How does the Construction Products Regulation affect manufacturers of constructional steelwork and aluminium?
The Construction Products Regulation requires that, from July 2014, any fabricated steel or aluminium must be CE Marked. This applies to products both manufactured within the European Economic Area or imported into it. BS EN 1090-1 Execution of steel and aluminium structures specifies how compliance with the requirements is achieved in order to legally CE Mark products being released to market.
How to determine if your product needs CE Marking?
- Is the construction product made from steel or aluminium?
- Is the product load-bearing?
- Will the product been installed in a permanent manner?
- Is the requirement for CE Marking specified on the customer drawing?
If it has been established that your product(s) meet any of the above requirements then it must be CE Marked and a signed declaration of performance provided which details the characteristics of the fabricated product.
The declaration of performance must be supported by in-house documentation which includes a Factory Production Control System which details procedures, inspections and processes undertaken to fabricate the product. There must be recorded evidence that details states how you fabricated your products from design to delivery. Records must be retained for a minimum of 10 years.
Steps to achieve CE Marking?
Step 1: Obtain a copy of the relevant standards
1. EN 1090-1:2009+A1:2011 Requirements for conformity assessment of structural components.
2. EN 1090-2:2008+A1:2011 Technical requirements for steel structures.
3. EN 1090-3:2008 Technical requirements for aluminium structures.
Step 2: Identify which Execution Class you need
The Execution Class is a measure related to the nature of the product covering its materials, manufacturing processes, mechanical performance and, crucially, what would be the impact in the event of its failure, all of which establish the level of risk involved. EN 1090 gives guidance on how to determine a given Execution Class.
The Execution Class ranging from 1 to 4, covers the fabricated products from barns to stadia respectively. The most common class is Execution Class 2, which covers the vast majority of structural projects that fall into the scope of EN 1090.
The higher the Execution Class, the more stringent the Factory Production Control System quality assurance procedures and traceability must be. The relevant issue of ISO 3834 Quality requirements for fusion welding of metallic materials describes in detail how each execution class is addressed. It is not possible to be accredited to an execution class and CE Mark to a higher class.
Step 3: Appoint a responsible welding coordinator
One of the requirements of EN 1090 is that the fabricator must employ (or subcontract) a Responsible Welding Coordinator who has the necessary qualifications, technical knowledge and experience to oversee all welding aspects of the Factory Production Control System. The Responsible Welding Coordinator will be able to determine the competence of the in-house welding personnel and the capability of the equipment and advise (or provide) any necessary training or improvements to meet all the requirements of the declared Execution Class.
Step 4: Carry out a self assessment
You will now be in a position to assess the effectiveness of your Factory Production Control System against your stated Execution Class. There are seven main clauses against which you will be assessed on:
- Personnel
- Equipment
- Structural Design Process
- Constituent Products Used in Manufacture
- Component Specification
- Product Evaluation
- Non-Conforming Products
Step:5 Gain certification from an approved body
As part of achieving approval to CE Mark, you will require a third-party certification of your Factory Production Control System. In the UK the Certification Body must be UKAS (United Kingdom
Accreditation Service).
How Independent Advice for Business Can Help?
We have worked with a number of clients to successfully achieve EN 1090 certification.
We are able to assist you in:
- identifying a suitable responsible welding coordinator
- developing your Factory Production Control System Manual and associated documentation
- advise on implementing the procedures into the company’s processes
- carry out the self assessment on your behalf
- attend the certification audit and and support your accreditation process
Please Contact Us to arrange a meeting to discuss your requirements further
