Structural Steelwork Procedure Approval
The Construction Products Regulation (CPR) was created in March 2011 to legally enforce the European Construction Products Directive (CPD). Under the CPR, from July 1st 2014 any “series” manufactured structural metal components or kits that have been either made in the UK or imported, and to which a harmonised European standard applies, must comply with the CPR & CE marking requirements. The harmonised European standard that applies to structural metalwork is BSEN 1090-1:2009.
New legislation introduced in 2013 allows the CPR to be enforced by the Trading Standards authority, which will have the power to stop a business from trading and to withdraw any products supplied after July 1st 2014, until the company has shown that it complies with the Regulations. This will be costly for any businesses that are discovered not to be complying with CPR, as they will be unable to trade, until they comply with BSEN 1090-1 and will have to carry the cost of product recalls and fines. In severe cases, Directors may also be imprisoned.
By "series", the regulations mean any activity that an organisation carries out more than once, not just the production of a series of standard items. For example a factory that makes bespoke staircases is in the business of "series" manufacture of staircases and all of them will need to carry a CE mark. If the same factory produces a single platform as a special commission, this will be exempt. However if the factory decides to diversify into platforms and makes more than one, CE marking will be required.
Organisations covered by CPR will need to show that they comply with BSEN 1090-1, which involves a number of steps that culminate in certification by a third party, known as a notified inspection body (NB). In the UK all NBs must be accredited themselves by the United Kingdom Accreditation Service (UKAS).
BSEN 1090-1 requires a number of actions in place, many of which will already be standard practise in well-run companies:
- Purchasing systems will need to buy only CE Marked sections, bolts and welding consumables.
- Designers will identify the execution class of the product, as defined in the companion standard BS EN 1091-2, which is determined by the potential risk to the public if the component or structure fails. The designers will also need well-defined specifications for components and kits.
- Prototypes will be produced and subjected to initial type testing. Where type testing is impractical, for example on bespoke designs, the company can use calculations to serve the same purpose.
Type testing is used to define Key Control Checks. These are monitored within a quality control system, called Factory Production Control (FPC). The FPC system also covers
- design and drawing controls
- competence and training of staff
- equipment maintenance & calibration
- control of non-conforming product & keeping of records
EN 1090- Part 1: Requirements for conformity assessment of structural components
EN 1090- Part 2: Technical requirements for steel structures
EN 1090- Part 3: Technical requirements for aluminium structures
I work closely with an experienced consultant, Mr. Tony Wishart, and together we have produced procedures to simplify the implementation and to allow certification and ease of use, for small to medium sized companies. I am also registered with Steel Construction Certification Scheme Ltd and approved as a registered welding coordinator (RWC) to execution class 4 and below.
So, if you like simplicity and a no-nonsense approach, please contact me and I'll be happy to provide you with a quotation for EN1090.
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