Epernon CEDEX, France
Template for comments and secretariat observations Date: 2021-09-30 Document: EN 13369 Project: WD

MB/ Line Clause/ Paragraph/ Type of Comments Proposed change Observations of the
NC1 number Subclause Figure/ comment2 secretariat
(e.g. 17) (e.g. 3.1) Table/
(e.g. Table 1)

CH 4.1.2.2.3 2nd te The cited Annex E.3 is only informative and not Add the following sentence:
paragraph valid in all countries.
Switzerland has more detailed regulations – " … given in EN 206:2013+A1:2016, E.3, or other
based on long lasting experiences - on recycled regulations which are valid in the place of use of
aggregates which apply. Those regulations the product."
should be applicable.

GB ge The British National committee are not certain Put work on hold.
that the standard is even needed. This is
particularly the case now that the individual
product standards are to be deharmonized, and
therefore can contain any relevant information for
this standard. If the standard is kept there would
be three precast standards for any one product,
essential requirements, common rules and
product specific, this is in addition to supporting
design and execution standards and ca n not be
considered ease of use. In any case its contents
seem to be mainly covered elsewhere, and the
other standards often contradict the EN 13369
requirements whilst taking precedence over them.
If it remains, then the contradictions in EN 13369
should be removed. This work is ongoing on
some of the other standards so any revision work
on 13369 should be held until the work on the
others is finalised.
GB ge Somewhere the document needs to note that the Make clear reference, to the items that are or
use of Normative Annexes is subject to National maybe subject to national choice.
decision. Either in a National Foreword, or, as this
document contains design information, in a
National Annex. It would also be helpful to note
that some of the Normative references have
National Annexes or National Forwards that are
relevant to the references made.
GB Scope te The Scope says “Concrete containing fibres for Improve clarity of scope as to application of the
other than mechanical properties (steel, polymer standard to fibres used for structural strength.
or other fibres) is also covered.”. This is
understood to mean that if fibres are used for
crack control, and the like, then this standard still
covers the products, but if the fibres are used for
1 MB = Member body / NC = National Committee (enter the ISO 3166 two-letter country code, e.g. CN for China; comments from the ISO/CS editing unit are identified by **)
2 Type of comment: ge = general te = technical ed = editorial
page 1 of 4
ISO/IEC/CEN/CENELEC electronic balloting commenting template/version 2012-03
Template for comments and secretariat observations Date: 2021-09-30 Document: EN 13369 Project: WD

MB/ Line Clause/ Paragraph/ Type of Comments Proposed change Observations of the
NC1 number Subclause Figure/ comment2 secretariat
(e.g. 17) (e.g. 3.1) Table/
(e.g. Table 1)

the structural strength of the product then this

standard does not apply. However, there is
confusion and the standard can cover glassfibre
reinforced concrete products where the
glassfibres are used for the structural strength.
This needs to be made clearer.
There is similar confusion in some parts of the
market (particularly in Spain) concerning EN
14992 covering glassfibre reinforced concrete,
even though it states “Also fibre reinforced
concrete (steel – see EN 14889-1, polymer – see
EN 14889-2 or other fibres (see EN 15422)
covered by European Standards) may be used,
provided the fibres are not taken into account in
structural calculation”, which clearly excludes
GRC.
GB 4.1.3 ed This clause should be a "should". EN 10080 is Replace “shall” with ”should”
not harmonised and in any case the next
sentence allows a deviation.
GB 4.2.3.2.5 Last para ed What is intended by a “one piece moulded Define “one piece moulded product”
product” and why is it exempt from measuring
slippage?
GB 4.3.1.1 Table 2 te The final note states that As this is a national annex value the product
A manufacturer may achieve and declare smaller standard cannot override the value. Replace “than
values for Δcdev than given in the National Annex given” with “where permitted”
by taking the appropriate measures.

GB 4.3.1.1 3rd para ed Not clear what “A combination of global Replace text with: "Stricter tolerances than those
tolerances may not be used to determine obtained from a combination of global tolerances
tolerances at the support, as in most cases they may be used where these can be justified".
have to be stricter than tolerances achieved by
such combinations” means. As written in "code
speak" it is a permission not to use them if you
don’t want to (meaning you can use them if you
do want to). However, in English translation it
would be interpreted as you cannot use the global
tolerances. This needs to be clarified. Surely
there is a required action to ensure that the
stricter tolerances will be achieved/specified if

1 MB = Member body / NC = National Committee (enter the ISO 3166 two-letter country code, e.g. CN for China; comments from the ISO/CS editing unit are identified by **)
2 Type of comment: ge = general te = technical ed = editorial
page 2 of 4
ISO/IEC/CEN/CENELEC electronic balloting commenting template/version 2012-03
Template for comments and secretariat observations Date: 2021-09-30 Document: EN 13369 Project: WD

MB/ Line Clause/ Paragraph/ Type of Comments Proposed change Observations of the
NC1 number Subclause Figure/ comment2 secretariat
(e.g. 17) (e.g. 3.1) Table/
(e.g. Table 1)

they are used.

GB 4.3.7.1 Last para te EN1992-1-1 also gives rules for 100 years? Also Reword to : “In case of non-structural concrete
these rules are subject to NDP and it would be products or when the design working life of the
helpful to note that. concrete product is shorter or longer than the
corresponding value in EN 1992-1-1 (50 or 100
years) and its National Annex, the durability
specifications may be adapted to the specific field
of application of the product.
GB 4.3.5 Para 2 te Not sure why annex B of EN ISO 12354-1 is Annex B is for sound reduction index. Does the
referenced. Is this correct? reference need to be so specific?
GB 4.3.5 Para 2 ed The latest version of EN ISO 10140-1 was Amend date – if it needs to be dated.
published this year.
GB 4.3.5 Para 3 te Not sure why annex B of EN ISO 12354-2 is Annex B is for homogeneous floor systems. Annex
referenced. Is this correct? B in part 1 is for SRI. Does the reference need to
be so specific?
GB 4.3.5 Para 3 ed The latest version of EN ISO 10140-2 was Amend date – if it needs to be dated.
published this year.
GB 7 Para 2 ed Under UK legislation it may be necessary to mark Propose reword “For identical or serial units of a
each product where safety critical, many precast concrete product, where permitted in the place of
products should be safety critical. use, the above procedure may be simplified or
replaced by overall marking or labelling of
packaged units or lots of units”
GB Annex A1 Para 1 te As the table is derived from the EN1992-1-1 Add to end of sentence “where the national annex
recommended values it is not valid in countries of a country does not adopt the recommended
which have not used the recommended values values in EN1992-1-1 the table below is not valid.”
GB Annex B5 Exp B8 te It is wrong to have alpha,cc within the Reference should be made to the calculations
compliance, this is an additional safety term methods in EN13791 for assessing design
adopted by some countries and is not related to strengths from insitu strengths.
testing. In any case the whole approach appears
to ignore some of the factors that are required to
go from an actual strength to a design strength. In
particular this approach seems to remove any
model factor at all by combining a reduced
gamma with the "safety conversion factor".

1 MB = Member body / NC = National Committee (enter the ISO 3166 two-letter country code, e.g. CN for China; comments from the ISO/CS editing unit are identified by **)
2 Type of comment: ge = general te = technical ed = editorial
page 3 of 4
ISO/IEC/CEN/CENELEC electronic balloting commenting template/version 2012-03
Template for comments and secretariat observations Date: 2021-09-30 Document: EN 13369 Project: WD

MB/ Line Clause/ Paragraph/ Type of Comments Proposed change Observations of the
NC1 number Subclause Figure/ comment2 secretariat
(e.g. 17) (e.g. 3.1) Table/
(e.g. Table 1)

GB Annex C5 te The partial factor on self weight is a matter for Any guidance here should be given based on
EN1990 and its national annex “where permitted in the place of use” and should
be based on a similar reliability approach as
EN1990;
GB Annex M1 Last para te If the annex is for the National Standards body as The whole annex should be shortened significantly
stated it should be in background documents. to note that this is an option where valid in the
Standards should be for the users. place of use and raise any particular aspect
relevant only to precast concrete.
GB Annex M4 First para te There are a number of proposed topics in Delete reference to “next revision of EN1992-1-1
prEN1992-1-1 that will require changes to and EN 206”
EN13369 - not least the method for determining
reduced material factors. However, none of these
methods are formally agreed and therefore there
should be no mention of possible future revisions.
The list of additional considerations is, however,
relevant.

1 MB = Member body / NC = National Committee (enter the ISO 3166 two-letter country code, e.g. CN for China; comments from the ISO/CS editing unit are identified by **)
2 Type of comment: ge = general te = technical ed = editorial
page 4 of 4
ISO/IEC/CEN/CENELEC electronic balloting commenting template/version 2012-03