The Construction Products Regulations 2011 (CPR) make it a legal requirement to CE marking series-manufactured structural metal components or kits that are covered by a harmonised European standard. After the 1st of July 2014 it became a criminal offence to supply metalwork for civil engineering uses without a legitimate CE mark. The harmonised European standard for structural steel and aluminium is BS EN 1090-1:2009 +A1:2011, otherwise known as EN 1090 part 1.
Who does CE marking apply to?
The regulations apply to a wide range of activities involving “series” manufactured items:-
- Fabricators of structural beams and frames
- Manufacturers of secondary metal access, platforms and barriers that have a structural element in their design
- Stockholders and metal processors that modify stock for a construction end-use, for example by drilling, painting, bending and hot-cutting.
- Importers of structural metalwork kits or components
By “series”, the regulations mean any activity that an organisation carries out more than once, not just the production of a series of standard items. For example a factory that makes bespoke staircases is in the business of “series” manufacture of staircases and all of them will need to carry a CE mark.
What fabricators need to do?
Organisations covered by CPR will need to show that they comply with EN 1090 part 1. In order to do this organisations have to put quality assurance measures in place that, combined, are known as a Factory Production Control system. Factory Production Control includes:-
- Evidence that designs are structurally fit for purpose and that an Execution Class has been defined
- Purchasing of CE Marked materials, fixings and welding consumables
- Where welding is part of the process, a Welding Quality Management system that conforms to BS EN ISO 3834 and that is controlled by a Responsible Welding Coordinator.
- Standardised welding procedures, known as Qualified Weld Procedures and evidence that welders are competent, for example by coding.
- A method for producing clear manufacturing instructions
- Critical control points need to be identified and monitored, which include design and drawing controls; competence and training of staff; equipment maintenance & calibration; control of non-conforming product & keeping of records. If a company has a UKAS approved ISO 9001, this may cover some of the requirements for a FPC system.
- Certification by an accredited “Notified Inspection Body”
Because there are a number of international standards that need to be taken into account when putting in a Factory Production Control system and because there is a lead-time involved in developing welding procedures, having welders coded and arranging for final certification, the implementation process can take up to 12 months from start to finish.
What help is available?
AW Inspection has years of experience working with fabricators, so can reduce the time and cost needed to set up a Welding Quality Management system, establish Qualified Weld Procedures, arrange coding of welders, coaching for the Responsible Welding Coordinator and calibration of weld sets. We also work with an experienced FPC consultant who can carry out gap analyses to identify what you need to do to comply with EN 1090 part 1, help you to define a plan to implement any changes, guide the preparation of Factory Production Control, carry out pre-certification checks on the compliance of your systems and manage the certification visit by the Notified Inspection Body.