In the past few years in the UK, the government has effectively kick-started the market for domestic renewable energy technology with financial incentives, though these have recently been made much less generous following controversial cuts to the Feed-in Tariff scheme, a process that is still rumbling on.
However, over the last year and a half, sales have increased dramatically and, despite a reduction in the scale of Government grants, the initial funding has helped to propel the technology to the position where some now see it as a mainstream industry.
Not surprisingly, the Government was concerned to protect its investment by ensuring that all equipment (and the contractors who install it) is robust and effective. Since the financial incentive package is linked to a 25-year lifespan of power generation, the quality of the product is critical. The Government introduced a system of certification to provide reassurance of product quality, and enforced it by linking certification to funding: only products that can achieve certification under the Microgeneration Certification Scheme (MCS) will qualify for the financial support offered under the Feed In Tariff (FiT) and the Renewable Heat Incentive (RHI) programmes.
Getting solar certified in the UK
Product certification is not a new concept in the UK, but for renewable energy the process is complicated by the global nature of the supply chain providing components into the UK market. Few people outside the manufacturing organisations directly involved are aware of how the certification process is completed.
There are two aspects to MCS product certification:
- the assessment of the production facility manufacturing the products;
- the standard product testing process to ensure the finished articles meet the required performance criteria.
To satisfy the first part of this process, the producer must operate a documented manufacturing quality control and assurance system – its Factory Production Control (FPC) - and this FPC must meet the requirements of MCS 010.
This FPC must include a Quality Management System or Quality Plan to ensure the manufacturing processes are accurate and consistent. Regular reviews must consider factory procedures and issues, with the goal of maintaining or improving the standards originally measured. It must also include an agreed process for resolving problems and eliminating them from future production.
The FPC will not only focus on the production facility itself, but also take into account the suppliers of design, products and materials used in the final products and have systems in place to deal with any material that is deemed to be “non-conforming”. It will also consider the facilities for the storage, handling and packaging.
To ensure traceability, manufacturers must keep accurate records of all manufactured products and contract details. Any complaints must also be recorded together with details of actions carried out to resolve the complaint.
This may sound onerous, but manufacturers that already hold the international quality standard ISO 9001 will be familiar with the process and will already satisfy the majority of the requirements for MCS certification. Manufacturers wishing to apply for MCS certification will present the documentation they already hold for ISO 9001, together with the FPC as the first stage in the MCS certification process.
NQA (MCS certification body) examine all the paperwork and visit the factory to make sure that the processes appearing in the documentation really reflect the working practice on the ground. This audit process requires considerable expertise and time – usually a minimum of two days on site would be expected for most factories.
Stage two of the process involves testing the product itself. This needs to be carried out in a suitably equipped facility to demonstrate whether or not the product meets all the MCS scheme requirements relevant to the individual technology. There are a number of options around the choice of testing facility but it must satisfy the requirements of MCS 011.
The easiest choice for a manufacturer is to use an independent third party test laboratory that is accredited to ISO 17025 by a recognised certification organisation (The United Kingdom Accreditation Service or equivalent). In this case, the manufacturer simply has to demonstrate that the products have been tested according to the performance criteria set out in MCS 011 Clause 2.1. The test reports will need to be in English and the manufacturer will need to sign a declaration stating that the tested items are production samples representative of the current production.
If, on the other hand, the manufacturer elects to carry out the product testing within their own facilities, then the MCS certification body will need to carry out a separate assessment of the test facility. This visit will examine the facility to ensure that it has the equipment, procedures and staff to conduct the testing to an appropriate standard. The assessor will be looking to ensure that the facility meets all the requirements of ISO 17025.
If the testing facility is located close to, or within, the manufacturing plant, then the assessor is likely to combine its visit with the FPC audit. At the testing facility the assessor will need to witness a representative sample of testing for each product and be content with the validity and integrity of the results obtained.
The final choice for the manufacturer is to use an independent product testing house that is not accredited for the requisite testing. In this case again, the facility will provide evidence that it has the equipment and expertise to satisfy the requirements of ISO 17025 and a site visit will be required by the MCS assessor to verify the information supplied by the facility and to witness a representative sample of testing.
For manufacturers that are already part of the international standards community, gaining MCS certification is simply a matter of the additional considerations relating to the particular renewable technology they produce. This provides an environment where the UK market is assured of the quality of the products being installed while enabling manufacturers to gain certification by building on existing quality procedures rather than having to conform to a whole new set of criteria.
Once all the auditing is complete and assuming that certification is recommended, the product will be listed on the MCS website as an approved product. The producer will be able to display the MCS Mark on all certified products and use the logo in the advertising and promotion of that product.
Once certification has been achieved, it must then be maintained. Annual surveillance visits and product audit testing will be required to ensure that the FPC continues to meet the requirements and the testing will confirm that the products continue to meet the required standard.
If any surveillance visit identifies any non-conformities then the certification body will instruct the manufacturer to take action to remedy the problem. In extreme cases, the certification may be suspended immediately, to be lifted only following a successful re-visit or re-test.
Surveillance visits will also be required to ensure that the manufacturers react to any changes in the MCS requirements. January 2012 should see the long-awaited MCS 012. This new standard extends the scope of certification to include the fixing mechanism as well as the generation equipment. The new standard is being introduced in reaction to the number of problems caused by fixings originally designed for countries outside the UK and not compatible with the very specific design of pitched roofs in the UK.
This process of MCS certification is designed to be uniform, no matter which body is carrying out the certification process. To the buyer or the installer of the product, therefore, it should make no difference which organisation carried out the function as they will be equally rigorous. To the manufacturer that has to work with the certification body, however, the difference can be marked.
If the UK is to keep on track with its carbon reduction targets there will be an increasing role for renewable energy technology. Government incentives may change, but the commitment to increasing take-up of these technologies is long-term: there can be no doubt that any Government scheme will require products to demonstrate their quality through recognised certification schemes such as MCS.
For more information on the services provided by NQA, go to www.nqa.com. For enquiries specifically about the MCS product certification, contact: firstname.lastname@example.org.