guide to ce marking of structural steelwork

Guide to the CE Marking

of Structural Steelwork

BCSA Publication No. 46/08

Guide to the

CE Marking of

Structural Steelwork

2

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The British Constructional Steelwork Association Ltd.

4, Whitehall Court

Westminster

London

SW1A 2ES

Tel: +44(0)20 7839 8566

Fax: +44(0)20 7976 1634

E-mail: [email protected]

Website: www.steelconstruction.org

BCSA Publication No. 46/08

ISBN 10 1-85073-562-X

ISBN 13 978-1-85073-562-5

British Library Cataloguing-in-Publication Data

A catalogue record for this book is available from the British Library.

©The British Constructional Steelwork Association Ltd

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Guide to the CE Marking of Structural Steelwork

3

THE BRITISH CONSTRUCTIONAL

STEELWORK ASSOCIATION LIMITED

The British Constructional Steelwork Association Limited (BCSA) is the national

organisation for the steel construction industry: its Member companies undertake

the design, fabrication and erection of steelwork for all forms of construction in

buildings and civil engineering. Associate Members are those principal companies

involved in the supply to all or some Members of components, materials or products.

Corporate Members are clients, professional offices, and educational

establishments etc., which support the development of national specifications,

quality, fabrication and erection techniques, overall industry efficiency and good

practice.

The principal objectives of the Association are to promote the use of structural

steelwork; to assist specifiers and clients; to ensure that the capabilities and

activities of the industry are widely understood and to provide members with

professional services in technical, commercial, contractual and quality assurance

matters. The Association's aim is to influence the trading environment in which

member companies have to operate in order to improve their profitability.

A current list of members and a list of current publications and further membership

details can be obtained from:

The British Constructional Steelwork Association Ltd.

4, Whitehall Court

Westminster

London

SW1A 2ES

Tel: +44(0)20 7839 8566

Fax: +44(0)20 7976 1634

E-mail: [email protected]

Website: www.steelconstruction.org

4

SUMMARY

This document gives guidance on the CE Marking of structural steelwork. It applies to structural

steel components that are manufactured as welded or non-welded fabrications. The components

may be CE Marked individually or collectively as a kit.

The general guidance applies to structural steel components to be used in building construction.

It can also be applied, with some modification, to components to be used in other construction

applications including bridges.

This publication has been reviewed by Stephen Rein MCIOB, MInstCES, who was a consultant to

CEN for five years and is co-author of ‘The Construction Products Directive: A practical guide to

implementation and CE marking’.


5

CONTENTS PAGE

1 INTRODUCTION AND SCOPE 71.1 Objective 7

1.2 Scope 7

1.3 Overview 7

2 CE MARKING REGULATIONS 92.1 Construction Products Directive 9

2.2 Harmonised standards 9

2.3 Certification 10

2.4 CE Marking 11

2.5 Construction Products Regulations 11

2.6 Future developments 12

3 CE MARKING STANDARD FOR STRUCTURAL STEELWORK 133.1 Basis 13

3.2 Scope 13

3.3 Definitions 13

3.4 Requirements 20

3.5 Evaluation methods 21

3.6 Evaluation of conformity 21

3.7 Marking system 26

4 EUROPEAN FABRICATION STANDARD 294.1 Status and scope 29

4.2 Documentation 30

4.3 Constituent products 30

4.4 Tolerances 30

4.5 Welding 31

4.6 Surface treatment 32

5 WELDING QUALITY MANAGEMENT 335.1 Welding as a 'special process' 33

5.2 Control of welding 33

5.3 Technical instructions 34

5.4 Competence of personnel 34

5.5 Implementation 34

6 RESPONSIBLE WELDING COORDINATORS 356.1 Welding coordination 35

6.2 Tasks for welding coordinators 35

7 TRACEABILITY 377.1 Introduction 37

7.2 Government Circular 37

7.3 Inspection documents 38

7.4 Requirements 38

7.5 Batch or type traceability 39

7.6 Welding 39

6

8 SUPPLY CHAIN IMPLICATIONS 408.1 Introduction 40

8.2 Manufacturers 40

8.3 Importers 40

8.4 Distributors 40

8.5 Stockholders 41

8.6 Steel processors 41

8.7 Special products and processes 41

8.8 Transition period 42

9 EXECUTION CLASS 439.1 General 43

9.2 Application to buildings 43

9.3 Wider application 43

10 FACTORY PRODUCTION CONTROL 4410.1 Introduction 44

10.2 FPC systems 44

10.3 System requirements 45

11 ROUTES TO CERTIFICATION 4811.1 Introduction 48

11.2 Assessment of the WQMS 48

11.3 Assessment of the RWC 49

11.4 Surveillance audits 50

11.5 Steel Construction Certification Scheme 51

12 IMPLICATIONS FOR DESIGNERS,

SPECIFIERS AND CONSTRUCTION MANAGERS 5312.1 Introduction 53

12.2 Designers and specifiers 53

12.3 Construction managers 54

APPENDICES

A ASSESSMENT OF THE RWC 56

B ISSUES ASSOCIATED WITH BRIDGES 57

C DOCUMENTARY EXAMPLES 60

D SG17 GUIDANCE ON FPC ASSESSMENT 64

E ABBREVIATIONS 70

REFERENCES 71


7

1 INTRODUCTION AND SCOPE

1.1 Objective

The objective of this document is to provide practical guidance on the CE Marking of structural

steelwork in accordance with the Construction Products Directive (CPD) and the UK's

Construction Products Regulations (CPR). The guidance is for steelwork contractors, their

purchasing clients and supply chain including designers, specifiers and construction managers.

1.2 Scope

The guidance in this document applies to the CE Marking of structural components that are

manufactured from carbon steel as welded or non-welded fabrications. The components

may be CE Marked individually or collectively as a kit.

This document applies to components intended for installation in construction works to be

built in the United Kingdom (UK), and applies as appropriate to the Republic of Ireland (RoI).

It is addressed principally to components used in structural steelwork for building

construction works undertaken to the BCSA's National Structural Steelwork Specification for

Building Construction (CE Marking Edition). It can also be applied, with some modification,

to components to be used in other construction applications including bridges, or to

structural components manufactured from stainless steel or steel castings.

As explained in this document, CE Marking is applicable to the manufacture of structural

steel components, that is to the operations undertaken by steelwork contractors in the

fabrication of structural steelwork rather than the erection of structural steel frames on site.

1.3 Overview

With respect to the European Construction Products Directive, CE Marking applies to

manufactured structural components placed on the market individually or as a kit of

components and intended for use in any form of construction works (except marine and

offshore). The basis of the regulatory regimes applicable in the UK and the Republic of

Ireland is explained in section 2.

Components manufactured from structural steel may be CE Marked once they demonstrate

compliance with the relevant harmonised European Standard using the appropriate system

of attestation. The European Standard relevant to structural steel components is EN 1090-

1 and this document assumes that the British Standard BS EN 1090-1 will be available by

the end of 2008 from which date CE Marking of structural steel components is possible. EN

documents are designated with I.S. EN when issued in the RoI with otherwise identical text

to BS EN versions.

BS EN 1090-1 Execution of steel structures and aluminium structures - Part 1:

Requirements for conformity assessment of structural components defines the

manufacturing controls needed to ensure that structural steel components meet the

necessary technical requirements that are defined in BS EN 1090-2 Execution of steel

structures and aluminium structures - Part 2: Technical requirements for steel structures.

The contents of these standards are explained in sections 3 and 4.

Special provisions apply if welding is used in steel component manufacture, and these are

explained in sections 5 and 6 and Appendix A.

The fabrication of structural steelwork is an assembly process that uses constituent

products (i.e. steel sections, fasteners and welding consumables). Some of these products,

SECTION 1 : INTRODUCTION AND SCOPE

8

such as curved beams, may be part-processed but not ready for incorporation into the

construction works until after further fabrication. Sections 7 and 8 explain how CE Marking

applies to these supply chain products and the requirements applicable to the fabrication

process necessary to ensure sufficient traceability.

BS EN 1090-2 introduces the concept of “Execution Class” that enables specifiers to select

the level of manufacturing quality management appropriate to how safety critical the

component will be in the construction works. This is explained in section 9.

As structural steel components are safety critical, CE Marking to BS EN 1090-1 requires

that the component manufacturer's factory production control (FPC) system is

independently assessed and certified by a body notified to the European Commission by

the appropriate national agency (DCLG in the UK). A manufacturer may employ any

suitable notified body (NB) from any member state to undertake initial inspection and

continuous surveillance of its FPC. Sections 10 and 11 explain this and what manufacturers

need to do. Further guidance issued by the European Group of Notified Bodies is included

in Appendix D.

Section 12 explains that, whilst CE Marking of structural steel components is relevant

primarily to manufacturers, it also has implications for designers - whether as specifiers of

the construction works requirements or as drafters of the manufacturing specification.

The general guidance in this document applies to structural steelwork used in building

construction. It can also be applied, with some modification, to components to be used in

other construction applications, and the different issues applicable to bridgework are

explained in Appendix B.

Appendix C provides example of the documents that support CE Marking.

Appendix E lists the abbreviations used in this document.


9

2 CE MARKING REGULATIONS

2.1 Construction Products Directive

The Construction Products Directive (CPD) came into force in 1988 and introduced the concept

of CE Marking for all construction products permanently incorporated into 'construction works'.

This includes steel products such as steel sections, bolts, welding consumables and fabricated

steel components that are used in buildings, bridges, highways or other civil engineering

projects. The CPD is a piece of European legislation that is considered as one of the 'New

Approach' Directives, though the CPD differs in certain significant ways from the typical New

Approach Directive. Like all New Approach Directives the CPD was created to remove barriers

to trade by providing a common set of 'tools' across Europe to address the different rules on

construction products in the various member states; specifically the CPD establishes the

following framework:

• A system of harmonised standards (sometimes referred to as hENs);

• An agreed system for demonstrating the suitability of products;

• A framework of certification bodies (known as Notified Bodies); and

• The ability to CE Mark products.

This is explained in summary in the document CE marking under the Construction Products

Directive, published by the Department for Communities and Local Government (DCLG) and

currently available from the DCLG website.

A more detailed guide is: The Construction Products Directive - A practical guide to

implementation and CE marking, authored by Adam Pinney and Stephen Rein, two UK experts

who have acted as consultants to CEN and the European Commission in this area. Further

information can be found on http://www.apsrconsultantsltd.com.

As the CPD relates to public safety, enforcement is by means of a criminal prosecution against

the company and its relevant employee. Some enforcement proceedings have been

undertaken by UK regulators over the period since 1988.

2.2 Harmonised standards

The CPD lists six 'essential requirements' that apply to all civil engineering works, these are

listed below:

1. Mechanical resistance and stability.

2. Safety in case of fire.

3. Hygiene, health and the environment.

4. Safety in use.

5. Protection against noise.

6. Energy economy and heat retention.

These essential requirements derive from a comparison of what public safety provisions are

included in the building and construction regulations of the EU's member states. In essence,

meeting the provisions should ensure that the products meet the regulatory requirements of all

EU member states, including, for instance, the provisions on materials and workmanship in

Regulation 7 of the Building Regulations applicable to England and Wales.

For steel products and ancillaries only mechanical resistance and stability and safety in case of

fire apply. The harmonised product standards break down these general requirements into

specific measurable properties termed essential 'performance characteristics' (e.g. yield

strength, toughness and load bearing capacity) and establishes the values to be met.

SECTION 2 : CE MARKING REGULATIONS

10

The harmonised product standards establish common test methods and reporting styles for

declaring the essential characteristics of a product in the information accompanying CE Marking

- for example the required yield strength of nominal S275 steels reducing with thickness. They

also define the test methods and the testing frequency if sampling is to be adopted.

For steel products the main harmonised product standards are:

Steel sections and plates - BS EN 10025-1;

Hollow sections - BS EN 10210-1 and BS EN 10219-1;

Preloadable bolts - BS EN 14399-1;

Non-preloadable bolts - BS EN 15048-1;

Fabricated structural steelwork - BS EN 1090-1.

Providing the attestation of conformity procedures have been complied with, then CE Marking

is possible after the harmonised standards are cited in the Official Journal (OJ) and the date of

applicability given on the NANDO website has passed.

(See http://ec.europe.eu/enterprise/newapproach/nando/index.cfm?fuseaction=cpd.hs).

The Commission and much of Europe consider CE Marking is compulsory once the date of the

end of the coexistence with national technical specifications has passed: the date is also given

on the NANDO website.

For EN 10025-1 the date of applicability was 1st September 2005 and the date for the end

of the coexistence period was 1st September 2006 giving a year's transition period for

manufacturers to implement CE Marking against the standard. For EN 1090-1 it is expected

that the standard will be published by CEN around December 2008. The date of applicability

will then be published on the NANDO website. This is likely to be around August 2009. It has

been agreed that there will be a two year coexistence period which would then end around

August 2011. By then the amended Construction Products Regulations are likely to be in

force and, as explained below, these are likely to make CE Marking mandatory throughout

the European Union.

2.3 Certification

The CPD gives four different systems (with two additional sub-systems) for attesting that a

product conforms to the performance characteristics given in the harmonised standard (this is

called attestation of conformity). The system which applies to a product is published as a

Commission Decision in the OJ and is also given in a mandate from the European Commission

to CEN and is chosen on the basis of the nature of the product, its intended end use and the

role it plays in the structure. In the case of structural steelwork this is covered in mandate M/120

for structural metallic products and ancillaries that also covers rolled steel products, fasteners

and welding consumables.

Safety critical products like structural steel components and fabricated structural steelwork

are at attestation of conformity system 2+. This means that the manufacturer is not allowed

to fix the CE Marking without having a suitable factory production control (FPC) system in

place. This is verified by a notified inspection body (NB) after initial inspection and subject to

continuing surveillance who issues a certificate confirming that the manufacturer's FPC is

adequate to give confidence that the manufacturer's processes can produce products that

comply with the relevant harmonised standard.

For a body to be a NB for the purposes of BS EN 1090-1 it must be notified as an FPC

inspection body by a member state to the Commission and to other member states. This

notification confirms the NB as competent to assess the manufacturer's FPC as capable of

ensuring conformity of products to BS EN 1090-1 and that the NB meets the criteria set out


11

in Annex IV of the CPD. This notification is therefore specific to each harmonised standard,

and once this is done the NB can undertake the tasks for which it has been notified. The Steel

Construction Certification Scheme is seeking notification and will act as a notified body for

the harmonised standard for structural steel components to BS EN 1090-1. Even before BSI

publishes BS EN 1090-1, as soon as CEN publishes EN 1090-1 it will be available for

certification bodies and steelwork contractors to use to implement and assess FPC systems.

NBs can apply for notification concurrently with the final stages of the EN, which can be made

as soon as the EN passes its formal vote and is ratified. The CE Marking of products cannot

commence, however, until the date of applicability given on the NANDO website.

2.4 CE Marking

The CE Marking signifies that the products are in conformity with the relevant harmonised

technical specification (e.g. harmonised standard) and that the relevant conformity assessment

procedures have been complied with: hence the product has the declared performance for the

essential characteristics in the information accompanying the CE Marking.

CE Marking under the CPD shows purchasing clients, the authorities and others that the

product complies with the appropriate harmonised European Standard. In the case of steel

products (such as sections, bolts and fabricated steelwork) the CE Marking is a declaration by

the manufacturer that the product is in conformity with the relevant harmonised standard(s) and

meets any threshold values required by the harmonised standard and has the values declared

in the information accompanying the CE Marking.

CE Marking and its accompanying information is a legal declaration by the manufacturer on

matters concerning health and safety about how the product performs in an intended use and

its impact is less about changing what the manufacturer has to do, and more about placing

greater onus on the manufacturer to get it right. To that end the manufacturer needs to satisfy

a notified body about the adequacy of its FPC system to avoid producing non-conforming

product.

2.5 Construction Products Regulations

The CPD is implemented in the UK by the Construction Products Regulations (CPR) and

manufacturers obey the CPR rather than the CPD directly. The CPR came into force in 1991

and describes two ways of complying with the legal provisions - by CE Marking products and

by not CE Marking products. Under the regulations CE Marked components are presumed

to comply with the harmonised technical specification and have the characteristics declared

when meeting building requirements/regulations, whilst other declarations about the product

do not carry this explicit presumption and the manufacturer may need to demonstrate to the

building control authorities etc that it does comply with the building regulations/requirements.

Under the non-CE Marking route, if asked, the manufacturer must supply to the authority all

the information it has on the product to enable the authority to satisfy itself whether the

product complies with the building regulations/requirements and hence can be placed on the

market for use in the works. CE Marking is therefore not mandatory in the UK but by opting

for the CE Marking route the legal position is much clearer and BCSA is recommending that

all of its members CE Mark the steel frames and components they fabricate.

The authorities responsible for enforcing the CPR are Trading Standards Officers in England,

Wales and Scotland, Environmental Officers in Northern Ireland and authorised officers in the

Republic of Ireland. The penalties for not complying with the CPR can be a £5,000 fine, 3

months in prison or both.

SECTION 2 : CE MARKING REGULATIONS

12

2.6 Future developments

The European Commission is proposing to replace the CPD by a new Regulation with the

aim of further improving the free trade of construction products in the European Union and

simplifying the CE Marking process.

Unlike a European Directive, a European Regulation is enforceable as law in all member

states without the need for national legislation. In many ways a European Regulation is

equivalent to an 'Act of Parliament of the European Union'. A consequence of replacing the

CPD with a European Regulation is that CE Marking will become mandatory in the UK and

the Republic of Ireland.

The proposed regulation places legal obligations on Manufacturers, Importers and

Distributors and on those companies in the supply chain who either place a product on the

market under their own trademark or modify a construction product already placed on the

market so as to change its essential characteristics. If the regulation becomes law it will have

implications for all parts of the structural steelwork supply chain including the fabrication

services provided by steel stockholders and steel benders.

The proposal also replaces the six 'essential requirements' with seven 'basic works

requirements'. These will apply to all construction works. The first six 'basic works

requirements' are identical to the six 'essential requirements' given on page 9. The seventh

reflects the European Community's drive for a more sustainable built environment. The draft

wording of this requirement is:

7. Sustainable use of Natural Resources

The construction works must be designed, built and demolished in such a way that the use of

natural resources is sustainable and ensure the following:

a) Recyclability of the construction works, their material and parts after demolition;

b) Durability of the construction works;

c) Use of environmentally compatible raw and secondary materials in the construction

works.

The European Commission is keen for the proposed regulation to pass all stages by spring

2009, i.e. sufficiently before the European elections in early 2009. This will mean that the

Regulation will come into UK and RoI laws in July 2011 with some provisions coming into

force sooner.


13

3 CE MARKING STANDARD FOR STRUCTURAL STEELWORK

3.1 Basis

The basis of CE Marking is that the manufacturer declares that its products meet specified

performance characteristics that are defined as essential to the application of the products

in the field of construction. In order to do this the manufacturer needs to:

• Know the requirements in terms of defined essential performance characteristics and

required values to be met. For structural steel components these requirements are

defined in clause 4 of BS EN 1090-1.

• Use specified test methods that can evaluate whether products conform to the

specified requirements. For structural steel components these evaluation methods

are defined in clause 5 of BS EN 1090-1.

• Implement a system for controlling regular production. For structural steel

components the system for evaluation of conformity is defined in clause 6 of BS

EN 1090-1.

• Mark its products in the correct way using a suitable classification and designation

system. For structural steel components the marking system is defined in clauses 7

and 8 of BS EN 1090-1.

These four aspects of BS EN 1090-1 Execution of steel structures and aluminium structures

- Part 1: Requirements for conformity assessment of structural components are explained

in detail below.

BS EN 1090-1 is one of a suite of harmonised European Standards dealing with structural

metallic products and ancillaries. All harmonised standards include an Annex ZA and the

implications of this are explained in detail below.

3.2 Scope

BS EN 1090-1 deals with the manufacture of load bearing components and kits of

components for use in structures. The components can be made of steel that is hot rolled, cold

formed or produced with other technologies. They may be produced of sections/profiles with

various shapes, flat products (plates, sheet, strip), bars, castings, forgings made of steel or

aluminium materials, unprotected or protected against corrosion by coating or other surface

treatment, e.g. anodising of aluminium. The standard does not cover conformity assessment

of components for suspended ceilings, rails or sleepers for use in railway systems.

3.3 Definitions

Some important principles may be drawn from the definitions given in clause 3 of

BS EN 1090-1.

3.3.1 Constituent products

The scope of BS EN 1090-1 acknowledges that the fabrication of structural steelwork is an

assembly process that uses constituent products such as steel sections, fasteners and

welding consumables. Importantly, the application of BS EN 1090-1 relies on using the

harmonised product standards for these constituent products.

For instance, BS EN 10025-1 Hot-rolled products of structural steels - Part 1: General

technical delivery conditions is a harmonised standard and it requires that steel products

SECTION 3 : CE MARKING STANDARD FOR STRUCTURAL STEELWORK

14

produced to the standard possess defined levels of strength - e.g. as S275. These strength

values then underpin the evaluation of the load bearing capacity of a component produced

to BS EN 1090-1.

In welding standards such as BS EN 1011 Welding - Recommendations for welding of

metallic materials, constituent products are referred to as parent materials or parent metal

and weld metal.

3.3.2 Component specification

BS EN 1090-1 applies to both series and non-series production. These terms are explained

by Pinney & Rein in their practical guide. Although fabricated steel components are

generally bespoke, being one-offs or to a limited number typically of less than 10 identical

items this may be series or non-series production.➀

Whether a component is made in series or non-series production, specific details are

required before manufacture can be undertaken. The document giving all necessary

information and technical requirements for manufacture is termed the component

specification. For structural steelwork the suite of relevant component specifications would

comprise the fabrication drawings defined in the National Structural Steelwork Specification

for Building Construction (CE Marking Edition) (NSSS).

One principle to be observed in CE Marking is that the manufacturer should be clear and not

confusing in its declarations. The simplest way this can be achieved is to start from a definitive

component specification and then to warrant that the component has been made in

accordance with that specification. This procedure differs little from how steelwork contractors

have been used to satisfying their purchasing clients and the national building regulations.

3.3.3 Kits

A kit is defined as a construction product when it is a set of at least two separate components

that need to be put together to be installed permanently in the works. For a "kit" to come within

the scope of the CPD, the following conditions must be satisfied:

• The "kit" must be placed on the market, allowing a purchaser to buy it in one transaction

from a single supplier,

• The "kit" must have characteristics that allow the works in which it is incorporated to

satisfy the essential requirements, when the works are subject to regulations containing

such requirements.

It is thus possible to consider structural steel components as a kit when they are supplied as

components of a whole building project or as defined phases of the whole project. Two CE

Marking options are thus open to the steelwork contractor:

• To apply CE Marking to the individual components as they are delivered from the

manufacturing works, using the component specifications issued for manufacture as

the reference;

• To apply CE Marking to a defined set of components as a kit, using as a reference a

collection of component specifications linked to, say, and erection marking plan or

delivery list.

➀ For example, a manufacturer making bridges or bridge components of all sizes and shapes, where no two

are ever the same, is still involved with series production. This is because the work is making bridges/bridge

components. If the manufacturer were asked to make a steel door and this was not part of normal production

line then that would be non-series production. If the manufacturer did not normally make purlins but then

made several of a common type as a special order then that would also be non-series production.


15

Generally the steelwork contractor will also be the manufacturer and hence this distinction is

not generally an issue. However, if the steelwork contractor alters components or a kit supplied

by another manufacturer, or adds to such a kit in any way and then relies upon CE Marking

as a demonstration of conformity then the steelwork contractor becomes the manufacturer of

that kit or those components.

3.3.4 Design brief

Fabricated steel components are generally bespoke because they are made for specific

projects. In the NSSS the term project specification is used for the specification prepared for

a specific building project. With respect to those parts of the construction works described in

the project specification as structural steelwork, the NSSS anticipates that the engineer who

is responsible for the design of structural members will prepare design drawings that include

all information necessary for the design of connections and completion of the fabrication

drawings. Irrespective of whether the engineer is working directly for the employer or for the

steelwork contractor, the NSSS assumes that the steelwork contractor will undertake the

detailing of the steelwork and the design and detailing of connections.

Thus, it is generally necessary for the steelwork contractor to undertake some design work

in preparing the details needed for the component specification. This design work will be

undertaken to what BS EN 1090-1 terms a design brief which would in essence comprise

the design drawings and the other appropriate information itemised in Tables 1.1 to 1.7 of

the NSSS.

3.3.5 Structural characteristics

BS EN 1090-1 defines some of the essential performance characteristics as structural

characteristics. These are governed in part by the design approach used to evaluate them

and refer to:

• Load bearing capacity;

• Fatigue strength; and

• Resistance to fire.

The essential performance characteristics itemised in BS EN 1090-1 that are not defined as

structural characteristics are:

• Tolerances on dimensions and shape;

• Weldability;

• Fracture toughness;

• Reaction to fire;

• Emission of radioactivity; and

• Release of cadmium.

The extent to which these essential characteristics may depend on the constituent products

used in manufacture can be identified by checking the essential performance characteristics

itemised in the harmonised standard for the constituent product. For instance, BS EN

10025-1 includes the following essential characteristics:

• Tolerances on dimensions and shape;

• Elongation;

• Tensile strength;

• Yield strength;


16

• Impact strength;

• Weldability.

The tolerances relevant to a constituent product continue to apply to components

manufactured from such products, unless BS EN 1090-2 (which is invoked for such

requirements by BS EN 1090-1) specifies more stringent criteria. Elongation is not directly

specified as an essential characteristic in BS EN 1090-1, but the evaluation of structural

design characteristics will depend on assumptions about elongation. For instance,

Eurocode designs apply to steels with minimum elongation of 15%.

Steel products to BS EN 10025-1 are designated with a steel grade, e.g.S275, which

signifies both the permitted range of tensile strength and the minimum yield strength. To the

extent that these values are affected by subsequent processes used in manufacture (e.g.

welding, hot or cold bending, or thermal cutting used in fabrication), BS EN 1090-2 specifies

restrictions on how these processes may be used.

BS EN 1090-1 defines fracture toughness and impact resistance as the same requirement.

BS EN 10025-1 refers to the impact strength of steel products which is assessed using Charpy

V-notch (CVN) impact tests, and BS EN 10025-1 defines weldability in terms of chemical

composition using the carbon equivalent value (CEV). Both these characteristics may be

affected by subsequent processes used in manufacture of steel components, especially in the

heat affected zone (HAZ) of the parent metal during welding. Thus BS EN 1090-2 specifies

particular requirements for the CEV of steel products that may be welded, as well as the

minimum CVN and maximum hardness permitted in the HAZ and the weld metal.

3.3.6 Load bearing capacity

The determination of the load bearing capacity of a structural component can be a complex

issue as it may involve, for instance, member design for buckling, connection design for

bearing, crushing etc. as well as an understanding of the behaviour of welds and

mechanical fasteners such as preloadable bolts. Prior to the advent of a harmonised

standard for structural steel components, steelwork contractors and/or their purchasing

clients have been undertaking such design evaluations on all steelwork projects. It is not the

intention of the CPD to change this way of working or to place unnecessary impediments in

how such design matters have been undertaken in meeting the existing national regulations

for building construction etc.

Parties undertaking design in support of developing the component specification should not

expect to alter their ways of working. The only supplementary change is that the

manufacturer undertaking (some of the) design work has the option of including a warranty

on that element of the design when declaring that the component meets the component

specification (see the optional methods for preparing the component specification explained

below).

The simplest way of looking at the issues associated with load bearing capacity is that the

component derives its capacity from that of its constituent products and the way those are

assembled. Typically the shape and yield or tensile strength of, say, a steel beam

determines its load bearing capacity - and values for safe loads are given in member

capacity tables. What the manufacturer is charged with is that the processes used in

fabrication do not impair the properties of the “plain” member.

BS EN 1090-1 requires the manufacturer to address how structural characteristics are

dependent on the manufacturing characteristics of the product. Most importantly for load

bearing capacity in quasi-static building construction, this depends on the yield strength of

the constituent products, and, as noted above, this can be affected by subsequent


17

processes used in manufacture such as welding. Hence, the manufacturer needs to

observe the provisions of BS EN 1090-2 with respect to welding and to have a suitable

welding quality management system (WQMS) in place. This enables the manufacturer to be

confident that any impairment of the yield strength of, say, parent materials in the HAZ is

within defined limits as evidenced by the limits on hardness etc. measured during the testing

in support of the Welding procedure qualification record (WPQR).

Then, in effect, the manufacturer may declare the equivalent of load bearing capacity by

warranting that the component has been made in accordance with its component

specification (i.e. fabrication drawing) on which appears the grade, shape, configuration etc.

of the constituent products from which load bearing capacity can be evaluated by

calculation to, say, the Eurocodes.

3.3.7 Evaluation methods

In most harmonised standards, essential characteristics are evaluated by physical testing to

a supporting European Standard. For instance the test method specified in BS EN 10025-1

for evaluating impact strength is BS EN 10045-1 Charpy impact test on metallic materials -

Part 1: Test method (V-and U-notches). Physical testing is applicable to products of a

standard or standardised type but is not easily applied to bespoke products. Whilst the safe

load bearing capacity of a lifting beam might be established by a physical test, such non-

destructive proof load testing of bespoke structural components is impractical; and it may be

impossible to establish fatigue strength or resistance to fire by other than destructive testing.

Hence, BS EN 1090-1 allows measurement of geometry and/or structural calculations to be

used as evaluation methods, as well as structural testing supported by calculations.

3.3.8 Preparation of the component specification

BS EN 1090-1 includes an informative Annex A that provides guidelines for preparation of

the component specification. The annex distinguishes the following typical cases:

Manufacturer provided component specification (MPCS). This case is typical of

steelwork contracting in general whereby the detailing and connection design are

undertaken by the steelwork contractor. In this case BS EN 1090-1 allows two options:

Option 1:

The manufacturer only declares the geometry and the material properties of the

component. The manufacturer “attaches” the component specification to the

component and provides a CE Marking that warrants that the as-manufactured

component complies with its component specification. The manufacturer provides

no warranty with respect to the design work that it has undertaken to develop the

MPCS from the design brief.

BS EN 1090-1 relates this option to Method 1 in Guidance Paper 'L' Application and

use of Eurocodes. If this is the option that the manufacturer always uses then this

limitation should be clear on the scope statement on the manufacturer's declaration

of conformity.

Option 2:

In this case, the manufacturer declares not only the geometry and the material

properties of the component but also the structural characteristics (such as load

bearing capacity) resulting from design of the component. The manufacturer needs

to undertake the design. The manufacturer thus includes in the CE Marking a

warranty that its design work has been undertaken according to the design brief.


18

BS EN 1090-1 relates this option to Method 2 in Guidance Paper 'L' and assumes

that such a design brief would be wholly based on the relevant parts of the

Eurocodes. This would be particularly useful for manufacturers of standardised

products, such as cold-formed purlins, intended for sale throughout Europe. Then the

product could be supplied against a component specification showing dimensions

and giving constituent material properties, together with an attached data sheet

giving, for example, Eurocode-based load bearing capacities in relation to spans and

fixings. The parameterisation would need to cater for National Annex values adopted

for the nationally determined parameters (NDPs) allowed by the Eurocodes.

Alternatively, Method 3 in Guidance Paper 'L' allows CE Marking of structural

characteristics to a design brief that is bespoke to a client's project. Thus BS EN

1090-1 defines an MPCS to Method 3b as one that includes structural characteristics

evaluated by design to a brief issued by the purchaser or one developed by the

manufacturer to meet the purchasing client's order. Method 3a to BS EN 1090-1 thus

allows CE Marking of components with design values evaluated at least in part to,

say, an American standard provided that this is explicitly agreed in the purchasing

client's order. For instance, the component may be designed to the Eurocodes for

static design, but to the AISC code for seismic design resistance. It should be noted

that Method 3b is not applicable to products placed on the European market where

the purchaser is not known in advance of product delivery. In such cases it is

imperative that component specification is clearly linked to the design basis used for

calculations.

Purchaser provided component specification (PPCS). In this case the manufacturer

undertakes no design and simply provides a product that meets the fully definitive PPCS

together with the necessary supporting documentation. BS EN 1090-1 defines this as

Method 3a to Guidance Paper 'L', as this allows components to be supplied to a PPCS

based on the purchasing client's choice of design code that may be other than the

Eurocodes.

However, this case is more typical of a steelwork contractor subcontracting fabrication to

another fabricator/supplier on the basis that the purchasing steelwork contractor

provides fully detailed fabrication drawings for the manufacture of the sublet work. The

purchasing steelwork contractor will usually require the components to be supplied with

appropriate CE Marking, which will mean that the subcontract fabricator/supplier must

have a suitably certified FPC.

3.3.9 Use and location

In the case of a PPCS the use and location of a component are known in advance.

However, for a MPCS there is an important distinction to be made between components

made for a use and location that is known in advance and those whose use and location

are unknown at the time the component is placed on the market. For design to the

Eurocodes under Method 2 (Option 2) above, BS EN 1090-1 describes the former case as

Method 2a and the latter case as Method 2b. Under Method 2a the relevant NDPs in the

National Annex for the location and use will be known. Under Method 2b the structural

performance characteristics for the component will be “application neutral”. Hence a product

data sheet containing, say, load-span tables for such a component would need to be

carefully drafted to avoid a potential purchaser/user making a mistake about, say, the

component's load bearing capacity that is “safe” in the actual location and use decided by

the purchaser/user.


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3.3.10 Reaction to fire

Reaction to fire refers to issues such as surface spread of flame, and uncoated steel

constituent products are classified as Class A1 with respect to reaction to fire. No further

documentation is required to support this classification for an uncoated steel component

manufactured to BS EN 1090-1.

There is currently no harmonised standard covering how reaction to fire for coatings applied to

steel components shall be declared. BS EN 1090-1 anticipates that this will be dealt with by

specifying the applied coating in the component specification, and providing supporting

information using the coating manufacturer's product data sheet as evidence of the coating's

properties. In due course, a standard format for declaring the properties of applied coatings is

likely to be prepared as the basis for CE Marking such products supplied for use in construction.

3.3.11 Dangerous substances

The CPD requires manufacturers to declare whether their products emit radioactivity or

release cadmium. In general, BS EN 1090-1 requires no testing for these dangerous

substances if the steel component is manufactured from steel constituent products and is

not coated. If the steel is coated the manufacturer may have to make a separate declaration

concerning the coating as with reaction to fire.

3.3.12 No performance determined

Unless an essential characteristic is regulated in the European member state where the

component is to be used, a manufacturer's CE Marking may state “No performance

determined” (NPD - not to be confused with a National Annex NDP) for that characteristic.

For instance, structural steelwork undertaken to the NSSS is intended for building

construction where fatigue is not a factor in design. It would then be in order to state

“Fatigue strength - NPD”. The manufacturer may however wish to declare performance

characteristics not regulated in certain member states for marketing purposes or for

economy reasons to facilitate easier movement of products within all member states.

In Annex ZA of BS EN 10025-1, for instance, some essential performance characteristics

are noted as “threshold values” (a minimum value below which the product is not fit for use).

Where performance characteristics for structural steel components are declared using the

properties of constituent products which are in turn based on threshold values, then the

restriction still applies that NPD cannot be stated for those characteristics as a minimum or

threshold value must always be met.

Although BS EN 1090-1 allows NPD to be declared for weldability for non-welded

components, it should be noted that the harmonised standards for most constituent steel

products include weldability as a threshold value (e.g. see BS EN 10025-1). In such cases,

whether the steel component is welded or not, NPD may not be declared for the component

if the declaration relies upon properties transmitted from those of its constituent products.

All the examples of CE Marking given in Annex ZA of BS EN 1090-1 state that NPD is used

for release of cadmium, and emission of radioactivity. In practice, steel products do not emit

or release either dangerous substance, and hence rather than NPD it is practical to declare

“No release of cadmium” and “No emission of radioactivity”.


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3.4 Requirements

3.4.1 General

The basis of how the essential performance characteristics defined in BS EN 1090-1 are

specified as requirements for manufacture of a steel component is as follows:

• Steel components are manufactured from steel constituent products with essential

characteristics that are defined in the harmonised standards for those products.

• The manufacturer incorporating those products into a structural steel component

needs to ensure that:

• Incoming materials to be used as constituent products comply with the relevant

specification by documentary check supplemented by re-testing if necessary (see

section 8 on how this affects the supply chain);

• The use of those constituent products in manufacture meets the necessary

traceability requirements (see section 7);

• The modification of the essential characteristics of the constituent products by the

processes of steel component manufacture, such as by welding, is controlled to

meet the requirements of BS EN 1090-2 Execution of steel structures and

aluminium structures - Part 2: Technical requirements for steel structures (see

section 4 below which explains the content of BS EN 1090-2 in detail).

• Structural characteristics are established by suitable design calculations and/or

physical testing.

3.4.2 Durability

The CPD requires that the durability of the essential characteristics is established. It should

be noted that the durability required is related to the essential performance characteristics

identified in the harmonised standard.

As there is no applicable direct method for testing durability, BS EN 1090-1 introduces the

following principles to establish the durability of a steel component. The durability depends

on the constituent products. The essential characteristics of steel constituent products are

immune from degradation over time with the major exception that atmospheric corrosion

can impair cross-sectional dimensions.

Some products use structural steels with improved atmospheric corrosion resistance, for

which the required chemical composition is specified in the relevant supporting standard.

Otherwise, durability is defined in terms of the corrosion protection applied to the surface of

a steel component.

The selection of a method for protecting steel components from corrosion is covered by BS

EN 1090-2. This allows the indirect evaluation of durability in terms of the classified

exposure of the component linked to specified requirements for surface protection in the

component specification. The NSSS offers six standard specifications for applied surface

coatings that may be invoked in component specifications.

It is arguable that in two other respects - fatigue and fracture - the properties of constituent

steel products are less than permanently durable as over the longer term steel can be

susceptible to failure due to externally applied cyclic stresses or low temperatures. As both

these properties are explicitly defined as essential structural characteristics in BS EN 1090-

1, the issue of durability can be addressed by declaring values that are related to the stress

cycling or working temperature as relevant.


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3.5 Evaluation methods

The evaluation methods to be used are related to the manufacturing requirements to be

evaluated that are derived from the essential performance characteristics defined in BS EN

1090-1. A combination of three methods is included in BS EN 1090-1 and the harmonised

standards for constituent products:

• Physical testing - used for example to establish fracture toughness of steel materials

using the CVN impact test.

• Measurements of geometry - used for tolerances on dimension and shape, and

covered in BS EN 1090-2.

• Structural calculations - which may be used to evaluate load bearing capacity, fatigue

strength and resistance to fire.

BS EN 1090-1 allows the use of physical testing instead of or in support of calculations. For

instance, the supplementary rules in the Eurocodes for the design of steel cold-formed

members and sheeting specifies testing procedures to be used. BS EN 1990 Eurocode -

Basis of structural design defines various types of test and specifies the proper statistical

methods for the evaluation of test results.

It is also worth noting that BS EN 10025-1 relies wholly on physical testing and

measurements of geometry to establish conformity and the introduction of structural

calculations as a third evaluation method in BS EN 1090-1 is linked to the fact that it covers

bespoke products and non-series production.

3.6 Evaluation of conformity

3.6.1 Initial type testing

The general principles behind the evaluation of conformity are the use of initial type testing

(ITT) and factory production control (FPC). The basis of ITT is:

• A manufacturer develops a product type.

• What might be termed prototype examples of the new product type are tested to

establish their properties against the essential performance characteristics.

• The new product type is commissioned into production and representative samples

from new production are tested to establish that the production methods used can

produce conforming product.

Thus ITT is necessary at the commencement of production of a new product type including

production using new constituent products, and at the commencement of new or modified

methods of production.

As BS EN 1090-1 applies to the manufacture of bespoke components that may be unique

examples of their type, it is impractical to apply the simple concept of ITT described above.

Hence, the concept of initial type calculation (ITC) is introduced as a conformity evaluation

method. What this builds on is the wealth of physical testing undertaken in research

laboratories that has been codified into the design rules that underpin the ITC. Thus even a

unique example of a structural component is built up in the calculations from what might be

termed sub-types - for instance the behaviour and bearing resistance of an end plate in a

bolted connection.

ITC is built up wholly on what might be termed “historical data”, and BS EN 1090-1 allows

historical data from both ITC and ITT to be used. This reduces the amount of type testing

that the manufacturer needs to perform. However, the application of historical data needs


22

to be carefully considered when, say, test results obtained in support of a product meeting

British Standards are extended to meet a European Standards. BS EN 1990 provides the

statistical basis for using such prior information.

The steel constituent product standards, such as BS EN 10025-1, measure the essential

performance characteristic of weldability in terms of chemical composition as a carbon

equivalent value (CEV). Welding to BS EN 1090-2 builds on this concept of weldability by

applying the concepts behind ITT in the methods used to evaluate conformity of welded

components, as follows:

• A manufacturer wishes to develop a welding procedure specification (WPS) and

defines parent and weld materials, welding process, joint design and preparation,

welding position and technique etc. in a preliminary welding procedure specification

(pWPS).

• Using the pWPS as the reference document, the manufacturer carries out a welding

procedure test, which is then subjected to destructive and non-destructive tests

(NDT) to specified standards. The results of the testing and the actual welding

parameters used are recorded in a welding procedure qualification record (WPQR).

• The WPQR is used to support application of the WPS in practice and the qualification

of other WPS to be used in production within a defined range of essential variables,

for example material type/thickness, joint types, welding position etc.

The fact that the WPS may be used over a range of actual welds that differ somewhat from

the initial type tested is an example of the allowance in BS EN 1090-1 to extend application

of ITT to other situations in a “family”. The range of qualification allowed in the welding

standards defines how big the family may be, which in terms of parent materials is done

using steel groups cited in BS EN 1090-2.

BS EN 1090-2 also builds on the ITT concept with respect to using a qualified WPS in

production as it specifies that the first five joints made to the same new WPS must meet

quality levels comparable to those in the procedure test when subjected to NDT. This

establishes that a WPS can produce conforming quality when implemented in production.

Thereafter the NDT on production welding is reduced to sampling as part of FPC.

BS EN 1090-1 restricts the application of a given ITT programme to a production of

components within a defined Execution Class (EXC). This concept is explained further

below, but it has a particular implication for production welding in that requirements for the

welding quality management system (WQMS), the methods of qualification, the extent of

FPC testing and the production quality levels required differ for EXC2, EXC3 and EXC4. For

EXC4, BS EN 1090-2 requires production welds to meet a higher quality than that

established by ITT in the WPQR.

3.6.2 Factory production control

Factory production control (FPC) is needed to establish that a manufacturer can produce

conforming product in regular ongoing production. In essence what the manufacturer does

is to establish the key control checks during the ITT phase and then to sample test actual

production to compare it with necessary quality levels established by ITT. FPC is thus used

to prove that products conform to the product type, given that ITT has been used to prove

that the product type meets the required essential performance characteristics.

As FPC is based on sampling, the minimum frequency and extent of sample testing is

defined in the harmonised standard. For products to BS EN 10025-1, this can be specific to

a lot or cast (type 3.1 inspection certificate) or non-specific (type 2.2 test report). Specific


23

testing is required for all steel products except those of the following qualities: S275JR,

S275J0, S355JR or S355J0.

As BS EN 1090-1 covers bespoke non-series production the required number of samples

is specified as only one (i.e. the component may be its own unique type) when applied to

calculations of structural characteristics, dimensional measurements, and the checking of

CEV and CVN values for the constituent steel products. More extended sampling is required

when the conformity evaluation is established by physical testing rather than calculation.

In practice, production to BS EN 1090-2 as a supporting standard for BS EN 1090-1 means

that many requirements relating to production are specified. As noted above this has

particular application to the use of NDT to establish that production continues to produce

conforming welds treating further joints welded according to the same WPS as a single

continuing production lot. The NSSS uses the term “routine testing” for this aspect of FPC.

In many ways FPC may be seen as a sub-set of the controls necessary in a quality

management system based on BS EN ISO 9001, and BS EN 1090-1 allows (but does

not require) an FPC conforming to BS EN ISO 9001 to be used as the basis for the

required system.

The detailed requirements for the FPC are explained in section 10, and it should be noted

that the system is defined in terms of written procedures, regular/routine inspection (i.e.

quality control) supported by competent personnel and suitable equipment for production

and testing.

3.6.3 Attestation levels

Attestation of conformity is the term used to define the whole system needed to ensure that

only conforming products are placed on the market. This allocates certain tasks to the

manufacturer and others to an independent organisation that the manufacturer appoints to

certify defined aspects of its operations as meeting the required standard.

Certification organisations themselves need to be suitably competent to undertake their

allotted tasks. Their competence is established against BS ISO/IEC 17021 Conformity

assessment - Requirements for bodies providing audit and certification of management

systems and the scope of competence of the organisation is accredited by, say, UKAS. This

accreditation is then used by the competent authority (DCLG in the UK) to notify the

European Commission and the certification organisation then becomes a notified body (NB).

Depending on the attestation level which has been chosen by the European Commission,

the NB may be involved as a third party in certifying:

• The FPC system, as is required for all structural steel components and explained

below with respect to BS EN 1090-1. This is system 2+ and it permits the

manufacturer to issue a Declaration of Conformity related to its products. The role of

the NB under system 2+ is defined as that of an inspection body rather than that of a

certification body as the latter implies that product or product type certification is

involved (as below);

• The product type by involvement in the ITT/ITC. This would be system 1+ and would

result in the NB issuing a Certificate of Conformity related to the manufacturer's

product types; or

• The products themselves. Outside of the CE Marking requirements, BS EN 10025-1

allows this option for certain higher quality steels whereby the purchaser's authorised

inspection representative endorses the declaration that the products supplied are in

compliance with the requirements of the order.


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The attestation level specified for all structural steel components is level 2+ which allocates

the tasks as follows:

• Tasks under the responsibility of the manufacturer: ITT, FPC and product testing.

• Tasks for the NB: Certification of the manufacturer's FPC on the basis of both initial

inspection and continuous surveillance.

3.6.4 Product testing

BS EN 1090-1 specifies the amount of product testing by the manufacturer as follows:

• Checking those essential dimensions that are critical to use of the component on

each component or a suitable sample if components are manufactured under similar

conditions. The requirements for dimensions that are essential are listed as essential

tolerances in BS EN 1090-2.

• Checking the manufactured components against the component specification with

respect to the requirements for surface treatment for corrosion protection as specified

in BS EN 1090-2.

• Checking that the inspection documents for constituent products conform to the

required values for CEV, CVN, and yield, proof or tensile strengths as specified in BS

EN 10025-1 or other relevant harmonised standards for steel products.

• For design undertaken by the manufacturer, verifying that the calculations used to

develop the component specification are relevant and have been carried out in

accordance with the design brief.

• Checking that manufacturing processes that affect structural characteristics are being

undertaken to BS EN 1090-2. This is relevant to processes that may alter the

essential performance characteristics of constituent products. Hence, BS EN 1090-2

specifies the relevant procedure and production testing for welding, bending, and

thermal cutting.

3.6.5 Laboratory testing

The possibility for third party endorsement of the product type is comparable to third party

endorsement of actual laboratory test results as opposed to endorsement that the system

for control of laboratory testing has been checked within the scope of the FPC

endorsement. In terms of BS EN 10025-1 laboratories undertake material tests to establish

CEV, CVN etc., and the system for control of laboratory testing requires;

• A direct check of the performance of the manufacturer's own laboratory within the

scope of the FPC;

• Accreditation of the laboratory under BS EN ISO/IEC 17025 General requirements for

the competence of testing and calibration laboratories (or equivalent) with the

accreditation being specific for the tests carried out; or

• Direct assessment of an external laboratory by the NB.

In terms of BS EN 1090-1 there are similar requirements that treat laboratory testing as part

of the manufacturer's FPC. For EXC2 and above this applies to tests associated with

welding, and the NSSS thus requires a competent examiner or examining body to verify the

WPQRs, to witness welder qualification tests (WQTs) and to endorse the WQT certificates.

These responsibilities are distinct from those of a possible project-specific third party

inspection authority that may be appointed.


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3.6.6 Design control

As noted above, control of design is seen as part of FPC to the extent that the manufacturer

chooses to warrant the design work it undertakes to develop the component specification

from the design brief. The NB is not required to verify the content of the design or that the

component specification complies with the design brief as this would be equivalent to

product type certification to attestation system 1.

The NB is required to certify during initial inspection and continuous surveillance that

suitable design control procedures are in place (e.g. for revising drawings), and that design

work is being undertaken using suitable equipment and other resources (e.g. suitable

computer programs and latest copies of design codes). During initial inspection the NB is

also asked to certify that that design work is being undertaken by suitably competent

personnel with defined job descriptions.

3.6.7 Certification of the FPC

BS EN 1090-1 defines those minimum aspects of the FPC that must be assessed by the

NB. During initial inspection these relate to checking whether the resources (premises,

personnel and equipment) are adequate for the manufacture of steel components to BS EN

1090-2. This also comprises:

• Checking that the FPC has procedures for checking conformity and handling

procedural non-conformities and non-conforming product.

• Evaluation of job descriptions (e.g. based on an organogram) and requirements for

competence of personnel (e.g. for weld inspection personnel).

During continuous surveillance the NB:

• Checks that the manufacturer is undertaking the specified product testing described

above that is associated with execution work.

• Checks that the FPC procedures for checking conformity and handling procedural

non-conformities and non-conforming product are being operated properly.

3.6.8 Welding certification

Specifically for those manufacturers who use welding and following the initial inspection, the

NB is required to identify the scope of certification of the FPC in terms of the welding

processes and parent materials covered. The manufacturer can establish the basis for this

scope by using its portfolio of WPSs, WPQRs and WQTs as those documents underpin the

operation of the FPC for welding. In this regard it is required that for each main welding

process the manufacturer shall have available welder(s) with suitably qualified welding

procedures.

As the NB also needs to confirm on the certificate which Execution Class is relevant to the

manufacturer's FPC for welding, the NB needs to assess the welding quality management

system (WQMS), the methods of qualification, the extent of FPC testing and the production

quality levels and to relate these to the Execution Class using the requirements specified in

BS EN 1090-2 (see section 5).

Unless the scope of certification is limited to EXC1, the Responsible Welding Coordinator

(RWC) also needs to be identified on the certificate. The certification of the FPC for welding

may be identified within the general FPC certificate or issued as a separate welding certificate.

Although it is not required, it may also be agreed between the manufacturer and the NB that

the WQMS is certificated according to the appropriate level of BS EN ISO 3834. If the


26

manufacturer already has its WQMS certified to BS EN ISO 3834, then this may be relied upon

as relevant when the NB issues the general certificate for the FPC.

During continuous surveillance, the NB is not specifically required to re-certificate the FPC for

welding, but in practice re-certification of the FPC will include a review of the WQMS for a

manufacturer of welded components. The NB also has the authority to undertake a surveillance

audit if circumstances change. In this respect, the manufacturer is required to inform the NB of

changes that could affect the validity of the certificate, such as:

• New or changed essential facilities;

• Change of Responsible Welding Coordinator;

• New welding processes;

• New essential equipment.

3.7 Marking system

3.7.1 General

The basis of the marking system is that the component shall be identifiable against the relevant

essential performance characteristics that are to be warranted by the manufacturer as

complying with the requirements of BS EN 1090-1. This requires that the component is linked

uniquely to its component specification, and if this is in the form of a fabrication drawing the

information required by BS EN 1090-1 can be given on the drawing.

In addition, BS EN 1090-2 specifies certain requirements related to traceability (see section 7)

and identification methods applicable to component manufacture, and links these to the

marking necessary for correct use of the component in terms of erection.

Most often bespoke steel components are supplied to a given project for eventual erection as

a complete structural frame for, say, a building. In such cases the components may be seen as

a kit, and the marking can be done on a collective basis for them all. Typically this might be

done using the erection marking plan as a central reference point to define the kit, and then to

attach the necessary CE Marking information to the whole kit via the marking plan. This method

has an obvious extension for steelwork contractors undertaking design-and-build projects and

who wish to warrant the design as well as the manufacture of all the components by reference

to the design calculation sheets.

3.7.2 Classification and designation

BS EN 1090-1 requires that the Execution Class relevant to its manufacture is given on the

component specification.

The requirements for dimensions that are essential performance characteristics are listed as

essential tolerances in BS EN 1090-2. For some essential tolerances, such as those for

cylindrical and conical shells, more than one class is specified. In which case, the component

specification needs to identify the class that is relevant to the component.

3.7.3 CE Marking

BS EN 1090-1 includes an informative Annex ZA related to the application of the CPD to

structural steel components. It is informative as it pertains to application of national regulations

which cannot be made mandatory by a European Standard. Instead the framework is given in

the informative annex which is then mandated in practice by the appropriate regulations in each

European member state.


27

The annex links together the following elements of the required CE Marking system:

• The FPC certificate issued by the NB (as described above).

• The declaration of conformity made by the manufacturer. This is a document that the

manufacturer prepares and maintains which then entitles the manufacturer to affix the

CE Marking. It must be signed by an appropriate employee of the manufacturing

company, and is the basis for criminal proceedings if the regulators believe that the CE

Marking has been wrongly applied by the manufacturer. Appendix C illustrates an

example of a declaration of conformity.

• The CE Marking of the component. This includes the CE Mark itself (literally the letters

C and E in a particular type style and size) as well as other information as illustrated in

Appendix C.

BS EN 1090-1 allows the CE Marking to be done on one of four templates linked to the

preparation of the component specification via the methods defined in Guidance Paper 'L' as

follows:

• By reference to component geometrical data and the material properties of constituent

products with NPD for structural characteristics determined by design (Method 1 using

MPCS Option 1);

• As above but including values for structural characteristics determined by design to the

relevant Eurocodes (Method 2 using MPCS Option 2);

• As above but including values for structural characteristics determined by design to the

purchaser's design requirements (Method 3b using MPCS Option 2); or

• By reference to component geometrical data and the material properties of constituent

products with a cross-reference to the purchaser's design but no specific values for

structural characteristics determined by design (Method 3a using PPCS).

As noted previously, at the present time CE Marking under the CPD is not mandatory under the

national regulations implemented in the UK and the RoI. Most often CE Marking of structural

steel components to BS EN 1090-1 applies to production intended for a bespoke project-

specific application that is known in advance of manufacture. In such cases, even if CE Marking

were mandatory or adopted voluntarily, it would be reasonable to apply BS EN 1090-1 to the

final completed component that is directly ready for site assembly and/or erection. Whether the

steelwork contractor as manufacturer of the completed component requires CE Marking to be

used by its supply chain (see section 8) then depends on how the manufacturer wishes to

exercise FPC. Clearly the steelwork contractor will require most constituent products to be CE

Marked, but might control the operations of some sublet suppliers undertaking steel processing

within the purchasing steelwork contractor's own FPC system. This has particular relevance for

the WQMS and the control of welding by sublet suppliers.

3.7.4 Affixing the CE Marking

The CE Marking may be located in one of the following places:

• on the product;

• on the packaging; or

• in the manuals or other supporting commercial literature accompanying the product.➁

It is likely that for bespoke project-specific items the CE Marking would be located on the

➁ In this context “accompanying” means “unambiguously linked to”, it does not mean that the commercial

literature has to physically be attached to the product.


28

fabrication drawings that comprise the component specification. The component itself then

only needs an identity mark (such as the piece marks in use currently) that links it

unambiguously to the relevant drawing, perhaps via a delivery list or marking plan as

currently.

For series items, such as proprietary purlins, it is more likely to be placed on the product

label. For steel products it is generally on the inspection document, and for fasteners and

welding consumable it is generally on the packaging.

3.7.5 Packaging

In principle the importance of packaging for a product with CE Marking is that the

manufacturer produces conforming product “ex-works” and the obligation on the

manufacturer is to use packing that is sufficient to preserve the essential performance

characteristics for a reasonable time reflecting the period until the purchaser is ready to

install the product in the construction works.

For structural steel components, the context is somewhat different, as the components are

nearly always “made to order”, and the essential performance characteristics are largely

unaffected by exposure during the period between leaving the manufacturer's works and

being installed on site. Furthermore, in “bespoke” cases a steelwork contractor would be

liable to rectify any damage that the component received before it was finally handed over

as part of the construction works.

For these reasons, BS EN 1090-1 is largely silent about packaging requirements, and BS

EN 1090-2 includes the requirements for rectification of any damage sustained in delivery

or erection.


29

4 EUROPEAN FABRICATION STANDARD

4.1 Status and scope

BS EN 1090-2 Execution of steel structures and aluminium structures - Part 2: Technical

requirements for steel structures is not a harmonised standard but it supports the

application of BS EN 1090-1 by providing the technical requirements relevant to

manufacture of steel components. This is analogous to BS EN 10045-1 being a supporting

standard giving the test methods for CVN in support of the harmonised standards for steel

products BS EN 10025-1 etc. As well as building on these test methods used to establish

the characteristics of constituent products, BS EN 1090-2 includes its own test methods for

such items as measuring geometrical dimensions of components. It also makes reference

to other test methods in further supporting standards such as those specifying requirements

for welding.

The scope of BS EN 1090-2 is wider than simply the technical requirements for manufacture

(e.g. by fabrication including welding), as it also covers all execution requirements for steel

structures including erection. Erection and other operations (such as bolting) that take place

on a project site where the construction works are being built are not relevant to the CE

Marking process which merely assumes that the works will be otherwise properly designed

and built.➂

In addition, the scope of BS EN 1090-2 is much wider than the individual British Standards

that it will replace as it includes requirements for all types of steel structure: buildings,

bridges, towers, masts, chimneys, shells, sheeting in carbon manganese steels up to S690

and stainless steels up to S700. It applies to structures subjected to fatigue or seismic

actions.

Despite this extremely wide scope, the requirements related to steel structures used in

building construction are very close to those in previous British Standards and those in the

National Structural Steelwork Specification for Building Construction (NSSS). To assist

steelwork contractors and specifiers, BCSA is preparing a CE Marking Edition of the NSSS

that includes only those provisions relevant to the majority of steel-framed buildings.

Undertaking projects to the NSSS should ensure that the steelwork complies with the

provisions relevant to all types of building construction designed for static loading in EXC2

according to BS EN 1090-2.

With respect to CE Marking the relevant clauses of BS EN 1090-2 are as follows:

• Documentation (clause 4 and Annex A);

• Constituent steel products (clauses 5, 12.1 and 12.2);

• Geometrical tolerances (clauses 11 and 12.3 and Annex D);

• Welding and other fabrication operations (clauses 7, 6 and 12.4);

• Surface treatment for corrosion protection and durability (clauses 10 and 12.6 and

Annex F).

With respect to their application as requirements for BS EN 1090-1 these clauses form three

groups as follows:

➂ Potentially there could be situations (such as on a major stadium, power station or bridge project) where a

substantial amount of “manufacture” takes place on the construction site. Arguably this is outside the scope of

the CPD as the fabrication (assembly and welding) work is not undertaken in a works/factory covered by the

manufacturer's FPC certification. It would, however, generally be the case that the WQMS and the RWC's

scope of responsibility would include such site-based operations anyhow. In special circumstances where the

site facility existed for a long enough time, it would be possible for those facilities to be certified by the NB,

and hence for CE Marking to be applied to the “components” produced from those facilities.

SECTION 4 : EUROPEAN FABRICATION STANDARD

30

• Those associated with inspection, testing and corrections (in clause 12 of BS EN

1090-2) that support quality control of product conformity;

• Those associated with documentary controls (in clause 4 and 5) that support quality

assurance of product conformity; and

• The rest which underpin the procedural controls of processes of fabrication.

It is assumed that clauses 8 and 12.5 on mechanical fastening, clauses 9 and 12.7 on

erection and Annexes E, G, H, J, K and M generally have little or no relevance to the CE

Marking of structural steel components.

4.2 Documentation

BS EN 1090-2 uses the term execution specification for the set of documents covering

technical data and requirements for a particular steel structure. This equates to the project

specification referenced in the NSSS, and both include the portfolio of component

specifications that are the key documents referred to in BS EN 1090-1.

Annex A of BS EN 1090-2 lists all those requirements that may need specifying for a

particular project and hence for specific components. Annex A.3 lists several that are linked

to the choice of Execution Class. The application of the concept of Execution Class is

explained in section 9 below which notes how the NSSS requires who is responsible for the

structural design to review A.3 for its implications.

In terms of documentation and as part of FPC, the manufacturer should review the

extensive list of supporting standards given in clause 3 of BS EN 1090-2 to ensure that its

library contains up-to-date versions of those relevant to its scope of operations.

4.3 Constituent products

Section 3 above explains the concept of constituent products. The manufacturer needs to

know that it is using the right products and to ensure that its manufacturer's processes do

not impair those properties that underpin the declared essential characteristics of the

finished component. Many of the requirements in BS EN 1090-2 for traceability and welding

relate to these needs.

4.4 Tolerances

Those geometrical tolerances that are essential to the evaluation of the strength of a

component (e.g. straightness required to avoid premature strut buckling) are defined in BS

EN 1090-2 as essential requirements. It is those and only those tolerances that the

manufacturer warrants when CE Marking under the CPD. As noted in section 3 above, it is

necessary to choose which class applies for some essential tolerances and to include this

in the component specification.

It should be noted that BS EN 1090-2 also gives requirements in two tolerance classes for

what are termed functional tolerances. The functional tolerances are outside the application

of the CPD to structural steel components, but they are relevant to the contractual

obligations that the manufacturer has to its purchasing client. Thus the manufacturer may

choose to link the component to the relevant functional tolerance class by showing this

information on the fabrication drawings. To simplify this process, a statement on the marking

plan that the component is manufactured in accordance with the NSSS makes the link to

functional tolerance class 1.


31

4.5 Welding

BS EN 1090-2 covers fabrication requirements in clauses dealing with preparation of

constituent products, assembly and welding. The implications of BS EN 1090-2 for CE

Marking of welded structural components are widely discussed throughout this document

as welding is a special process and has the most relevance to the potential impairment of

the properties of the constituent products. Similar procedural restrictions apply to other

processes used in manufacture that have such a risk if not properly controlled (e.g. hot or

cold bending, or thermal cutting used in fabrication).

In terms of welding, it should be noted that the NSSS applies the requirements of BS EN

1090-2 to building structures to EXC2. These requirements are broadly similar to the

requirements in the previous editions of the NSSS except that the conceptual principle is

now made clear that welding of a given type (as defined by a given WPS) may be

considered as a single continuing production lot in quality management terms.

BS EN 1090-2 includes a National Foreword that explains that whilst the Service Category

(see section 9) differentiates between quasi-static (SC1) and fatigue (SC2) applications, this

is too coarse a differentiation with respect to the control of weld quality in fatigue. BS EN

1090-2 uses the quality levels in BS EN ISO 5817 in four steps as listed below:

• EXC1: Quality level D.

• EXC2: Quality level C generally;

• EXC3: Quality level B (i.e. as required for WQTs and WPQRs);

• EXC4: Quality level B+.

Whilst the levels above may be partly suitable for use in the manufacturer's WQMS to

establish, prequalify and certificate the general quality level of the manufacturer's welding

operations, they are incomplete as follows:

• Using informative Annex B of BS EN 1090-2, “low consequences risk” structures in

CC1 (see section 9 for explanation) that are designed for fatigue are in EXC2 and

hence the suggested quality level is C generally. This quality level is unsafe for any

but the most modest levels of fatigue, and reduced consequences do not

compensate for inappropriate specification.

• The EXC4 level is impractical as it requires the manufacturer to demonstrate the

general capability of meeting quality level B+ which is more stringent than that

required for WQTs and WPQRs. The only way of assuring a quality level above the

prequalification standards is to undertake 100% testing on the (minority of) welds

which the designer specifies as demanding such a high standard and individually

assess them for acceptance.

• The conclusion from the above is that the specifier needs to identify the fatigue

demand placed on individual welds subjected to dynamic loads and to decide the

acceptance criteria that are relevant on a fitness-for-purpose basis using fracture

mechanics based on the function of the component and the characteristics of the

imperfections (type, size, location). Whilst this procedure is allowed by BS EN 1090-

2 after non-conformities are identified, it is more sensible to start with a properly

classified set of values. This is available in ISO 10721-2 which specifies a suite of

acceptance criteria appropriate to a series of fatigue classes. These acceptance

criteria are consistent with those used in previous British Standards and the NSSS,

and should be used by specifiers in fatigue applications rather than relying on the

coarse SC2 categorisation.

SECTION 4 : EUROPEAN FABRICATION STANDARD

32

4.6 Surface treatment

As explained in section 3 above, for structural steel components there is no applicable direct

method for testing durability of the essential characteristics defined in BS EN 1090-1.

Provided it can be protected from corrosion, there is no tendency for the properties of steel

to decay over time; it is stable chemically and does not creep.

Hence, the simplest ways to ensure durability are to make the component from stainless or

weather-resistant steel (e.g. with improved atmospheric corrosion resistance), or to protect

its surface from atmospheric corrosion by paint, galvanizing or sprayed metal. In terms of

declared characteristics, it is simple enough in principle to specify the required surface

coating and the surface preparation necessary in the component specification and for the

manufacturer to warrant that the component conforms to its component specification. This

is the basis that BS EN 1090-2 provides, allowing the manufacturer to check the

manufactured components against the component specification according to the specified

testing requirements for surface preparation and treatment.

It is less simple to warrant that the component is durable for a specified time as this involves a

simultaneous specification of a corrosivity category for the expected environment in the intended

component application and a measure of the durability of the surface protection material.

Thus, a direct warranty on the durability of the steel component would be dependent on a

warranty on the durability of the surface coating material. Even though there are standard

tests that can be used to establish the long term performance of, say, paints, none of these

yet form the test standards supporting harmonised product standards for paints. In this

circumstance, BS EN 1090-2 allows purchasing clients and steelwork contractors to agree

the execution specification durability in more prescriptive terms and for this to be used to

develop the component specification. Thus, whilst the standard coating specifications given

in the NSSS are scientifically related to particular environmental classifications, there is no

warranty on the coatings.


33

5 WELDING QUALITY MANAGEMENT

5.1 Welding as a 'special process'

For many years welding has been classed as a 'special process' as defined in BS EN ISO

9000 and it is widely recognised that welding normally requires continuous control and/or

that specified procedures are followed since the end result may not be capable of being

verified by testing. In light of this, a fundamental requirement of CE Marking is that the

manufacturer using welding needs to implement an appropriate welding quality

management system (WQMS).

The CE Marking fabrication standard, BS EN 1090-2, states that all welding shall be

undertaken in accordance with the quality requirements of the relevant part of BS EN ISO

3834 which identifies the controls and procedures required. Determination of the relevant

part of BS EN ISO 3834, and the stringency of requirements, is ultimately dependent on the

Execution Class declared by the manufacturer for its product. With respect to the WQMS,

BS EN 1090-2 invokes BS EN ISO 3834 Quality requirements for fusion welding of metallic

materials as follows:

• EXC3 and 4: Comprehensive quality requirements to BS EN ISO 3834-2.

• EXC2: Standard quality requirements to BS EN ISO 3834-3. (The quality level

required by the NSSS is BS EN ISO 3834-3 appropriate to EXC2.)

• EXC1: Elementary quality requirements to BS EN ISO 3834-4.

BS EN ISO 3834 is not a quality system standard to replace BS EN ISO 9001. It can be

used independently but it is often best used to complement BS EN ISO 9001 requirements.

It is also important to note that, whilst some steelwork contractors may choose to have their

WQMS certified by a certification body independently of the notified body, the standards for

CE Marking do not require this. Compliance with the requirements of BS EN ISO 3834 can

be verified by the notified body during assessment of a steelwork contractor’s FPC system.

Routes to certification of the FPC system are described in section 11.

The basic principles of a welding quality management system to BS EN ISO 3834 are

focused around the requirements of the principal welding-related activities, in particular:

• Control of welding as a special process;

• Technical instructions for production; and

• Demonstration of personnel competence.

5.2 Control of welding

A manufacturer may have several people involved with the control of welding, but the

manufacturer needs to identify a Responsible Welding Coordinator (RWC) with overall

responsibility for all welding activities.

Whilst specific requirements for the RWC are detailed in section 6 the appointed person

would develop and implement documented procedures to control such aspects as:

• Identification, qualification and production of welding procedures and welder

qualifications;

• Availability, suitability and maintenance of equipment;

• Identification of product requirements (contractual and technical);

• Production planning;

• Storage and handling of parent metals and welding consumables;

SECTION 5 : WELDING QUALITY MANAGEMENT

34

• Operation and performance of inspection activities;

• Identification and traceability of the product and work in progress; and

• Correction of non-conforming product.

5.3 Technical instructions

BS EN ISO 3834 requires the steelwork contractor to have written technical instructions,

procedures and specifications that demonstrate and ensure that the welding control system

is effective. The standard identifies the typical documents necessary to demonstrate control

of all welding related activities. These include instructions and procedures for the following:

• Reviewing contract/technical requirements;

• Subcontracting;

• Qualification of procedures and personnel for welding and inspection;

• Storage and handling of consumables;

• Equipment maintenance/calibration;

• Production/inspection plans;

• Repair procedures;

• Traceability records; and

• Documentation control.

5.4 Competence of personnel

Personnel competence in welding process control is the cornerstone to an effective WQMS.

This is reflected in BS EN ISO 3834, by setting out the standards required for qualification

of welders and welding operators, inspection personnel and perhaps most importantly,

those responsible for welding coordination.

Dependent on the size of company, control and coordination of welding might be

undertaken by more than one person. However the RWC must have overall control of and

be competent to make decisions and sign documents which affect product quality, whereas

other personnel might only be qualified to undertake specialised welding coordination tasks

such as control/issue of welding consumables, verification of materials etc.

In allocating welding tasks and responsibilities the steelwork contractor must identify criteria

for competence in terms of qualification, experience and training for each position. The

manufacturer must also ensure that the competence of all welding coordinators, especially

the RWC, is adequate for their allocated tasks.

5.5 Implementation

Application of the appropriate WQMS is left to the discretion of the manufacturer, who can

make use of PD CEN ISO/TR Quality requirements for fusion welding of metallic materials

- Part 6: Guidelines on implementing ISO 3834. The manufacturer's choice should be based

upon its current purchasing client base, the declared Execution Class of its product and,

where possible, its future market. The NSSS requires a WQMS compliant with the

requirements of BS EN ISO 3834-3 Standard quality requirements. However, this will

require careful consideration so as to ensure the manufacturer is not precluded from tender

invitations requiring a higher Execution Class and subsequently more stringent quality

requirements.


35

6 RESPONSIBLE WELDING COORDINATORS

6.1 Welding coordination

The coordination of welding activities is vital if a manufacturer wants to demonstrate control

of the process and give confidence to purchasing clients of the quality of its welded product.

BS EN 1090-2 states that, with respect to the welding operations being supervised, welding

coordination shall be maintained during the execution of welding for all but Execution Class 1.

The term Responsible Welding Coordinator (RWC) is used to identify the person who is

competent to supervise the manufacturer's welding operations as demonstrated by the

RWC's technical knowledge and experience for the range of products being manufactured.

The level and scope of technical knowledge and experience required may thus be linked to

the scope of certification of the manufacturer's FPC in terms its Execution Class, the

welding processes and the parent materials covered. As noted above, this can be

established using the manufacturer's portfolio of WPSs, WPQRs and WQTs as the RWC

must be competent to coordinate the development of those documents.

6.2 Tasks for welding coordinators

All manufacturers should nominate at least one Responsible Welding Coordinator (RWC)

with overall responsibility for establishing and monitoring welding activities and for taking

action when welding has not been carried out correctly.

When nominating RWCs, the manufacturer should identify clearly the tasks and

responsibilities that will be allocated to them and ensure that they are suitably qualified and

experienced to do the job and competent to make decisions and sign documents which

affect product quality.

BS EN ISO 14731 Welding coordination - Tasks and responsibilities gives guidance on the

essential welding related tasks that need to be considered. These might include, but are not

limited to:

• Review of contractual/technical welding requirements;

• Ensuring welding personnel are appropriately qualified;

• Suitability of welding and associated equipment;

• Development/qualification of welding procedures;

• Writing welding procedure specifications (WPSs);

• Production planning;

• Storage and handling parent materials;

• Control of welding consumables; and

• Inspection and testing before, during and after welding.

Welding coordinators thus need the ability to detect and assess defects, to instruct repairs

and know how to avoid defects, as well as having knowledge about the relevant standards,

regulations and specifications to be observed.

With respect to the welding operations being supervised BS EN 1090-2 specifies the

technical knowledge requirements for welding coordination personnel based on the three

categories given in BS EN ISO 14731:

• B - Basic

• S - Specific

SECTION 6 : RESPONSIBLE WELDING COORDINATORS

36

• C - Comprehensive

The required category is determined by the manufacturer's declared Execution Class, the

type/grades of steel used (given in terms of steel groups and reference standards) and

limiting thicknesses. RWCs may demonstrate that they have sufficient technical knowledge

by presenting evidence that they meet the recommendations prepared by the International

Institute of Welding (IIW). However, these recommendations are generic and thus cover a

much wider scope that is well in excess of that required for many steelwork manufacturers.

Hence, BCSA, the Steel Construction Certification Scheme (SCCS) and the Welding

Institute (TWI) have developed more focussed methods for assessing the technical

knowledge and experience of welding coordinators (see section 11 and Appendix A).


37

7 TRACEABILITY

7.1 Introduction

It is essential to have a suitable traceability system in place to enable checks to be made

that the correct steel component has been delivered and/or erected and that it is made from

the correct steel sections and fittings. Guidance on the traceability systems required for CE

Marking is given in two different documents - A Government Circular and in BS EN 1090-2.

These two documents give very different requirements. It is therefore important to know

what they say and why the guidance given in this document is based on the traceability

requirements given in BS EN 1090-2.

7.2 Government Circular

The following requirements appear in the UK's Construction Product Regulation (SI 1991

No 1620):

Regulation 3 'Requirement to be satisfied by products'

This addresses all construction products whether they are CE Marked or not. It states:

A construction product, other than a minor part product, shall have such characteristics

that the works in which it is to be incorporated, assembled, applied or installed can, if

properly designed and built, satisfy the essential requirements when, where and to the

extent that such works are subject to regulations containing such requirements.

In 1991 the then Department of the Environment (now called the Department of

Communities and Local Government, DCLG) issued Government Circular 13/91 related to

European Economic Community: Directive 89/106/EEC Construction Products. It primarily

gave guidance to enforcement bodies on the application of the Construction Products

Regulations. In 8 the Government Circular 13/91 reinforces the responsibilities of 'building

control officers and approved inspectors to ensure the fitness of purpose for use on site in

works that are subject to Building Regulations. Building control officers will need to satisfy

themselves that a product (whether or not it carries the CE mark) is fit for intended use or

actual use and to reject products that are unfit'.

This circular includes the following statement 'The Regulations apply at all stages of the

supply chain' but this statement does not single out CE Marked products for attention.

Regulation 4 'Products bearing the EC mark' ➃

Any construction product which bears the EC mark shall be presumed to satisfy the

relevant requirement in regulation 3 (see above) unless there are reasonable grounds

for suspecting that the product does not satisfy that requirement or that the EC mark has

not been affixed in accordance with regulation 5.

Regulation 6 'Requirement to keep available and give information about products which

bear the EC mark'

The person who has affixed the EC mark… shall, for a period of 10 years after the

material date, keep the EC certificate of conformity or, as the case may be, the EC

declaration of conformity relating to the product, or a copy of it, available for inspection

by an enforcement authority or any of its officers and, if required to do so by any such

authority or officer at a reasonable time, produce the document so kept and permit any

such officer to take copies of it.

➃ The EC Mark (as it was in English translation) is now termed the CE Mark throughout Europe. certified by the

NB, and hence for CE Marking to be applied to the “components” produced from those facilities.

SECTION 7 : TRACEABILITY

38

Regulation 7 'Requirement to give information about products which do not bear the EC mark'

A person who supplies a construction product which does not bear the EC mark shall

give to an enforcement authority, or any of its officers, all information which he has about

the product and which the authority or officer may reasonably require for the purpose of

ascertaining whether the product satisfies the requirement in regulation 3 or is one to

which these Regulations do not apply.

There are no explicit requirements on traceability throughout the whole of the supply chain,

but given that building control authorities may need to be satisfied on the performance of

the product regarding the essential characteristics of the product, appropriate

documentation should accompany the product to satisfy building control officers and

approved inspectors. Consequently the traceability recommendations for CE Marking given

in this publication are based on the requirements given in BS EN 1090-2 which are

explained below and in section 8.

7.3 Inspection documents

BS EN 1090-2 gives traceability requirements for both the material delivered to the

workshop or construction site and for the flow of material through the fabrication shop. Both

of these requirements are explained below.

Traceability of the essential characteristics of steel sections and other steel constituent

products in terms of the material properties is important and only certain inspection

documents (often referred to as “test certificates”) provide sufficient details. For products to

BS EN 10025-1, this can be specific to a lot or cast (type 3.1 inspection certificate) or non-

specific (type 2.2 test report). BS EN 1090-2 requires type 3.1 inspection certificates for all

steel products except those of the following qualities: S275JR, S275J0, S355JR or S355J0.

7.4 Requirements

BS EN 1090-2 gives general recommendations for checking that supplied constituent

products comply with the relevant product standards given in BS EN 1090-2 and match

those on the purchase order. These general requirements apply to all Execution Classes.

For Execution Classes 2, 3 and 4 the standard gives specific requirements for distinguishing

between different steel grades where different grades and/or qualities are processed

through the fabrication shop at the same time. Finally, for Execution Classes 3 and 4 the

standard requires all constituent products to be traceable at all stages from receipt to

handover and incorporation in the works. Batch or type traceability may be used unless

traceability of each product is specified by the purchasing client. The requirements in 5.2 of

BS EN 1090-2 are:

The properties of supplied constituent products shall be documented in a way that

enables them to be compared to the specified properties. Their conformity with the

relevant product standards shall be checked in accordance with 12.2.

For EXC3 and EXC4, constituent products shall be traceable at all stages from receipt

to hand over after incorporation in the works.

This traceability may be based on records for batches of products allocated to a common

production process, unless traceability for each product is specified.

For EXC2, EXC3 and EXC4, if differing grades and/or qualities of constituent products are

in circulation together, each item shall be designated with a mark that identifies its grade.

An interpretation of the above for each of the four Execution Classes is given below.

Execution Class 1 - does not require traceability only control of the incoming material


39

against the purchase order. This includes steel sections, fasteners, subcontracted

fabrication, coating products and items delivered directly to site such as decking and purlins.

Execution Class 2 - requires control of incoming material against the purchase order as

described for Execution Class 1 and constituent products to be marked where more than

one grade/quality is in circulation. This applies to steel sections and plate, and fasteners

delivered to the workshop.

Execution Classes 3 and 4 - requires control of the incoming material against the purchase

order as described for Execution Class 1, marking of constituent products where more than

one grade is in circulation and all products to be traceable at all stages from receipt to

handover after they have been included in the structure (this includes activities on site).

Unless traceability for each product is specified by the purchasing client then batch or type

traceability may be used.

7.5 Batch or type traceability

Batch or type traceability means nominally identical items do not need to be distinguished;

hence, backwards traceability is limited. This type of traceability can be achieved by carrying out

a paper check of the order against the delivery note and a physical check of the steel sections

and other products against the order when the steel sections and products are delivered.

Traceability through the workshop can then be achieved through a combination of shape and

location within the workshop - i.e. serial size and weight can be obtained from the shape of the

section and the grade and job reference can be obtained by storing different grades in different

locations. Alternatively a colour coding or marking system can be used to distinguish between

different grades, sections and project jobs. The steel quality (or sub-grade) is the most difficult

property to trace through the workshop and it may be possible generally to limit steel sections

purchased and used to a single sub-grade (e.g. J0). Where other sub-grades are used these

can then be treated as specials and alternatively marking systems can be used.

BS EN 1090-2 distinguishes between the documentation required to support the required

traceability of completed components sent to site from that required for constituent products

explained above. In both cases suitable supporting documentation is required, and this will be in

the form of a component specification when components are ready for delivery to a project site.

7.6 Welding

BS EN 1090-2 does not require that individual welds be identified against the qualified

welder who welded them. However, the manufacturer's WQMS needs to provide a

comparable level of batch or type traceability. Hence, the welding coordinator would need

to be able to demonstrate that the WQMS ensures the following in terms of traceability of

welding for all except EXC1:

• The portfolio of WQTs held by the manufacturer is up-to-date with respect to the

scope of welding operations being undertaken;

• On a sample basis at any stage during certification of the WQMS, the conduct of the

work is traceable to the extent that welding personnel with suitable and valid

qualifications are assigned to appropriate welding tasks;

• Work instructions issued to welders are appropriate to the joint configuration and

material to be welded;

• Work instructions issued to welders are traceable back to an appropriate WPS that is

supported by an appropriate and valid WPQR.

The NSSS requires that these provisions are met for EXC2 building construction.

SECTION 8 : SUPPLY CHAIN ISSUES

40

8 SUPPLY CHAIN ISSUES

8.1 Introduction

The CPD applies to all construction products that are permanently incorporated into a

structure. For the steel construction industry this means steel sections and plate, hollow

sections, preloadable bolts, non-preloadable bolts, purlins, sheeting, decking and fabricated

steelwork. It also applies to those manufacturers, importers and distributors who modify a

product already placed on the market in such a way that conformity with its original CE

Marking is affected. This last range of products includes proprietary products such as

cellular beams, part-fabricated products such as curved steel sections and modified and/or

re-tested steel sections. Clearly this has implications for all parts of the steel construction

supply chain.

Within the supply chain, organisations can be categorised as a manufacturer, an agent, an

importer or a distributor. Importers and distributors are not subjects of the CPD because the

legal responsibility for placing the product on the market and its subsequent CE marking rests

with the manufacturer or his appointed agent established in the community. However, the 'Blue

Guide' introduces the two more possibilities of importer and distributor and so their roles are

also mentioned here.➄ It is also possible for some organisations to be placed in different

categories for different products. Knowing which category one falls into is very important.

8.2 Manufacturers

A manufacturer is defined as any person or organisation that is responsible for designing and

manufacturing a product to be placed on the EU market. This includes steel manufacturers

who place steel sections on the EU market, steelwork contractors who place fabricated

steelwork on the market, purlin, sheeting and decking manufacturers. If a manufacturer is not

established within the European Union, then the manufacture must appoint an agent who is

to act as the manufacturer's legal entity within the EU - i.e. a person/corporate entity against

which legal action can be taken by the enforcement authorities.

8.3 Importers

An importer is a person within the EU, responsible for placing products on the EU market

(e.g. a bolt supplier where the bolts are imported having been manufactured outside the

EU). If the importer puts the products onto the EU market and its name appears on the

product then it becomes a manufacturer with all the responsibilities of the manufacturer. If,

however, the importer brings already CE Marked products on to the EU market with the

original manufacturer's name still on the product and does not change the product in any

way then it is a distributor.

8.4 Distributors

A distributor is a person or organisation which stores and distributes a CE Marked product

that has already been placed on the EU market. Some steel stockholders fall in to this

category. The distributor does not alter the product in any way nor does it put its name on

the product. For examples some stockholders re-test steel sections or plates in order to

establish improved CVN values. This process changes the declared properties of the

product and the stockholder then becomes a manufacturer.

➄ Further information on the role of the importer and the distributor is contained in the Pinney & Rein reference.


41

Although distributors do not have any responsibilities under the CPD they do have a duty to

ensure that the correct CE Marking is associated with the correct product and that clearly

non-compliant products are not placed on the EU market.

The issue of an organisation buying a CE Marked product changing some of its declared

properties and putting it back on the market is worth exploring further with reference to

certain parts of the steel construction supply chain. For example some steel stockholders

offer a service to steelwork contractors which involves modifying the original CE Marked

steel section. Steel benders provide a service which bends the original steel beam

modifying some of declared properties. In both cases the stockholders and steel benders

are classed as manufacturers.

8.5 Stockholders

Steel stockholders generally purchase steel sections which have been CE Marked by the

steel manufacturer to BS EN 10025-1 for I and H sections, BS EN 10210-1 for hot-finished

structural hollow sections and BS EN 10219-1 for cold-formed structural hollow sections.

Sometimes these sections are then cut to exact length, drilled, blast cleaned and painted by

the stockholder before being supplied to the steelwork contractor. All of these activities are

fabrication activities which are covered by the CE Marking standard BS EN 1090-1. For

example it is important that the section is cut to exact length and the holes are drilled in

accordance with the tolerances given in BS EN 1090-2. Stockholders who provide these

services will therefore need to extend the CE Marking for the modified steel sections in

accordance with the fabrication CE Marking standard BS EN 1090-1. This will require initial

type testing (ITT) and the setting up a certified factory production control (FPC) system as

described in section 10.

Sometimes stockholders re-test steel sections to re-evaluate fracture toughness. Fracture

toughness is one of the performance values declared on the CE Marking by the steel

manufacturer. Therefore a change to the product's original performance values for fracture

toughness will require the section to be re-CE Marked. The stockholder will therefore have to

perform ITT for the change in the performance value for fracture toughness and set up an

appropriate FPC system. In this case setting up an FPC system cannot be based on the original

steel production process as the stockholder has no control over the raw materials or the

production process. The FPC system will be based on documentary controls and testing of the

finished product. The laboratory testing will need to be checked by the NB as described above.

8.6 Steel processors

The fabrication of structural steelwork is an assembly process that uses constituent

products such as steel sections and some of these products, such as curved beams, may

be part-processed but not ready for incorporation into the construction works until after

further fabrication. The manufacturer of a steel component that is to be directly placed on

the market needs either to be confident that the part-processed constituent products being

used in fabrication have properties that conform to the standards for the original steel

product manufacture (for example BS EN 10025) or to have a declaration from the steel

processor of the changed performance characteristics.

Processes of bending or curving a steel section may change some of its characteristics, the

most obvious being its fracture toughness. The changes to the performance values will

depend on the amount of bending and for small strains the changes will be so small that the

original performance values may be relied upon. For higher strains the curved section will

need to be CE Marked with its new performance values. The process of bending a section

SECTION 8 : SUPPLY CHAIN ISSUES

42

will not change all of the originally declared performance values. For those unaltered values

the steel bender is entitled to assume that the CE Marked product has been correctly tested

according to the appropriate standards and therefore the performance values can be

passed on without repeating the Initial Type Testing (ITT) and tests included in the FPC of

the steel manufacturer.

Bending a steel section is a fabrication activity and it is therefore suggested that bent or

curved steel sections are CE Marked according to BS EN 1090-1. This will require setting

up ITT for those characteristics whose performance values are changed by the bending

process and an FPC system to control the bending processes.

Similar issues arise with respect to some operations undertaken by steel service centres

(e.g. thermal cutting) and by manufacturers of cellular beams and plated profiles.

8.7 Special products and processes

BS EN 1090-2 anticipates that there will be circumstances where steel products etc other

those listed as structural steels etc may need to be used in the construction works.

Examples include proprietary products not covered by a European (EN) or International

Standard (ISO) and without a European Technical Approval (ETA). Other examples would

be products such as engineering steels that are covered by an EN or a national standard

but which are not cited in BS EN 1090-2; such steels might be used in complex structural

components as machined connectors.

The general rules for manufacturers to follow in such circumstances are as follows:

• It is not allowed to use CE Marking on a product that is not covered by either a

harmonised standard or an ETA under the CPD.

• It is important in all cases for the manufacturer not to confuse the market with CE

Marking that might be misconstrued.

BS EN 1090-2 covers such special products and processes as, although it supports BS EN

1090-1, it is written for wider application. Hence, in potentially ambiguous or uncertain

circumstances the manufacturer needs to be clear in the CE Marking documentation what

is covered by the CE Marking and what is not. The execution specification includes the

component specifications and provides a definitive reference in this respect. The fact that

such products are not covered by a harmonised standard or ETA does not prevent them

being specified and used in construction works.

8.8 Transition period

During the transition period between the date of applicability and the end of the co-existence

period (expected to be two years), organisations in the supply chain may continue to place

non-CE Marked products on the market even in those countries where CE Marking is

mandatory. Then in those countries at the end of the co-existence period non-CE Marked

products may not be placed on the market even if they are products that had already been

manufactured before the date of applicability published on the NANDO website. In countries

where CE Marking is not mandtory it may be possible for, say, steelwork contractors to use

up their long-standing stocks of, say, fasteners indefinitely. However, it is arguable that the

UK regulations require products to meet the essential requirements even in the absence of

a relevant harmonised standard. Different provisions apply to products (such as re-used

steel components) manufactured before the CPD and/or the UK Construction Products

Regulations came into law in 1991. These provisions will need to be re-addressed if the

European regulations are extended to encourage the “recyclability of the construction

works, their material and parts after demolition”.


43

9 EXECUTION CLASS

9.1 General

Informative Annex B of BS EN 1090-2 provides guidance for the determination of Execution

Classes (EXC) based on reference to consequences classes (CC) defined in BS EN 1990,

service categories (SC) and production categories (PC) defined in BS EN 1090-2.

SC relates principally to whether a component is designed for fatigue or for quasi-static

actions only. BS EN 1090-2 recommends that PC1 is limited to non-welded components and

welded components manufactured from steel grades below S355. In practice the distinction

between PC1 and PC2 makes no practical difference to most structural steelwork. The NSSS

is applicable to structural steelwork in SC1 only, and in both PC1 and PC2

9.2 Application to buildings

Following the recommendations of BS EN 1090-2, the NSSS recommends that CC may be

determined directly by reference to the building classes defined in Table 11 of Approved

Document 'A' of the Building Regulations of England and Wales as follows:

Thus NSSS is based on execution of structural steelwork in EXC2 excluding steelwork in

SC2, hence to Building Class 2 and without modification to Building Class 1. Structural

steelwork in Building Class 3 and SC1 can also be undertaken to EXC 2 by steelwork

contractors whose conformity assessment procedures are certified as meeting the

requirements of EXC2, provided that the different requirements tabulated in Annex A.3 of BS

EN 1090-2 are reviewed by the designer who is responsible for the structural design and

specifies which, if any, of the supplementary requirements listed under EXC 3 are applicable.

In terms of BS EN 1090-1 this means that amendments to the structural characteristics

relevant to manufacturing would then be specified in the component specification.

9.3 Wider application

BS EN 1090-2 defines EXC as a classified set of requirements specified for the execution

of the works as a whole, of an individual component or of a detail of a component. In

practical terms it is expected that all the components and details in the works as a whole

would generally be classified with the same EXC. Hence, the NSSS ignores the possibility

that some components or details could be EXC1 as BCSA believes that EXC2 is the best

basis for ensuring consistent quality of steelwork appropriate for building construction.

In terms of wider application, the following list provides a basis for determining EXC:

• EXC1 - Farm buildings.

• EXC2 - Buildings (similar to the scope of the NSSS).

• EXC3 - Bridges.

• EXC4 - Special structures (power stations, long span bridges etc.).

Building class Consequences class (CC)

Class 1 (except domestic buildings) Class 1

Classes 2A or 2B (also including

domestic buildings of 4 storeys and below)Class 2

Class 3 Class 3

10 FACTORY PRODUCTION CONTROL

10.1 Introduction

CE Marking requires the manufacturer to operate a factory production control (FPC) system

certificated by a NB. An FPC system is a management control system that focuses mainly

on the manufacturing operations although procedures for controlling design operations can

be included. It aims to ensure that the quality of the product (be it a steel section, a bolt, a

purlin or fabricated steelwork) is consistently maintained to the required specification. An

FPC system is very similar to a BS EN ISO 9001 system and can be regarded as a subset

of BS EN ISO 9001.

A typical FPC system consists of regular maintenance and calibration of equipment,

frequent checking to ensure product conformity and the management of non-conforming

products. FPC is all about producing products with the same declared characteristics time

and time again.

For CE Marking of fabricated structural steelwork, steelwork contractors and those

organisations involved in fabrication activities need to set up an FPC system that complies

with the requirements given in BS EN 1090-1. The need for suitable FPC extends to steel

stockholders that offer limited fabrication services, steel benders and those organisations

that produce proprietary steel products (see section 8). FPC will include the procedures for

controlling manufacture as described in BS EN 1090-1. It may also include the procedures

for controlling design and/or the quality of the welds, and, excluding EXC1, a Responsible

Welding Coordinator. In general based on the activities undertaken, there are four possible

FPC systems and these are listed in the following table:

10.2 FPC systems

FPC system A - applies to those organisations that have no welding activities and are not

declaring design characteristics - e.g. manufacturers of purlins, decking etc.

FPC system B - applies to those organisations that have no welding activities and wish to

declare design characteristics - e.g. manufacturers of purlins and decking who wish to make

their safe load tables part of the CE Marking.

FPC system C - applies to those organisations that carry out welding activities and do not

wish to declare design characteristics - e.g. this category will apply to the majority of

steelwork contractors even though they may be carrying out all or part of the design.

FPC system D - applies to those organisations that carry out welding activities and wish to

declare design characteristics - e.g. some manufacturers of proprietary products (cellular

beams) may wish to declare design values as part of the CE Marking. This system is also

seen as a future development for those steelwork contractors wishing to declare design

values as part of the CE Marking.

SECTION 10 : FACTORY PRODUCTION CONTROL

44

Activities FPC systems

A B C D

Manufacturing Yes Yes Yes Yes

Design No Yes No Yes

Welding No No Yes Yes

RWC No No Yes Yes


45

10.3 System requirements

The following list includes the manufacturing and design procedures that should be covered

in a typical FPC system to meet the requirements of BS EN 1090-1. The activities

associated with managing and controlling the welding processes and the requirements for

the Responsible Welding Coordinator are given in sections 5 and 6 respectively.

It should be noted that FPC systems in other product standards (BS EN 10025-1 for the

manufacture of steel sections and BS EN 14399-1 for the manufacture of preloadable bolts

etc.) differ from the one described below.

10.3.1 Personnel (Clause 6.3.2, BS EN 1090-1)

Document the responsibility, authority and the relationship between personnel that manage,

perform or verify work affecting the characteristics of your steelwork. This is best done by

developing an organogram which names key personnel, their function and the lines of

communication.

The system should also describe the measures to ensure that personnel have adequate

qualifications and training for the range of steelwork the company fabricates and the

Execution Class(es) used.

10.3.2 Equipment (Clause 6.3.3, BS EN 1090-1)

All weighing, measuring and testing equipment that may have an influence on the

characteristics of the steel frames/members must be calibrated, regularly maintained and

inspected. Each company will need to decide the inspection procedures and the frequency

of inspection.

Manufacturing equipment (cutting, sawing and drilling equipment) must be regularly

inspected and maintained to ensure that it remains sufficiently accurate and that its use,

wear and failure does not cause significant inconsistency in the fabrication process.

The procedures should document the frequency of inspections and maintenance and for

how long this information should be retained. (Note: The Construction Products Regulations

require records to be retained for a minimum of 10 years. However, as many construction

contracts are signed as deeds it is recommended that records are retained for a minimum

of 12 years).

10.3.3 Structural design process (Clause 6.3.4, BS EN 1090-1)

In the case where structural design is carried out by the steelwork contractor and design

characteristics are declared as part of the CE Marking, the steelwork contractor needs to

establish procedures to control and verify compliance with the design brief, for checking

calculations and for ensuring the competence of the individuals responsible for the design.

With respect to building steelwork an appropriate checklist for design control adapted from

BCSA's Commentary on the Fourth Edition of the National Structural Steelwork

Specification for Building Construction is as follows:

The Steelwork Contractor should have established procedures to control and verify the

contract requirements for design. These may include:

• A design plan defining the principal design activities in a logical sequence, the type

of design output and target dates to meet the programme requirements and allocation

of design responsibilities.

• Procedures for controlling design variations, changes and concessions that take

place during the contract including procedures for controlling revisions to the design

brief and the issue of revised fabrication drawings.

• Design of the structure so it can be safely erected, bearing in mind that the designer

who is responsible for preparing the structural design must take account of safety and

stability aspects of the erection method statement.

• Design documentation, production and checking procedures (verification).

• A check that software used in the design has been validated.

• Procedures for the acceptance of general arrangement drawings and connection

design calculations by the designer who is responsible for the structural design and

specifies the structural characteristics relevant to manufacturing in the component

specification.

• Handling and transportation requirements for unusually shaped or large components

to ensure stability during movement.

• A formal documented review of the design before issue for connection calculations

and associated detail drawings.

10.3.4 Constituent products used in manufacture

Constituent products are defined as materials or products used in manufacture with

properties that enter into structural calculations or otherwise relate to the mechanical

resistance and stability of the structure and/or the fire resistance, including durability and

serviceability. For most manufacturers (i.e. steelwork contractors, stockholders, etc.) this

will include the following range of products:

• Steel sections (open and closed), plates and strip.

• Structural bolts.

• Cladding, sheeting, purlins and side rails.

• Welding consumables.

• Painting and galvanizing.

• Castings, bearings.

Identify the range of constituent products used in your factory. Develop and implement a

written inspection procedure for checking and recording that the constituent products

coming in to your factory conform to the specification, and that traceability of the constituent

products through the factory conforms to the requirements for traceability given in BS EN

1090-2 (see section 7).

Retain the documentation related to the constituent products for the period of document

retention.

10.3.5 The component specification (fabrication drawing)

The component specification is defined as a document or documents that gives all the

necessary information for fabricating the structural steelwork. For the majority of

manufacturers this will be a fabrication drawing. In addition to all the usual items on the

drawing (e.g. dimensions, steel grade, weld size etc.) the drawings should include a

reference to the Execution Class and the Service Category (see BS EN 1090-2). Service

Category is defined in BS EN 1090-2 as 'Categories that categorise a component in terms

of the circumstances of use'. In simple terms this means the steelwork is designed for

fatigue or not. For the majority of manufacturers the steelwork will not be subject to fatigue.

SECTION 10 : FACTORY PRODUCTION CONTROL

46


47

Develop and implement a written inspection and test plan for checking and recording that

the fabricated steel frame/members conform to the component specification - i.e. make sure

you have made what you said you were going to make. This will generally be covered by

the quality manual and only requires a project-specific quality plan if requested by the

purchasing client. In those cases Annex C of BS EN 1090-2 gives a checklist for the content

of a quality plan for structural steelwork with reference to the general guidelines in BS ISO

10005 Quality management - Guidelines for quality plans.

Prepare the fabrication drawings from design information/specification.

10.3.6 Product evaluation

The list of declared characteristics for fabricated steelwork from BS EN 1090-1 is given

below:

• Tolerances on dimension and shape

• Weldability (as CEV for constituent products)

• Fracture toughness (as CVN for constituent products)

• Load bearing capacity

• Fatigue strength

• Resistance to fire

• Reaction to fire (as Class A1)

• Dangerous substances

• Release of cadmium and its compounds

• Emission of radioactivity

• Durability of performance characteristics (given with respect to the

requirements for surface treatment for corrosion protection as specified in BS

EN 1090-2).

For steelwork used in most buildings in the UK you need only evaluate those characteristics

that are highlighted in bold above. These are the characteristics that you will be declaring

on your CE Marking.

10.3.7 Non-conforming products

Set up a written procedure that states how your company will deal with non-conforming

products (i.e. steel frames/members that do not comply with the specification). This

procedure must comply with the principles of BS EN 1090-1 as amplified by the

requirements of BS EN 1090-2. Non-conformities must be recorded when they occur.

Records of non-conformities must be retained for the period of document retention.

11 ROUTES TO CERTIFICATION

11.1 Introduction

For safety critical products like structural components, the manufacturer is not allowed to fix

CE Marking without having a factory production control (FPC) system in place which has a

valid certificate from an approved notified body (NB). This requires a NB to assess and

satisfy itself that the manufacturer's FPC system is able to produce products that comply

with the relevant harmonised standard. Once satisfied, the NB will issue the manufacturer

with an FPC certificate. If the manufacturer undertakes welding, the NB may issue either a

separate welding certificate or include the required scope of welding certification in the FPC

certificate. These certificates enable the manufacturer to produce a Declaration of

Conformity, and the Declaration of Conformity permits the manufacturer to affix CE Marking

to its products, provided that the products fall within the scope of certification given on the

certificate(s) issued by the NB. Examples of all documents are given in Appendix C.

For fabricated steelwork the FPC system must comply with BS EN 1090-1 and satisfy the

relevant requirements of BS EN 1090-2 where invoked in BS EN 1090-1. A typical FPC

system suited to BS EN 1090-1 can be conveniently split in to three distinct parts. These are:

Part 1 is that part of the FPC system controlling the manufacturing and, if relevant, design

operations. These activities are given in BS EN 1090-1 (see sections 3 and 10).

Part 2 is that part of the FPC system controlling the welding operations. These activities are

referred to in BS EN 1090-2 and are described in the relevant part of BS EN ISO 3834 (see

sections 3 and 5).

Part 3 is that part of the FPC system dependent on the competence of the Responsible

Welding Coordinator in terms of the RWC's technical knowledge and experience. The level

of technical knowledge required is linked to the Execution Class and the role of the RWC is

described in BS EN ISO 14731 (see sections 3 and 6).

As explained in section 3, the NB will need to satisfy itself that all three parts of the FPC

system comply with the harmonised standard BS EN 1090-1 before it issues an FPC

certificate or a welding certificate. Part 1 will always be assessed by the NB. For Part 2 there

are two ways in which the manufacturer can demonstrate to the NB that its welding

operations are properly controlled. Similarly there are a number of options available for

demonstrating the competence of the RWC. The different options available for Parts 2 and

3 are described below.

11.2 Assessment of the WQMS

The manufacturer can demonstrate that its welding operations are properly controlled in

accordance with the relevant part of BS EN ISO 3834 by providing independent (third party)

certification of its WQMS to the NB for review. Independent certification typically acceptable

to the NB would normally be issued by an Authorised National Body for Company

Certification (e.g. The Welding Institute in the UK).

Alternatively the NB can assess the manufacturer's WQMS as a part of the manufacturer's

FPC system. Under this option the WQMS is an embedded part of the FPC system. The

certification of the FPC for welding may be identified within the general FPC certificate or

issued as a separate welding certificate. A separate certification explicitly according to EN

ISO 3834 is not required but may be agreed between the manufacturer and the NB.

More information on FPC assessment with respect to BS EN 1090-1 and on assessment of

the WQMS in particular may be found in a guidance document issued by the Structural

SECTION 11 : ROUTES TO CERTIFICATION

48


49

Metallic Products Sector Group 17 of Notified Bodies for the Construction Products Directive

89/106/EEC (GNB CPD SG17) entitled Guidance for the FPC assessment according to

Annex B of EN 1090-1. An abstract of this document is included in Appendix D.

11.3 Assessment of the RWC

Assessment of the relevant competence of the RWC requires the NB to:

• Assess the RWC's experience. This can be demonstrated by employment evidence

over at least the last four years.

• Assess the RWC's technical knowledge. There are three ways in which this can be

demonstrated and these are explained further below.

• Check that the manufacturer's FPC has defined a suitable role and has given the

RWC suitable responsibilities to enable the RWC to coordinate the manufacturer's

welding operations. This requires the NB to know the scope of certification of the

welding operations for which the manufacturer is seeking certification.

• Assess whether the RWC is acting competently in the defined role. This can be done

in parallel with the NB's assessment of the manufacturer's WQMS by questioning the

RWC about the manufacturer's portfolio of WPSs, WPQRs and WQTs. Also, during

this technical interview the RWC will need to demonstrate to the NB the ability to

detect and assess defects, to instruct repairs and know how to avoid defects, as well

as knowledge about the relevant standards, regulations and specifications to be

observed.

There are three ways in which the RWC can demonstrate the necessary technical

knowledge. In the first two routes described below the RWC can either be a subcontractor

or a member of the manufacturer's staff.

Route 1

The first and simplest approach is where the RWC has an appropriate International Institute

of Welding (IIW) qualification. In this case the RWC will need to supply the NB with evidence

of this qualification. Clearly this qualification is portable and is not specific to the RWC's

current employer or post, but the level of this qualification (Basic, Specific or

Comprehensive) must match the scope of the RWC's employer's WQMS.

The relationship between the IIW qualifications and the levels referred to in BS EN ISO

14731 is as follows:

• Comprehensive requires a level of technical knowledge of all tasks and

responsibilities in welding fabrication - International Welding Engineer (IWE);

• Specific requires a level of technical knowledge that is sufficient within a selective or

limited technical field - International Welding Technologist (IWT);

• Basic requires a level of technical knowledge that is sufficient within a limited

technical field involving only simple welded constructions - International Welding

Specialist (IWS).

IIW qualifications are valid indefinitely and are fully portable within and beyond the steelwork

industry.

Route 2

In recognition of the fact that some welding coordination functions do not require the breadth

of knowledge provided by the IIW qualifications, TWI Certification has developed

Requirements for the Certification of Welding Coordinators in accordance with BS EN ISO

14731: 2006 under the Certification Scheme for Welding and Inspection Personnel (CSWIP).

This allows a manufacturer's nominated RWC to gain appropriate, industry-specific, CSWIP

certification as a welding coordinator working in structural steelwork. The scheme assesses

the knowledge, experience and competence of the nominated RWC by assessing a portfolio

of evidence, interview, additional training where necessary and examination. The successful

candidate will, in this case, be issued with a CSWIP certification.

The CSWIP process includes both an off-the-job knowledge examination, and a job-specific

assessment focussing on the competence of the RWC to fulfil the job specification. This

latter step could take place during the certification process when a manufacturer is seeking

independent certification of its WQMS to BS EN ISO 3834.

Under this option the RWC will need to supply the NB with a copy of the RWC's CSWIP

certificate to demonstrate the RWC's technical knowledge. A technical interview with the NB

may be required to demonstrate the RWC's competence in the context of the welding

operations covered by the manufacturer's WQMS. Again, the level of this qualification must

match the scope of the RWC's employer's WQMS. This certification is valid for review after

three years and re-assessment after six years. It has limited portability as it would only be

suitable for another manufacturer with a congruent scope of WQMS certification.

Route 3

The third route is available to those manufacturers working within a limited scope of operations

and whose RWC is a directly employed member of staff. The assessment may differ from

certification body to certification body but it is likely to involve an assessment of the individual's

experience based on a typical portfolio of information (see Appendix A). A successful

assessment would lead to company-specific qualification of the nominated RWC who would

be embedded in its WQMS and, as such, not transferable should they decide to leave.

The table below summarises how the required level of technical knowledge relates to

welding processes and the grades and thicknesses of parent materials for building

steelwork in EXC2 undertaken in accordance with the NSSS.

With respect to this table, Appendix A describes the limited scope of operations to which

route 3 might typically apply.

11.4 Surveillance audits

To maintain its declaration of conformity, the company's FPC system is subject to regular

surveillance audits. The interval between these audits is related to the Execution Class. For

EXC1 and EXC2 surveillance audits will take place one year after the initial assessment,

two years after that and then every three years. These periods are only applicable in the

case of no major non-conformities. If major non-conformities are identified the regime must


50

TECHNICAL KNOWLEDGE OF RWC

Scope of welding operations Maximum parent metal thickness t (in mm)

being supervised t ≤ 25(1) 25 < t ≤ 50(2) t > 50

Welding of S275 steel products Basic Specific Specific

Welding of S355 steel products Basic Specific Comprehensive

Welding of S420 steel products Specific Specific Comprehensive

(1) Column base plates and endplates ≤ 50mm.



51

be at such intervals that give confidence that the non-conformity has been corrected. For

EXC3 and EXC4 the audits will take place at yearly intervals for the first two years, the third

audit will be two years after that and then every three years. The table below shows the

relationship between Execution Class and audit inspection intervals:

In periods where the interval between surveillance is two or three years audits the

manufacturer must make an annual declaration to the NB that none of the following

changes have been made:

• New or changed essential facilities;

• Change of RWC;

• New welding procedures, change to the type of parent material and associated

WPQRs;

• New equipment, where it affects the declared characteristics.

There is no formal requirement for the FPC system to be re-certified at each surveillance

audit as it is merely a confirmation that the manufacturer still has the FPC system under

control as was the case at the initial inspection. Thus the FPC certification does not have

an “expiry date” as such. However, it is likely that the NB will wish to state the date of the

next required surveillance audit in accordance with intervals stated in BS EN 1090-1 and

this is shown in the example documents in Appendix C.

If a separate welding certificate is issued this also does not have an expiry date as such as

it is indefinitely valid in terms of time but not in terms of circumstances. Hence, if any of the

four changes listed above do occur this automatically means that the details listed on the

existing welding certificate will become either invalid or incomplete. For instance, a change

of RWC or move of factory location and hence site address would render the whole

certificate invalid. On the other hand, the addition of a new factory, new welding process or

manufacture using materials not listed would not invalidate the existing certificate, but those

new additions would not be covered. Hence, CE Marking could not be applied to welded

components manufactured using those new facilities etc until the welding certificate had

been updated.

In practice the company needs to agree a suitable programme of certification with the

relevant NB. Audit visits to BS EN ISO 9001 would often be undertaken on a six-monthly

basis. In those circumstances, and with the need to keep a close watch on changes in

welding circumstances, the practical way would be to undertake FPC surveillance on an

annual basis using the intervening six-monthly visit to audit the other aspects of the quality

management system covered only by BS EN ISO 9001. Thus, welding changes could be

identified and dealt with within a maximum of six months. In terms of the latitude allowed by

BS EN 1090-1 to extend the FPC surveillance intervals beyond a year, the practical way

would be to use that latitude not to extend the interval but to reduce the scope of the annual

FPC audit in terms of which facilities or processes are audited.

11.5 Steel Construction Certification Scheme

The Steel Construction Certification Scheme (SCCS) is the steel construction industry's

Execution Class Intervals between inspection of manufacturer's

FPC after ITT (years)

EXC1 and EXC2 1 - 2 - 3 - 3

EXC3 and EXC4 1 - 1 - 2 - 3 - 3

dedicated certification scheme. SCCS will become a notified body for CE Marking of

structural steelwork and is already able to offer FPC gap analysis of FPC systems to BS EN

1090-1. Within the limited but common scope of operations explained above, SCCS has

competent welding and fabrication assessors which allow it to assess WQMSs and the

associated RWC as an integral part of the FPC assessment. SCCS may be contacted via

the BCSA's website www.steelconstruction.org.


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12 IMPLICATIONS FOR DESIGNERS, SPECIFIERS ANDCONSTRUCTION MANAGERS

12.1 Introduction

CE Marking already appears on some construction products and CE Marking in general has

been with us for many years. Most of the manufactured products that we buy have CE

Marks on them. It is therefore important that all parts of the supply chain, including

specifiers, designers and construction managers are aware of their responsibilities and the

benefits of CE Marking.

In essence CE Marking is a declaration by the manufacturer that the product meets certain

minimum public safety requirements. Although CE Marking is currently not a legal

requirement in the UK it is in most other European countries and under the UK's

Construction Products Regulations a CE Marked product is assumed to comply with the law.

For fabricated structural steelwork CE Marking, applies both to the steel constituent

products (steel sections, structural bolts, purlins, cladding and propriety products such as

cellular beams) and to the fabricated steelwork itself. This imposes implications on the

designer when specifying steel components, designing the structure and when choosing an

appropriate steelwork contractor. It also has implications for construction managers.

12.2 Designers and specifiers

12.2.1 Roles

For building steelwork in the UK there are generally two design roles that are fulfilled

separately. In terms of the NSSS one role is allocated to the engineer who is the responsible

for the design of structural members and will prepare design drawings. The engineer may

be appointed by the purchasing client, or on design-and-build projects the engineer will be

appointed by the steelwork contractor.

The design drawings and the associated project specification will form the design brief that

includes all information necessary for the design of connections and completion of the

fabrication drawings. The latter design work is generally undertaken by designers and

detailers working for the steelwork contractor.

The completed fabrication drawings and associated project specification agreed between

the engineer and the steelwork contractor comprise a portfolio of component specifications

for the structural steelwork to be manufactured.

12.2.2 Components

CE Marking is already in place for steel products such as rolled steel beams to BS EN

10025-1, and their inspection documents (test certificates) are now endorsed with a CE

Marking. Similarly structural fasteners to BS EN 14399-1 and BS EN 15048-1 now have CE

Marking on their packaging.

One of the benefits of CE Marking is that it includes technical information in the form of the

product's declared characteristics (in the case of steel sections one of the declared

properties is its grade - e.g. S275). Hence the CE Marking can be seen as a technical data

sheet. The information given in the CE Marking together with the appropriate harmonised

standard gives the information needed for the specifier to judge whether the product is

suitable for a particular intended use in terms of the requirements in the building regulations

related to materials and workmanship. Furthermore because CE Marking is a legal

requirement in most European countries specifiers can have confidence in the declared

characteristics.

Another benefit of CE Marking is that there is only one set of requirements and procedures

with which to comply. The various national regulations are eliminated. As a result the

product no longer has to be adapted to the specific requirements of the different member

states, such as the U-Marking scheme used hitherto in German building construction.

Designers and specifiers are therefore strongly advised to keep abreast of the developing

CE Marking standards (called harmonised standards) for construction products and to

specify CE Marked materials and products where appropriate.

12.2.3 Fabricated steelwork

The new European fabrication standard introduces the concept of Execution Class (EXC)

for steel structures. The choice of EXC is a design issue and sets the level of quality

required for different types of structure. EXC can be applied to the whole structure, part of

a structure and individual details. Recommendations for determining the EXC are give in BS

EN 1090-2 and it is linked to Consequences Class (risk to life and the environment),

Production Category and Service Category (static or fatigue). The link between

Consequences Class and type of structure is still being discussed with national authorities

but it is likely that the following simple relationship between EXC and type of structure will

be the basis:

• Execution Class 1 - Farm buildings.

• Execution Class 2 - Buildings (similar to the scope of the National Structural

Steelwork Specification).

• Execution Class 3 - Bridges.

• Execution Class 4 - Special structures (power stations, long span bridges etc.).

The designer will need to specify the Execution Class for each structure. This also has

implications for choosing a steelwork contractor. Under the CE Marking rules for fabricated

steelwork each steelwork contractor will be assessed against a chosen Execution Class and

will only be able to use CE Marking on its products for certain Execution Classes. Therefore

a steelwork contractor will need to be selected both on the ability to do the job and on the

Execution Class related to its certified manufacturing facilities. BCSA is developing a web

based facility listing the execution class for steelwork contractors who are members of

BCSA. BCSA has also developed a CE Marking Edition of its National Structural Steelwork

Specification based on EXC2 as the most common basis for building steelwork in the UK.

12.3 Construction managers

Construction managers have a duty of care to ensure that the correct CE Marking is

associated with the correct product and that they are not using clearly non-compliant

products that have been placed on the EU market. This means developing a purchasing

system that requires CE Marking of products and checking that the appropriate CE Marking

is on products which are delivered to site. CE Marking standards are continuously being

developed for new and existing products, therefore construction managers need to keep

abreast of these developments and update their procedures accordingly.

When choosing a steelwork contractor construction managers need to select one with the

correct certified Execution Class. BCSA is developing a web based facility listing the

Execution Class for steelwork contractors who are members of BCSA.

SECTION 12 : IMPLICATIONS FOR DESIGNERS, SPECIFIERS & CONSTRUCTION MANAGERS

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Fabricated steel components are often bespoke products made to a particular purchasing

client's order and specification and designed for a particular project site. It is current practice

for the purchasing client to select the steelwork contractor rather than choose an off-the-

shelf product. On this basis CE Marking might seem to add little, however this would be

wrong as CE Marking does add the following:

• The regulatory imperative from the Construction Products Directive ensures attention

is given to key public safety concerns;

• The requirement for certification of the manufacturer's FPC provides assurance of

comparable and appropriate controls across the market place;

• The declared characteristics can be relied upon as being accurate;

• A consistent technical language is used by authorities, specifiers and manufacturers

to describe the characteristics of products.

APPENDIX A – ASSESSMENT OF THE RWC

Manufacturers working within a limited scope of operations may choose to ask the NB to assess

the knowledge and competence of the RWC as an “embedded” part of the WQMS (i.e. the third

route to assessment described in section 11)

In adopting this route the RWC may only be assessed for evidence of Basic or Specific technical

knowledge in accordance with BS EN ISO 14731. Assessment of Comprehensive technical

knowledge is not possible. As a NB, SCCS also generally applies the following limitations:

• The RWC has to be a directly employed member of staff;

• Manufacturing operations are limited to EXC2;

• Steel grades up to and including S355 for qualities JR, J0 or J2;

• Parent metal thicknesses up to a general maximum of 50mm with column base plates and

endplates up to 75mm;

• Use of MMA or MAG welding (processes 111 and 135) for general welding or SAW (process

121) for mechanised “automatic” production.

Where all of the above apply, the following five step procedure is appropriate:

Step 1 - The manufacturer provides a written declaration confirming:

• The Execution Class of its fabricated product range (EXC1 or EXC2).

• Its product range and the welding processes and materials used in fabrication.

• The level of knowledge required for its RWC - Basic or Specific.

• A job specification for the RWC.

• The RWC's roles and responsibilities.

Step 2 - The nominated RWC provides for review/assessment:

• A detailed authenticated CV highlighting the RWC's technical knowledge and experience in

welding and fabrication.

• Documentary evidence of training and qualifications (e.g. photocopy of certificates).

• Examples of job-related documents that the RWC has been responsible for (e.g. WPSs,

WPQRs, WQTs, project-specific quality plans etc.)

Step 3 - Professional Interview

A suitably qualified welding specialist acting on behalf of SCCS will interview the RWC focussing

on the RWC's knowledge and competence to fulfil the job specification during discussion. As part

of the interview process, the candidate would also be required to complete a technical question

paper tailored to suit the manufacturer's declared product range and welding activities.

Step 4 - Successful candidates

If the candidate is successful they will form an integral part of the company's WQMS. This route

does not provide the RWC with separate certification and, as with other routes to certification, a

change in job specification or the nominated RWC will invalidate both the WQMS and FPC

systems and will require reassessment by SCCS.

Step 5 - Unsuccessful candidates

If the candidate is unsuccessful the company can either retrain the candidate, or nominate another

employee or engage the services of a suitably qualified and competent external RWC. If the RWC

is engaged on a subcontract basis by the manufacturer the RWC will be expected already to hold

a recognised and appropriate IIW or CSWIP qualification in welding or equivalent.

APPENDIX A : ASSESSMENT OF THE RWC

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APPENDIX B – ISSUES ASSOCIATED WITH BRIDGES

Introduction

The use of CE Marking for bridge components in the UK is an additional requirement to the

existing contractual provisions for quality management. This Appendix is based on those

arrangements that currently exist between steel bridgework contractors and the Highways Agency

(HA), although similar provisions underpin steel bridgework contracts for Network Rail and the

County Surveyors.

It is already mandatory for steel bridgework contractors working for the HA to have their quality

management certified to BS EN ISO 9001. Whilst this is a contractual provision and not a public

safety regulation, the fact that the HA (and most other bridge authorities) is an organisation whose

activities are covered by the Public Procurement Regulations means in practice that contractual

provisions carry public obligations with them.

The HA will wish to make use of CE Marking to implement its obligations to ensure that safe and

reliable components are used in its bridges. This is a general policy and will affect how the HA

deals with type approvals, product certification etc for proprietary products and specific items

supplied for installation such as bridge bearings. This wider context is not considered further in this

Appendix, but additional information can be found on the HA website on standards:

http://www.standardsforhighways.co.uk/index.htm.

Quality management

In order to identify a common interpretation of BS EN ISO 9001 for organisations and certification

bodies engaged in the sector, the HA sponsors the development of Sector Scheme Documents

(SSD). National Highways Sector Scheme 20 (NHSS 20) relates to the quality management

system requirements for the execution of steelwork in transportation infrastructure assets for the

supply of new steelwork and for work on existing steelwork in new and existing assets. NHSS 20

is entitled Sector Scheme Document for the Execution of Steelwork in Transportation

Infrastructure Assets. Potentially it can be used for a wider scope of steelwork infrastructure

projects including toll plazas, railway bridges and station buildings.

It is expected that NHSS 20 will be published by the end of 2008 to coincide with the publication

of BS EN 1090-1 and -2. Steel bridgework contractors will then be expected to have their BS EN

ISO 9001 certifications “endorsed” as complying also with the provisions of NHSS 20 when they

are next re-certified. As BCSA steel bridgework contractors have collaborated in its development,

its provisions should reflect existing good quality management practice in the sector.

Certification bodies

As NHSS 20 is one of many National Highways Sector Schemes, there are already many

certification bodies that are familiar with using them. Several of these have already endorsed the

development of NHSS 20. Steel bridgework contractors will need to match the certification body

they use for their existing BS EN ISO 9001 certification with those able to certify to NHSS 20.

Also, it is not necessarily the case that existing certification bodies operating in the sector will seek

to become notified bodies under BS EN 1090-1. Hence, steel bridgework contractors need to be

aware of this in order to avoid unnecessary duplication of certification audits.

Basis of NHSS 20

NHSS 20 clearly states that it is based on the requirements of BS EN 1090-1 for conformity

assessment of manufacturing operations, BS EN 1090-2 as the specification for the execution of

steel structures and BS EN ISO 3834-2 and -3 as the basis for the welding quality requirements.

It should be noted that NHSS 20 covers a much wider scope than FPC to BS EN 1090-1, as it

covers, for instance, all site-based operations including bridge refurbishment. However, with

respect to conformity assessment of manufacturing operations and manufacturing welding quality

requirements it is congruent in its requirements with BS EN 1090-1. Hence, the guidance provided

in the main sections of this document applies directly to the CE Marking of manufactured steel

bridgework components.

NHSS 20 is also based on using BS EN 1090-2 as the basis for the execution specification. This

supersedes the use of BS EN 5400-6 Steel, concrete and composite bridges - Part 6: Specification

for materials and workmanship, steel. In order to assist with the transition between these two

standards, the Steel Bridge Group (on which BCSA sits) has prepared SCI Publication P382

Model Project Specification for the Execution of Steelwork in Bridge Structures. The SCI will also

be issuing updates as relevant to its publication P185 Steel Bridge Group: Guidance Notes on

Best Practice in Steel Bridge Construction. As BS EN 1090-2 is the supporting standard for BS EN

1090-1, steel bridgework contractors seeking to have their FPC certified as complying with BS EN

1090-1 and NHSS 20 should ensure that they follow the guidance in those two SCI publications.

Execution Class

Publication P382 is based on EXC3, whereas the guidance provided in the main sections of this

document refers generally to EXC2. The principal implications of this for CE Marking to BS EN

1090-1 are for:

• The traceability requirements for constituent products used in manufacture;

• The manufacturer's WQMS;

• The technical knowledge of the RWC;

• Weld inspection and acceptance requirements.

Traceability

Section 7 defines the requirements for all Execution Classes and P382 provides a detailed definition

of how those requirements are implemented in practice, as follows:

A record shall be maintained of the source of, and test certificates for, main structural steel

elements in order to provide traceability for each product. Traceability shall be by piece, by type

or by stock certificate, as follows:

• For flanges, webs and diaphragms in main girders, the records shall be maintained for each

individual piece. A unique item mark shall be made on each piece.

• For stiffeners, splice plates, bracing members, and fasteners, the records shall be

maintained for each item type, of which there can be many individual pieces. Products of

one type may come from more than one source and be installed in more than one location.

• For welding consumables and shear connectors, the records shall be maintained according

to stock certification, which shall show that the stock material meets the project requirements.

WQMS and RWC

EXC3 requires that the manufacturer's WQMS shall be certified as complying with BS EN ISO

3838-2, i.e. Comprehensive quality requirements. The technical knowledge for the RWC

responsible for a WQMS to BS EN ISO 3838-2 is as follows:

APPENDIX B : ISSUES ASSOCIATED WITH BRIDGES

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BS EN 1090-2 states that the technical knowledge required is with respect to the welding

operations being supervised. It may be seen that a Specific level of knowledge may be suitable

for bridgework contractors only undertaking the manufacture of footbridges and sign gantries, but

otherwise a Comprehensive level of knowledge of welded steel bridgework would be required.

Weld inspection and acceptance requirements

BS EN 1090-2 requires routine supplementary NDT to be undertaken on a more frequent basis for

EXC3 than EXC2. BS EN 1090-2 also requires that production welds meet quality level B for EXC3

(i.e. as required for WQTs and WPQRs). The implications of these quality level requirements are

explained in section 4.

Publication P382 deals with this issue in more detail, as well as recommending an approach for

dealing with weld acceptance criteria for welded fatigue details that avoids the difficulties (noted

in section 4 above) that would occur with trying to meet the weld quality levels for EXC4 if these

were specified for general production. The approach requires the execution specification to

identify specific joints that are designed for significant fatigue so that the extent and method of

testing can be chosen to detect imperfections and to characterise them.

Assessment of whether such imperfections are non-conforming defects is then judged using

published fitness-for-purpose criteria that relate the function of the component to the

characteristics of the imperfections (type, size, location) in order to decide whether the weld is

either acceptable or shall be repaired. In effect this replaces routine inspection with joint-specific

inspection for “fatigue welds” which is based on the same fitness-for-purpose weld acceptance

criteria that underpin BS 5400-6.

TECHNICAL KNOWLEDGE OF RWC

Scope of welding operations Maximum parent metal thickness t (in mm)

being supervisedt ≤ 25 (1) t > 25 (1)

Welding of S275 or S355 steel products Specific Comprehensive

Welding of S420 steel products Comprehensive Comprehensive


APPENDIX C – DOCUMENTARY EXAMPLES

APPENDIX C : DOCUMENTARY EXAMPLES

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APPENDIX C : DOCUMENTARY EXAMPLES

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APPENDIX D – SG17 GUIDANCE ON FPC ASSESSMENT

This is an abstract of a draft position paper prepared by SG17, the Structural Metallic Products

Sector Group of Notified Bodies for the Construction Products Directive 89/106/EEC on which

SCCS is represented.

Introduction

The aim of this document is to give Notified Bodies (NB) and manufacturers of steel or aluminium

structural components or kits of components➅ guidance for the performance of FPC assessment

according to Annex B of EN 1090-1. In addition to Annex B of EN 1090-1 this document identifies

the tasks of the NB both for the Initial Inspection and for the Continuous Surveillance.➆

This guidance applies to factories whether they produce series or non-series production.➇

1 Initial Inspection of the Factory and FPC

1.1 General

1.1.1

The manufacturer shall demonstrate that the FPC fulfils the requirements given in clause 6.3 of

EN 1090-1. The tasks for the NB for the Initial Inspection are given in Table B.1 of EN 1090-1.

1.1.2

The FPC system shall cover all processes, production lines, units or departments including those

outsourced or operated by subcontractors.

1.1.3

If the manufacturer declares with the CE Marking symbol characteristics influenced by the

structural design (clause ZA 3.3 or ZA 3.5 of EN 1090-1) the assessment of the FPC also includes

the control of tasks related to structural design work in Table B.1 of EN 1090. The manufacturer

may be selective in its declaration of the structural characteristics for products provided that the

manufacturer's declaration is unambiguous in this respect.➈

1.1.4

The certificate issued by the NB shall make it clear whether the design process is included or not.

1.1.5

As specified in 6.3.5 of EN 1090-1, if constituent products or structural components bearing CE

marks are incorporated into finished products during the manufacturing of EN 1090-1 products,

they shall be traceable in accordance with the provisions for the relevant Execution Class given in

6.3.5 of EN 1090-2 or -3 as appropriate.

1.1.6

For finished products to be supplied to a Member State where CE Marking is mandatory and a

harmonised standard exists for a constituent product, the manufacturer shall use a constituent

product with a CE mark.

APPENDIX D : SG17 GUIDANCE ON FPC ASSESSMENT

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➅ A manufacturer may make a single declaration of conformity for a kit of components provided that all

components are intended for incorporation in the same construction work.

➆ A checklist made by the Notified Body and specific to EN 1090-1 and to this document is strongly

recommended as a tool for the assessment.

➇ Series production may be taken as batch sizes of 10 or more identical components.

➈ For instance, the load bearing capacity of a beam's connections could be declared even though the

manufacturer's declaration is silent about the capacity of the beam in bending.


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1.1.7

The factory covered by a single FPC system may comprise several production units, production

lines and/or departments. The NB shall define the scope of certification in terms of processes,

units, lines and departments in all records issued to verify that the FPC system has been certified.

1.1.8

If the manufacturer is performing any testing in its own laboratory, the testing facilities shall be

included in the assessment. The capability of the laboratory shall be demonstrated to the Notified

Body according to one of the following possibilities:

- direct check of the performance of the manufacturer's own laboratory testing operations

within the scope of the FPC;

- independent accreditation of the laboratory under ISO/IEC 17025 or equivalent

accreditation; the accreditation shall be specific for the tests carried out;

- assessment of a subcontracted laboratory by the Notified Body.

1.1.9

After a new ITT program based on physical testing has been undertaken the manufacturer shall

inform the NB. The NB should review the FPC to ensure that it is capable of controlling the

production of the new product. The NB does not need to undertake a supplementary assessment

visit if the method of production is covered by the existing certified FPC system. This requirement

does not apply where a product type is developed by calculation (ITC).

1.1.10

If the FPC is part of a certified EN ISO 9001 and/or EN ISO 3834 quality management system and

the NB has satisfied itself that the system is compliant with the requirements of EN 1090-1 and

this document then the NB may use any EN ISO 9001 or EN ISO 3834 certification information in

support of the FPC certification according to the CPD.

1.1.11

The number of samples used to establish product quality during ITT/ITC is defined as a single item

in Table 1 of EN 1090-1. This is because many structural components are non-series items and

with a unique component specification . If a new product type is developed using physical testing

then suitable statistical techniques shall be used to assess product characteristics based on the

number of samples tested.

1.1.12

The sampling procedure to be used during production is given in Table 2 of EN 1090-1.

1.1.13

The component specification defines the initial type and is thus the primary control document that

links ITT/ITC with production requirements. The NB shall check that typical component

specifications issued for manufacture are fully definitive in terms of the characteristics that support

the manufacturer's declaration of conformity.

1.1.14

Special processes shall be assessed according to 1.3.

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10

There could be a single set of calculations to verify the load bearing capacity of the component. This wouldbe based on verification procedures given in, for example, the Eurocodes which are based on many “type tests”undertaken in support of the codified rules.

Annex D of EN 1990 provides a reference for structural product design assisted by physical testing.11

10

1.2 Performance of the Initial Inspection of the Factory and FPC

1.2.1

During the initial assessment of the factory all processes, units, lines and departments covered by

a single FPC system shall be inspected individually. This shall include those outsourced or operated

by subcontractors unless their FPC is certified by a NB for the scope of the work being undertaken.

1.2.2

During the initial inspection of factory and FPC the NB shall take into account the Initial Type

Calculation (ITC) and/or the Initial Type Testing (ITT) as applicable (see 6.2 of EN 1090-1). This

also applies if ITC is outsourced or done by subcontractors.

1.2.3

The manufacturer or its subcontractors shall make available the records of the ITC if applicable

and ITT. The NB shall check that the results of the ITC/ITT procedure are consistent with the scope

of processes, product types, materials and production lines covered (see Annex B of EN 1090-1).

1.2.4

During the initial inspection the NB shall check that the factory has the necessary resources

(premises, personnel and equipment) to achieve conformity of products.

1.2.5

Initial visits to packaging and warehouse units shall check that the FPC system ensures that

products retain their traceability such that the product shall be delivered with a mark that clearly

identifies it, with reference to the component specification.

1.2.6

The certificate issued by the NB shall be definitive in terms of the scope and Execution Class of

product types, the applicable standards and the facilities covered.

1.2.7

If the product types produced in a factory do not incorporate welding, the certificate shall explicitly

exclude welding.

1.2.8

If the product types produced in a factory incorporate welding, the certificate shall be explicit

concerning the welding processes and parent materials covered. Unless the scope of certification

is limited to Execution Class 1, the Responsible Welding Coordinator (RWC) shall also be

identified on the certificate. This may be by means of certification to EN ISO 3834 (see 1.3.2.3).

1.3 Initial Inspection for Special Processes

1.3.1 General

1.3.1.1

Special processes are those processes where the conformity of the finished product cannot be

readily or economically verified.

1.3.1.2

Special processes require special consideration during the initial inspection.

1.3.1.3

Welding is most widely used special process for products covered by EN 1090-1 and is dealt with

in detail in 1.3.2.

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The requirement to consider ITC undertaken by others only applies if the manufacturer is using that ITC asthe basis for its declaration of the structural characteristics of the finished product.

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1.3.2 Initial Inspection for the Special Process “Welding”

1.3.2.1

The quality requirements are defined in terms of the Execution Class according to EN 1090-2/-3

as appropriate.

1.3.2.2

EN 1090-2/-3 as appropriate also defines the quality requirements for fusion welding according to

EN ISO 3834 and the relevant to the Execution Class for the products being manufactured.

1.3.2.3

The NB shall be satisfied that the manufacturer is deploying suitable resources to ensure proper

operation of the FPC for welding with respect to the following:

- Welders

For each main welding process the manufacturer shall have available welder(s) with valid

qualification according to EN 287-1 for steel or EN ISO 9606-2 for aluminium. Welders for fillet

welds should have a suitable qualification for welding fillet welds.

- Operators

For each main fully mechanised or automatic welding process the manufacturer shall have

available operator(s) with valid qualification according to EN 1418.

- Welding Coordination

RWCs identified as managing welding coordination should be competent to manage the

processes under their supervision and understand the limits of their competence . Guidance on

suitable knowledge is given in EN 1090-2/-3 as appropriate in terms of EN ISO 14731 and the

relevant Execution Class.

- Qualification of Welding Procedures

Except where welding is undertaken to Execution Class 1, all welding operations shall be

performed according to qualified welding procedures. The welding procedure specifications

(WPSs) to be used shall be based on a Welding Procedure Qualification Record (WPQR). The

method of qualification shall be according to EN 1090-2/-3 as appropriate.

1.3.3 Performance of the Initial Inspection for the Special Process “Welding”

1.3.3.1

The requirements for the FPC of the manufacturer's factory where welding is performed are given

in clause 6.3 of EN1090-1.

1.3.3.2

The NB shall assess whether the personnel, procedure qualifications and equipment of the

manufacturer meet the requirements of EN 1090-2/-3 as appropriate.

1.3.3.3

During the initial inspection of the welding factory it has to demonstrate that the production process

is under control in accordance with the requirements for welding given in EN 1090-2/-3 as

appropriate.

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Certification to EN ISO 3834 is not required but may be agreed between the manufacturer and the Notified Body.

The RWC is permitted to rely on additional assistance from an outside specialist source of welding advice tocoordinate welding operations outside his general scope of competence on a “unit verification” basis (e.g. widerrange of parent materials to be welded).

14

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1.3.3.4

The audit and the independent assessment of the RWC's competence and knowledge shall be

performed by experienced auditors.

1.3.3.5

With respect to the processes being used, the Execution Class for the products being produced,

the constituent products being welded and the welding consumables being used, the assessment

of the RWC's competence shall include the following checks with respect to the RWC's ability to

coordinate the processes etc within the FPC system:

- During a technical discussion, check the knowledge of the welding coordinator(s) about the

relevant standards, regulations and specifications to be observed.

- Check the ability of the welding coordinator(s) to detect and assess defects, to instruct repairs

and to know how to avoid defects.

1.3.3.6

With respect to the processes being used, the Execution Class for the products being produced,

the constituent products being welded and the welding consumables being used, the audit of the

FPC system shall include the following checks:

- Check that the certificates of welders, operators and NDT-Personnel are appropriate.

- Check that the WPSs are based on appropriate WQPRs .

- During an inspection tour through the plant, check that suitable equipment is available for

joint preparation, welding, heat treatment (if necessary) and treatment after welding, and

that the equipment is suitably maintained.

- Check that the quality of welding works is being monitored in accordance with the specified

requirements.

- Check that relevant standards, regulations and specifications, necessary for the production

are available.

2 Continuous Surveillance, Assessment and Approval of the FPC

2.1

The frequency of surveillance visits shall be in accordance with B.4 of EN 1090-1. The FPC

system in every unit, line and department covered by a single FPC system shall be included in a

surveillance visit at least once every three years.

Subject to inspection of non-conformance reports or irregularities identified during the NB audit,

the NB may request more frequent visits from that given in B.4 of EN1090-1. The issues to be

considered include:

- irregularities in the performance and evaluation of welder, welding operator or welding

procedure qualification tests;

- irregularities in welding procedure specifications and production weld tests;

- incomplete or wrong material inspection documents;

- incomplete necessary standards, specifications and regulations for the production;

- incomplete technical knowledge of the welding coordinator;

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EA 6/02 gives guidelines for certification to EN ISO 3834.

WPQRs and associated WPSs are the equivalent of Initial Type Tests for welds executed within the “family”defined by the range of qualification given in the WPQR. In this context, the process control of welding defined inEN 1090-2/-3 may be seen as suitable for series production.

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- significant defects in products.

An additional surveillance audit may be required due to one of the following reasons:

- new or changed essential facilities;

- change of Responsible Welding Coordinator;

- new welding processes, parent materials and associated WPQRs;

- new essential equipment.

If the NB becomes aware that one of the above reasons applies but the manufacturer has not

informed the NB promptly, then an additional surveillance visit shall be undertaken.

2.2

The tasks of the NB during the surveillance audit are given in Table B.2 of EN 1090-1.

2.3

The audit of special process “welding” shall check the following in accordance with the

requirements of EN 1090-2/-3:

- the commissioning of new WPSs into production;

- plans for the control of production welding are being properly implemented;

- the methods and frequency of inspection and testing being undertaken.

APPENDIX E – ABBREVIATIONS

BCSA The British Constructional Steelwork Association Ltd

CC Consequences class

CEN European Committee for Standardization

CEV Carbon equivalent value

CPD Construction Products Directive

CPR Construction Products Regulations

CSWIP Certification Scheme for Welding and Inspection Personnel

CVN Charpy V-notch

DCLG Department for Communities and Local Government

ETA European technical approval

EXC Execution class

FPC Factory production control

HA Highways Agency

HAZ Heat affected zone

IIW International Institute of Welding

ITC Initial type calculation

ITT Initial type testing

IWE International welding engineer

IWS International welding specialist

IWT International welding technologist

MPCS Manufacturer provided component specification

NB Notified body

NDT Non destructive testing

NHSS 20 National Highways Sector Scheme 20

NPD No performance determined

NSSS National Structural Steelwork Specification for Building Construction

OJ Official Journal

PC Production category

PPCS Purchaser provided component specification

pWPS Preliminary welding procedure specification

RWC Responsible welding coordinator

SC Service category

SCCS Steel Construction Certification Scheme

SCI The Steel Construction Institute

TWI The Welding Institute

UKAS United Kingdom Accreditation Service

WPQR Welding procedure qualification record

WPS Welding procedure specification

WQMS Welding quality management system

WQT Welder qualification tests

APPENDIX E : ABBREVIATIONS

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REFERENCES

BCSA Publications:

National Structural Steelwork Specification for Building Construction (CE Marking Edition) (In

preparation title subject to confirmation)

Commentary on the Fourth Edition of the National Structural Steelwork Specification for Building

Construction

BSI Publications:

BS EN 5400-6 Steel, concrete and composite bridges - Part 6: Specification for materials and

workmanship, steel

BS EN 1011 Welding - Recommendations for welding of metallic materials

BS EN 1090-1 Execution of steel structures and aluminium structures - Part 1: Requirements for

conformity assessment of structural components

BS EN 1090-2 Execution of steel structures and aluminium structures - Part 2: Technical

requirements for steel structures

BS EN 1990 Eurocode - Basis of structural design

BS EN 10025-1 Hot-rolled products of structural steels - Part 1: General technical delivery

conditions

BS EN 10045-1 Charpy impact test on metallic materials - Part 1: Test method (V-and U-notches)

BS EN 10210-1 Hot finished structural hollow sections of non-alloy and fine grain steels - Part 1

Technical delivery conditions

BS EN 10219-1 Cold form welded structural hollow sections of non-alloy and fine grain steels -

Part 1 Technical delivery conditions

BS EN 14399-1 High strength structural bolting assemblies for preloading - Part 1: General

requirements

BS EN 15048-1 Non-preloaded structural bolting assemblies - Part 1: General requirements

BS EN ISO 3834 Quality requirements for fusion welding of metallic materials

Part 1: Criteria for the selection of the appropriate level of quality requirements

Part 2: Comprehensive quality requirements

Part 3: Standard quality requirements

Part 4: Elementary quality requirements

PD CEN ISO/TR Quality requirements for fusion welding of metallic materials - Part 6: Guidelines

on implementing ISO 3834

BS EN ISO 9001 Quality management systems - Requirements

BS EN ISO/IEC 17021 Conformity assessment - Requirements for bodies providing audit and

certification of management systems

BS EN ISO/IEC 17025 General requirements for the competence of testing and calibration

laboratories

BS EN ISO 14731 Welding coordination - Tasks and responsibilities

BS ISO 10005 Quality management - Guidelines for quality plans

Other publications:

CE marking under the Construction Products Directive published by DCLG available at

http://www.communities.gov.uk/documents/planningandbuilding/pdf/156006.pdf

The Construction Products Directive - A practical guide to implementation and CE marking, Adam

A. Pinney and Stephen J. Rein, published by AuthorHouse, Milton Keynes, 2007.

Certification Scheme for Welding and Inspection Personnel (CSWIP), Requirements for the

Certification of Welding Coordinators in accordance with BS EN ISO 14731: 2006, Document No.

CSWIP-WCO-18-06, Administered by TWO Certification Ltd.

Guidance Paper 'L' Application and use of Eurocodes.

NB-CPD/SG17 Guidance for the FPC assessment according to Annex B of EN 1090-1

NHSS 20 Sector Scheme Document for the Execution of Steelwork in Transportation

Infrastructure Assets published by the Highways Agency

P185 Steel Bridge Group: Guidance Notes on Best Practice in Steel Bridge Construction

published by the Steel Construction Institute

P382 Model Project Specification for the Execution of Steelwork in Bridge Structures published by

the Steel Construction Institute

REFERENCES

72

guide to ce marking of structural steelwork

Documents

transportation

load bearing

column base

previous british

directly employed

welding quality

ce marking

ce marked