Professional Documents
Culture Documents
of Structural Steelwork
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BCSA Publication No. 46/08 BCSA Publication No. 46/08
E513 CE Book Cover 20/10/08 15:15 Page 1
Guide to the
CE Marking of
Structural Steelwork
E513 CE Marking Book 20/10/08 15:21 Page 1
2
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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Guide to the CE Marking of Structural Steelwork
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THE BRITISH CONSTRUCTIONAL
STEELWORK ASSOCIATION LIMITED
The British Constructional Steelwork Association Limited (BCSA) is the national
organisation for the steel construction industry: its Member companies undertake
the design, fabrication and erection of steelwork for all forms of construction in
buildings and civil engineering. Associate Members are those principal companies
involved in the supply to all or some Members of components, materials or products.
Corporate Members are clients, professional offices, and educational
establishments etc., which support the development of national specifications,
quality, fabrication and erection techniques, overall industry efficiency and good
practice.
The principal objectives of the Association are to promote the use of structural
steelwork; to assist specifiers and clients; to ensure that the capabilities and
activities of the industry are widely understood and to provide members with
professional services in technical, commercial, contractual and quality assurance
matters. The Association's aim is to influence the trading environment in which
member companies have to operate in order to improve their profitability.
A current list of members and a list of current publications and further membership
details can be obtained from:
The British Constructional Steelwork Association Ltd.
4, Whitehall Court
Westminster
London
SW1A 2ES
Tel: +44(0)20 7839 8566
Fax: +44(0)20 7976 1634
E-mail: postroom@steelconstruction.org
Website: www.steelconstruction.org
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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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Guide to the CE Marking of Structural Steelwork
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CONTENTS PAGE
1 INTRODUCTION AND SCOPE 7
1.1 Objective 7
1.2 Scope 7
1.3 Overview 7
2 CE MARKING REGULATIONS 9
2.1 Construction Products Directive 9
2.2 Harmonised standards 9
2.3 Certification 10
2.4 CE Marking 11
2.5 Construction Products Regulations 11
2.6 Future developments 12
3 CE MARKING STANDARD FOR STRUCTURAL STEELWORK 13
3.1 Basis 13
3.2 Scope 13
3.3 Definitions 13
3.4 Requirements 20
3.5 Evaluation methods 21
3.6 Evaluation of conformity 21
3.7 Marking system 26
4 EUROPEAN FABRICATION STANDARD 29
4.1 Status and scope 29
4.2 Documentation 30
4.3 Constituent products 30
4.4 Tolerances 30
4.5 Welding 31
4.6 Surface treatment 32
5 WELDING QUALITY MANAGEMENT 33
5.1 Welding as a 'special process' 33
5.2 Control of welding 33
5.3 Technical instructions 34
5.4 Competence of personnel 34
5.5 Implementation 34
6 RESPONSIBLE WELDING COORDINATORS 35
6.1 Welding coordination 35
6.2 Tasks for welding coordinators 35
7 TRACEABILITY 37
7.1 Introduction 37
7.2 Government Circular 37
7.3 Inspection documents 38
7.4 Requirements 38
7.5 Batch or type traceability 39
7.6 Welding 39
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8 SUPPLY CHAIN IMPLICATIONS 40
8.1 Introduction 40
8.2 Manufacturers 40
8.3 Importers 40
8.4 Distributors 40
8.5 Stockholders 41
8.6 Steel processors 41
8.7 Special products and processes 41
8.8 Transition period 42
9 EXECUTION CLASS 43
9.1 General 43
9.2 Application to buildings 43
9.3 Wider application 43
10 FACTORY PRODUCTION CONTROL 44
10.1 Introduction 44
10.2 FPC systems 44
10.3 System requirements 45
11 ROUTES TO CERTIFICATION 48
11.1 Introduction 48
11.2 Assessment of the WQMS 48
11.3 Assessment of the RWC 49
11.4 Surveillance audits 50
11.5 Steel Construction Certification Scheme 51
12 IMPLICATIONS FOR DESIGNERS,
SPECIFIERS AND CONSTRUCTION MANAGERS 53
12.1 Introduction 53
12.2 Designers and specifiers 53
12.3 Construction managers 54
APPENDICES
A ASSESSMENT OF THE RWC 56
B ISSUES ASSOCIATED WITH BRIDGES 57
C DOCUMENTARY EXAMPLES 60
D SG17 GUIDANCE ON FPC ASSESSMENT 64
E ABBREVIATIONS 70
REFERENCES 71
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Guide to the CE Marking of Structural Steelwork
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1 INTRODUCTION AND SCOPE
1.1 Objective
The objective of this document is to provide practical guidance on the CE Marking of structural
steelwork in accordance with the Construction Products Directive (CPD) and the UK's
Construction Products Regulations (CPR). The guidance is for steelwork contractors, their
purchasing clients and supply chain including designers, specifiers and construction managers.
1.2 Scope
The guidance in this document applies to the CE Marking of structural components that are
manufactured from carbon steel as welded or non-welded fabrications. The components
may be CE Marked individually or collectively as a kit.
This document applies to components intended for installation in construction works to be
built in the United Kingdom (UK), and applies as appropriate to the Republic of Ireland (RoI).
It is addressed principally to components used in structural steelwork for building
construction works undertaken to the BCSA's National Structural Steelwork Specification for
Building Construction (CE Marking Edition). It can also be applied, with some modification,
to components to be used in other construction applications including bridges, or to
structural components manufactured from stainless steel or steel castings.
As explained in this document, CE Marking is applicable to the manufacture of structural
steel components, that is to the operations undertaken by steelwork contractors in the
fabrication of structural steelwork rather than the erection of structural steel frames on site.
1.3 Overview
With respect to the European Construction Products Directive, CE Marking applies to
manufactured structural components placed on the market individually or as a kit of
components and intended for use in any form of construction works (except marine and
offshore). The basis of the regulatory regimes applicable in the UK and the Republic of
Ireland is explained in section 2.
Components manufactured from structural steel may be CE Marked once they demonstrate
compliance with the relevant harmonised European Standard using the appropriate system
of attestation. The European Standard relevant to structural steel components is EN 1090-
1 and this document assumes that the British Standard BS EN 1090-1 will be available by
the end of 2008 from which date CE Marking of structural steel components is possible. EN
documents are designated with I.S. EN when issued in the RoI with otherwise identical text
to BS EN versions.
BS EN 1090-1 Execution of steel structures and aluminium structures - Part 1:
Requirements for conformity assessment of structural components defines the
manufacturing controls needed to ensure that structural steel components meet the
necessary technical requirements that are defined in BS EN 1090-2 Execution of steel
structures and aluminium structures - Part 2: Technical requirements for steel structures.
The contents of these standards are explained in sections 3 and 4.
Special provisions apply if welding is used in steel component manufacture, and these are
explained in sections 5 and 6 and Appendix A.
The fabrication of structural steelwork is an assembly process that uses constituent
products (i.e. steel sections, fasteners and welding consumables). Some of these products,
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SECTION 1 : INTRODUCTION AND SCOPE
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such as curved beams, may be part-processed but not ready for incorporation into the
construction works until after further fabrication. Sections 7 and 8 explain how CE Marking
applies to these supply chain products and the requirements applicable to the fabrication
process necessary to ensure sufficient traceability.
BS EN 1090-2 introduces the concept of Execution Class that enables specifiers to select
the level of manufacturing quality management appropriate to how safety critical the
component will be in the construction works. This is explained in section 9.
As structural steel components are safety critical, CE Marking to BS EN 1090-1 requires
that the component manufacturer's factory production control (FPC) system is
independently assessed and certified by a body notified to the European Commission by
the appropriate national agency (DCLG in the UK). A manufacturer may employ any
suitable notified body (NB) from any member state to undertake initial inspection and
continuous surveillance of its FPC. Sections 10 and 11 explain this and what manufacturers
need to do. Further guidance issued by the European Group of Notified Bodies is included
in Appendix D.
Section 12 explains that, whilst CE Marking of structural steel components is relevant
primarily to manufacturers, it also has implications for designers - whether as specifiers of
the construction works requirements or as drafters of the manufacturing specification.
The general guidance in this document applies to structural steelwork used in building
construction. It can also be applied, with some modification, to components to be used in
other construction applications, and the different issues applicable to bridgework are
explained in Appendix B.
Appendix C provides example of the documents that support CE Marking.
Appendix E lists the abbreviations used in this document.
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Guide to the CE Marking of Structural Steelwork
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2 CE MARKING REGULATIONS
2.1 Construction Products Directive
The Construction Products Directive (CPD) came into force in 1988 and introduced the concept
of CE Marking for all construction products permanently incorporated into 'construction works'.
This includes steel products such as steel sections, bolts, welding consumables and fabricated
steel components that are used in buildings, bridges, highways or other civil engineering
projects. The CPD is a piece of European legislation that is considered as one of the 'New
Approach' Directives, though the CPD differs in certain significant ways from the typical New
Approach Directive. Like all New Approach Directives the CPD was created to remove barriers
to trade by providing a common set of 'tools' across Europe to address the different rules on
construction products in the various member states; specifically the CPD establishes the
following framework:
A system of harmonised standards (sometimes referred to as hENs);
An agreed system for demonstrating the suitability of products;
A framework of certification bodies (known as Notified Bodies); and
The ability to CE Mark products.
This is explained in summary in the document CE marking under the Construction Products
Directive, published by the Department for Communities and Local Government (DCLG) and
currently available from the DCLG website.
A more detailed guide is: The Construction Products Directive - A practical guide to
implementation and CE marking, authored by Adam Pinney and Stephen Rein, two UK experts
who have acted as consultants to CEN and the European Commission in this area. Further
information can be found on http://www.apsrconsultantsltd.com.
As the CPD relates to public safety, enforcement is by means of a criminal prosecution against
the company and its relevant employee. Some enforcement proceedings have been
undertaken by UK regulators over the period since 1988.
2.2 Harmonised standards
The CPD lists six 'essential requirements' that apply to all civil engineering works, these are
listed below:
1. Mechanical resistance and stability.
2. Safety in case of fire.
3. Hygiene, health and the environment.
4. Safety in use.
5. Protection against noise.
6. Energy economy and heat retention.
These essential requirements derive from a comparison of what public safety provisions are
included in the building and construction regulations of the EU's member states. In essence,
meeting the provisions should ensure that the products meet the regulatory requirements of all
EU member states, including, for instance, the provisions on materials and workmanship in
Regulation 7 of the Building Regulations applicable to England and Wales.
For steel products and ancillaries only mechanical resistance and stability and safety in case of
fire apply. The harmonised product standards break down these general requirements into
specific measurable properties termed essential 'performance characteristics' (e.g. yield
strength, toughness and load bearing capacity) and establishes the values to be met.
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SECTION 2 : CE MARKING REGULATIONS
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The harmonised product standards establish common test methods and reporting styles for
declaring the essential characteristics of a product in the information accompanying CE Marking
- for example the required yield strength of nominal S275 steels reducing with thickness. They
also define the test methods and the testing frequency if sampling is to be adopted.
For steel products the main harmonised product standards are:
Steel sections and plates - BS EN 10025-1;
Hollow sections - BS EN 10210-1 and BS EN 10219-1;
Preloadable bolts - BS EN 14399-1;
Non-preloadable bolts - BS EN 15048-1;
Fabricated structural steelwork - BS EN 1090-1.
Providing the attestation of conformity procedures have been complied with, then CE Marking
is possible after the harmonised standards are cited in the Official Journal (OJ) and the date of
applicability given on the NANDO website has passed.
(See http://ec.europe.eu/enterprise/newapproach/nando/index.cfm?fuseaction=cpd.hs).
The Commission and much of Europe consider CE Marking is compulsory once the date of the
end of the coexistence with national technical specifications has passed: the date is also given
on the NANDO website.
For EN 10025-1 the date of applicability was 1st September 2005 and the date for the end
of the coexistence period was 1st September 2006 giving a year's transition period for
manufacturers to implement CE Marking against the standard. For EN 1090-1 it is expected
that the standard will be published by CEN around December 2008. The date of applicability
will then be published on the NANDO website. This is likely to be around August 2009. It has
been agreed that there will be a two year coexistence period which would then end around
August 2011. By then the amended Construction Products Regulations are likely to be in
force and, as explained below, these are likely to make CE Marking mandatory throughout
the European Union.
2.3 Certification
The CPD gives four different systems (with two additional sub-systems) for attesting that a
product conforms to the performance characteristics given in the harmonised standard (this is
called attestation of conformity). The system which applies to a product is published as a
Commission Decision in the OJ and is also given in a mandate from the European Commission
to CEN and is chosen on the basis of the nature of the product, its intended end use and the
role it plays in the structure. In the case of structural steelwork this is covered in mandate M/120
for structural metallic products and ancillaries that also covers rolled steel products, fasteners
and welding consumables.
Safety critical products like structural steel components and fabricated structural steelwork
are at attestation of conformity system 2+. This means that the manufacturer is not allowed
to fix the CE Marking without having a suitable factory production control (FPC) system in
place. This is verified by a notified inspection body (NB) after initial inspection and subject to
continuing surveillance who issues a certificate confirming that the manufacturer's FPC is
adequate to give confidence that the manufacturer's processes can produce products that
comply with the relevant harmonised standard.
For a body to be a NB for the purposes of BS EN 1090-1 it must be notified as an FPC
inspection body by a member state to the Commission and to other member states. This
notification confirms the NB as competent to assess the manufacturer's FPC as capable of
ensuring conformity of products to BS EN 1090-1 and that the NB meets the criteria set out
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Guide to the CE Marking of Structural Steelwork
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in Annex IV of the CPD. This notification is therefore specific to each harmonised standard,
and once this is done the NB can undertake the tasks for which it has been notified. The Steel
Construction Certification Scheme is seeking notification and will act as a notified body for
the harmonised standard for structural steel components to BS EN 1090-1. Even before BSI
publishes BS EN 1090-1, as soon as CEN publishes EN 1090-1 it will be available for
certification bodies and steelwork contractors to use to implement and assess FPC systems.
NBs can apply for notification concurrently with the final stages of the EN, which can be made
as soon as the EN passes its formal vote and is ratified. The CE Marking of products cannot
commence, however, until the date of applicability given on the NANDO website.
2.4 CE Marking
The CE Marking signifies that the products are in conformity with the relevant harmonised
technical specification (e.g. harmonised standard) and that the relevant conformity assessment
procedures have been complied with: hence the product has the declared performance for the
essential characteristics in the information accompanying the CE Marking.
CE Marking under the CPD shows purchasing clients, the authorities and others that the
product complies with the appropriate harmonised European Standard. In the case of steel
products (such as sections, bolts and fabricated steelwork) the CE Marking is a declaration by
the manufacturer that the product is in conformity with the relevant harmonised standard(s) and
meets any threshold values required by the harmonised standard and has the values declared
in the information accompanying the CE Marking.
CE Marking and its accompanying information is a legal declaration by the manufacturer on
matters concerning health and safety about how the product performs in an intended use and
its impact is less about changing what the manufacturer has to do, and more about placing
greater onus on the manufacturer to get it right. To that end the manufacturer needs to satisfy
a notified body about the adequacy of its FPC system to avoid producing non-conforming
product.
2.5 Construction Products Regulations
The CPD is implemented in the UK by the Construction Products Regulations (CPR) and
manufacturers obey the CPR rather than the CPD directly. The CPR came into force in 1991
and describes two ways of complying with the legal provisions - by CE Marking products and
by not CE Marking products. Under the regulations CE Marked components are presumed
to comply with the harmonised technical specification and have the characteristics declared
when meeting building requirements/regulations, whilst other declarations about the product
do not carry this explicit presumption and the manufacturer may need to demonstrate to the
building control authorities etc that it does comply with the building regulations/requirements.
Under the non-CE Marking route, if asked, the manufacturer must supply to the authority all
the information it has on the product to enable the authority to satisfy itself whether the
product complies with the building regulations/requirements and hence can be placed on the
market for use in the works. CE Marking is therefore not mandatory in the UK but by opting
for the CE Marking route the legal position is much clearer and BCSA is recommending that
all of its members CE Mark the steel frames and components they fabricate.
The authorities responsible for enforcing the CPR are Trading Standards Officers in England,
Wales and Scotland, Environmental Officers in Northern Ireland and authorised officers in the
Republic of Ireland. The penalties for not complying with the CPR can be a 5,000 fine, 3
months in prison or both.
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2.6 Future developments
The European Commission is proposing to replace the CPD by a new Regulation with the
aim of further improving the free trade of construction products in the European Union and
simplifying the CE Marking process.
Unlike a European Directive, a European Regulation is enforceable as law in all member
states without the need for national legislation. In many ways a European Regulation is
equivalent to an 'Act of Parliament of the European Union'. A consequence of replacing the
CPD with a European Regulation is that CE Marking will become mandatory in the UK and
the Republic of Ireland.
The proposed regulation places legal obligations on Manufacturers, Importers and
Distributors and on those companies in the supply chain who either place a product on the
market under their own trademark or modify a construction product already placed on the
market so as to change its essential characteristics. If the regulation becomes law it will have
implications for all parts of the structural steelwork supply chain including the fabrication
services provided by steel stockholders and steel benders.
The proposal also replaces the six 'essential requirements' with seven 'basic works
requirements'. These will apply to all construction works. The first six 'basic works
requirements' are identical to the six 'essential requirements' given on page 9. The seventh
reflects the European Community's drive for a more sustainable built environment. The draft
wording of this requirement is:
7. Sustainable use of Natural Resources
The construction works must be designed, built and demolished in such a way that the use of
natural resources is sustainable and ensure the following:
a) Recyclability of the construction works, their material and parts after demolition;
b) Durability of the construction works;
c) Use of environmentally compatible raw and secondary materials in the construction
works.
The European Commission is keen for the proposed regulation to pass all stages by spring
2009, i.e. sufficiently before the European elections in early 2009. This will mean that the
Regulation will come into UK and RoI laws in July 2011 with some provisions coming into
force sooner.
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3 CE MARKING STANDARD FOR STRUCTURAL STEELWORK
3.1 Basis
The basis of CE Marking is that the manufacturer declares that its products meet specified
performance characteristics that are defined as essential to the application of the products
in the field of construction. In order to do this the manufacturer needs to:
Know the requirements in terms of defined essential performance characteristics and
required values to be met. For structural steel components these requirements are
defined in clause 4 of BS EN 1090-1.
Use specified test methods that can evaluate whether products conform to the
specified requirements. For structural steel components these evaluation methods
are defined in clause 5 of BS EN 1090-1.
Implement a system for controlling regular production. For structural steel
components the system for evaluation of conformity is defined in clause 6 of BS
EN 1090-1.
Mark its products in the correct way using a suitable classification and designation
system. For structural steel components the marking system is defined in clauses 7
and 8 of BS EN 1090-1.
These four aspects of BS EN 1090-1 Execution of steel structures and aluminium structures
- Part 1: Requirements for conformity assessment of structural components are explained
in detail below.
BS EN 1090-1 is one of a suite of harmonised European Standards dealing with structural
metallic products and ancillaries. All harmonised standards include an Annex ZA and the
implications of this are explained in detail below.
3.2 Scope
BS EN 1090-1 deals with the manufacture of load bearing components and kits of
components for use in structures. The components can be made of steel that is hot rolled, cold
formed or produced with other technologies. They may be produced of sections/profiles with
various shapes, flat products (plates, sheet, strip), bars, castings, forgings made of steel or
aluminium materials, unprotected or protected against corrosion by coating or other surface
treatment, e.g. anodising of aluminium. The standard does not cover conformity assessment
of components for suspended ceilings, rails or sleepers for use in railway systems.
3.3 Definitions
Some important principles may be drawn from the definitions given in clause 3 of
BS EN 1090-1.
3.3.1 Constituent products
The scope of BS EN 1090-1 acknowledges that the fabrication of structural steelwork is an
assembly process that uses constituent products such as steel sections, fasteners and
welding consumables. Importantly, the application of BS EN 1090-1 relies on using the
harmonised product standards for these constituent products.
For instance, BS EN 10025-1 Hot-rolled products of structural steels - Part 1: General
technical delivery conditions is a harmonised standard and it requires that steel products
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produced to the standard possess defined levels of strength - e.g. as S275. These strength
values then underpin the evaluation of the load bearing capacity of a component produced
to BS EN 1090-1.
In welding standards such as BS EN 1011 Welding - Recommendations for welding of
metallic materials, constituent products are referred to as parent materials or parent metal
and weld metal.
3.3.2 Component specification
BS EN 1090-1 applies to both series and non-series production. These terms are explained
by Pinney & Rein in their practical guide. Although fabricated steel components are
generally bespoke, being one-offs or to a limited number typically of less than 10 identical
items this may be series or non-series production.
Whether a component is made in series or non-series production, specific details are
required before manufacture can be undertaken. The document giving all necessary
information and technical requirements for manufacture is termed the component
specification. For structural steelwork the suite of relevant component specifications would
comprise the fabrication drawings defined in the National Structural Steelwork Specification
for Building Construction (CE Marking Edition) (NSSS).
One principle to be observed in CE Marking is that the manufacturer should be clear and not
confusing in its declarations. The simplest way this can be achieved is to start from a definitive
component specification and then to warrant that the component has been made in
accordance with that specification. This procedure differs little from how steelwork contractors
have been used to satisfying their purchasing clients and the national building regulations.
3.3.3 Kits
A kit is defined as a construction product when it is a set of at least two separate components
that need to be put together to be installed permanently in the works. For a "kit" to come within
the scope of the CPD, the following conditions must be satisfied:
The "kit" must be placed on the market, allowing a purchaser to buy it in one transaction
from a single supplier,
The "kit" must have characteristics that allow the works in which it is incorporated to
satisfy the essential requirements, when the works are subject to regulations containing
such requirements.
It is thus possible to consider structural steel components as a kit when they are supplied as
components of a whole building project or as defined phases of the whole project. Two CE
Marking options are thus open to the steelwork contractor:
To apply CE Marking to the individual components as they are delivered from the
manufacturing works, using the component specifications issued for manufacture as
the reference;
To apply CE Marking to a defined set of components as a kit, using as a reference a
collection of component specifications linked to, say, and erection marking plan or
delivery list.
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.