“Two Steps Forward, One Step Back” — Dancing Tango with Greek Technical Legislation
I will begin with some slightly boring, but historically important, information about Technical Specifications. Anyone who wishes may skip directly to the present by reading the next section.
The existence of complete and updated standard technical specifications for all sectors of Public Works had long been a standing demand of all stakeholders involved.
The first institutional effort was made in 2002 through the Joint Ministerial Decision DO/O/98/F.1510/21-10-2002 — Government Gazette B 1363, issued by the Ministers of YPECHODE and Interior, Public Administration and Decentralisation, establishing two Project Management Groups.
The second Project Management Group was responsible for coordinating and managing the implementation of the section titled “Technical Specifications and Cost Determination Systems” and operated from late 2002 until early 2006.
In cooperation with the Institute of Construction Economy — IOK, a total of 440 PETEPs — Provisional National Technical Specifications were delivered between 2005 and 2006.
The term “provisional” was used because these specifications required consultation with the remaining stakeholders before being officially institutionalised. Subsequently, the provisional specifications would become standardised technical specifications.
These first PETEPs, coded as XX-XX-XX-XX, were uploaded to the website of the General Secretariat for Public Works, www.ggde.gr, for further consultation and comments, bearing the watermark “draft”.
During the period 2006–2010, a further 220 PETEP titles were processed.
Although the work of drafting and publishing the first 440 PETEPs had already been completed by 2006, they were never put into force. A considerable period of time was spent discussing how they should be implemented — through a Ministerial Decision or through ELOT.
Eventually, in 2009, it was decided that the PETEPs would be institutionalised through the procedures of ELOT.
In August 2009, following a contract signed with YPECHODE, ELOT undertook the transformation of PETEPs into ETEPs — Hellenic Technical Specifications. This involved formatting the texts according to the structure of European Standards — CEN drafting rules — and updating the references to the European Standards in force at the time.
The ETEPs would retain the coding of the PETEPs, with the addition of the prefix ELOT TP 1501 to the original code XX.XX.XX.XX.
The notification process of the ETEPs to the EU through ELOT was completed, and the EU’s agreement was given in May 2010.
Finally, 440 ETEP titles were approved by decision of the Alternate Minister of Development, Competitiveness, Infrastructure, Transport and Networks and published in Government Gazette 2221 B / 30-07-2012.
In 2014 and 2016, the mandatory application of 67 ETEPs was suspended through Ministerial Decisions, and the Ministry recommended the use of the corresponding older PETEPs instead.
Most of these — 70 ETEPs — returned with new texts in 2019 through Decision D22/4193/22.11.2019 — Government Gazette 4607 B / 2019 of the Ministry of Infrastructure and Transport.
From 2021 to 2023, ELOT began the revision of the first edition of 314 ETEPs, aiming to check and ensure their compatibility with Union law, the applicable European Standards and, where such standards did not exist, with International Standards, European Regulations and National Legislation, in accordance with Article 42 paragraph 3 of Directive 2014/24/EU.
The public consultation took place in four phases and, from December 2022 to March 2024, all ETEPs of the first revision and 18 of the second revision were approved and published in the Government Gazette through three decisions of the Ministry of Infrastructure and Transport.
The validity of these three decisions begins three months after their publication in the Government Gazette.
The Case of Road Marking Paints
Road marking and, by extension, the requirements for road marking paints were defined by PETEP 05-04-02-00 in May 2006.
The code corresponds to:
- 05 — Road Works.
- 04 — Signage.
- 02 — Horizontal marking of traffic surfaces.
- 00 — Specific technical specification.
The First Step Forward
On 4 January 2023, during the fourth phase of the revision of the 314 ETEPs, the draft ELOT TP 1501-05-04-02-00:2022 was submitted for consultation, with a deadline for comments on 21 February 2023.
The comments and the final text of the standard / ETEP were never published. The text appeared only on 26 March 2024 in Government Gazette 1890 B / 2024, through Decision 70969/2024 of the Ministry of Infrastructure and Transport.
The ETEP, now the standard ELOT TP 1501-05-04-02-00:2023, titled “Road Marking of Road Works”, states in its foreword that:
“It was prepared by experts and checked and evaluated by an editor / specialist expert in its field, who supported the work of ELOT/TE99 ‘Specifications for Technical Works’, whose secretariat is held by the Standardisation Directorate of the Hellenic Organisation for Standardisation — ELOT.
The text of this Hellenic Technical Specification ELOT TP 1501-03-07-06-01 was approved on 2023-03-24 by ELOT/TE 99 in accordance with the regulation for the drafting and publication of Hellenic Standards and Specifications.”
Obviously, the ETEP number is incorrect and should normally refer to ELOT TP 1501-05-04-02-00.
Nevertheless, the new revision is largely rationalised and introduced improvements, as shown in the tables below.
The Second Step Forward
The requirement for wheel passages was reduced for paints to P6 — 2,000,000 wheel passages.
At the same time, in the performance requirements of the material — according to EN 1463 — the requirement for measuring the retroreflection coefficient under wet conditions, RLR, was removed. This was a parameter that some laboratories did not measure.
The requirement for the retroreflection coefficient during rain, RLW, was also reduced from RW2 to RW1.
However, the most important change was the rationalisation of the high skid resistance requirement from S3 to S1, since this was the requirement that most commercial products failed to satisfy.
To explain this briefly for non-specialists: in a road marking paint, in order to achieve a high retroreflection coefficient — in other words, to be visible at night — special glass beads are added, reflecting the light from vehicle headlights.
At the same time, in order for a road marking paint to have anti-skid properties, special coarse aggregates are added.
These two additives act competitively within the paint, and it is very difficult to achieve high performance in both parameters at the same time.
Table 1. Requirements Defined per Road Category
| Road Category | Description | PETEP 05-04-02-00 | ELOT TP 1501-05-04-02-00:2023 — Type I, min. 0.4 mm | ELOT TP 1501-05-04-02-00:2023 — Type II, min. 0.6 mm |
|---|---|---|---|---|
| BI & BII | Urban motorway and express road | P7 | — | P6 |
| BIII & CIII | Urban arterial road and main collector road | P6 | P6 | P6 |
| BIV & CIV | Main collector road | P5 | P5 | — |
| — | Pedestrian crossings | P7 | P6 | — |
| AI | Motorway and express road | P7 | — | P6 |
| AII | Road between prefectures / provinces | P7 | P5 | P6 |
| AIII | Road between provinces / settlements | P6 | P5 | P6 |
| AIV | Road between small settlements and collector road | P5 | P5 | — |
Notes:
In the older PETEP, the reference concerned:
- 1.0–1.2 mm thermoplastic and cold-plastic systems.
- 0.6–0.8 mm for paints.
In the revised ELOT TP 1501-05-04-02-00:2023, the reference concerns:
- Sprayed road marking systems with applied film thickness ≤ 1.2 mm.
Table 2. Minimum Recommended Values According to EN 1463
| EN 1463 Parameter | PETEP 05-04-02-00 — Initial Condition | PETEP 05-04-02-00 — Functional Condition | ELOT TP 1501-05-04-02-00:2023 — Initial Condition | ELOT TP 1501-05-04-02-00:2023 — Functional Condition |
|---|---|---|---|---|
| Qd | — | Q2 | Q4 | Q3 |
| RL | R5 | R2 | R4 | R2 |
| RLW | — | RW2 | RW3 | RW1 |
| RLR | — | RR2 | — | — |
| SRT — BI, BII, AI and pedestrian crossings | — | S3 | S1 | S1 |
| SRT — remaining categories | — | S1 | S1 | S1 |
| Percentage of remaining surface | — | >90 | — | >90 |
Another important change was that, in the test report requirements under the section on acceptable materials, the reference to material durability as a percentage of remaining surface was removed, although it still exists as a general requirement in the standard.
The One Step Back
And while we had taken two steps forward after almost 18 years, paragraph 4.1 was added, taking us at least 10 years backwards.
4.1 Solvent Content
The use of road marking materials and systems whose paints contain a low percentage of volatile organic compounds — Low VOC — is recommended for reasons of environmental and personnel safety.
The content of volatile organic solvents in all road marking materials must not exceed 25% by weight.
The percentage of aromatic solvents classified in categories T+ — very toxic and T — toxic is required to be less than 0.1% by weight, while the percentage of those classified as Xn — harmful must be less than 1% by weight.
It is worth stressing that this paragraph did not exist at all in the standard under consultation in 2023 and was added by someone with very limited knowledge of the subject.
It is understandable that everyone is trying to produce paints that are more environmentally friendly. However, at present, solvent-based road marking paints with 25% by weight solvent content are not commercially available, and any exception simply proves the rule.
Not only that, but in the paragraph describing acceptable materials, it is also required that the certificate should state the composition percentage by weight of solvent — something that, until now, is not explicitly stated in any certificate.
Therefore, until any new certificate is issued — including the research required for paints of a new composition — no road marking paint containing solvents will be usable.
And while many fellow scientists might see this as a challenge for research and development of new products, the second paragraph takes us all many years backwards.
The hazard classification of solvents in this paragraph of the standard is made according to the DSD / DPD Regulation — 67/548/EEC and 1999/45/EC, which has been replaced since 1 June 2015 by the CLP Regulation — EC 1272/2008.
This makes interpretation of the standard very difficult today.
But even if we entered a time machine and went back to 2015, we would easily discover that all common solvents still used in acrylic road marking paints were at least classified as Xn — harmful.
Therefore, according to the standard, their content must be only 1% by weight.
In practice, the addition of this paragraph removes the possibility of using solvent-based road marking paints in all projects from 26 June 2024.
References
[2] https://www.et.gr/api/DownloadFeksApi/?fek_pdf=20020201363
[3] https://www.et.gr/api/DownloadFeksApi/?fek_pdf=20120202221
[4] https://www.et.gr/api/DownloadFeksApi/?fek_pdf=20190204607
[5] http://www.ggde.gr/dmdocuments/05-04-02-00.pdf
[7] https://elot.gr/sites/default/files/h-files/2023-01/etep_05-04-02-00_dt1_stg4_wm.pdf
[8] https://www.ggde.gr/images/attachments/etep/2024/79_18_etep/FEK-2024-B-01890.pdf
[9] https://www.ggde.gr/images/attachments/etep/2024/79_18_etep/ETEP_05-04-02-00.pdf