EN 1090-1 and CE marking of structural metalwork
EU & UK Law on CE marking of construction products
The Construction Products Regulation (CPR) was placed on the statute books in March 2011 to enforce the European Construction Products Directive. The aim of the Directive is to harmonise the safety performance of construction products across the European trading bloc and they apply to construction products whether they are imported or manufactured in the EU. The Directive identifies six principles for materials that are to be used in civil engineering:-
- Mechanical resistance & stability
- Safety in case of fire
- Hygiene, health & the environment
- Safety in use
- Protection against noise
- Energy economy & heat retention
From July 1st 2014 any “series” manufactured structural metal components or kits that are either made in the UK or imported, and to which a harmonised European standard applies, must comply with the CPR & CE marking requirements. The harmonised European standard that applies to structural metalwork is BS EN 1090-1:2009 +A1:2011 and it is a criminal offence to supply structural metalwork after the 1st of July 2014 unless it conforms to this standard and carries a legitimate CE mark.
A second piece of legislation was introduced in 2013 to allow the Construction Products Regulation to be enforced by the Trading Standards authority, which has the power to stop a business from trading and also to withdraw any products supplied after July 1st 2014, until the company has shown that it complies with the Regulation. This will be costly for any businesses that are discovered not to be complying with the law because they may need to cease trading during the long period needed to implement BS EN 1090-1. The company will also have to carry the cost of product recalls and fines. In severe cases Directors may also be imprisoned.
Who needs to comply with CE marking of structural metal?
The regulations apply to a wide range of activities involving “series” manufactured items:-
- Importers of structural metalwork kits or components
- Stockholders and metal processors that modify stock – for example by drilling, painting, bending etc.
- Manufacturers of metal components or kits that have a structural use in civil engineering.
By “series”, the regulations mean an 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. If the same factory produces a single platform as a special commission, this will be exempt. However if the factory decides to diversify into platforms and makes more than one, CE marking will be required.
How do I comply?
Organisations covered by the Regulation will need to show that they comply with BS EN 1090-1 and that they have a written Factory Production Control (FPC) system in place. An FPC is a quality management system that states how the company controls everything from first contact with the customer, through to final inspection before shipping. Setting up the FPC involves a number of steps that end with certification by a third party, known as a notified inspection body (NB). In the UK all NBs must be accredited themselves by the United Kingdom Accreditation Service (UKAS), many of which are familiar as certifying ISO 9001, ISO 14001 and other international management standards.
BS EN 1090-1 requires a number of actions to be in place, many of which will already be standard practice in well-run companies:-
- Purchasing systems will need be set up such that suppliers ship materials, bolts and welding consumables that are compatible with CE marking.
- Designers will need to identify the execution class of the product, as defined in the companion standard BS EN 1091-2, which is determined by the potential risk to the public if the component or structure fails. The designers will also need to ensure that the design is structural sound.
- Prototypes will be produced and subjected to initial type testing. Where type testing is impractical, for example on bespoke designs, the company can use structural calculations to serve the same purpose.
- The FPC system needs to be designed to 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 ISO 9001, this may cover some of the requirements for a FCP system, but will almost certainly need to be modified.
- Where welding is part of the process, a Welding Quality Management system is needed and this must conform to BS EN ISO 3834. The company should either employ, or have access to, a Responsible Welding Coordinator to control their welding quality management system.
- Once the above in place the company is ready to become certified by a notified inspection body.
The organisation may decide that it has the skills, experience & free-time to meet these commitments in-house. Depending on the existing level of experience of putting management systems in place, an organisation should budget for up to 60 person-days to get BS EN 1090-1 up & running. As an alternative the organisation may decide to appoint a consultant to cover weaknesses that it has identified in skills & experience or time availability. An experienced consultant will be able to short-cut much of the planning process, which should lead to faster implementation, a simpler system and a major reduction in the time committed by the organisation’s own people.
Most well-run manufacturers of structural metalwork will already have the elements needed to conform to BS EN 1090-1 and a skilled consultant can take what an organisation already does and demonstrate how it meets the standard, rather than having to write completely new processes from scratch. This avoids the need for employees to learn new ways of working and cuts down the time needed for implementation.
How can I get help?
Construction Certification has years of experience helping companies in construction & allied trades to implement quality, environmental & safety management systems and so can reduce the time and cost needed to achieve certification. We can carry out gap analyses to identify what you need to do to comply with BS EN 1090-1, 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 NB.