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BCSA Guide To The CE Marking of Structural Steelwork
BCSA Guide To The CE Marking of Structural Steelwork
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Guide to the
CE Marking of
Structural Steelwork
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Apart from any fair dealing for the purposes of research or private study or criticism or review, as
permitted under the Copyright Design and Patents Act 1988, this publication may not be
reproduced, stored, or transmitted, in any form or by any means, without the prior permission of
the publishers, or in the case of reprographic reproduction only in accordance with terms of the
licences issued by the UK Copyright Licensing Agency, or in accordance with the terms of licences
issued by the appropriate Reproduction Rights Organisation outside the UK.
Enquiries concerning reproduction outside the terms stated here should be sent to the publishers,
The British Constructional Steelwork Association Ltd. at the address given below.
Although care has been to ensure, to the best of our knowledge, that all data and information
contained herein are accurate to the extent that they relate to either matters of fact or accepted
practice or matters of opinion at the time of publication, The British Constructional Steelwork
Association Limited, the authors and the reviewers assume no responsibility for any errors in or
misinterpretations of such data and/or information or any loss or damage arising from or related
to their use.
Publications supplied to members of BCSA at a discount are not for resale by them.
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: postroom@steelconstruction.org
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
Printed by: Box of Tricks Advertising and Design Limited
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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.
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CONTENTS
PAGE
1.1
1.2
1.3
Objective
Scope
Overview
7
7
7
CE MARKING REGULATIONS
2.1
2.2
2.3
2.4
2.5
2.6
9
9
10
11
11
12
13
3.1
3.2
3.3
3.4
3.5
3.6
3.7
Basis
Scope
Definitions
Requirements
Evaluation methods
Evaluation of conformity
Marking system
13
13
13
20
21
21
26
29
4.1
4.2
4.3
4.4
4.5
4.6
29
30
30
30
31
32
33
5.1
5.2
5.3
5.4
5.5
33
33
34
34
34
35
6.1
6.2
Welding coordination
Tasks for welding coordinators
35
35
TRACEABILITY
37
7.1
7.2
7.3
7.4
7.5
7.6
Introduction
Government Circular
Inspection documents
Requirements
Batch or type traceability
Welding
37
37
38
38
39
39
5
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40
8.1
8.2
8.3
8.4
8.5
8.6
8.7
8.8
Introduction
Manufacturers
Importers
Distributors
Stockholders
Steel processors
Special products and processes
Transition period
40
40
40
40
41
41
41
42
EXECUTION CLASS
43
9.1
9.2
9.3
General
Application to buildings
Wider application
43
43
43
10
44
10.1
10.2
10.3
Introduction
FPC systems
System requirements
44
44
45
11
ROUTES TO CERTIFICATION
48
11.1
11.2
11.3
11.4
11.5
Introduction
Assessment of the WQMS
Assessment of the RWC
Surveillance audits
Steel Construction Certification Scheme
48
48
49
50
51
12
53
12.1
12.2
12.3
Introduction
Designers and specifiers
Construction managers
53
53
54
APPENDICES
A
56
57
DOCUMENTARY EXAMPLES
60
64
ABBREVIATIONS
70
REFERENCES
71
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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 10901 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,
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CE MARKING REGULATIONS
2.1
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.
2.
3.
4.
5.
6.
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.
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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
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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
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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.
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.
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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:
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.
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.
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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;
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.
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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:
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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
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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.
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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.
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
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
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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
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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
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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 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;
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Checking that the FPC has procedures for checking conformity and handling
procedural non-conformities and non-conforming product.
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
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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.
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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:
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
on the product;
on the packaging; or
in the manuals or other supporting commercial literature accompanying the product.
It is likely that for bespoke project-specific items the CE Marking would be located on the
In this context accompanying means unambiguously linked to, it does not mean that the commercial
literature has to physically be attached to the product.
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4.1
With respect to their application as requirements for BS EN 1090-1 these clauses form three
groups as follows:
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.
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Those associated with documentary controls (in clause 4 and 5) that support quality
assurance of product conformity; and
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.
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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:
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:
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 10902 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.
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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.
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5.1
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:
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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:
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.
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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
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
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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).
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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'
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.
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.
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SECTION 7 : TRACEABILITY
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 nonspecific (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
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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.
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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. 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.
Further information on the role of the importer and the distributor is contained in the Pinney & Rein reference.
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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
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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.
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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:
Building class
Class 1
Class 2
Class 3
Class 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:
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10
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:
Activities
FPC systems
A
Manufacturing
Yes
Yes
Yes
Yes
Design
No
Yes
No
Yes
Welding
No
No
Yes
Yes
RWC
No
No
Yes
Yes
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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
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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.
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:
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.
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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
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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:
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25 < t 50 (2)
t > 50
Basic
Specific
Specific
Basic
Specific
Comprehensive
Specific
Specific
Comprehensive
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1-2-3-3
1-1-2-3-3
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:
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12
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
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The regulatory imperative from the Construction Products Directive ensures attention
is given to key public safety concerns;
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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:
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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:
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t > 25 (1)
Specific
Comprehensive
Comprehensive
Comprehensive
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60
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Introduction
The aim of this document is to give Notified Bodies (NB) and manufacturers of steel or aluminium
structural components or kits of components 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.
This guidance applies to factories whether they produce series or non-series production.
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.
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.
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.
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.
Series production may be taken as batch sizes of 10 or more identical components.
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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direct check of the performance of the manufacturer's own laboratory testing operations
within the scope of the FPC;
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 10 . 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. 11
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.
10 There could be a single set of calculations to verify the load bearing capacity of the component. This would
be based on verification procedures given in, for example, the Eurocodes which are based on many type tests
undertaken in support of the codified rules.
11
Annex D of EN 1990 provides a reference for structural product design assisted by physical testing.
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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. 12
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
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.
12 The requirement to consider ITC undertaken by others only applies if the manufacturer is using that ITC as
the basis for its declaration of the structural characteristics of the finished product.
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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
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.
13
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 to
coordinate welding operations outside his general scope of competence on a unit verification basis (e.g. wider
range of parent materials to be welded).
14
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Check that the certificates of welders, operators and NDT-Personnel are appropriate.
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.
15
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 in
EN 1090-2/-3 may be seen as suitable for series production.
16
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An additional surveillance audit may be required due to one of the following reasons:
-
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:
-
plans for the control of production welding are being properly implemented;
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APPENDIX E : ABBREVIATIONS
APPENDIX E ABBREVIATIONS
BCSA
CC
Consequences class
CEN
CEV
CPD
CPR
CSWIP
CVN
Charpy V-notch
DCLG
ETA
EXC
Execution class
FPC
HA
Highways Agency
HAZ
IIW
ITC
ITT
IWE
IWS
IWT
MPCS
NB
Notified body
NDT
NHSS 20
NPD
No performance determined
NSSS
OJ
Official Journal
PC
Production category
PPCS
pWPS
RWC
SC
Service category
SCCS
SCI
TWI
UKAS
WPQR
WPS
WQMS
WQT
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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
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REFERENCES
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
72