Privileged public comment on prEN 16165:2019 slip resistance tests

Richard Bowman
Intertile Research, Australia.
[email protected]

Abstract
This public comment provides several reasons for rejecting the proposed standard. While three of the
four slip resistance test methods could be improved, the GMG 200 motorised drag sled is questionable
as it has severely limited application. The sole adoption of the pendulum test method would fulfil the
1994 EU M/119 Mandate. Adoption of appropriate accelerated wear conditioning (AWC) protocols
should enable the practical realisation of EU Regulation No 305/2011, slip resistance at the end of an
economically reasonable life cycle. Such a decision would not prevent continued use of the DIN 51130
and DIN 51097 ramp tests, in conjunction with many other elements of the German regulatory system
that were not included in the draft proposal.

Establishing a ‘new norm al’ contex t

Building regulatory systems must fulfil societal needs. Objective-based performance requirements
depend on the existence of appropriate test regimes. While building regulators continue to struggle
with creating effective regulations to keep people safe, it is only three years since 72 people died in
the Grenfell Tower fire in London (on 14 June 2017).

EU Regulation No 305/2011 for construction products (CPR) requires “Floors must be safe (slip
resistant) at the end of an economically reasonable working life”. The 1994 EU M/119 Mandate to
CEN called for a single and unique slip resistance test method that could be applicable to all flooring
product surfaces. The prEN 16165 draft contains four slip resistance test methods and is principally
concerned with the slip resistance of ex-factory products.

The Covid-19 pandemic has enabled us to reflect on issues in isolation. Catchphrases such as “We’re
all in this together” and “Let’s stay the distance” equally apply to ensuring public safety standards are
fit for purpose. Unfortunately, the prEN 16165:2019 draft lacks 2020 vision. It fails to meet the project
specification. It does not facilitate the sustainable slip resistance measures required for effective
building regulations. The committee has not stayed the distance but has just picked the lowest hanging
fruit. prEN 16165 perpetuates the late 20th century German status quo but fails to build on it. It fails
to allow improved selection practices where the slip resistance characteristics are sustainable.

prEN 16165 incorporates three key elements of the respected German slip resistance system but fails
to state critical limitations that are detailed in associated integral documents. There have been too
many wet barefoot accidents where products were used in accordance with the German system.
There is a long history of problems with the ramp calibration boards, particularly in securing equivalent
replacements. There has been a lack of transparency in such matters, leading to a loss of faith in the
integrity of the system and its future use. Such aspects are considered in greater detail subsequently.

The draft also includes the well-established non-proprietary pendulum test. This device has been
adopted in several national and multi-national standards, albeit with minor procedural variations.
Pendulum standards are distinctive in that they have often included cautionary warnings about
potential limitations that might apply in some circumstances. This policy of full open disclosure has
been mischievously used globally by advocates of some other tests in attempts to undermine the
credibility of the pendulum. Such inappropriate bias is evident in the prEN 16165 draft.

July 1st 2020

It would be foolish to believe that any test method can provide an accurate indication of slip resistance
for all flooring products and in all situations. However, some past limitations of the pendulum test
have been overcome by approaching them with an open, curious, and unprejudiced mindset. Such
advances have not been fully incorporated or recognised in the draft. While other constraints need to
be similarly tackled, this will occur. It does not limit adoption of the pendulum test now.

Most importantly, the pendulum is not limited to laboratory tests. It is well suited to conducting tests
on both ex-factory products and those that have been subjected to relevant accelerated wear
conditioning (AWC) protocols. A wide range of conditioning protocols have been used as an inherent
component of many building product standards. Some pendulum slip resistance standards have made
provision for such prognostic testing. One must first determine which types of flooring products are
likely to lose significant slip resistance in service and to then identify AWC protocols that are relevant
to specific products and circumstances.

The suddenness of the Covid-19 threat triggered unprecedented changes. This is quite the opposite
of the boiling frog fable, where the rising temperature of the water is so gradual that the frog does
not perceive the danger. The boiling frog is an apt metaphor for ramp testing. Wear of the calibration
boards occurs so invisibly and gradually that it is not detected. This sinister threat to the original 1990s
reference basis was not appreciated until too late. Such problems would seem to have already
compromised the wet barefoot ramp test method. Effective contingency plans have yet to be
developed since the results are a direct reflection of the condition of the calibration boards.

The 1994 EU Mandate could be achieved using the pendulum to test suitably prepared floor
specimens. If the prEN 16165 draft was rejected, the Mandate could be satisfied with a European
standard based solely on an upgraded version of the pendulum Annex. The other test methods exist
as DIN 51097, DIN 51130 and DIN 51131, and the Annexes could be published as updated standards.

Germany has a highly regulated slip resistance system for workplaces and public areas, based on the
DIN 51097, DIN 51130 and DIN 51131 standards together with rules and associated guidance material
including DGUV Information 207-006, DGUV Information 208-041 and ASR A1.5/1,2. If the prEN 16165
draft was rejected, Germany could opt to retain its current system for industrial and wet barefoot
situations. While the ramp test methods require further controls to ensure the original 1990s
performance requirements are reproduced, Germany has competent experts who should be able to
bridge the gap between current test performance and excellent safety performance.

A personal note
I always approach slip resistance matters from an objective scientific perspective in accordance with
my experience. It is quite sobering to deal with those who have been crippled, bereaved, or greatly
disadvantaged by slip and fall incidents. I do not apologise for my passion to get slip resistance matters
right. Whatever decisions are made, there will be no financial consequences for me personally.

The CEN/TC 339 Committee members may have become frustrated and fatigued by the protracted
nature of its deliberations. However, safety professionals cannot abdicate their responsibilities. If the
2010 draft was not worthy of past publication, how has it now become fit for purpose? This is not
evident. While I embraced DIN 51097 and DIN 51130 in the 1990s, the ramp tests have largely gone
backwards since then. Many recent changes seem more focused on reducing the time taken to test,
and its cost, rather than improving measurement precision and reliability.

2
I was told I would receive notification of the draft so that I could submit a formal comment. When I
discovered the draft 2 days prior to its closing, my initial comments were frustrated by technological
issues. While I was concerned about some of the prEN 16165fine detail, I was more concerned about
the larger picture, where comment was not being sought. When we can enable progressive change,
we must fully consider the options and any consequences. As such, I chose to prepare this very public
comment, encouraged by British interests. I should apologise to those who asked me not to comment,
but someone needs to represent the millions of people who are not represented on the committee.

If you cannot yet do as I suggest, I will understand. If you could, I would certainly appreciate it, as
should billions of others, who will probably never become aware of their debt to you. However, in the
long term, it is obvious what we should all be aiming to do: establishing a fully integrated testing
regime that provides sufficient slip resistance that can be sensibly maintained throughout an
economically reasonable life cycle.

W hy do responsible slip resistance m easurem ents m atter?

We must minimise the number of preventable environmentally-induced falls, and thus the associated
personal and societal costs of injuries. From an environmental sustainability perspective, we should
optimise the life cycle performance of pedestrian surfaces, including their maintenance. Standards
should do more than enable spurious sales and archaic specification practices. If tiling can be
condemned as defective if it deteriorates due to poor workmanship soon after completion, surely
flooring should be condemned if its long term slip resistance characteristics were never fit for the
intended purpose? We need to know which products may become unsafe due to rapid slip resistance
loss. We need test methods that can adequately inform product selection and maintenance decisions.

We have experienced decades of bickering about slip resistance test methods nationally and
internationally, often fuelled by partisan issues and vested interests, without sufficient analysis of
their true worth. At least we have now dispensed with static coefficient of friction measures. However,
some have still to appreciate that a test method that is considered to provide valid results over a small
range of surfaces is not necessarily suitable for assessing surfaces that have quite different structures.

With respect to slip resistance test methods we might ask, “Where are we, how did we get here, and
where should we be going?” I will concentrate on addressing future needs. Where we seek an upwards
quality spiral in the Standards, the process of achieving consensus is only a point in time, whereupon
we restart the process of trying to achieve improved outcomes. Thus the CEN/TC 339 committee must
consider whether publication of the proposed standard would improve the prospects of attaining its
mandated long term goal: provision of a single test method that ensures that floors will be safe at the
end of an economically reasonable life cycle? Or, might publication lead to unexpected problems?
Some committee members may have long term goals, a firm idea of purpose, and a focus on how well
a future standard will meet diverse needs, but has the Committee formed a consensus opinion? Or has
it just picked the low hanging fruit?

Tim e travelling
This standard seeks to emulate what we achieved in Australia in 1999: production of a multi-test slip
resistance standard that includes three widely respected test methods (DIN 51097, DIN 51130 and the
pendulum) together with a motorised drag sled 1. Singapore did likewise in 2001, and Israel in 2009.
As subsequently discussed, China largely achieved this in 2019, so why not follow suit?

1
I have been advocating removal of the motorised drag sled test method from the Australian standards for
over 10 years, favouring the use of the pendulum for both wet and dry measurements.

3
As previously stated, one significant reason for not approving this standard is that it fails to comply
with EU M/119 Mandate (1994) to CEN, which called for a single and unique slip resistance test
method that could be applicable to all sorts of flooring product surfaces. However, flooring product
manufacturers also want to test to a single test method, not to multiple test methods.

More importantly, this standard fails to provide a solution to Regulation (EU) No 305/2011 for
construction products (CPR) that essentially requires that “Floors must be safe (slip resistant) at the
end of an economically reasonable working life”.

We know that some materials can lose considerable slip resistance due to wear, such that some ex-
factory results are illusory. This is the “elephant in the room”. It must be considered. The prEN 16165
draft makes no attempt to consider the slip resistant working life cycle.

The standard’s four test methods only determine a product’s ex-factory characteristics, and no more.
However, the pendulum and the GMG 200 drag sled can be subsequently used in situ.

As such, the draft fails in that it does not assist to promote a framework for building regulatory system
development. It should be objective based and aim to meet a fundamental societal need: walking
surfaces that can be maintained in a safe condition with minimal environmental cost.

This standard does not reflect current best practice. Annex C, the pendulum component could and
should be improved by adopting international (Australian) developments. A few aspects of pendulum
usage require further research and development. The pendulum can be used almost anywhere, and
on all manner of surfaces, providing users are well trained and their equipment is well maintained.

There are significant questions concerning the ramp test methods, which I have held in high respect.
Lastly, is there really a need for DIN 51131 to be converted to an international or a European test
method when it already exists? Indeed, what is the benefit of converting DIN 51097 and DIN 51130 to
European status? By the end of this commentary, you may question if there is any benefit in elevating
these test methods to ISO status, where the process has already been initiated within ISO/TC 189
Ceramic Tiles, WG10, Slip Resistance.

R eality check
Pedestrian friction research and standardisation have a history of isolationism, where too many
people have been concerned about maintaining their own status quo, resisting the changes associated
with most external interventions. Once people have invested in a test method, they would prefer not
to have to change. They would like to believe that their test is perfect and that any result it produces
is capable of providing a reliable indication of relative safety. Once countries have enacted building
codes or safety regulations that contain quantified requirements based on specific test methods, the
resistance to change may increase. While a clear realisation that the system may not be operating as
expected might also trigger an appetite for change, most bureaucrats do not ask the questions that
should be asked:

1. Is the system working perfectly?

2. If not, where could it be improved and how?

While modern democratic governments recognise that access to information is a fundamental right,
and Standards are developed on the principles of openness and transparency, consensus and balanced
representation, there is often little accessible information that provides detailed strategic analysis of
how and why standards are developed and the potential effectiveness of various options.

4
A question of purpose?
Is prEN 16165 primarily intended to test new product so that one can assess whether the flooring will
be fit for some specific purpose? Is it primarily to enable specifications so installations will be safe? Is
it expected that the standard is capable of being referenced in building codes or safety regulations
that ensure floors will provide long term safety? Is the standard intended to provide a means of
determining or demonstrating that a floor is safe as it is, or to enable investigations of incidents?

The standard was perhaps written with all these goals in mind, where different parties would place
different priorities on different aspects. However, the standard appears to have been written to
principally test new products, whereby it lacks the necessary detail or direction for other uses.

The Foreword currently provides the only explanation: “The purpose of this European Standard is to
harmonise the procedures used when using any of the above test methods. It is not intended to
promote any particular test method to Product Group Technical Committees or to limit their choice”.

It appears other documentation is needed to educate users as to how the standard might best be used
for the previously mentioned purposes. Such documentation certainly exists in Germany as technical
rules for workplaces (ASR) and in DGUV (German Statutory Accident Insurance) publications. Indeed,
the test methods only result in results, without any form of classification and without being subjected
to any pass/fail criteria. In some respects this is quite welcome: too many specifiers are overly
concerned with the classification a product obtains rather than considering whether the product sits
at the top, middle or bottom of a classification. Many manufacturers only publish a classification,
without a result. Indeed, the fine print in much product literature may state that the result obtained
only relates to the product tested and provides no guarantee that other batches will achieve similar
performance.

It seems to me that the word “harmonised” might be redundant where CEN committees basically
adopt DIN or other national standards as CEN standards. That would seem to be the case with the
prEN 16165 German test methods, although they may lack some of the content of the German
standards.

However, where there are several similar existing test methods that differ, as is the case with the
pendulum test, then combining them into one would certainly be a case of harmonisation. In such a
case, if there are other national standards that use the pendulum (several do), and the production of
ISO standards is envisaged, surely it would be sensible to fully include those countries in the consensus
decision making process. A failure to do so suggests dismissive respect, that the power of the CEN
voting block can be used to perpetuate whatever CEN chooses to adopt. Such arrogance implies that
no others can do better.

This draft seems focused on enshrining existing practice and elevating DIN 51097, DIN 51130 and DIN
51131 from national to European status, before seeking their conversion to ISO standards. The CEN/TC
339 chair has also led the ISO/TC 189 Ceramic tiles WG 10 slip resistance for the last several years.

Having represented BSI on ISO/TC 189, I know that Standards Australia made AS 4586:2013, AS 4663:
2013 and HB 198 (2014) available in February 2015 for committee consideration. The AS 4586 wet
pendulum test method states that if a product Standard or specification contains a requirement for
the permanence of slip resistance, it shall be determined after the appropriate accelerated wear
protocol. This provides an obvious means of satisfying the EU CPR requirements.

5
A standard based on existing practice (and standards) would be acceptable if there was not a sensible
alternative that better meet societal needs. The focus must be on whole of life product performance
rather than solely on ex-factory performance. The EU CPR should be respected and accommodated.

R eflecting on the past

One should reflect on history before placing excessive trust in systems. In the early 1990s, I watched
ramp tests being conducted in four European laboratories before investing in a ramp, both sets of
calibration boards and Bottrop boots. We then introduced both ramp test methods into the AS/NZS
4586-1999 standard. Acceptance of the procedure was greatly assisted by independent overseas
testing that confirmed the test results of my laboratory.

Imagine my extreme embarrassment when it then turned out that my employer had an exclusive
Australian monopoly on ramp testing: some of the calibration boards were no longer available. This
situation lasted for almost 10 years. A few boards then became available, but only for a short period.
There have been ongoing supply issues. Just as people had trusted in me in producing AS/NZS 4586,
I had trusted in continued availability of supply of the boards, and also their steady performance.

Since products were tested with direct reference to the wet barefoot calibration boards, it was
important that the calibration boards remain constant. If they were to wear and to lose their slip
resistance, then the benchmark would continually be declining. Well, we now know those boards did
lose their slip resistance, so how do we protect the integrity of the system? How does one know when
boards have been used beyond their expiry point? How does one obtain new replacement boards
when existing boards no longer perform as they once did? What does one do if the boards are
unavailable? I will return to these issues subsequently.

In 2017, I was pleased to find SFV/IFA 2015 study FP341 “Development of a calibration procedure for
floor coverings in wet barefoot areas” that sought to verify the performance of proposed new
calibration boards. I was unimpressed by the wide spread of results and other aspects. The study
raised more questions than it answered. While its authors considered it confirmed the assumption
that some test walkers are unsuitable for the barefoot test procedure, nobody has addressed the issue
of how a test lab should select suitable walkers. Having analysed the test data for members of the
public who walked on the boards, limits were proposed and inserted in the 2016 prEN 16165 draft.
Although individual outlying results (that might be attributed to unsuitable walkers) were discarded,
the mean values scarcely changed. Five of the twelve results obtained by professional walkers (SFV
and IFA staff) were outside the proposed 2016 prEN 16165 recommended limits.

When a new version of DIN 51097 went to public comment draft in May 2019, there was either a new
set of calibration boards or a new set of compliance requirements. We went from a situation where it
took years to find suitable boards to having them readily available for a new draft. My submission
raised issues and I asked for the study that had informed and confirmed the board selection and the
compliance criteria. Although I wrote to several German authorities, I am still awaiting meaningful
replies. The same boards and criteria are now proposed for use in EN 16165. I understand that CEN/TC
339 members did not receive a copy of the 2015 SFV/IFA study FP341. They have essentially been
asked to just trust the German proposal. This is unfortunate when people are seeking to assure that
proposed changes are fit for purpose, and indeed the test method itself. The late Juanma Iriate raised
concerns at the London 2016 STF conference. He reported several accidents had occurred in Spanish
swimming pools after the required DIN 51097 class B tiles were installed.

6
In my 2019 DIN 51097 public comment submission, I raised the matter where a German tile that had
received a C classification for tiles that the Australian importer considered slippery. We ended up with
the manufacturer’s result (30 degrees), a respected German laboratory but (not SFV or IFA) result
(27°), and two Australian NATA-ILAC accredited laboratory results (15° and 16°). Although we were
never able to determine the reason for the disparity, the importer provided a candid digest:
Whenever we have made any attempt to ask a question about a result or testing, the
responses are pretty defensive. Regarding the two German class C results and the two
Australian class A results, how could anyone trust the test? Specification by the barefoot ramp
rating is rare anyway. This type of result, coupled with one lab no longer offering it, means
that it is probably pretty much finished as a relevant test method, when any question of floor
performance will ultimately be resolved by the pendulum.
Our experience is that a barefoot B rating on a pool concourse is hopelessly inadequate. There
are many significantly sized aquatic centres who have fallen foul of this recommendation.
Of course we would love to know the reason behind the difference, but that would be more
of an academic exercise. The commercial reality is that the pendulum test is “everything”. This
is certainly what we are advising our clients.
I suspected that different generations of calibration boards were being used, rather than a difference
in walker verification procedures (although it is proposed that less frequent walker verification will
soon be permitted). However, if worn calibration boards have been used to select new replacement
calibration boards, the goalposts have certainly been moved (and who knows by how much?).
Standards Australia Handbook 198 well may advise “There are a number of Australian testing
laboratories with the necessary testing apparatus, thus enabling the laboratory verification of an
overseas classification, if required”, but I doubt that anyone envisaged such large differences being
experienced between Australian and German laboratories on exactly the same batch of tiles.
Further to this, I submitted samples to two Australian NATA-ILAC accredited laboratories for testing
as part of a broader research project. On some specimens, some walkers yielded quite different results
even though they had just qualified on the verification boards. If a laboratory has walkers yielding
dissimilar wet barefoot results, what should they do? prEN 16165 provides no guidance. If one uses a
third (or fourth) walker, is there a basis for accepting two of the results and discarding the other/s?
The test method seems to be drifting further from its original foundations. While Wetzel (2020) has
addressed some aspects of the new calibration procedure, there are still unanswered questions.

R eturning to the present and then looking forw ard

I was initially pleased to see that Chinese standard GB/T 35153-2017, Slip resistance ceramic tile, had
adopted the pendulum test. Chinese standard GB/T 37798-2019, Evaluation of slip resistance of
ceramic, has since adopted the AS 4586:2013 pendulum P0 to P5 classifications; the DIN 51097 A, B,
C classifications; the DIN R9 to R13 classifications; and the withdrawn ASTM C 1028 manual drag sled
test procedure. However, if the much shorter Chinese standards lack some of the detail that is in AS
4586, the tests may differ somewhat. If so, some Chinese test reports may disagree with Australian
and European test reports in terms of the reported classifications 2.

2
Further to this, there should be a requirement for manufacturers to report a test value as well as a
classification in their product literature. There is far less difference in the slip resistance between the products
at the top of a class and the bottom of the class above, than between the top and bottom of a class. If the
goalposts have moved, one might avoid products at the bottom of a classification but still accept those at the
top. This assumes that the product has adequate sustainable slip resistance.

7
Some Chinese manufactured pendulums have developed a poor reputation for quality. As the saying
goes, “Be careful what you wish for!” Everybody wants consumables, like the rubber test feet, to be
reasonably priced. One slip resistance test method yielded inaccurate results when a much cheaper
Chinese rubber was used for the test feet, until the folly was discovered. Such globalisation problems
with equipment, reference surfaces and consumables may worsen with the further development of
multi -test standards.

In the current AS 4586-2013, the shod ramp test includes two sets of walker compliance criteria,
recognising the possible use of two sets of calibration boards and footwear:

• the Lupos Picasso footwear with the original E, P and R calibration boards, and
• Uvex Athletic footwear with the ST-I, ST-II and ST-III calibration boards.

The 1999 standard had criteria for the Bottrop footwear with calibration boards E, P and R. All the
boards and footwear have been deemed capable of yielding DIN 51130 R9 to R13 classifications. This
raises the question “Does one have to immediately reinvest in the latest boards and/or footwear each
time DIN 51130 changes, regardless of their condition?” To put this into context, in January 2011, I
received a €5780 quotation for a set of the DIN 51130 calibration boards and a €7029 quotation for a
set of the DIN 50197 calibration boards, plus shipping costs. Such boards are prohibitively expensive
in third world countries, particularly if they must be periodically replaced.

The prEN 16165 draft shows the required sole profile but fails to provide a manufacturer name. This
makes it somewhat difficult for users to refer to the shoe type in discussions. The calibration boards
are now referred to as St-1, St-II and St-IIIA, scarcely differentiating them from earlier boards (should
one be seeking to understand any strange results). Chinese standard GB/T 37798-2019 shows the
same (Bergmann) shoe as the prEN 16165 draft, and it refers to the calibration boards as St-1, St-II
and St-III. Critically, it has compliance criteria that differ from those published in FprCEN/TS
16165:2016. Logically one would conclude that the St-1 and St-2 boards differ even though they have
been given the same name. While the Chinese may have used German boards and guidance, there
may now be a problem of equivalence. However, one would also logically presume that any continuing
use of validated calibration boards would not invalidate any determination of R9 to R13 classifications.
This assumes that the aim has always been to ensure that no matter which combination of footwear
and calibration boards is used, the testing will yield consistent classifications as long as the boards
(and shoes) do not become too worn. Unfortunately, the standard provides no mechanism for
determining if or when this occurs.

If prEN 16165 is published and 200 new laboratories decided that they wanted two sets of each of the
wet barefoot and wet shod calibration boards, how long would the existing stock last? Would there
be an immediate call for new boards (and shoes) as well as a need for revision of the standard? Would
laboratories that had just received their boards need to discard them to buy the next generation of
new boards? Would laboratories need to buy reserve boards for use when the calibration boards
become too worn, and a set of master boards to act as a primary reference standard? How should
laboratory accreditation assessors seek to verify that the calibration boards remain suitable for use?

While CEN/TC 339 has produced a draft, who should one turn to for answers to such questions?
I received no responses when seeking similar clarifications from the German mirror committee. Open
communications can both prevent and overcome problems.

8
Desperate tim es, desperate actions?
It was hoped the new calibration boards might become readily available and at a reasonable cost,
rather than remaining the world’s most expensive tiles. When the DIN 51097 calibration boards were
unavailable what did people do? Ali Sariisik published “Safety analysis of slipping barefoot on marble
covered wet areas”, a paper where he stated he used DIN 51097 to determine the slip resistance.
When I wrote to ask him where he had obtained his calibration boards, I received no replies.

When I organised a slip resistance workshop in Turkey in 2018, I spent time with Gültekin Coşkun, who
confirmed that he, Ali Sariisik and Gencay Sariisik had not used DIN 51097 calibration boards when
“testing to DIN 51097” in the several papers that they have individually and jointly published, even
though they have reported wet barefoot ramp angles and classifications 3. They classified samples
based on an assumption that their walkers would have obtained mean results of exactly 12, 18 and 24
degrees on the A, B and C calibration boards.

Falls prevention is a serious business. Researchers should not mislead or be misled.

If researchers or test houses encounter supply problems with calibration boards or with some aspect
of how the test is conducted, what authority should they contact to obtain answers (where answers
to many potential questions are not in the draft standard)? Answers have not been forthcoming
recently on DIN 51097.

A good investm ent?

I have encountered several people interested in providing pendulum slip testing services, which were
regarded as a low cost investment and a licence to print money. Unfortunately, cheap, inferior
pendulums have recently appeared on the market. I have heard many reports of associated problems.
This indicates an increased need for laboratory accreditation, as well as the importance of effective
internal laboratory equipment assurance programs.

If one has a well built, properly maintained pendulum, the results obtained may be a factor of
knowledge of the operator and their diligence in applying the necessary skills. Industry groupings (such
as the UK Slip Resistance Group and the Slip Resistance Group of Spain) are important for developing
and imparting knowledge, as is the process of laboratory accreditation to ILAC levels, whereby
assessors can help operators to improve their techniques.

Proficiency studies are essential to performance improvements. The work that Carl Strautins has
conducted over recent years is to be commended. His paper “Pendulum calibration, metrological
traceability and reference material” supports the CEN 16165 pendulum calibration procedure. It is a
testament to the benefits of allowing non-Europeans to contribute to the work of CEN/TC 339.

I have just accepted an invitation to participate in round 4 of the Proficiency Testing Program for Slip
Resistance, as have a number of international laboratories that are using the pendulum. Other
interested laboratories should seek to participate.

P ast Australian Contributions

When Australia adopted the oil wet ramp test method in 1999, class R9 then commenced at 3 degrees,
mirroring DIN 51130. I wrote at the time in Standards Australia HB 197:1999, “However, one should
also recognise that the lower end of the R9 classification (3 to 6 degrees) includes some noticeably

3
While Coşkun recently published a correction to one paper, he did not make a suggested correction about his
calibration board misdirection. I understand that he intends to purchase calibration boards soon.

9
slippery materials. Thus one may need to be cautious about specifying class R9 products unless the
corrected mean acceptance angle is also published”.

Shortly afterwards, when DIN 51130 was being reviewed in Germany, I was asked “Should DIN 51130
drop the belatedly added R9 class?” My response was “No, but please increase the starting point from
3 to 6 degrees”. This occurred in the DIN 51130:2004 revision. We separately reported that the
proposed new Lupos boots gave a result that was on average 0.3 degrees higher than the Bottrop
boots. The Lupos boots replaced the Bottrop boots in the DIN 51130:2004 revision. I have not seen
comparable data published for any of the later changes of footwear (or calibration boards).

Many of the changes that were made in a revision of DIN 51097 arose from issues that were identified
in Australia, particularly with respect to the water temperature, a prohibition on the continuous
recycling of the test liquid, identification of the surfactant, etc.

Testing directions
The prEN 16165 ramp test methods state “If the slip resistance differs depending on the direction of
walking, then it will be necessary to determine the direction of lowest slip resistance. It is
recommended that tests are carried out in at least two directions (longitudinally and laterally) to
establish whether there is directionality of the slip resistance of the sample. Once a lack of
directionality has been established, it is acceptable to test in a single direction.” While two 0.5 x 0.5 m
test boards would allow orthogonal ramp testing of 1 x 0.5 m surfaces, there would obviously be a
problem with diagonal tests.

For laboratory testing, the prEN 16165 pendulum test method states “If the dimensions allow 4 repeat
at 90° and 45° to the original direction 5 to determine whether the slip properties are isotropic. If the
sample is non-isotropic and there are differences in PTV values, then take the median of the five
readings 6 taken in the direction of lowest value”.

For on-site pendulum testing, additional guidance is provided: “On profiled surfacing values of PTV
will often be found to be dependent on the angle between the direction of test and the direction of
the main profile axis and several tests at different angles may be necessary in order to determine the
minimum slip resistance offered by that surface. When setting the measurement length of 124 mm it
is important that the slider should start on the top of the profile”; and “On tiled surfaces or surfaces
with many joints, the minimum value of PTV will be found in a direction of about 10° to 20° to the
longer joint line. On timber surfaces, the minimum value of PTV will generally be found along the
grain”. Surely, such guidance is equally valid for new products? The Australian standard AS 4586
specifies a 30° direction for testing of tactile ground surface warning indicators and a 10° direction for
testing of directional tactile ground surface indicators and step treads with a severe profile such as
castellated blocks. Specification of an angle should ensure consistency among operators.

4
There is a note: “If the dimensions are too small to carry out testing in three directions it may be possible to
butt two samples of the same product together.” Why butt small tiles together if they will be laid with a grout
joint, which will assist with drainage as well as creating a profile that should improve slip resistance?
5
There is another note: “Some product specifications require testing at 180° to the original direction. In this
case follow the relevant standard for the product being tested.” Wire cut extruded products may have quite
different slip resistance in opposing directions. One should not have to rely on product standards in order to
have products competently tested. Furthermore, such advice is omitted from the onsite test procedure.
6
This should be the median of the last five readings since eight readings are made.

10
The prEN 16165 GMG 200 test method states “If the slip resistance of the test surface is directional it
is recommended that tests are carried out in at least three directions (longitudinally, laterally and
approximately 45° between the two) to establish whether there is directionality of the slip resistance
of the sample. Once a lack of directionality has been established, it is acceptable to test in a single
direction”; and “If the slip resistance property is directional, then test in the direction of the lowest
slip resistance”. However, there is no requirement to report the direction of test.

The prEN 16165 GMG 200 on-site test method also states, “In accordance with the question to be
investigated, it is necessary to test the surface for instance as follows:”. However, there is nothing in
the test report section to require that the “question” be identified. Wherever on-site testing is
commissioned, there should be a test report requirement for reporting the nature and purpose of the
test. This provides the client with an assurance that the appropriate testing was performed, and clearly
communicates what was done and why to anyone reading the report.

M aking sense of DI N 51131 – a m ism atch?

One of the major limitations of the ramp tests is that they cannot be performed in situ. To compensate
for this DIN 51131 was published in 2008, featuring the FSC 2000 and the GMG 100. It is now based
on the GMG 200. I understand that no manufacturer has yet adopted the GMG 200 for measuring and
classifying the slip resistance of new products. In fact, DGUV 208-041 document indicates that the
GMG 200 test does not classify materials and cannot be used to select floor coverings in the planning
stage.

DGUV 208-041 provides the necessary guidance on how to use DIN 51131. It states the test has good
applicability on smooth, hardly profiled surfaces, but it may produce unusable results on some highly
polished surfaces due to slip-stick effects. It has limited applicability on profiled surfaces. prEN 16165
contains a note aimed at reducing slip-stick behaviour. Unlike the other test methods, Annex D for the
tribometer does not have a test report requirement for “a description of the surface (or sample) tested
and its condition (e.g. smooth, profiled, structured7)”.

Use of DIN 51131 is best understood by gaining familiarity with (German language) DGUV 208-041. It
can be inferred that the GMG 200 is best suited for monitoring the slip resistance of flat smooth
surfaces or those with a gritty micro rough texture. The GMG 200 is impaired by loss of contact on
macro rough structured and textured surfaces.

Workplace rule, ASR A1.5 / 1.2, requires employers to conduct risk assessments that has to be carried
out by the employer. In order to ensure that operational facilities are safe, GMG 200 measurements
need to be made starting either with the new products or just after their installation. Control
measurements are made using a 0.1% SLS solution and the SBR rubber slider assembly (as in Annex D
of prEN 16165). DGUV 208-041 operational measurements are made using contaminants that are
present during operations, as well as the footwear. prEN 16165 makes provision for using “other
contaminants commonly used in the test area” but fails to provide for the use of variously profiled
safety footwear as is shown in Fig 4 of DGUV 208-041, as extracted below. The footwear material
seems to lack the chamfer at the leading edge of each slider, although the greater wear of the rubber
sliders has led to greater contact being made than with the leather sliders. Presumably, the variable
amount of profile on the footwear material would exert some influence on the results.

7
Despite this requirement, prEN 16165 fails to provide any definition of smooth, profiled or structured. Slip
resistance is very much influenced by both the macrotexture and the microtexture, while some slip resistance
measurements may be affected by the planarity of the specimen surface.

11
 66 mm

167.5 mm

Enhanced Figure R. Bowman. Source: DGUV 208-041.

N
o
t

c
l
a
s
s
i
f
i
e R9 R10 R11 R12 R13
d

Enhanced Figure R. Bowman. Source: Wetzel et al., 2015. Figure 9 Correlation between GMG 200 test
(with SBR slider and 0.1% SLS solution) and ramp test (with Uvex Athletic shoe and motor oil).

12
If prEN 16165 fails to provide for the use of safety footwear soling material, can the test be sensibly
used as an integral part of measurements that seek to follow DGUV 208-041?

It should be noted that Wetzel et al reported “Owing to the differences between the test shoe and
lubricant materials, the results of tests performed under standardized conditions (Technical
Specification No. CEN/TS 16165:2012, Annex B and Annex D) exhibit poor correlation (Figure 9)”. This
is shown above, where I have superimposed the R classifications and colour coded the GMG 200
interpretation of results based on Skiba’s safe walking Wuppertal limit values.

According to DGUV 208-041, any GMG 200 result of 0.45 or greater is accepted as an indication of
safety. Where μ ≥ 0.30 and μ <0.45, the floor system is assessed as operational, but special measures
may be required. Where μ <0.30, the floor system is assessed as critical and action is required, unless
a zero measurement is available and a control measurement has been made and is at 90% of the value
of the zero measurement, such that the floor system is assessed as operational, although special
measures may be required. In order to reduce the number of slipping accidents, DGUV 208-041
contains a number of technical, organisational, and personal preventive measures.

Looking at Figure 9, the GMG 200 gave a safe rating to several products that did not receive a DIN
51130 classification. In practice, unclassified products should not be installed in German public,
commercial and industrial settings. According to the work of the SlipSTD Consortium, the GMG 200
works well on smooth non-profiled surfaces, where the ramp test is poorly suited. At the other end of
the spectrum, the GMG 200 is not applicable on structured and textured macro rough surfaces where
the ramp test is well suited. The GMG 200 would thus seem to be poorly suited for assessing surfaces
that have been selected on the basis of ramp test results.

Clause D.4.2 of prEN 16165 provides concerning information about the two GMG 200 reference/
verification surfaces:
It can generally be said that (potential) reference and/or verification materials (D.3.6 and D.3.7)
in a certain batch are never completely uniform, and thus the individual surfaces can have a
different dynamic coefficient of friction. Furthermore, as a general rule the surfaces are not entirely
stable, and the measured value is affected by the number of measurements taken on this surface.
For the case that the values in the Table D.1 can not be met because the verification surface has
changed, alternatively individual reference values and confidence intervals may be determined in
a proficiency test according to ISO 13528. The validity period of the individual verification surface
is two years in maximum until they have to be rechecked. The so obtained individual reference
values are applicable for this specific reference/verification board.
To preserve the verification surfaces, additionally, the laboratory or the user can apply a system of
internal testing in which a minimum of two different verification surfaces are used. The dynamic
coefficient of friction values μ for the reference surfaces are approximately 0,30 and 0,45. It may
also be necessary to condition/prepare one or more of these materials in advance to obtain stable
and target reference values. Materials deviating from the reference materials (D.3.6 and D.3.7)
could also be used for this.

ISO 13528:2015, Statistical methods for use in proficiency testing by interlaboratory comparison, is
not listed in the prEN 16165 bibliography. Given the time it has taken to develop prEN 16165, users
might have expected that suitable stable surfaces would have already been developed. Given the wear
that occurs in the ramp test calibration boards, one might have expected to see similar cautionary
material in Annexes A and B. However, the situation with those tests is more complicated due to the
need to maintain the integrity of the classification systems.

Many users may find it simpler to purchase new verification surfaces rather than returning them (to
Germany?) for rechecking. In lacking such details, the draft seems more theoretical than practical.

13
I ntem perate language?
Annex B of prEN 16165 indicates that “A profiled sole is needed to determine the physical-interlock-
slip-resistance which is provided by the profile of the test surface.” I accept that for the purposes of
assessing industrial safety, it is appropriate to specify a shoe of a type that may be mandated to be
worn by staff and visitors. A profiled sole will generally give a higher slip resistance rating than a
smooth sole. However, a result obtained with a profiled sole may overestimate the traction that would
be available to someone not wearing heavily profiled safety shoes. Hence, many people can slip on
wet metallic “safety” chequer plate.

prEN 16165 generally requires that when flooring materials are tested, they shall be tested in the
direction that yields the lowest results. This is in accord with risk management principles. Given that
people are at liberty to choose their footwear in public areas, is the oil wet test a valid test if it assumes
that everyone will be wearing a heavily profiled sole?

In clause C.3.5 there is another reference to interlocking “Where heavily profiled surfaces have been
specifically manufactured to have high slip resistance, which relies heavily upon the interlock action
between the highly profiled pedestrian surface and the heavily profiled soles of some footwear, the
‘pendulum test’ method may not provide accurate indications of the slip resistance”. What defines an
accurate indication of the slip resistance? In what circumstances does the oil wet ramp test provide
an accurate indication of the slip resistance of a flooring material? Arguably, only when the flooring
material is new, appropriately maintained safety footwear is to be worn where the material is
installed, and the calibration boards and specified test shoes are in fine condition.

Is a pendulum slip resistance result inaccurate if it does not represent the maximum traction that
might be available to someone wearing footwear with heavily profiled soles? Surely the lower rating
would provide a better indication of the danger when unprofiled footwear is worn?

In clause C.3.4 there is a statement “If the measurement surface is not sufficiently flat, it will not be
possible to carry out a reliable measurement. In that case, a different section of the surface should be
measured or else a different sample should be selected that does comply with the flatness criterion”.
One has to ask what is a reliable measurement? Is it better if a slip resistance test overestimates or
underestimates the slip resistance of a surface?

The flatness criterion is defined by “The measurement surface should be rejected if the deviation from
a straight line over the length of the surface exceeds 2,0 mm (concave or convex) or if the deviation
from a straight line over the width of the surface exceeds 0,5 mm. This should be checked in the middle
of the measurement surface with the help straight edges and a feeler gauge set over the appropriate
length (135 mm) or width (80 mm).” While it is much easier to state such a criterion than to perform
it in a reproducible fashion, one has to ask whether it applies to all smooth, profiled, and structured
surfaces. I would like to see a published study that supports such a requirement.

Logically, if such a requirement is imposed, it would also have to be applied to the GMG 200 test,
together with an appropriate provision for small units, and an open acknowledgement that the
‘tribometer test’ method may not provide accurate indications of the slip resistance”.

The pendulum foot is spring loaded so it can move up and down, as well as the 76 mm wide slider
being able to slightly rotate in a horizontal plane about its central axis. The pendulum foot moves in
an arc throughout the 126 mm of contact with the specimen, so it is well designed to flatness
variations. As clause C.2.1.2.11 states “In this configuration the slider can turn about its axis without
obstruction to follow unevenness of the surface of the test surface as the pendulum swings”. By

14
contrast, the GMG 200 has three 37.5 ± 2.5 mm long 10 mm wide sliders in a flat plane that extends
over a length of 167.5 mm and a width of 66 mm. It would seem to be far more susceptible to
variations in flatness and profile. Yet there is no flatness criterion in Annex D.

I appreciate the SlipSTD European Collective Research project findings, even if relatively little of the
fine detail of the testing was published in the final report. I accept the observation that attention was
needed to impact variation of the pendulum when testing geometrically profiled surfaces. There is
certainly more sophisticated guidance for testing of geometrically profiled surfaces in AS 4586:2013.

Clause C.3.5 of prEN 16165 also states “When testing highly profiled surfaces, slider 57 generally
produces more consistent results than slider 96”. Whenever such observations are stated as
conclusions, it would be sensible to refer to the studies on which they are based and exactly how the
testing was conducted, and to be able to understand the specific characteristics of the samples that
were tested. Too often, the sample may be atypical and the comment unjustified. Since the ‘expertise’
of many consultants is often based on what they read in standards, it is important that all informative
material should be able to be placed into the correct context.

An unfortunate stum bling block

Having seen so many derogatory remarks inserted into pendulum test methods over the years, the
attempt to integrate the two pendulum soft rubber sliders (Smithers Rapra slider 55 and BAM slider
59) into a slider 57 compromise resolution might be seen as an unfortunate stumbling block rather
than a deliberate act of sabotage. While either slider can be used, they can give different results and
therefore classifications. Similarly the manner in which the rubber sliders are prepared will affect the
test result. Use of lapping film to condition the sliders has caused some products to obtain lower
results, where one product fell from a PTV of 37 to 24. Twenty years ago the product might have been
considered to offer a slip risk of one in a million; today, the slip risk might be considered to be one in
twenty. However, the product is just the same. One benefit of using the lapping film preparation is to
obtain better discrimination between materials at the slippery end of the spectrum.

While the cost of the proprietary rubber test feet may be considered high in first world countries, it is
prohibitively expensive in some emerging economies, particularly if the price has been marked up by
supply chain succession. The rubber manufacturers should take steps to ensure that the rubber will
have an economically reasonable usage life if it is stored appropriately, rather than requiring that they
be discarded 12 months after certification. Many test houses may be tempted to continue using sliders
after the maximum width of the working edge of the slider is reached (2.5 mm for slider 57 and 4.0
mm for slider 96). Many users would like to know how these values were obtained and why they are
so critical.

Considering a prudent Am erican lead

At one stage American interests were very keen to have the ANSI A326.3 wet DCOF test method
included in the ISO ceramic tile slip resistance test methods. In reviewing this test method in 2018, I
commented that while tile manufacturers once reported individual values for products, most were
now merely indicating compliance or not with a (>0.42) requirement for use in wet and level interiors.
However, there were a few exceptions, with some indicating products were within value ranges. One
company indicated minimum wet DCOF values of 0.60 and 0.65 were required for some other uses.
One company provided results accompanied by sensible notes such as “The increased real world
traction of these types of surfaces cannot be fully realized by any current DCOF testing methodology
due to their exaggerated facial structures”; and “Due to heavily textured surface, DCOF value is not

15
able to be measured by testing device”. I asked, “If US tile manufacturers have minimal faith in making
use of the results, why impose them on the rest of the world?”

American interests have since suggested that while a focus on test methods may not be productive, a
focus on classification may be beneficial. This attracted much international interest. At the 2020
Madrid STF Conference, Davidson and Astrachan revealed that the system being developed by the
U.S. ceramic tile industry for inclusion in ANSI A137.1 has five “area of use” classification categories:

1) SR‐Dry
2) SR‐Interior, Wet
3) SR‐Interior, Wet Plus
4) SR‐Exterior
5) SR‐Oils/Greases

The first two categories utilize the ANSI A326.3 wet DCOF (0.42) criteria for level, interior spaces
expected to be walked upon when wet. The other three criteria are based on manufacturer
declarations.

It will be interesting to see if manufacturers base such declarations on ramp tests, pendulum tests or
some other test protocol. It will also be interesting to learn what quality control procedures they
adopt. Pendulum tests can be conducted straight off the production line, and an AWC procedure might
only take a further ten minutes.

The DIN test m ethods and AW C

There is no reason why samples that are to be tested by the DIN test methods could not be prepared
using accelerated wear conditioning protocols (Engels, 2016). However the 1000 x 400 mm size of the
ramp test specimens and the 1000 x 300 mm size of the GMG specimens is much larger than the
pendulum test area, 126 x 76 mm. Ensuring consistent wear becomes more difficult as the area
increases. The need to test for directionality may further complicate the preparation of some surfaces.

The End Gam e

DIN 51130 is the jewel in the crown of the German test methods. We could assume that it was initially
perfect, but even with the changes in calibration boards and footwear, it still seems to be a sensible
means of determining the relative degree of traction that may be available due to the interlocking of
safety footwear with the floor surface in industrial conditions. The ratings have been successfully used
as the basis for ensuring workplace safety in Germany and elsewhere, based on Technical rule No. ASR
A1.5/1,2 that classifies different working areas into the assessment groups R9–R13 according to their
risk of slipping.

One of the virtues of the German system is that they can change the slip resistance requirements for
any work situation should there be any concern about a current requirement. If there was similar
concern in Australia, Spain or elsewhere, there is no clear path for remedial action.

Since the prEN 16165 test methods lack any form of classification, unlike DIN 51097 and DIN 51130,
Annexes A, B and D might be considered to be subsidiary clones of the German standards, whereby a
German committee would assume responsibility for and management of any future changes to the
verification surfaces, test methods, etc, on behalf of the CEN committee or a broader ISO committee
or committees. I perceive a recent trend towards facilitating faster conduct of the testing with less
verification of the walkers. I am concerned about the lack of transparency with regard to the selection
of verification surfaces, and an absence of guidance as to the lifespan of such surfaces (and even
whether it should be measured in terms of time or the number of usages).

16
By contrast, the wet pendulum test can be conducted in the laboratory and in situ. It has the advantage
of a compact test area (126 x 76 mm), which is well suited to many accelerated wear conditioning
(AWC) protocols. As Muñoz has shown, such AWC protocol might be used to prepare samples and to
then estimate their probable end of life slip resistance. Each AWC protocol should be relevant to the
type of material being tested.

The prEN 16165 draft includes a number of critical comments about the pendulum test method
implying that it is limited in use, whereas the three DIN methods are not subjected to such criticism.
The comments in C.3.4 Flatness of the surface and C.3.5 Profiled surfaces are actually far more relevant
to the GMG 200. Annex D recognises limitations associated with its reference surfaces whereas
Annexes A and B overlook such limitations. Standards become reference documents in matters of
litigation. They should be free of biased comments that cannot be supported by respected
publications. Pendulum tests in EN standards seem to have been peppered with critical comments
over the years, whereas the DIN standards have had protected status by virtue of being DIN standards.
It would be churlish to subject them to the same treatment. However, if limitations are to be stated,
all test methods should be subjected to the same approach.

The wet pendulum test has long been used in Australia. In 1999, AS 4586 also adopted the two German
ramp test methods, when we effectively established our own version of EN 16165. The current EN
16165 ramp test method draft has benefited from the Australian gap analyses of ramp testing.

Due to its versatility and ability to be used on site, the pendulum has become our primary test method,
where the ramp tests provide a secondary role in informing product selection in some industrial
situations where safety footwear will be worn, and in some wet barefoot situations.

Having arrived at this juncture, should Australian standards play catch up each time there is a problem
with the calibration boards or the standard footwear? The answer is “probably not”. Another way of
considering the question is to what extent can an Australian committee meaningfully amend such a
standard, or in the CEN context, what committee/s will be responsible for future changes to the
standard, DIN, CEN, or even ISO if it becomes an ISO test method. If a multi-test EN or ISO slip
resistance test method is published, would nations be able to demand data that defines the derivation
of new calibration boards or the consequences of other proposed modifications?

Given recent test result differences that have been obtained by Australian and foreign laboratories,
my personal inclination is to leave the production of secondary (ramp testing) standards to those who
want to legitimise their global use (while presumably seeking to retain total control). However, in
noting that Germany never revised DIN 51097 to adopt the wet barefoot calibration boards that it had
proposed for EN 16165:2016, one has to question why the recommendation was made.

I cannot envisage DIN 51131 ever being used in Australia. It is only a tertiary standard where pendulum
results are already used for monitoring surfaces that were specified according to ramp test results.
However, the manner in which the pendulum should be used for such monitoring should be better
documented in a revision of the HB 198 informative Handbook.

The wet pendulum test is capable of fulfilling the EU M/119 Mandate (1994), as well as Regulation
(EU) No 305/2011. This simply requires the identification of AWC protocol that are appropriate to
specific products and circumstances. There will never be a single AWC protocol for all flooring surfaces.
Wear is not an intrinsic material characteristic but an engineering-system dependent property.

The Australian experience of separating the slip resistance testing into separate standards for new and
existing surfaces paid dividends in forcing us to identify what needs to be considered when testing
existing surfaces and how the reporting must reflect the nature and purpose of the test as this will

17
often influence the choice/s of test site, the methods of preparation used, etc. This all needs to come
out in the test report. The prEN 16165 pendulum draft fails to define the sample, minimum number
of specimens and many other fundamental aspects.

The Australian wet pendulum test methods make some allowance for testing specimens after AWC.
EN 16165 should prepare for a productive future rather than entrenching past practices that reached
their maximum usefulness many years ago.

If prEN 16165 is not adopted, DIN 51097, Din 51130 and DIN 51131 will still exist together with several
pendulum based test methods. There will still be a need to see how existing pendulum test methods
can be improved and which ones can be withdrawn. Such work should involve all interested parties
and need not take a long time.

We have invested in self isolation for the common good. Do we continue to place societal needs, the
minimisation of environmentally induced slip incidents, above self-interests? Where there are
perceived issues with a test method, do we resolve to ask the right questions so that sensible solutions
can be identified? Or do we adopt an attitude that what we have cannot be improved on within an
acceptable time frame; that we can sweep any minor problems under the carpet; that there is no
urgency; and that once we have completed our assignment, any problems can be transferred to
someone else? If prEN 16165 is adopted, will it make it easier or harder to fulfil the highly sensible and
desirable EU M/119 Mandate (1994) and Regulation (EU) No 305/2011?

P ersonal reflections
In Australia, comprehensive legislative reform packages, such as the NSW Design and Building
Practitioners Act 2020 (DBP Act) and the Residential Apartment Buildings (Compliance and
Enforcement Powers) Act 2020 (RAB Act), are being prepared to target defective building work. Where
developers have previously enjoyed a level of flexibility in relation to material usage and final designs,
the new legislation will create a more rigorous certification process. Design and building practitioners
will be required to sign compliance declarations that their works comply with the Act and other
required standards, including the National Construction Code (NCC). Although the NCC has quantified
some deemed to satisfy slip resistance provisions for the surfaces on ramps and stairways, it has yet
to quantify performance requirements that satisfy the objective that buildings provide safe, equitable
and dignified access for people to the services and facilities within. There are significant regulatory
and enforcement powers associated with these Acts where economic loss becomes apparent within
ten years. The practitioners’ duty of care applies to all residential buildings, and thus arguably extends
to ensuring that floors will remain safe for at least ten years.
In Australia, our priority should be to use the pendulum as the principal means of specifying products,
where architects might choose to use the ramp test methods as secondary standards to better inform
themselves, particularly in workplace environments where people will be wearing safety footwear.
The advantage of using the pendulum is its ability to test products at all life stages from cradle to
grave, as well as after product relevant AWC procedures.

We will have to consider whether it is worth the effort to be constantly playing catch up in our national
standards with enforced changes that are made overseas, particularly if we have no say in those
changes. It might be much simpler to simply drop those test methods, namely the wet barefoot ramp
and the oil shod ramp test methods. If Australia wants to continue to use the oil wet ramp test, it
should pay greater attention in its guidance documentation to the significance of the volumetric
displacement requirements, which are an integral element of the German specification system.

18
W hat I w ill suggest
I will be formally recommending that Australia should delete the wet barefoot ramp test method, the
oil wet shod ramp test method and the displacement volume test method (an essential part of the
German slip resistance control system that was not included in prEN 16165). My logic is that since our
Committee has no control over any aspect of any of the test methods, and more particularly the
calibration boards, the footwear, the acceptance angles, critical differences, etc., what benefit is there
in spending hours playing catch up if all one has to do is to call up DIN 51097 and DIN 51130?

One possible benefit in retaining the test methods would be to add guidance material that is absent
in the German standards. However, it might not be possible to add extracts from some German
documents due to copyright restrictions. This material might be added as a local variation, where
satisfactory answers have not been forthcoming from Germany. However, is such effort worthwhile
when one is only considering the initial performance of the ex-factory product? Such a tactic could
address problems with prEN 16165 that have not been resolved in a transparent and well documented
manner. However, would it cause the problems to be addressed and then create a need for one or
more amendments?

There is little point in considering the use of DIN 51131 if this motorised GMG 200 drag sled is only
well suited to smooth flat surfaces. The BOT 3000E test foot might make more effective contact on
other surfaces than the three GMG 200 planar sleds, but the Americans have recognised that such
testing is not well suited for all purposes.

Let Germany revise DIN 51097, DIN 51130 and DIN 51131. Germany already has associated guidance
material including DGUV Information 208-041 and ASR A1.5/1,2 that are vital to the overall operation
of its slip resistance management system.

Australia should concentrate on developing standards based on use of the pendulum: fit for purpose
standards capable of satisfying the European mandates; thus protecting manufacturers, merchants,
design and building practitioners from the potentially increased liability of new building regulations;
better satisfying building owners’ needs and expectations; whilst also better protecting workers and
the general public.

These might be unprecedented times, but it would be an unprecedented mistake to lock in the past
rather than to create a new normal. We have to exercise better judgement. We can choose to deliver
purposeful standards that fulfil visionary social expectations.

P ersonal credentials
I have been privileged to hold various relevant positions over the last 30 years. I established the slip
resistance laboratory at CSIRO, Australia’s premier governmental R&D organisation. I was a member
of the National Occupational Health and Safety Commission’s Research Advisory Panel. I chaired the
Standards Australia slip resistance committee for its first 20 years. I have been active in ASTM F13 slip
resistance committee for over 20 years. I have represented Standards Australia and the British
Standards Institute at ISO/TC 189, Ceramic Tiles, WG 10 slip resistance meetings. I have chaired the
Slips, Trips and Falls Technical Committee of the International Ergonomics Association for the last 5
years. I am the President of the Australian Ceramic Society and represent it on the Standards Australia
slip resistance, and ceramic and stone tiling committees.

19
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Directive 89/106/EEC Text with EEA relevance
Residential Apartment Buildings (Compliance and Enforcement Powers) Act 2020 No 9
Strautins, C. (2008). “Sustainable slip resistance: An opportunity for innovation”, Proc. 10th World
Congress on Ceramic Tile Quality, Castellon, Spain, Vol. 3, P.BC 381.
Strautins, C. (2020). ‘Pendulum calibration, metrological traceability and reference material’. Slips,
Trips & Falls Conf. Madrid 2020, pp 153 – 168.
Wetzel, C, Windhövel, U, Mewes, D, and Ceylan, O. (2015) Slipping on pedestrian surfaces: methods
for measuring and evaluating the slip resistance, International Journal of Occupational Safety and
Ergonomics, 21:3, 256-267.
Wetzel, C. (2020). “Determination of the slip resistance of floorings for barefoot areas”, Slips, Trips
and Falls Conference Madrid 2020, pp 169 - 174.

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Appendix - Sum m ary points
I have sometimes referred to the prEN 16165 test methods by their current DIN standard numbers.
This is somewhat mischievous since I doubt prEN 16165 alone would meet the needs of the German
falls prevention slip resistance system. I anticipate Germany will retain rather than discard DIN 51097,
DIN 51130 and DIN 51131, although the test procedures will be equivalent to those in prEN 16165.
However, since the prEN 16165 oil-wet shod ramp test method does not include the DIN 51130 test
method for measuring volumetric displacement, there is a logical reason for its retention. If DIN 51130
is retained, I would expect EN 16165 follow future amendments of DIN 51130, rather than vice versa.

DIN 51097
• New calibration boards (St-A, St-B and St-C)
• New wetting agent. Increased test solution temperature.
• New walker validation procedure: minimum bimonthly rather than daily
• Direct comparison with calibration board replaced by calculated evaluation process
• No information on derivation of new calibration boards
• No indication of long-term drift from original calibration boards
• Walks now normally cease at an angle of 30 degrees unless there is agreement to go higher
• The result for the first of the four walks on the test sample is now discarded when calculating
the sample mean, where previously the mean of five walks was determined. Originally, when
each walker was required to perform four walks, both walkers would have to perform a
further 4 walks if any individual value deviated by more than 2° from the mean.
• No instructions are provided if the walkers obtain significantly different results on the test
board, as sometimes happens.
• Imprecise calibration instructions.
• One has to report the surface structure, where no guidance is provided other than: e.g.
smooth, profiles, structured; where these terms are not defined.
• One reports the mean result rounded down to the nearest 0.1 degree, but does not provide
an opportunity to report a quality group, such as the DIN 51097 class A, B, or C
• No requirement to report any directional aspects, or to provide any details of the surface
configuration is the flooring is segmented (such as type and width of grout joints).

Many people learn how to conduct tests by reading and interpreting published standards. Clause A.3
of the draft states:

“The inclination of the inclinable walkway surface shall be calibrated annually and checked
periodically. When testing barefoot the standard surfaces can become contaminated with
body fats/oils. This may affect the performance of the surface. It is important to know, when
calibrating or checking that any changes in the surface are due to wear or the operator and
not contamination and it is recommended that the surfaces are thoroughly and properly
cleaned before use.”

How does a novice or an experienced operator conduct such periodic checks and annual calibrations?
How do they differentiate between changes in the surface that are due to (i) wear; (ii) contamination:
and (iii) the operator? How should the surfaces be ‘properly cleaned’ before use? If one uses
inappropriate cleaning practices, wear might occur. How else might the operator compromise the
condition of the boards? Given that the test results are dependent on the condition of the boards,
whether brand new or degraded, how does the operator determine when they need replacing?

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DIN 51130
• New calibration boards (St-I, St-II and St-IIIA)
• New calibration footwear (manufacturer not identified).
• No information on derivation of new calibration boards or footwear
• No indication of long-term drift from original calibration boards and footwear
• Walks now normally cease at an angle of 38 degrees unless there is agreement to go higher
• One has to report the surface structure, where no guidance is provided other than: e.g.
smooth, profiles, structured; where these terms are not defined.
• One reports the mean result rounded down to the nearest 0.1 degree, but does not report a
quality group, such as the DIN 51130 class R9, R10, R11, R12 or R13
• No requirement to report any directional aspects, or to provide any details of the surface
configuration is the flooring is segmented (such as type and width of grout joints).

DIN 51131
• Acknowledges problematic nature of verification surfaces (unstable results due to wear)
• Fails to acknowledge poor suitability when testing surfaces that are profiled, structured, or
not flat. No limitations on use on profiled or structured surfaces.
• No requirement to report whether surface is smooth, profiled, or structured (unlike other test
methods)
• Poor correlation with DIN 51130 results
• No instruction provided on effective use of test method.
• No reference to DGUV 208-041, which provides some guidance on how to use the test method
• Classification of new surfaces forbidden by DGUV 208-041.
• Not suited to testing the required broad range of flooring types.

Pendulum
• Suitable for use in laboratory and on-site
• Can be used to yield product classifications
• Can be readily used in conjunction with surfaces subjected to AWC protocols
• Improved calibration procedure
• Further work required to enable it to become world best practice
• Some unsubstantiated negative comments need to be removed.
• Needs to incorporate use of AWC procedures in order that a modified pendulum test could
fulfil the European mandates.

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2019 correspondence to DI N com m ittee
I trust that the following comments are of assistance. I have severe reservations about some aspects
of the draft, but primarily with the derivation of the calibration boards.
The calibration boards appear to be different from those that were used during the disappointing SFV
project FP341.
Are you able to provide test data that confirms that these boards will reliably perform in the same
manner as the original new A, B and C boards (rather than old worn A, B and C boards)? It is essential
to develop robust and properly validated standards in a transparent manner.
I think the translation at the bottom of section 6 is: "This aptitude test must be repeated at regular
intervals, but at least every 2 months. NOTE The aptitude test does not have to take place on every
test day”. I am uncertain exactly what this means, or rather, the breadth of how it will be interpreted?
However, it seems that if one is confident that the walkers are proficient, the board to be tested is
tested first, and then only the calibration board nearest to that has to be tested.
If other boards are to be tested on the same day and the same calibration board has to be used more
than once, it seems that there is a short cut (compared to our current testing) to prevent too much
testing (of calibration boards) being performed. This would seem to assume that walkers do not tire
during the day and that they are highly consistent.
While labs may welcome less work to generate each result, the new procedure fails to address the
potential variability that we have observed between experienced walkers on some test boards, as well
as their variability on the calibration boards during a day and over longer periods of time.
While some test houses might plot each result of each test walker on the calibration boards in order
to detect variations (and to assess changes in the calibration boards - loss of slip resistance due to
wear) there is no requirement to do so.
The real problem with this test is that if the characteristics of the calibration boards change with time
(as Engels has found to be the case) then the goal posts shift such that any classification is related to
the degree of degradation in the calibration board.
Without providing numerous examples of baffling examples of inconsistent walks made by
experienced test walkers, it would seem sensible to require that the following be reported:
• the direction/s in which a shape was tested (particularly if there are directional issues with
respect to the slip resistance)
• The number of times that the calibration boards have been walked on (as well as the date of
their first use) as we know that they wear. As the calibration boards wear, progressively
more slippery boards will be granted each of the classifications.
• when the aptitude test was last conducted for each of the walkers, together with some
measure as to the walkers' consistency of performance, recognising that such tests also
provide a history of the results obtained on the calibration boards.
• the test results for each of the walkers, together with the calibration board results.
When accidents occur in Australia, greater reliance is placed on in situ (pendulum ) results than on the
wet barefoot testing of new product. However, from a litigious perspective, one still has to address
the issue as to whether the product was fit for purpose when first installed and the fitness for purpose
of individual test methods and their variants. This can foreseeably lead to questions about the
derivation of standards and the relevance of any set of replacement calibration boards and whether
they have then been used past a sensible "use by date" or "condition".
There needs to be some method of determining when the calibration boards have come to the end of
their life cycle. The sooner this can be discussed the better it will be for all countries that rely upon
wet barefoot testing.

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