CE Marking Guide

Guide on the CE Marking of Structural Steelwork

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BCSA Publication No. 46/08BCSA Publication No. 46/08

E513 CE Book Cover 20/10/08 14:17 Page 1

Guide on the CE Marking of

Structural Steelwork

E513 CE Marking Book 20/10/08 14:18 Page 1

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Apart from any fair dealing for the purposes of research or private study or criticism or review, aspermitted under the Copyright Design and Patents Act 1988, this publication may not bereproduced, stored, or transmitted, in any form or by any means, without the prior permission ofthe publishers, or in the case of reprographic reproduction only in accordance with terms of thelicences issued by the UK Copyright Licensing Agency, or in accordance with the terms of licencesissued 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 informationcontained herein are accurate to the extent that they relate to either matters of fact or acceptedpractice or matters of opinion at the time of publication, The British Constructional SteelworkAssociation Limited, the authors and the reviewers assume no responsibility for any errors in ormisinterpretations of such data and/or information or any loss or damage arising from or relatedto 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 CourtWestminsterLondonSW1A 2ESTel: +44(0)20 7839 8566Fax: +44(0)20 7976 1634E-mail: [email protected] Website: www.steelconstruction.org

BCSA Publication No. 46/08ISBN 10 1-85073-562-XISBN 13 978-1-85073-562-5British Library Cataloguing-in-Publication DataA 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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THE BRITISH CONSTRUCTIONALSTEELWORK ASSOCIATION LIMITEDThe British Constructional Steelwork Association Limited (BCSA) is the nationalorganisation for the steel construction industry: its Member companies undertakethe design, fabrication and erection of steelwork for all forms of construction inbuildings and civil engineering. Associate Members are those principal companiesinvolved in the supply to all or some Members of components, materials or products.Corporate Members are clients, professional offices, and educationalestablishments etc., which support the development of national specifications,quality, fabrication and erection techniques, overall industry efficiency and goodpractice.The principal objectives of the Association are to promote the use of structuralsteelwork; to assist specifiers and clients; to ensure that the capabilities andactivities of the industry are widely understood and to provide members withprofessional services in technical, commercial, contractual and quality assurancematters. The Association's aim is to influence the trading environment in whichmember companies have to operate in order to improve their profitability.A current list of members and a list of current publications and further membershipdetails can be obtained from:

The British Constructional Steelwork Association Ltd.4, Whitehall CourtWestminsterLondonSW1A 2ESTel: +44(0)20 7839 8566Fax: +44(0)20 7976 1634E-mail: [email protected] Website: www.steelconstruction.org


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SUMMARYThis document gives guidance on the CE Marking of structural steelwork. It applies to structuralsteel components that are manufactured as welded or non-welded fabrications. The componentsmay 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 constructionapplications including bridges.This publication has been reviewed by Stephen Rein MCIOB, MInstCES, who was a consultant toCEN for five years and is co-author of ‘The Construction Products Directive: A practical guide toimplementation and CE marking’.



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CONTENTS PAGE

1 INTRODUCTION AND SCOPE 71.1 Objective 71.2 Scope 71.3 Overview 7

2 CE MARKING REGULATIONS 92.1 Construction Products Directive 92.2 Harmonised standards 92.3 Certification 102.4 CE Marking 112.5 Construction Products Regulations 112.6 Future developments 12

3 CE MARKING STANDARD FOR STRUCTURAL STEELWORK 133.1 Basis 133.2 Scope 133.3 Definitions 133.4 Requirements 203.5 Evaluation methods 213.6 Evaluation of conformity 213.7 Marking system 26

4 EUROPEAN FABRICATION STANDARD 294.1 Status and scope 294.2 Documentation 304.3 Constituent products 304.4 Tolerances 304.5 Welding 314.6 Surface treatment 32

5 WELDING QUALITY MANAGEMENT 335.1 Welding as a 'special process' 335.2 Control of welding 335.3 Technical instructions 345.4 Competence of personnel 345.5 Implementation 34

6 RESPONSIBLE WELDING COORDINATORS 356.1 Welding coordination 356.2 Tasks for welding coordinators 35

7 TRACEABILITY 377.1 Introduction 377.2 Government Circular 377.3 Inspection documents 387.4 Requirements 387.5 Batch or type traceability 397.6 Welding 39


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8 SUPPLY CHAIN IMPLICATIONS 408.1 Introduction 408.2 Manufacturers 408.3 Importers 408.4 Distributors 408.5 Stockholders 418.6 Steel processors 418.7 Special products and processes 418.8 Transition period 42

9 EXECUTION CLASS 439.1 General 439.2 Application to buildings 439.3 Wider application 43

10 FACTORY PRODUCTION CONTROL 4410.1 Introduction 4410.2 FPC systems 4410.3 System requirements 45

11 ROUTES TO CERTIFICATION 4811.1 Introduction 4811.2 Assessment of the WQMS 4811.3 Assessment of the RWC 4911.4 Surveillance audits 5011.5 Steel Construction Certification Scheme 51

12 IMPLICATIONS FOR DESIGNERS, SPECIFIERS AND CONSTRUCTION MANAGERS 53

12.1 Introduction 5312.2 Designers and specifiers 5312.3 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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1 INTRODUCTION AND SCOPE

1.1 ObjectiveThe objective of this document is to provide practical guidance on the CE Marking of structuralsteelwork in accordance with the Construction Products Directive (CPD) and the UK'sConstruction Products Regulations (CPR). The guidance is for steelwork contractors, theirpurchasing clients and supply chain including designers, specifiers and construction managers.

1.2 ScopeThe guidance in this document applies to the CE Marking of structural components that aremanufactured from carbon steel as welded or non-welded fabrications. The componentsmay be CE Marked individually or collectively as a kit.This document applies to components intended for installation in construction works to bebuilt 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 buildingconstruction works undertaken to the BCSA's National Structural Steelwork Specification forBuilding Construction (CE Marking Edition). It can also be applied, with some modification,to components to be used in other construction applications including bridges, or tostructural components manufactured from stainless steel or steel castings.As explained in this document, CE Marking is applicable to the manufacture of structuralsteel components, that is to the operations undertaken by steelwork contractors in thefabrication of structural steelwork rather than the erection of structural steel frames on site.

1.3 OverviewWith respect to the European Construction Products Directive, CE Marking applies tomanufactured structural components placed on the market individually or as a kit ofcomponents and intended for use in any form of construction works (except marine andoffshore). The basis of the regulatory regimes applicable in the UK and the Republic ofIreland is explained in section 2.Components manufactured from structural steel may be CE Marked once they demonstratecompliance with the relevant harmonised European Standard using the appropriate systemof 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 bythe end of 2008 from which date CE Marking of structural steel components is possible. ENdocuments are designated with I.S. EN when issued in the RoI with otherwise identical textto BS EN versions.BS EN 1090-1 Execution of steel structures and aluminium structures - Part 1:Requirements for conformity assessment of structural components defines themanufacturing controls needed to ensure that structural steel components meet thenecessary technical requirements that are defined in BS EN 1090-2 Execution of steelstructures 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 areexplained in sections 5 and 6 and Appendix A.The fabrication of structural steelwork is an assembly process that uses constituentproducts (i.e. steel sections, fasteners and welding consumables). Some of these products,


SECTION 1 : INTRODUCTION AND SCOPE

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such as curved beams, may be part-processed but not ready for incorporation into theconstruction works until after further fabrication. Sections 7 and 8 explain how CE Markingapplies to these supply chain products and the requirements applicable to the fabricationprocess necessary to ensure sufficient traceability.BS EN 1090-2 introduces the concept of “Execution Class” that enables specifiers to selectthe level of manufacturing quality management appropriate to how safety critical thecomponent 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 requiresthat the component manufacturer's factory production control (FPC) system isindependently assessed and certified by a body notified to the European Commission bythe appropriate national agency (DCLG in the UK). A manufacturer may employ anysuitable notified body (NB) from any member state to undertake initial inspection andcontinuous surveillance of its FPC. Sections 10 and 11 explain this and what manufacturersneed to do. Further guidance issued by the European Group of Notified Bodies is includedin Appendix D.Section 12 explains that, whilst CE Marking of structural steel components is relevantprimarily to manufacturers, it also has implications for designers - whether as specifiers ofthe construction works requirements or as drafters of the manufacturing specification.The general guidance in this document applies to structural steelwork used in buildingconstruction. It can also be applied, with some modification, to components to be used inother construction applications, and the different issues applicable to bridgework areexplained 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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2 CE MARKING REGULATIONS

2.1 Construction Products DirectiveThe Construction Products Directive (CPD) came into force in 1988 and introduced the conceptof CE Marking for all construction products permanently incorporated into 'construction works'.This includes steel products such as steel sections, bolts, welding consumables and fabricatedsteel components that are used in buildings, bridges, highways or other civil engineeringprojects. The CPD is a piece of European legislation that is considered as one of the 'NewApproach' Directives, though the CPD differs in certain significant ways from the typical NewApproach Directive. Like all New Approach Directives the CPD was created to remove barriersto trade by providing a common set of 'tools' across Europe to address the different rules onconstruction products in the various member states; specifically the CPD establishes thefollowing 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 ProductsDirective, published by the Department for Communities and Local Government (DCLG) andcurrently available from the DCLG website.A more detailed guide is: The Construction Products Directive - A practical guide toimplementation and CE marking, authored by Adam Pinney and Stephen Rein, two UK expertswho have acted as consultants to CEN and the European Commission in this area. Furtherinformation can be found on http://www.apsrconsultantsltd.com.As the CPD relates to public safety, enforcement is by means of a criminal prosecution againstthe company and its relevant employee. Some enforcement proceedings have beenundertaken by UK regulators over the period since 1988.

2.2 Harmonised standardsThe CPD lists six 'essential requirements' that apply to all civil engineering works, these arelisted 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 areincluded 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 allEU member states, including, for instance, the provisions on materials and workmanship inRegulation 7 of the Building Regulations applicable to England and Wales.For steel products and ancillaries only mechanical resistance and stability and safety in case offire apply. The harmonised product standards break down these general requirements intospecific measurable properties termed essential 'performance characteristics' (e.g. yieldstrength, toughness and load bearing capacity) and establishes the values to be met.


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The harmonised product standards establish common test methods and reporting styles fordeclaring 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. Theyalso 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 Markingis possible after the harmonised standards are cited in the Official Journal (OJ) and the date ofapplicability 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 theend of the coexistence with national technical specifications has passed: the date is also givenon the NANDO website.For EN 10025-1 the date of applicability was 1st September 2005 and the date for the endof the coexistence period was 1st September 2006 giving a year's transition period formanufacturers to implement CE Marking against the standard. For EN 1090-1 it is expectedthat the standard will be published by CEN around December 2008. The date of applicabilitywill then be published on the NANDO website. This is likely to be around August 2009. It hasbeen agreed that there will be a two year coexistence period which would then end aroundAugust 2011. By then the amended Construction Products Regulations are likely to be inforce and, as explained below, these are likely to make CE Marking mandatory throughoutthe European Union.

2.3 CertificationThe CPD gives four different systems (with two additional sub-systems) for attesting that aproduct conforms to the performance characteristics given in the harmonised standard (this iscalled attestation of conformity). The system which applies to a product is published as aCommission Decision in the OJ and is also given in a mandate from the European Commissionto CEN and is chosen on the basis of the nature of the product, its intended end use and therole it plays in the structure. In the case of structural steelwork this is covered in mandate M/120for structural metallic products and ancillaries that also covers rolled steel products, fastenersand welding consumables.Safety critical products like structural steel components and fabricated structural steelworkare at attestation of conformity system 2+. This means that the manufacturer is not allowedto fix the CE Marking without having a suitable factory production control (FPC) system inplace. This is verified by a notified inspection body (NB) after initial inspection and subject tocontinuing surveillance who issues a certificate confirming that the manufacturer's FPC isadequate to give confidence that the manufacturer's processes can produce products thatcomply 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 FPCinspection body by a member state to the Commission and to other member states. Thisnotification confirms the NB as competent to assess the manufacturer's FPC as capable ofensuring conformity of products to BS EN 1090-1 and that the NB meets the criteria set out



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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 SteelConstruction Certification Scheme is seeking notification and will act as a notified body forthe harmonised standard for structural steel components to BS EN 1090-1. Even before BSIpublishes BS EN 1090-1, as soon as CEN publishes EN 1090-1 it will be available forcertification 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 madeas soon as the EN passes its formal vote and is ratified. The CE Marking of products cannotcommence, however, until the date of applicability given on the NANDO website.

2.4 CE MarkingThe CE Marking signifies that the products are in conformity with the relevant harmonisedtechnical specification (e.g. harmonised standard) and that the relevant conformity assessmentprocedures have been complied with: hence the product has the declared performance for theessential characteristics in the information accompanying the CE Marking. CE Marking under the CPD shows purchasing clients, the authorities and others that theproduct complies with the appropriate harmonised European Standard. In the case of steelproducts (such as sections, bolts and fabricated steelwork) the CE Marking is a declaration bythe manufacturer that the product is in conformity with the relevant harmonised standard(s) andmeets any threshold values required by the harmonised standard and has the values declaredin the information accompanying the CE Marking. CE Marking and its accompanying information is a legal declaration by the manufacturer onmatters concerning health and safety about how the product performs in an intended use andits impact is less about changing what the manufacturer has to do, and more about placinggreater onus on the manufacturer to get it right. To that end the manufacturer needs to satisfya notified body about the adequacy of its FPC system to avoid producing non-conformingproduct.

2.5 Construction Products RegulationsThe CPD is implemented in the UK by the Construction Products Regulations (CPR) andmanufacturers obey the CPR rather than the CPD directly. The CPR came into force in 1991and describes two ways of complying with the legal provisions - by CE Marking products andby not CE Marking products. Under the regulations CE Marked components are presumedto comply with the harmonised technical specification and have the characteristics declaredwhen meeting building requirements/regulations, whilst other declarations about the productdo not carry this explicit presumption and the manufacturer may need to demonstrate to thebuilding 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 allthe information it has on the product to enable the authority to satisfy itself whether theproduct complies with the building regulations/requirements and hence can be placed on themarket for use in the works. CE Marking is therefore not mandatory in the UK but by optingfor the CE Marking route the legal position is much clearer and BCSA is recommending thatall 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 theRepublic of Ireland. The penalties for not complying with the CPR can be a £5,000 fine, 3months in prison or both.


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2.6 Future developmentsThe European Commission is proposing to replace the CPD by a new Regulation with theaim of further improving the free trade of construction products in the European Union andsimplifying the CE Marking process. Unlike a European Directive, a European Regulation is enforceable as law in all memberstates without the need for national legislation. In many ways a European Regulation isequivalent to an 'Act of Parliament of the European Union'. A consequence of replacing theCPD with a European Regulation is that CE Marking will become mandatory in the UK andthe Republic of Ireland.The proposed regulation places legal obligations on Manufacturers, Importers andDistributors and on those companies in the supply chain who either place a product on themarket under their own trademark or modify a construction product already placed on themarket so as to change its essential characteristics. If the regulation becomes law it will haveimplications for all parts of the structural steelwork supply chain including the fabricationservices provided by steel stockholders and steel benders. The proposal also replaces the six 'essential requirements' with seven 'basic worksrequirements'. These will apply to all construction works. The first six 'basic worksrequirements' are identical to the six 'essential requirements' given on page 9. The seventhreflects the European Community's drive for a more sustainable built environment. The draftwording of this requirement is:7. Sustainable use of Natural ResourcesThe construction works must be designed, built and demolished in such a way that the use ofnatural 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 spring2009, i.e. sufficiently before the European elections in early 2009. This will mean that theRegulation will come into UK and RoI laws in July 2011 with some provisions coming intoforce sooner.



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3 CE MARKING STANDARD FOR STRUCTURAL STEELWORK

3.1 BasisThe basis of CE Marking is that the manufacturer declares that its products meet specifiedperformance characteristics that are defined as essential to the application of the productsin the field of construction. In order to do this the manufacturer needs to:

• Know the requirements in terms of defined essential performance characteristics andrequired values to be met. For structural steel components these requirements aredefined in clause 4 of BS EN 1090-1.

• Use specified test methods that can evaluate whether products conform to thespecified requirements. For structural steel components these evaluation methodsare defined in clause 5 of BS EN 1090-1.

• Implement a system for controlling regular production. For structural steelcomponents the system for evaluation of conformity is defined in clause 6 of BSEN 1090-1.

• Mark its products in the correct way using a suitable classification and designationsystem. For structural steel components the marking system is defined in clauses 7and 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 explainedin detail below.BS EN 1090-1 is one of a suite of harmonised European Standards dealing with structuralmetallic products and ancillaries. All harmonised standards include an Annex ZA and theimplications of this are explained in detail below.

3.2 ScopeBS EN 1090-1 deals with the manufacture of load bearing components and kits ofcomponents for use in structures. The components can be made of steel that is hot rolled, coldformed or produced with other technologies. They may be produced of sections/profiles withvarious shapes, flat products (plates, sheet, strip), bars, castings, forgings made of steel oraluminium materials, unprotected or protected against corrosion by coating or other surfacetreatment, e.g. anodising of aluminium. The standard does not cover conformity assessmentof components for suspended ceilings, rails or sleepers for use in railway systems.

3.3 DefinitionsSome important principles may be drawn from the definitions given in clause 3 of BS EN 1090-1.

3.3.1 Constituent productsThe scope of BS EN 1090-1 acknowledges that the fabrication of structural steelwork is anassembly process that uses constituent products such as steel sections, fasteners andwelding consumables. Importantly, the application of BS EN 1090-1 relies on using theharmonised product standards for these constituent products.For instance, BS EN 10025-1 Hot-rolled products of structural steels - Part 1: Generaltechnical delivery conditions is a harmonised standard and it requires that steel products


SECTION 3 : CE MARKING STANDARD FOR STRUCTURAL STEELWORK

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produced to the standard possess defined levels of strength - e.g. as S275. These strengthvalues then underpin the evaluation of the load bearing capacity of a component producedto BS EN 1090-1.In welding standards such as BS EN 1011 Welding - Recommendations for welding ofmetallic materials, constituent products are referred to as parent materials or parent metaland weld metal.

3.3.2 Component specificationBS EN 1090-1 applies to both series and non-series production. These terms are explainedby Pinney & Rein in their practical guide. Although fabricated steel components aregenerally bespoke, being one-offs or to a limited number typically of less than 10 identicalitems this may be series or non-series production.➀Whether a component is made in series or non-series production, specific details arerequired before manufacture can be undertaken. The document giving all necessaryinformation and technical requirements for manufacture is termed the componentspecification. For structural steelwork the suite of relevant component specifications wouldcomprise the fabrication drawings defined in the National Structural Steelwork Specificationfor Building Construction (CE Marking Edition) (NSSS).One principle to be observed in CE Marking is that the manufacturer should be clear and notconfusing in its declarations. The simplest way this can be achieved is to start from a definitivecomponent specification and then to warrant that the component has been made inaccordance with that specification. This procedure differs little from how steelwork contractorshave been used to satisfying their purchasing clients and the national building regulations.

3.3.3 KitsA kit is defined as a construction product when it is a set of at least two separate componentsthat need to be put together to be installed permanently in the works. For a "kit" to come withinthe 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 transactionfrom a single supplier,

• The "kit" must have characteristics that allow the works in which it is incorporated tosatisfy the essential requirements, when the works are subject to regulations containingsuch requirements.

It is thus possible to consider structural steel components as a kit when they are supplied ascomponents of a whole building project or as defined phases of the whole project. Two CEMarking options are thus open to the steelwork contractor:

• To apply CE Marking to the individual components as they are delivered from themanufacturing works, using the component specifications issued for manufacture asthe reference;

• To apply CE Marking to a defined set of components as a kit, using as a reference acollection of component specifications linked to, say, and erection marking plan ordelivery list.

➀ For example, a manufacturer making bridges or bridge components of all sizes and shapes, where no twoare ever the same, is still involved with series production. This is because the work is making bridges/bridgecomponents. If the manufacturer were asked to make a steel door and this was not part of normal productionline then that would be non-series production. If the manufacturer did not normally make purlins but thenmade several of a common type as a special order then that would also be non-series production.

➉



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Generally the steelwork contractor will also be the manufacturer and hence this distinction isnot generally an issue. However, if the steelwork contractor alters components or a kit suppliedby another manufacturer, or adds to such a kit in any way and then relies upon CE Markingas a demonstration of conformity then the steelwork contractor becomes the manufacturer ofthat kit or those components.

3.3.4 Design briefFabricated steel components are generally bespoke because they are made for specificprojects. In the NSSS the term project specification is used for the specification prepared fora specific building project. With respect to those parts of the construction works described inthe project specification as structural steelwork, the NSSS anticipates that the engineer whois responsible for the design of structural members will prepare design drawings that includeall information necessary for the design of connections and completion of the fabricationdrawings. Irrespective of whether the engineer is working directly for the employer or for thesteelwork contractor, the NSSS assumes that the steelwork contractor will undertake thedetailing of the steelwork and the design and detailing of connections.Thus, it is generally necessary for the steelwork contractor to undertake some design workin preparing the details needed for the component specification. This design work will beundertaken to what BS EN 1090-1 terms a design brief which would in essence comprisethe design drawings and the other appropriate information itemised in Tables 1.1 to 1.7 ofthe NSSS.

3.3.5 Structural characteristicsBS EN 1090-1 defines some of the essential performance characteristics as structuralcharacteristics. These are governed in part by the design approach used to evaluate themand refer to:

• Load bearing capacity;• Fatigue strength; and• Resistance to fire.

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

• Tolerances on dimensions and shape;• Weldability;• Fracture toughness;• Reaction to fire;• Emission of radioactivity; and• Release of cadmium.

The extent to which these essential characteristics may depend on the constituent productsused in manufacture can be identified by checking the essential performance characteristicsitemised in the harmonised standard for the constituent product. For instance, BS EN10025-1 includes the following essential characteristics:

• Tolerances on dimensions and shape;• Elongation;• Tensile strength;• Yield strength;



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• Impact strength;• Weldability.

The tolerances relevant to a constituent product continue to apply to componentsmanufactured from such products, unless BS EN 1090-2 (which is invoked for suchrequirements by BS EN 1090-1) specifies more stringent criteria. Elongation is not directlyspecified as an essential characteristic in BS EN 1090-1, but the evaluation of structuraldesign 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, whichsignifies both the permitted range of tensile strength and the minimum yield strength. To theextent 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 specifiesrestrictions 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 CharpyV-notch (CVN) impact tests, and BS EN 10025-1 defines weldability in terms of chemicalcomposition using the carbon equivalent value (CEV). Both these characteristics may beaffected by subsequent processes used in manufacture of steel components, especially in theheat affected zone (HAZ) of the parent metal during welding. Thus BS EN 1090-2 specifiesparticular requirements for the CEV of steel products that may be welded, as well as theminimum CVN and maximum hardness permitted in the HAZ and the weld metal.

3.3.6 Load bearing capacityThe determination of the load bearing capacity of a structural component can be a complexissue as it may involve, for instance, member design for buckling, connection design forbearing, crushing etc. as well as an understanding of the behaviour of welds andmechanical fasteners such as preloadable bolts. Prior to the advent of a harmonisedstandard for structural steel components, steelwork contractors and/or their purchasingclients have been undertaking such design evaluations on all steelwork projects. It is not theintention of the CPD to change this way of working or to place unnecessary impediments inhow such design matters have been undertaken in meeting the existing national regulationsfor building construction etc.Parties undertaking design in support of developing the component specification should notexpect to alter their ways of working. The only supplementary change is that themanufacturer undertaking (some of the) design work has the option of including a warrantyon that element of the design when declaring that the component meets the componentspecification (see the optional methods for preparing the component specification explainedbelow).The simplest way of looking at the issues associated with load bearing capacity is that thecomponent derives its capacity from that of its constituent products and the way those areassembled. Typically the shape and yield or tensile strength of, say, a steel beamdetermines its load bearing capacity - and values for safe loads are given in membercapacity tables. What the manufacturer is charged with is that the processes used infabrication do not impair the properties of the “plain” member.BS EN 1090-1 requires the manufacturer to address how structural characteristics aredependent on the manufacturing characteristics of the product. Most importantly for loadbearing capacity in quasi-static building construction, this depends on the yield strength ofthe constituent products, and, as noted above, this can be affected by subsequent



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processes used in manufacture such as welding. Hence, the manufacturer needs toobserve the provisions of BS EN 1090-2 with respect to welding and to have a suitablewelding quality management system (WQMS) in place. This enables the manufacturer to beconfident that any impairment of the yield strength of, say, parent materials in the HAZ iswithin defined limits as evidenced by the limits on hardness etc. measured during the testingin support of the Welding procedure qualification record (WPQR).Then, in effect, the manufacturer may declare the equivalent of load bearing capacity bywarranting that the component has been made in accordance with its componentspecification (i.e. fabrication drawing) on which appears the grade, shape, configuration etc.of the constituent products from which load bearing capacity can be evaluated bycalculation to, say, the Eurocodes.

3.3.7 Evaluation methodsIn most harmonised standards, essential characteristics are evaluated by physical testing toa supporting European Standard. For instance the test method specified in BS EN 10025-1for evaluating impact strength is BS EN 10045-1 Charpy impact test on metallic materials -Part 1: Test method (V-and U-notches). Physical testing is applicable to products of astandard or standardised type but is not easily applied to bespoke products. Whilst the safeload bearing capacity of a lifting beam might be established by a physical test, such non-destructive proof load testing of bespoke structural components is impractical; and it may beimpossible to establish fatigue strength or resistance to fire by other than destructive testing.Hence, BS EN 1090-1 allows measurement of geometry and/or structural calculations to beused as evaluation methods, as well as structural testing supported by calculations.

3.3.8 Preparation of the component specificationBS EN 1090-1 includes an informative Annex A that provides guidelines for preparation ofthe component specification. The annex distinguishes the following typical cases:

Manufacturer provided component specification (MPCS). This case is typical ofsteelwork contracting in general whereby the detailing and connection design areundertaken by the steelwork contractor. In this case BS EN 1090-1 allows two options:

Option 1: The manufacturer only declares the geometry and the material properties of thecomponent. The manufacturer “attaches” the component specification to thecomponent and provides a CE Marking that warrants that the as-manufacturedcomponent complies with its component specification. The manufacturer providesno warranty with respect to the design work that it has undertaken to develop theMPCS from the design brief.BS EN 1090-1 relates this option to Method 1 in Guidance Paper 'L' Application anduse of Eurocodes. If this is the option that the manufacturer always uses then thislimitation should be clear on the scope statement on the manufacturer's declarationof conformity.Option 2: In this case, the manufacturer declares not only the geometry and the materialproperties of the component but also the structural characteristics (such as loadbearing capacity) resulting from design of the component. The manufacturer needsto undertake the design. The manufacturer thus includes in the CE Marking awarranty that its design work has been undertaken according to the design brief.



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BS EN 1090-1 relates this option to Method 2 in Guidance Paper 'L' and assumesthat such a design brief would be wholly based on the relevant parts of theEurocodes. This would be particularly useful for manufacturers of standardisedproducts, such as cold-formed purlins, intended for sale throughout Europe. Then theproduct could be supplied against a component specification showing dimensionsand giving constituent material properties, together with an attached data sheetgiving, for example, Eurocode-based load bearing capacities in relation to spans andfixings. The parameterisation would need to cater for National Annex values adoptedfor the nationally determined parameters (NDPs) allowed by the Eurocodes.Alternatively, Method 3 in Guidance Paper 'L' allows CE Marking of structuralcharacteristics to a design brief that is bespoke to a client's project. Thus BS EN1090-1 defines an MPCS to Method 3b as one that includes structural characteristicsevaluated by design to a brief issued by the purchaser or one developed by themanufacturer to meet the purchasing client's order. Method 3a to BS EN 1090-1 thusallows CE Marking of components with design values evaluated at least in part to,say, an American standard provided that this is explicitly agreed in the purchasingclient's order. For instance, the component may be designed to the Eurocodes forstatic design, but to the AISC code for seismic design resistance. It should be notedthat Method 3b is not applicable to products placed on the European market wherethe purchaser is not known in advance of product delivery. In such cases it isimperative that component specification is clearly linked to the design basis used forcalculations.

Purchaser provided component specification (PPCS). In this case the manufacturerundertakes no design and simply provides a product that meets the fully definitive PPCStogether with the necessary supporting documentation. BS EN 1090-1 defines this asMethod 3a to Guidance Paper 'L', as this allows components to be supplied to a PPCSbased on the purchasing client's choice of design code that may be other than theEurocodes.However, this case is more typical of a steelwork contractor subcontracting fabrication toanother fabricator/supplier on the basis that the purchasing steelwork contractorprovides fully detailed fabrication drawings for the manufacture of the sublet work. Thepurchasing steelwork contractor will usually require the components to be supplied withappropriate CE Marking, which will mean that the subcontract fabricator/supplier musthave a suitably certified FPC.

3.3.9 Use and locationIn the case of a PPCS the use and location of a component are known in advance.However, for a MPCS there is an important distinction to be made between componentsmade for a use and location that is known in advance and those whose use and locationare unknown at the time the component is placed on the market. For design to theEurocodes under Method 2 (Option 2) above, BS EN 1090-1 describes the former case asMethod 2a and the latter case as Method 2b. Under Method 2a the relevant NDPs in theNational Annex for the location and use will be known. Under Method 2b the structuralperformance characteristics for the component will be “application neutral”. Hence a productdata sheet containing, say, load-span tables for such a component would need to becarefully drafted to avoid a potential purchaser/user making a mistake about, say, thecomponent's load bearing capacity that is “safe” in the actual location and use decided bythe purchaser/user.



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3.3.10 Reaction to fireReaction to fire refers to issues such as surface spread of flame, and uncoated steelconstituent products are classified as Class A1 with respect to reaction to fire. No furtherdocumentation is required to support this classification for an uncoated steel componentmanufactured to BS EN 1090-1.There is currently no harmonised standard covering how reaction to fire for coatings applied tosteel components shall be declared. BS EN 1090-1 anticipates that this will be dealt with byspecifying the applied coating in the component specification, and providing supportinginformation using the coating manufacturer's product data sheet as evidence of the coating'sproperties. In due course, a standard format for declaring the properties of applied coatings islikely to be prepared as the basis for CE Marking such products supplied for use in construction.

3.3.11 Dangerous substancesThe CPD requires manufacturers to declare whether their products emit radioactivity orrelease cadmium. In general, BS EN 1090-1 requires no testing for these dangeroussubstances if the steel component is manufactured from steel constituent products and isnot coated. If the steel is coated the manufacturer may have to make a separate declarationconcerning the coating as with reaction to fire.

3.3.12 No performance determinedUnless an essential characteristic is regulated in the European member state where thecomponent is to be used, a manufacturer's CE Marking may state “No performancedetermined” (NPD - not to be confused with a National Annex NDP) for that characteristic.For instance, structural steelwork undertaken to the NSSS is intended for buildingconstruction where fatigue is not a factor in design. It would then be in order to state“Fatigue strength - NPD”. The manufacturer may however wish to declare performancecharacteristics not regulated in certain member states for marketing purposes or foreconomy reasons to facilitate easier movement of products within all member states.In Annex ZA of BS EN 10025-1, for instance, some essential performance characteristicsare noted as “threshold values” (a minimum value below which the product is not fit for use).Where performance characteristics for structural steel components are declared using theproperties of constituent products which are in turn based on threshold values, then therestriction still applies that NPD cannot be stated for those characteristics as a minimum orthreshold value must always be met.Although BS EN 1090-1 allows NPD to be declared for weldability for non-weldedcomponents, it should be noted that the harmonised standards for most constituent steelproducts include weldability as a threshold value (e.g. see BS EN 10025-1). In such cases,whether the steel component is welded or not, NPD may not be declared for the componentif the declaration relies upon properties transmitted from those of its constituent products.All the examples of CE Marking given in Annex ZA of BS EN 1090-1 state that NPD is usedfor release of cadmium, and emission of radioactivity. In practice, steel products do not emitor release either dangerous substance, and hence rather than NPD it is practical to declare“No release of cadmium” and “No emission of radioactivity”.



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3.4 Requirements

3.4.1 GeneralThe basis of how the essential performance characteristics defined in BS EN 1090-1 arespecified as requirements for manufacture of a steel component is as follows:

• Steel components are manufactured from steel constituent products with essentialcharacteristics that are defined in the harmonised standards for those products.

• The manufacturer incorporating those products into a structural steel componentneeds to ensure that:• Incoming materials to be used as constituent products comply with the relevant

specification by documentary check supplemented by re-testing if necessary (seesection 8 on how this affects the supply chain);

• The use of those constituent products in manufacture meets the necessarytraceability requirements (see section 7);

• The modification of the essential characteristics of the constituent products by theprocesses of steel component manufacture, such as by welding, is controlled tomeet the requirements of BS EN 1090-2 Execution of steel structures andaluminium structures - Part 2: Technical requirements for steel structures (seesection 4 below which explains the content of BS EN 1090-2 in detail).

• Structural characteristics are established by suitable design calculations and/orphysical testing.

3.4.2 DurabilityThe CPD requires that the durability of the essential characteristics is established. It shouldbe noted that the durability required is related to the essential performance characteristicsidentified in the harmonised standard.As there is no applicable direct method for testing durability, BS EN 1090-1 introduces thefollowing principles to establish the durability of a steel component. The durability dependson the constituent products. The essential characteristics of steel constituent products areimmune from degradation over time with the major exception that atmospheric corrosioncan impair cross-sectional dimensions.Some products use structural steels with improved atmospheric corrosion resistance, forwhich the required chemical composition is specified in the relevant supporting standard.Otherwise, durability is defined in terms of the corrosion protection applied to the surface ofa steel component.The selection of a method for protecting steel components from corrosion is covered by BSEN 1090-2. This allows the indirect evaluation of durability in terms of the classifiedexposure of the component linked to specified requirements for surface protection in thecomponent specification. The NSSS offers six standard specifications for applied surfacecoatings that may be invoked in component specifications.It is arguable that in two other respects - fatigue and fracture - the properties of constituentsteel products are less than permanently durable as over the longer term steel can besusceptible to failure due to externally applied cyclic stresses or low temperatures. As boththese properties are explicitly defined as essential structural characteristics in BS EN 1090-1, the issue of durability can be addressed by declaring values that are related to the stresscycling or working temperature as relevant.



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3.5 Evaluation methodsThe evaluation methods to be used are related to the manufacturing requirements to beevaluated that are derived from the essential performance characteristics defined in BS EN1090-1. A combination of three methods is included in BS EN 1090-1 and the harmonisedstandards for constituent products:

• Physical testing - used for example to establish fracture toughness of steel materialsusing the CVN impact test.

• Measurements of geometry - used for tolerances on dimension and shape, andcovered in BS EN 1090-2.

• Structural calculations - which may be used to evaluate load bearing capacity, fatiguestrength and resistance to fire.

BS EN 1090-1 allows the use of physical testing instead of or in support of calculations. Forinstance, the supplementary rules in the Eurocodes for the design of steel cold-formedmembers 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 statisticalmethods for the evaluation of test results.It is also worth noting that BS EN 10025-1 relies wholly on physical testing andmeasurements of geometry to establish conformity and the introduction of structuralcalculations as a third evaluation method in BS EN 1090-1 is linked to the fact that it coversbespoke products and non-series production.

3.6 Evaluation of conformity

3.6.1 Initial type testingThe general principles behind the evaluation of conformity are the use of initial type testing(ITT) and factory production control (FPC). The basis of ITT is:

• A manufacturer develops a product type.• What might be termed prototype examples of the new product type are tested to

establish their properties against the essential performance characteristics.• The new product type is commissioned into production and representative samples

from new production are tested to establish that the production methods used canproduce conforming product.

Thus ITT is necessary at the commencement of production of a new product type includingproduction using new constituent products, and at the commencement of new or modifiedmethods of production.As BS EN 1090-1 applies to the manufacture of bespoke components that may be uniqueexamples 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 evaluationmethod. What this builds on is the wealth of physical testing undertaken in researchlaboratories that has been codified into the design rules that underpin the ITC. Thus even aunique example of a structural component is built up in the calculations from what might betermed sub-types - for instance the behaviour and bearing resistance of an end plate in abolted connection.ITC is built up wholly on what might be termed “historical data”, and BS EN 1090-1 allowshistorical data from both ITC and ITT to be used. This reduces the amount of type testingthat the manufacturer needs to perform. However, the application of historical data needs



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to be carefully considered when, say, test results obtained in support of a product meetingBritish Standards are extended to meet a European Standards. BS EN 1990 provides thestatistical basis for using such prior information.The steel constituent product standards, such as BS EN 10025-1, measure the essentialperformance characteristic of weldability in terms of chemical composition as a carbonequivalent value (CEV). Welding to BS EN 1090-2 builds on this concept of weldability byapplying the concepts behind ITT in the methods used to evaluate conformity of weldedcomponents, as follows:

• A manufacturer wishes to develop a welding procedure specification (WPS) anddefines parent and weld materials, welding process, joint design and preparation,welding position and technique etc. in a preliminary welding procedure specification(pWPS).

• Using the pWPS as the reference document, the manufacturer carries out a weldingprocedure test, which is then subjected to destructive and non-destructive tests(NDT) to specified standards. The results of the testing and the actual weldingparameters used are recorded in a welding procedure qualification record (WPQR).

• The WPQR is used to support application of the WPS in practice and the qualificationof 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 fromthe initial type tested is an example of the allowance in BS EN 1090-1 to extend applicationof ITT to other situations in a “family”. The range of qualification allowed in the weldingstandards defines how big the family may be, which in terms of parent materials is doneusing 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 inproduction as it specifies that the first five joints made to the same new WPS must meetquality levels comparable to those in the procedure test when subjected to NDT. Thisestablishes 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 ofcomponents within a defined Execution Class (EXC). This concept is explained furtherbelow, but it has a particular implication for production welding in that requirements for thewelding quality management system (WQMS), the methods of qualification, the extent ofFPC testing and the production quality levels required differ for EXC2, EXC3 and EXC4. ForEXC4, BS EN 1090-2 requires production welds to meet a higher quality than thatestablished by ITT in the WPQR.

3.6.2 Factory production controlFactory production control (FPC) is needed to establish that a manufacturer can produceconforming product in regular ongoing production. In essence what the manufacturer doesis to establish the key control checks during the ITT phase and then to sample test actualproduction to compare it with necessary quality levels established by ITT. FPC is thus usedto prove that products conform to the product type, given that ITT has been used to provethat the product type meets the required essential performance characteristics.As FPC is based on sampling, the minimum frequency and extent of sample testing isdefined in the harmonised standard. For products to BS EN 10025-1, this can be specific toa lot or cast (type 3.1 inspection certificate) or non-specific (type 2.2 test report). Specific



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testing is required for all steel products except those of the following qualities: S275JR,S275J0, S355JR or S355J0.As BS EN 1090-1 covers bespoke non-series production the required number of samplesis specified as only one (i.e. the component may be its own unique type) when applied tocalculations of structural characteristics, dimensional measurements, and the checking ofCEV and CVN values for the constituent steel products. More extended sampling is requiredwhen the conformity evaluation is established by physical testing rather than calculation.In practice, production to BS EN 1090-2 as a supporting standard for BS EN 1090-1 meansthat many requirements relating to production are specified. As noted above this hasparticular application to the use of NDT to establish that production continues to produceconforming welds treating further joints welded according to the same WPS as a singlecontinuing production lot. The NSSS uses the term “routine testing” for this aspect of FPC.In many ways FPC may be seen as a sub-set of the controls necessary in a qualitymanagement system based on BS EN ISO 9001, and BS EN 1090-1 allows (but does not require) an FPC conforming to BS EN ISO 9001 to be used as the basis for the required system.The detailed requirements for the FPC are explained in section 10, and it should be notedthat the system is defined in terms of written procedures, regular/routine inspection (i.e.quality control) supported by competent personnel and suitable equipment for productionand testing.

3.6.3 Attestation levelsAttestation of conformity is the term used to define the whole system needed to ensure thatonly conforming products are placed on the market. This allocates certain tasks to themanufacturer and others to an independent organisation that the manufacturer appoints tocertify defined aspects of its operations as meeting the required standard.Certification organisations themselves need to be suitably competent to undertake theirallotted tasks. Their competence is established against BS ISO/IEC 17021 Conformityassessment - Requirements for bodies providing audit and certification of managementsystems and the scope of competence of the organisation is accredited by, say, UKAS. Thisaccreditation is then used by the competent authority (DCLG in the UK) to notify theEuropean Commission and the certification organisation then becomes a notified body (NB).Depending on the attestation level which has been chosen by the European Commission,the NB may be involved as a third party in certifying:

• The FPC system, as is required for all structural steel components and explainedbelow with respect to BS EN 1090-1. This is system 2+ and it permits themanufacturer to issue a Declaration of Conformity related to its products. The role ofthe NB under system 2+ is defined as that of an inspection body rather than that of acertification body as the latter implies that product or product type certification isinvolved (as below);

• The product type by involvement in the ITT/ITC. This would be system 1+ and wouldresult in the NB issuing a Certificate of Conformity related to the manufacturer'sproduct types; or

• The products themselves. Outside of the CE Marking requirements, BS EN 10025-1allows this option for certain higher quality steels whereby the purchaser's authorisedinspection representative endorses the declaration that the products supplied are incompliance with the requirements of the order.



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The attestation level specified for all structural steel components is level 2+ which allocatesthe tasks as follows:

• Tasks under the responsibility of the manufacturer: ITT, FPC and product testing.• Tasks for the NB: Certification of the manufacturer's FPC on the basis of both initial

inspection and continuous surveillance.

3.6.4 Product testingBS 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 oneach component or a suitable sample if components are manufactured under similarconditions. The requirements for dimensions that are essential are listed as essentialtolerances in BS EN 1090-2.

• Checking the manufactured components against the component specification withrespect to the requirements for surface treatment for corrosion protection as specifiedin BS EN 1090-2.

• Checking that the inspection documents for constituent products conform to therequired values for CEV, CVN, and yield, proof or tensile strengths as specified in BSEN 10025-1 or other relevant harmonised standards for steel products.

• For design undertaken by the manufacturer, verifying that the calculations used todevelop the component specification are relevant and have been carried out inaccordance with the design brief.

• Checking that manufacturing processes that affect structural characteristics are beingundertaken to BS EN 1090-2. This is relevant to processes that may alter theessential performance characteristics of constituent products. Hence, BS EN 1090-2specifies the relevant procedure and production testing for welding, bending, andthermal cutting.

3.6.5 Laboratory testingThe possibility for third party endorsement of the product type is comparable to third partyendorsement of actual laboratory test results as opposed to endorsement that the systemfor control of laboratory testing has been checked within the scope of the FPCendorsement. In terms of BS EN 10025-1 laboratories undertake material tests to establishCEV, CVN etc., and the system for control of laboratory testing requires;

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

• Accreditation of the laboratory under BS EN ISO/IEC 17025 General requirements forthe competence of testing and calibration laboratories (or equivalent) with theaccreditation being specific for the tests carried out; or

• Direct assessment of an external laboratory by the NB.In terms of BS EN 1090-1 there are similar requirements that treat laboratory testing as partof the manufacturer's FPC. For EXC2 and above this applies to tests associated withwelding, and the NSSS thus requires a competent examiner or examining body to verify theWPQRs, to witness welder qualification tests (WQTs) and to endorse the WQT certificates.These responsibilities are distinct from those of a possible project-specific third partyinspection authority that may be appointed.



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3.6.6 Design controlAs noted above, control of design is seen as part of FPC to the extent that the manufacturerchooses to warrant the design work it undertakes to develop the component specificationfrom the design brief. The NB is not required to verify the content of the design or that thecomponent specification complies with the design brief as this would be equivalent toproduct type certification to attestation system 1.The NB is required to certify during initial inspection and continuous surveillance thatsuitable design control procedures are in place (e.g. for revising drawings), and that designwork is being undertaken using suitable equipment and other resources (e.g. suitablecomputer programs and latest copies of design codes). During initial inspection the NB isalso asked to certify that that design work is being undertaken by suitably competentpersonnel with defined job descriptions.

3.6.7 Certification of the FPCBS EN 1090-1 defines those minimum aspects of the FPC that must be assessed by theNB. During initial inspection these relate to checking whether the resources (premises,personnel and equipment) are adequate for the manufacture of steel components to BS EN1090-2. This also comprises:

• Checking that the FPC has procedures for checking conformity and handlingprocedural non-conformities and non-conforming product.

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

During continuous surveillance the NB:• Checks that the manufacturer is undertaking the specified product testing described

above that is associated with execution work.• Checks that the FPC procedures for checking conformity and handling procedural

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

3.6.8 Welding certificationSpecifically for those manufacturers who use welding and following the initial inspection, theNB is required to identify the scope of certification of the FPC in terms of the weldingprocesses and parent materials covered. The manufacturer can establish the basis for thisscope by using its portfolio of WPSs, WPQRs and WQTs as those documents underpin theoperation of the FPC for welding. In this regard it is required that for each main weldingprocess the manufacturer shall have available welder(s) with suitably qualified weldingprocedures.As the NB also needs to confirm on the certificate which Execution Class is relevant to themanufacturer's FPC for welding, the NB needs to assess the welding quality managementsystem (WQMS), the methods of qualification, the extent of FPC testing and the productionquality levels and to relate these to the Execution Class using the requirements specified inBS 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 weldingmay 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 thatthe WQMS is certificated according to the appropriate level of BS EN ISO 3834. If the



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manufacturer already has its WQMS certified to BS EN ISO 3834, then this may be relied uponas relevant when the NB issues the general certificate for the FPC.During continuous surveillance, the NB is not specifically required to re-certificate the FPC forwelding, but in practice re-certification of the FPC will include a review of the WQMS for amanufacturer of welded components. The NB also has the authority to undertake a surveillanceaudit if circumstances change. In this respect, the manufacturer is required to inform the NB ofchanges that could affect the validity of the certificate, such as:

• New or changed essential facilities;• Change of Responsible Welding Coordinator;• New welding processes;• New essential equipment.

3.7 Marking system

3.7.1 GeneralThe basis of the marking system is that the component shall be identifiable against the relevantessential performance characteristics that are to be warranted by the manufacturer ascomplying with the requirements of BS EN 1090-1. This requires that the component is linkeduniquely to its component specification, and if this is in the form of a fabrication drawing theinformation 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 themarking 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 asa complete structural frame for, say, a building. In such cases the components may be seen asa kit, and the marking can be done on a collective basis for them all. Typically this might bedone using the erection marking plan as a central reference point to define the kit, and then toattach the necessary CE Marking information to the whole kit via the marking plan. This methodhas an obvious extension for steelwork contractors undertaking design-and-build projects andwho wish to warrant the design as well as the manufacture of all the components by referenceto the design calculation sheets.

3.7.2 Classification and designationBS EN 1090-1 requires that the Execution Class relevant to its manufacture is given on thecomponent specification.The requirements for dimensions that are essential performance characteristics are listed asessential tolerances in BS EN 1090-2. For some essential tolerances, such as those forcylindrical and conical shells, more than one class is specified. In which case, the componentspecification needs to identify the class that is relevant to the component.

3.7.3 CE MarkingBS EN 1090-1 includes an informative Annex ZA related to the application of the CPD tostructural steel components. It is informative as it pertains to application of national regulationswhich cannot be made mandatory by a European Standard. Instead the framework is given inthe informative annex which is then mandated in practice by the appropriate regulations in eachEuropean member state.



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The annex links together the following elements of the required CE Marking system:• The FPC certificate issued by the NB (as described above).• The declaration of conformity made by the manufacturer. This is a document that the

manufacturer prepares and maintains which then entitles the manufacturer to affix theCE Marking. It must be signed by an appropriate employee of the manufacturingcompany, and is the basis for criminal proceedings if the regulators believe that the CEMarking has been wrongly applied by the manufacturer. Appendix C illustrates anexample of a declaration of conformity.

• The CE Marking of the component. This includes the CE Mark itself (literally the lettersC and E in a particular type style and size) as well as other information as illustrated inAppendix C.

BS EN 1090-1 allows the CE Marking to be done on one of four templates linked to thepreparation of the component specification via the methods defined in Guidance Paper 'L' asfollows:

• By reference to component geometrical data and the material properties of constituentproducts with NPD for structural characteristics determined by design (Method 1 usingMPCS Option 1);

• As above but including values for structural characteristics determined by design to therelevant Eurocodes (Method 2 using MPCS Option 2);

• As above but including values for structural characteristics determined by design to thepurchaser's design requirements (Method 3b using MPCS Option 2); or

• By reference to component geometrical data and the material properties of constituentproducts with a cross-reference to the purchaser's design but no specific values forstructural characteristics determined by design (Method 3a using PPCS).

As noted previously, at the present time CE Marking under the CPD is not mandatory under thenational regulations implemented in the UK and the RoI. Most often CE Marking of structuralsteel components to BS EN 1090-1 applies to production intended for a bespoke project-specific application that is known in advance of manufacture. In such cases, even if CE Markingwere mandatory or adopted voluntarily, it would be reasonable to apply BS EN 1090-1 to thefinal completed component that is directly ready for site assembly and/or erection. Whether thesteelwork contractor as manufacturer of the completed component requires CE Marking to beused by its supply chain (see section 8) then depends on how the manufacturer wishes toexercise FPC. Clearly the steelwork contractor will require most constituent products to be CEMarked, but might control the operations of some sublet suppliers undertaking steel processingwithin the purchasing steelwork contractor's own FPC system. This has particular relevance forthe WQMS and the control of welding by sublet suppliers.

3.7.4 Affixing the CE MarkingThe CE Marking may be located in one of the following places:

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

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

➁ In this context “accompanying” means “unambiguously linked to”, it does not mean that the commercialliterature has to physically be attached to the product.



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fabrication drawings that comprise the component specification. The component itself thenonly needs an identity mark (such as the piece marks in use currently) that links itunambiguously to the relevant drawing, perhaps via a delivery list or marking plan ascurrently.For series items, such as proprietary purlins, it is more likely to be placed on the productlabel. For steel products it is generally on the inspection document, and for fasteners andwelding consumable it is generally on the packaging.

3.7.5 PackagingIn principle the importance of packaging for a product with CE Marking is that themanufacturer produces conforming product “ex-works” and the obligation on themanufacturer is to use packing that is sufficient to preserve the essential performancecharacteristics for a reasonable time reflecting the period until the purchaser is ready toinstall the product in the construction works.For structural steel components, the context is somewhat different, as the components arenearly always “made to order”, and the essential performance characteristics are largelyunaffected by exposure during the period between leaving the manufacturer's works andbeing installed on site. Furthermore, in “bespoke” cases a steelwork contractor would beliable to rectify any damage that the component received before it was finally handed overas part of the construction works.For these reasons, BS EN 1090-1 is largely silent about packaging requirements, and BSEN 1090-2 includes the requirements for rectification of any damage sustained in deliveryor erection.



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4 EUROPEAN FABRICATION STANDARD

4.1 Status and scopeBS EN 1090-2 Execution of steel structures and aluminium structures - Part 2: Technicalrequirements for steel structures is not a harmonised standard but it supports theapplication of BS EN 1090-1 by providing the technical requirements relevant tomanufacture of steel components. This is analogous to BS EN 10045-1 being a supportingstandard giving the test methods for CVN in support of the harmonised standards for steelproducts BS EN 10025-1 etc. As well as building on these test methods used to establishthe characteristics of constituent products, BS EN 1090-2 includes its own test methods forsuch items as measuring geometrical dimensions of components. It also makes referenceto other test methods in further supporting standards such as those specifying requirementsfor welding.The scope of BS EN 1090-2 is wider than simply the technical requirements for manufacture(e.g. by fabrication including welding), as it also covers all execution requirements for steelstructures including erection. Erection and other operations (such as bolting) that take placeon a project site where the construction works are being built are not relevant to the CEMarking process which merely assumes that the works will be otherwise properly designedand built.➂In addition, the scope of BS EN 1090-2 is much wider than the individual British Standardsthat it will replace as it includes requirements for all types of steel structure: buildings,bridges, towers, masts, chimneys, shells, sheeting in carbon manganese steels up to S690and stainless steels up to S700. It applies to structures subjected to fatigue or seismicactions.Despite this extremely wide scope, the requirements related to steel structures used inbuilding construction are very close to those in previous British Standards and those in theNational Structural Steelwork Specification for Building Construction (NSSS). To assiststeelwork contractors and specifiers, BCSA is preparing a CE Marking Edition of the NSSSthat includes only those provisions relevant to the majority of steel-framed buildings.Undertaking projects to the NSSS should ensure that the steelwork complies with theprovisions relevant to all types of building construction designed for static loading in EXC2according to BS EN 1090-2.With respect to CE Marking the relevant clauses of BS EN 1090-2 are as follows:

• Documentation (clause 4 and Annex A);• Constituent steel products (clauses 5, 12.1 and 12.2);• Geometrical tolerances (clauses 11 and 12.3 and Annex D);• Welding and other fabrication operations (clauses 7, 6 and 12.4);• Surface treatment for corrosion protection and durability (clauses 10 and 12.6 and

Annex F).With respect to their application as requirements for BS EN 1090-1 these clauses form threegroups as follows:

➂ Potentially there could be situations (such as on a major stadium, power station or bridge project) where asubstantial amount of “manufacture” takes place on the construction site. Arguably this is outside the scope ofthe CPD as the fabrication (assembly and welding) work is not undertaken in a works/factory covered by themanufacturer's FPC certification. It would, however, generally be the case that the WQMS and the RWC'sscope of responsibility would include such site-based operations anyhow. In special circumstances where thesite facility existed for a long enough time, it would be possible for those facilities to be certified by the NB,and hence for CE Marking to be applied to the “components” produced from those facilities.


SECTION 4 : EUROPEAN FABRICATION STANDARD

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• Those associated with inspection, testing and corrections (in clause 12 of BS EN1090-2) that support quality control of product conformity;

• Those associated with documentary controls (in clause 4 and 5) that support qualityassurance of product conformity; and

• The rest which underpin the procedural controls of processes of fabrication.It is assumed that clauses 8 and 12.5 on mechanical fastening, clauses 9 and 12.7 onerection and Annexes E, G, H, J, K and M generally have little or no relevance to the CEMarking of structural steel components.

4.2 DocumentationBS EN 1090-2 uses the term execution specification for the set of documents coveringtechnical data and requirements for a particular steel structure. This equates to the projectspecification referenced in the NSSS, and both include the portfolio of componentspecifications 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 aparticular project and hence for specific components. Annex A.3 lists several that are linkedto the choice of Execution Class. The application of the concept of Execution Class isexplained in section 9 below which notes how the NSSS requires who is responsible for thestructural design to review A.3 for its implications.In terms of documentation and as part of FPC, the manufacturer should review theextensive list of supporting standards given in clause 3 of BS EN 1090-2 to ensure that itslibrary contains up-to-date versions of those relevant to its scope of operations.

4.3 Constituent productsSection 3 above explains the concept of constituent products. The manufacturer needs toknow that it is using the right products and to ensure that its manufacturer's processes donot impair those properties that underpin the declared essential characteristics of thefinished component. Many of the requirements in BS EN 1090-2 for traceability and weldingrelate to these needs.

4.4 TolerancesThose geometrical tolerances that are essential to the evaluation of the strength of acomponent (e.g. straightness required to avoid premature strut buckling) are defined in BSEN 1090-2 as essential requirements. It is those and only those tolerances that themanufacturer warrants when CE Marking under the CPD. As noted in section 3 above, it isnecessary to choose which class applies for some essential tolerances and to include thisin the component specification.It should be noted that BS EN 1090-2 also gives requirements in two tolerance classes forwhat are termed functional tolerances. The functional tolerances are outside the applicationof the CPD to structural steel components, but they are relevant to the contractualobligations that the manufacturer has to its purchasing client. Thus the manufacturer maychoose to link the component to the relevant functional tolerance class by showing thisinformation on the fabrication drawings. To simplify this process, a statement on the markingplan that the component is manufactured in accordance with the NSSS makes the link tofunctional tolerance class 1.



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4.5 WeldingBS EN 1090-2 covers fabrication requirements in clauses dealing with preparation ofconstituent products, assembly and welding. The implications of BS EN 1090-2 for CEMarking of welded structural components are widely discussed throughout this documentas welding is a special process and has the most relevance to the potential impairment ofthe properties of the constituent products. Similar procedural restrictions apply to otherprocesses used in manufacture that have such a risk if not properly controlled (e.g. hot orcold bending, or thermal cutting used in fabrication).In terms of welding, it should be noted that the NSSS applies the requirements of BS EN1090-2 to building structures to EXC2. These requirements are broadly similar to therequirements in the previous editions of the NSSS except that the conceptual principle isnow made clear that welding of a given type (as defined by a given WPS) may beconsidered 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, thisis too coarse a differentiation with respect to the control of weld quality in fatigue. BS EN1090-2 uses the quality levels in BS EN ISO 5817 in four steps as listed below:

• EXC1: Quality level D.• EXC2: Quality level C generally;• EXC3: Quality level B (i.e. as required for WQTs and WPQRs);• EXC4: Quality level B+.

Whilst the levels above may be partly suitable for use in the manufacturer's WQMS toestablish, prequalify and certificate the general quality level of the manufacturer's weldingoperations, they are incomplete as follows:

• Using informative Annex B of BS EN 1090-2, “low consequences risk” structures inCC1 (see section 9 for explanation) that are designed for fatigue are in EXC2 andhence the suggested quality level is C generally. This quality level is unsafe for anybut the most modest levels of fatigue, and reduced consequences do notcompensate for inappropriate specification.

• The EXC4 level is impractical as it requires the manufacturer to demonstrate thegeneral capability of meeting quality level B+ which is more stringent than thatrequired for WQTs and WPQRs. The only way of assuring a quality level above theprequalification standards is to undertake 100% testing on the (minority of) weldswhich the designer specifies as demanding such a high standard and individuallyassess them for acceptance.

• The conclusion from the above is that the specifier needs to identify the fatiguedemand placed on individual welds subjected to dynamic loads and to decide theacceptance criteria that are relevant on a fitness-for-purpose basis using fracturemechanics based on the function of the component and the characteristics of theimperfections (type, size, location). Whilst this procedure is allowed by BS EN 1090-2 after non-conformities are identified, it is more sensible to start with a properlyclassified set of values. This is available in ISO 10721-2 which specifies a suite ofacceptance criteria appropriate to a series of fatigue classes. These acceptancecriteria 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 thecoarse SC2 categorisation.


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4.6 Surface treatmentAs explained in section 3 above, for structural steel components there is no applicable directmethod 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 steelto 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 orweather-resistant steel (e.g. with improved atmospheric corrosion resistance), or to protectits surface from atmospheric corrosion by paint, galvanizing or sprayed metal. In terms ofdeclared characteristics, it is simple enough in principle to specify the required surfacecoating and the surface preparation necessary in the component specification and for themanufacturer to warrant that the component conforms to its component specification. Thisis the basis that BS EN 1090-2 provides, allowing the manufacturer to check themanufactured components against the component specification according to the specifiedtesting requirements for surface preparation and treatment.It is less simple to warrant that the component is durable for a specified time as this involves asimultaneous specification of a corrosivity category for the expected environment in the intendedcomponent 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 awarranty on the durability of the surface coating material. Even though there are standardtests that can be used to establish the long term performance of, say, paints, none of theseyet form the test standards supporting harmonised product standards for paints. In thiscircumstance, BS EN 1090-2 allows purchasing clients and steelwork contractors to agreethe execution specification durability in more prescriptive terms and for this to be used todevelop the component specification. Thus, whilst the standard coating specifications givenin the NSSS are scientifically related to particular environmental classifications, there is nowarranty on the coatings.



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5 WELDING QUALITY MANAGEMENT

5.1 Welding as a 'special process'For many years welding has been classed as a 'special process' as defined in BS EN ISO9000 and it is widely recognised that welding normally requires continuous control and/orthat specified procedures are followed since the end result may not be capable of beingverified by testing. In light of this, a fundamental requirement of CE Marking is that themanufacturer using welding needs to implement an appropriate welding qualitymanagement system (WQMS).The CE Marking fabrication standard, BS EN 1090-2, states that all welding shall beundertaken in accordance with the quality requirements of the relevant part of BS EN ISO3834 which identifies the controls and procedures required. Determination of the relevantpart of BS EN ISO 3834, and the stringency of requirements, is ultimately dependent on theExecution Class declared by the manufacturer for its product. With respect to the WQMS,BS EN 1090-2 invokes BS EN ISO 3834 Quality requirements for fusion welding of metallicmaterials as follows:

• EXC3 and 4: Comprehensive quality requirements to BS EN ISO 3834-2.• EXC2: Standard quality requirements to BS EN ISO 3834-3. (The quality level

required by the NSSS is BS EN ISO 3834-3 appropriate to EXC2.)• EXC1: Elementary quality requirements to BS EN ISO 3834-4.

BS EN ISO 3834 is not a quality system standard to replace BS EN ISO 9001. It can beused independently but it is often best used to complement BS EN ISO 9001 requirements.It is also important to note that, whilst some steelwork contractors may choose to have theirWQMS certified by a certification body independently of the notified body, the standards forCE Marking do not require this. Compliance with the requirements of BS EN ISO 3834 canbe verified by the notified body during assessment of a steelwork contractor’s FPC system.Routes to certification of the FPC system are described in section 11.The basic principles of a welding quality management system to BS EN ISO 3834 arefocused around the requirements of the principal welding-related activities, in particular:

• Control of welding as a special process;• Technical instructions for production; and• Demonstration of personnel competence.

5.2 Control of weldingA manufacturer may have several people involved with the control of welding, but themanufacturer needs to identify a Responsible Welding Coordinator (RWC) with overallresponsibility for all welding activities.Whilst specific requirements for the RWC are detailed in section 6 the appointed personwould develop and implement documented procedures to control such aspects as:

• Identification, qualification and production of welding procedures and welderqualifications;

• Availability, suitability and maintenance of equipment;• Identification of product requirements (contractual and technical);• Production planning;• Storage and handling of parent metals and welding consumables;


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• Operation and performance of inspection activities;• Identification and traceability of the product and work in progress; and• Correction of non-conforming product.

5.3 Technical instructionsBS EN ISO 3834 requires the steelwork contractor to have written technical instructions,procedures and specifications that demonstrate and ensure that the welding control systemis effective. The standard identifies the typical documents necessary to demonstrate controlof all welding related activities. These include instructions and procedures for the following:

• Reviewing contract/technical requirements;• Subcontracting;• Qualification of procedures and personnel for welding and inspection;• Storage and handling of consumables;• Equipment maintenance/calibration;• Production/inspection plans;• Repair procedures;• Traceability records; and• Documentation control.

5.4 Competence of personnelPersonnel 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 qualificationof 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 beundertaken by more than one person. However the RWC must have overall control of andbe competent to make decisions and sign documents which affect product quality, whereasother personnel might only be qualified to undertake specialised welding coordination taskssuch as control/issue of welding consumables, verification of materials etc.In allocating welding tasks and responsibilities the steelwork contractor must identify criteriafor competence in terms of qualification, experience and training for each position. Themanufacturer must also ensure that the competence of all welding coordinators, especiallythe RWC, is adequate for their allocated tasks.

5.5 ImplementationApplication of the appropriate WQMS is left to the discretion of the manufacturer, who canmake 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 basedupon 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 therequirements of BS EN ISO 3834-3 Standard quality requirements. However, this willrequire careful consideration so as to ensure the manufacturer is not precluded from tenderinvitations requiring a higher Execution Class and subsequently more stringent qualityrequirements.



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6 RESPONSIBLE WELDING COORDINATORS

6.1 Welding coordinationThe coordination of welding activities is vital if a manufacturer wants to demonstrate controlof 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, weldingcoordination 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 iscompetent to supervise the manufacturer's welding operations as demonstrated by theRWC'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 tothe scope of certification of the manufacturer's FPC in terms its Execution Class, thewelding processes and the parent materials covered. As noted above, this can beestablished using the manufacturer's portfolio of WPSs, WPQRs and WQTs as the RWCmust be competent to coordinate the development of those documents.

6.2 Tasks for welding coordinatorsAll manufacturers should nominate at least one Responsible Welding Coordinator (RWC)with overall responsibility for establishing and monitoring welding activities and for takingaction when welding has not been carried out correctly.When nominating RWCs, the manufacturer should identify clearly the tasks andresponsibilities that will be allocated to them and ensure that they are suitably qualified andexperienced to do the job and competent to make decisions and sign documents whichaffect product quality.BS EN ISO 14731 Welding coordination - Tasks and responsibilities gives guidance on theessential welding related tasks that need to be considered. These might include, but are notlimited to:

• Review of contractual/technical welding requirements;• Ensuring welding personnel are appropriately qualified;• Suitability of welding and associated equipment;• Development/qualification of welding procedures;• Writing welding procedure specifications (WPSs);• Production planning;• Storage and handling parent materials;• Control of welding consumables; and• Inspection and testing before, during and after welding.

Welding coordinators thus need the ability to detect and assess defects, to instruct repairsand 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 thetechnical knowledge requirements for welding coordination personnel based on the threecategories given in BS EN ISO 14731:

• B - Basic• S - Specific


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• C - ComprehensiveThe required category is determined by the manufacturer's declared Execution Class, thetype/grades of steel used (given in terms of steel groups and reference standards) andlimiting thicknesses. RWCs may demonstrate that they have sufficient technical knowledgeby presenting evidence that they meet the recommendations prepared by the InternationalInstitute of Welding (IIW). However, these recommendations are generic and thus cover amuch wider scope that is well in excess of that required for many steelwork manufacturers.Hence, BCSA, the Steel Construction Certification Scheme (SCCS) and the WeldingInstitute (TWI) have developed more focussed methods for assessing the technicalknowledge and experience of welding coordinators (see section 11 and Appendix A).



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7 TRACEABILITY

7.1 IntroductionIt is essential to have a suitable traceability system in place to enable checks to be madethat the correct steel component has been delivered and/or erected and that it is made fromthe correct steel sections and fittings. Guidance on the traceability systems required for CEMarking 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 knowwhat they say and why the guidance given in this document is based on the traceabilityrequirements given in BS EN 1090-2.

7.2 Government CircularThe following requirements appear in the UK's Construction Product Regulation (SI 1991No 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 characteristicsthat the works in which it is to be incorporated, assembled, applied or installed can, ifproperly designed and built, satisfy the essential requirements when, where and to theextent that such works are subject to regulations containing such requirements.

In 1991 the then Department of the Environment (now called the Department ofCommunities and Local Government, DCLG) issued Government Circular 13/91 related toEuropean Economic Community: Directive 89/106/EEC Construction Products. It primarilygave guidance to enforcement bodies on the application of the Construction ProductsRegulations. In 8 the Government Circular 13/91 reinforces the responsibilities of 'buildingcontrol officers and approved inspectors to ensure the fitness of purpose for use on site inworks that are subject to Building Regulations. Building control officers will need to satisfythemselves that a product (whether or not it carries the CE mark) is fit for intended use oractual use and to reject products that are unfit'.This circular includes the following statement 'The Regulations apply at all stages of thesupply chain' but this statement does not single out CE Marked products for attention.Regulation 4 'Products bearing the EC mark' ➃

Any construction product which bears the EC mark shall be presumed to satisfy therelevant requirement in regulation 3 (see above) unless there are reasonable groundsfor suspecting that the product does not satisfy that requirement or that the EC mark hasnot been affixed in accordance with regulation 5.

Regulation 6 'Requirement to keep available and give information about products whichbear the EC mark'

The person who has affixed the EC mark… shall, for a period of 10 years after thematerial date, keep the EC certificate of conformity or, as the case may be, the ECdeclaration of conformity relating to the product, or a copy of it, available for inspectionby an enforcement authority or any of its officers and, if required to do so by any suchauthority or officer at a reasonable time, produce the document so kept and permit anysuch officer to take copies of it.

➃ The EC Mark (as it was in English translation) is now termed the CE Mark throughout Europe. certified by theNB, and hence for CE Marking to be applied to the “components” produced from those facilities.


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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 shallgive to an enforcement authority, or any of its officers, all information which he has aboutthe product and which the authority or officer may reasonably require for the purpose ofascertaining whether the product satisfies the requirement in regulation 3 or is one towhich 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 ofthe product regarding the essential characteristics of the product, appropriatedocumentation should accompany the product to satisfy building control officers andapproved inspectors. Consequently the traceability recommendations for CE Marking givenin this publication are based on the requirements given in BS EN 1090-2 which areexplained below and in section 8.

7.3 Inspection documentsBS EN 1090-2 gives traceability requirements for both the material delivered to theworkshop or construction site and for the flow of material through the fabrication shop. Bothof these requirements are explained below.Traceability of the essential characteristics of steel sections and other steel constituentproducts in terms of the material properties is important and only certain inspectiondocuments (often referred to as “test certificates”) provide sufficient details. For products toBS EN 10025-1, this can be specific to a lot or cast (type 3.1 inspection certificate) or non-specific (type 2.2 test report). BS EN 1090-2 requires type 3.1 inspection certificates for allsteel products except those of the following qualities: S275JR, S275J0, S355JR or S355J0.

7.4 RequirementsBS EN 1090-2 gives general recommendations for checking that supplied constituentproducts comply with the relevant product standards given in BS EN 1090-2 and matchthose 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 distinguishingbetween different steel grades where different grades and/or qualities are processedthrough the fabrication shop at the same time. Finally, for Execution Classes 3 and 4 thestandard requires all constituent products to be traceable at all stages from receipt tohandover and incorporation in the works. Batch or type traceability may be used unlesstraceability of each product is specified by the purchasing client. The requirements in 5.2 ofBS EN 1090-2 are:

The properties of supplied constituent products shall be documented in a way thatenables them to be compared to the specified properties. Their conformity with therelevant product standards shall be checked in accordance with 12.2.For EXC3 and EXC4, constituent products shall be traceable at all stages from receiptto hand over after incorporation in the works.This traceability may be based on records for batches of products allocated to a commonproduction process, unless traceability for each product is specified.For EXC2, EXC3 and EXC4, if differing grades and/or qualities of constituent products arein 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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against the purchase order. This includes steel sections, fasteners, subcontractedfabrication, coating products and items delivered directly to site such as decking and purlins.Execution Class 2 - requires control of incoming material against the purchase order asdescribed for Execution Class 1 and constituent products to be marked where more thanone grade/quality is in circulation. This applies to steel sections and plate, and fastenersdelivered to the workshop.Execution Classes 3 and 4 - requires control of the incoming material against the purchaseorder as described for Execution Class 1, marking of constituent products where more thanone grade is in circulation and all products to be traceable at all stages from receipt tohandover after they have been included in the structure (this includes activities on site).Unless traceability for each product is specified by the purchasing client then batch or typetraceability may be used.

7.5 Batch or type traceabilityBatch or type traceability means nominally identical items do not need to be distinguished;hence, backwards traceability is limited. This type of traceability can be achieved by carrying outa paper check of the order against the delivery note and a physical check of the steel sectionsand other products against the order when the steel sections and products are delivered. Traceability through the workshop can then be achieved through a combination of shape andlocation within the workshop - i.e. serial size and weight can be obtained from the shape of thesection and the grade and job reference can be obtained by storing different grades in differentlocations. Alternatively a colour coding or marking system can be used to distinguish betweendifferent grades, sections and project jobs. The steel quality (or sub-grade) is the most difficultproperty to trace through the workshop and it may be possible generally to limit steel sectionspurchased and used to a single sub-grade (e.g. J0). Where other sub-grades are used thesecan then be treated as specials and alternatively marking systems can be used.BS EN 1090-2 distinguishes between the documentation required to support the requiredtraceability of completed components sent to site from that required for constituent productsexplained above. In both cases suitable supporting documentation is required, and this will be inthe form of a component specification when components are ready for delivery to a project site.

7.6 WeldingBS EN 1090-2 does not require that individual welds be identified against the qualifiedwelder who welded them. However, the manufacturer's WQMS needs to provide acomparable level of batch or type traceability. Hence, the welding coordinator would needto be able to demonstrate that the WQMS ensures the following in terms of traceability ofwelding for all except EXC1:

• The portfolio of WQTs held by the manufacturer is up-to-date with respect to thescope of welding operations being undertaken;

• On a sample basis at any stage during certification of the WQMS, the conduct of thework is traceable to the extent that welding personnel with suitable and validqualifications are assigned to appropriate welding tasks;

• Work instructions issued to welders are appropriate to the joint configuration andmaterial to be welded;

• Work instructions issued to welders are traceable back to an appropriate WPS that issupported by an appropriate and valid WPQR.

The NSSS requires that these provisions are met for EXC2 building construction.


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8 SUPPLY CHAIN ISSUES

8.1 IntroductionThe CPD applies to all construction products that are permanently incorporated into astructure. For the steel construction industry this means steel sections and plate, hollowsections, preloadable bolts, non-preloadable bolts, purlins, sheeting, decking and fabricatedsteelwork. It also applies to those manufacturers, importers and distributors who modify aproduct already placed on the market in such a way that conformity with its original CEMarking is affected. This last range of products includes proprietary products such ascellular beams, part-fabricated products such as curved steel sections and modified and/orre-tested steel sections. Clearly this has implications for all parts of the steel constructionsupply chain. Within the supply chain, organisations can be categorised as a manufacturer, an agent, animporter or a distributor. Importers and distributors are not subjects of the CPD because thelegal responsibility for placing the product on the market and its subsequent CE marking restswith the manufacturer or his appointed agent established in the community. However, the 'BlueGuide' introduces the two more possibilities of importer and distributor and so their roles arealso mentioned here.➄ It is also possible for some organisations to be placed in differentcategories for different products. Knowing which category one falls into is very important.

8.2 ManufacturersA manufacturer is defined as any person or organisation that is responsible for designing andmanufacturing a product to be placed on the EU market. This includes steel manufacturerswho place steel sections on the EU market, steelwork contractors who place fabricatedsteelwork on the market, purlin, sheeting and decking manufacturers. If a manufacturer is notestablished within the European Union, then the manufacture must appoint an agent who isto act as the manufacturer's legal entity within the EU - i.e. a person/corporate entity againstwhich legal action can be taken by the enforcement authorities.

8.3 ImportersAn 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 theEU). If the importer puts the products onto the EU market and its name appears on theproduct 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 theoriginal manufacturer's name still on the product and does not change the product in anyway then it is a distributor.

8.4 DistributorsA distributor is a person or organisation which stores and distributes a CE Marked productthat has already been placed on the EU market. Some steel stockholders fall in to thiscategory. The distributor does not alter the product in any way nor does it put its name onthe product. For examples some stockholders re-test steel sections or plates in order toestablish improved CVN values. This process changes the declared properties of theproduct and the stockholder then becomes a manufacturer.

➄ Further information on the role of the importer and the distributor is contained in the Pinney & Rein reference.



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Although distributors do not have any responsibilities under the CPD they do have a duty toensure that the correct CE Marking is associated with the correct product and that clearlynon-compliant products are not placed on the EU market.The issue of an organisation buying a CE Marked product changing some of its declaredproperties and putting it back on the market is worth exploring further with reference tocertain parts of the steel construction supply chain. For example some steel stockholdersoffer a service to steelwork contractors which involves modifying the original CE Markedsteel section. Steel benders provide a service which bends the original steel beammodifying some of declared properties. In both cases the stockholders and steel bendersare classed as manufacturers.

8.5 StockholdersSteel stockholders generally purchase steel sections which have been CE Marked by thesteel manufacturer to BS EN 10025-1 for I and H sections, BS EN 10210-1 for hot-finishedstructural 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 bythe stockholder before being supplied to the steelwork contractor. All of these activities arefabrication activities which are covered by the CE Marking standard BS EN 1090-1. Forexample it is important that the section is cut to exact length and the holes are drilled inaccordance with the tolerances given in BS EN 1090-2. Stockholders who provide theseservices will therefore need to extend the CE Marking for the modified steel sections inaccordance with the fabrication CE Marking standard BS EN 1090-1. This will require initialtype testing (ITT) and the setting up a certified factory production control (FPC) system asdescribed in section 10. Sometimes stockholders re-test steel sections to re-evaluate fracture toughness. Fracturetoughness is one of the performance values declared on the CE Marking by the steelmanufacturer. Therefore a change to the product's original performance values for fracturetoughness will require the section to be re-CE Marked. The stockholder will therefore have toperform ITT for the change in the performance value for fracture toughness and set up anappropriate FPC system. In this case setting up an FPC system cannot be based on the originalsteel production process as the stockholder has no control over the raw materials or theproduction process. The FPC system will be based on documentary controls and testing of thefinished product. The laboratory testing will need to be checked by the NB as described above.

8.6 Steel processorsThe fabrication of structural steelwork is an assembly process that uses constituentproducts such as steel sections and some of these products, such as curved beams, maybe part-processed but not ready for incorporation into the construction works until afterfurther fabrication. The manufacturer of a steel component that is to be directly placed onthe market needs either to be confident that the part-processed constituent products beingused in fabrication have properties that conform to the standards for the original steelproduct manufacture (for example BS EN 10025) or to have a declaration from the steelprocessor of the changed performance characteristics.Processes of bending or curving a steel section may change some of its characteristics, themost obvious being its fracture toughness. The changes to the performance values willdepend on the amount of bending and for small strains the changes will be so small that theoriginal performance values may be relied upon. For higher strains the curved section willneed to be CE Marked with its new performance values. The process of bending a section


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will not change all of the originally declared performance values. For those unaltered valuesthe steel bender is entitled to assume that the CE Marked product has been correctly testedaccording to the appropriate standards and therefore the performance values can bepassed on without repeating the Initial Type Testing (ITT) and tests included in the FPC ofthe steel manufacturer. Bending a steel section is a fabrication activity and it is therefore suggested that bent orcurved steel sections are CE Marked according to BS EN 1090-1. This will require settingup ITT for those characteristics whose performance values are changed by the bendingprocess and an FPC system to control the bending processes. Similar issues arise with respect to some operations undertaken by steel service centres(e.g. thermal cutting) and by manufacturers of cellular beams and plated profiles.

8.7 Special products and processesBS EN 1090-2 anticipates that there will be circumstances where steel products etc otherthose listed as structural steels etc may need to be used in the construction works.Examples include proprietary products not covered by a European (EN) or InternationalStandard (ISO) and without a European Technical Approval (ETA). Other examples wouldbe products such as engineering steels that are covered by an EN or a national standardbut which are not cited in BS EN 1090-2; such steels might be used in complex structuralcomponents as machined connectors.The general rules for manufacturers to follow in such circumstances are as follows:

• It is not allowed to use CE Marking on a product that is not covered by either aharmonised standard or an ETA under the CPD.

• It is important in all cases for the manufacturer not to confuse the market with CEMarking that might be misconstrued.

BS EN 1090-2 covers such special products and processes as, although it supports BS EN1090-1, it is written for wider application. Hence, in potentially ambiguous or uncertaincircumstances the manufacturer needs to be clear in the CE Marking documentation whatis covered by the CE Marking and what is not. The execution specification includes thecomponent specifications and provides a definitive reference in this respect. The fact thatsuch products are not covered by a harmonised standard or ETA does not prevent thembeing specified and used in construction works.

8.8 Transition periodDuring the transition period between the date of applicability and the end of the co-existenceperiod (expected to be two years), organisations in the supply chain may continue to placenon-CE Marked products on the market even in those countries where CE Marking ismandatory. Then in those countries at the end of the co-existence period non-CE Markedproducts may not be placed on the market even if they are products that had already beenmanufactured before the date of applicability published on the NANDO website. In countrieswhere CE Marking is not mandtory it may be possible for, say, steelwork contractors to useup their long-standing stocks of, say, fasteners indefinitely. However, it is arguable that theUK regulations require products to meet the essential requirements even in the absence ofa relevant harmonised standard. Different provisions apply to products (such as re-usedsteel components) manufactured before the CPD and/or the UK Construction ProductsRegulations came into law in 1991. These provisions will need to be re-addressed if theEuropean regulations are extended to encourage the “recyclability of the constructionworks, their material and parts after demolition”.



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9 EXECUTION CLASS

9.1 GeneralInformative Annex B of BS EN 1090-2 provides guidance for the determination of ExecutionClasses (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-staticactions only. BS EN 1090-2 recommends that PC1 is limited to non-welded components andwelded components manufactured from steel grades below S355. In practice the distinctionbetween PC1 and PC2 makes no practical difference to most structural steelwork. The NSSSis applicable to structural steelwork in SC1 only, and in both PC1 and PC2

9.2 Application to buildingsFollowing the recommendations of BS EN 1090-2, the NSSS recommends that CC may bedetermined directly by reference to the building classes defined in Table 11 of ApprovedDocument 'A' of the Building Regulations of England and Wales as follows:

Thus NSSS is based on execution of structural steelwork in EXC2 excluding steelwork inSC2, hence to Building Class 2 and without modification to Building Class 1. Structuralsteelwork in Building Class 3 and SC1 can also be undertaken to EXC 2 by steelworkcontractors whose conformity assessment procedures are certified as meeting therequirements of EXC2, provided that the different requirements tabulated in Annex A.3 of BSEN 1090-2 are reviewed by the designer who is responsible for the structural design andspecifies which, if any, of the supplementary requirements listed under EXC 3 are applicable.In terms of BS EN 1090-1 this means that amendments to the structural characteristicsrelevant to manufacturing would then be specified in the component specification.

9.3 Wider applicationBS EN 1090-2 defines EXC as a classified set of requirements specified for the executionof the works as a whole, of an individual component or of a detail of a component. Inpractical terms it is expected that all the components and details in the works as a wholewould generally be classified with the same EXC. Hence, the NSSS ignores the possibilitythat some components or details could be EXC1 as BCSA believes that EXC2 is the bestbasis for ensuring consistent quality of steelwork appropriate for building construction.In terms of wider application, the following list provides a basis for determining EXC:

• EXC1 - Farm buildings.• EXC2 - Buildings (similar to the scope of the NSSS).• EXC3 - Bridges.• EXC4 - Special structures (power stations, long span bridges etc.).

Building class Consequences class (CC)

Class 1 (except domestic buildings) Class 1

Classes 2A or 2B (also including domestic buildings of 4 storeys and below) Class 2

Class 3 Class 3


10 FACTORY PRODUCTION CONTROL

10.1 IntroductionCE Marking requires the manufacturer to operate a factory production control (FPC) systemcertificated by a NB. An FPC system is a management control system that focuses mainlyon the manufacturing operations although procedures for controlling design operations canbe included. It aims to ensure that the quality of the product (be it a steel section, a bolt, apurlin or fabricated steelwork) is consistently maintained to the required specification. AnFPC system is very similar to a BS EN ISO 9001 system and can be regarded as a subsetof 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-conformingproducts. FPC is all about producing products with the same declared characteristics timeand time again. For CE Marking of fabricated structural steelwork, steelwork contractors and thoseorganisations involved in fabrication activities need to set up an FPC system that complieswith the requirements given in BS EN 1090-1. The need for suitable FPC extends to steelstockholders that offer limited fabrication services, steel benders and those organisationsthat produce proprietary steel products (see section 8). FPC will include the procedures forcontrolling manufacture as described in BS EN 1090-1. It may also include the proceduresfor controlling design and/or the quality of the welds, and, excluding EXC1, a ResponsibleWelding Coordinator. In general based on the activities undertaken, there are four possibleFPC systems and these are listed in the following table:

10.2 FPC systemsFPC system A - applies to those organisations that have no welding activities and are notdeclaring design characteristics - e.g. manufacturers of purlins, decking etc.FPC system B - applies to those organisations that have no welding activities and wish todeclare design characteristics - e.g. manufacturers of purlins and decking who wish to maketheir safe load tables part of the CE Marking.FPC system C - applies to those organisations that carry out welding activities and do notwish to declare design characteristics - e.g. this category will apply to the majority ofsteelwork contractors even though they may be carrying out all or part of the design.FPC system D - applies to those organisations that carry out welding activities and wish todeclare design characteristics - e.g. some manufacturers of proprietary products (cellularbeams) may wish to declare design values as part of the CE Marking. This system is alsoseen as a future development for those steelwork contractors wishing to declare designvalues as part of the CE Marking.

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Activities FPC systems

A B C D

Manufacturing Yes Yes Yes Yes

Design No Yes No Yes

Welding No No Yes Yes

RWC No No Yes Yes



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10.3 System requirementsThe following list includes the manufacturing and design procedures that should be coveredin a typical FPC system to meet the requirements of BS EN 1090-1. The activitiesassociated with managing and controlling the welding processes and the requirements forthe Responsible Welding Coordinator are given in sections 5 and 6 respectively. It should be noted that FPC systems in other product standards (BS EN 10025-1 for themanufacture of steel sections and BS EN 14399-1 for the manufacture of preloadable boltsetc.) differ from the one described below.

10.3.1 Personnel (Clause 6.3.2, BS EN 1090-1)Document the responsibility, authority and the relationship between personnel that manage,perform or verify work affecting the characteristics of your steelwork. This is best done bydeveloping an organogram which names key personnel, their function and the lines ofcommunication.The system should also describe the measures to ensure that personnel have adequatequalifications and training for the range of steelwork the company fabricates and theExecution Class(es) used.

10.3.2 Equipment (Clause 6.3.3, BS EN 1090-1) All weighing, measuring and testing equipment that may have an influence on thecharacteristics of the steel frames/members must be calibrated, regularly maintained andinspected. Each company will need to decide the inspection procedures and the frequencyof inspection. Manufacturing equipment (cutting, sawing and drilling equipment) must be regularlyinspected and maintained to ensure that it remains sufficiently accurate and that its use,wear and failure does not cause significant inconsistency in the fabrication process.The procedures should document the frequency of inspections and maintenance and forhow long this information should be retained. (Note: The Construction Products Regulationsrequire records to be retained for a minimum of 10 years. However, as many constructioncontracts are signed as deeds it is recommended that records are retained for a minimumof 12 years).

10.3.3 Structural design process (Clause 6.3.4, BS EN 1090-1)In the case where structural design is carried out by the steelwork contractor and designcharacteristics are declared as part of the CE Marking, the steelwork contractor needs toestablish procedures to control and verify compliance with the design brief, for checkingcalculations and for ensuring the competence of the individuals responsible for the design.With respect to building steelwork an appropriate checklist for design control adapted fromBCSA's Commentary on the Fourth Edition of the National Structural SteelworkSpecification for Building Construction is as follows:The Steelwork Contractor should have established procedures to control and verify thecontract requirements for design. These may include:

• A design plan defining the principal design activities in a logical sequence, the typeof design output and target dates to meet the programme requirements and allocationof design responsibilities.

• Procedures for controlling design variations, changes and concessions that take


place during the contract including procedures for controlling revisions to the designbrief and the issue of revised fabrication drawings.

• Design of the structure so it can be safely erected, bearing in mind that the designerwho is responsible for preparing the structural design must take account of safety andstability aspects of the erection method statement.

• Design documentation, production and checking procedures (verification).• A check that software used in the design has been validated.• Procedures for the acceptance of general arrangement drawings and connection

design calculations by the designer who is responsible for the structural design andspecifies the structural characteristics relevant to manufacturing in the componentspecification.

• Handling and transportation requirements for unusually shaped or large componentsto ensure stability during movement.

• A formal documented review of the design before issue for connection calculationsand associated detail drawings.

10.3.4 Constituent products used in manufactureConstituent products are defined as materials or products used in manufacture withproperties that enter into structural calculations or otherwise relate to the mechanicalresistance and stability of the structure and/or the fire resistance, including durability andserviceability. For most manufacturers (i.e. steelwork contractors, stockholders, etc.) thiswill include the following range of products:

• Steel sections (open and closed), plates and strip.• Structural bolts.• Cladding, sheeting, purlins and side rails.• Welding consumables.• Painting and galvanizing.• Castings, bearings.

Identify the range of constituent products used in your factory. Develop and implement awritten inspection procedure for checking and recording that the constituent productscoming in to your factory conform to the specification, and that traceability of the constituentproducts through the factory conforms to the requirements for traceability given in BS EN1090-2 (see section 7). Retain the documentation related to the constituent products for the period of documentretention.

10.3.5 The component specification (fabrication drawing)The component specification is defined as a document or documents that gives all thenecessary information for fabricating the structural steelwork. For the majority ofmanufacturers this will be a fabrication drawing. In addition to all the usual items on thedrawing (e.g. dimensions, steel grade, weld size etc.) the drawings should include areference to the Execution Class and the Service Category (see BS EN 1090-2). ServiceCategory is defined in BS EN 1090-2 as 'Categories that categorise a component in termsof the circumstances of use'. In simple terms this means the steelwork is designed forfatigue or not. For the majority of manufacturers the steelwork will not be subject to fatigue.

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Develop and implement a written inspection and test plan for checking and recording thatthe fabricated steel frame/members conform to the component specification - i.e. make sureyou have made what you said you were going to make. This will generally be covered bythe quality manual and only requires a project-specific quality plan if requested by thepurchasing client. In those cases Annex C of BS EN 1090-2 gives a checklist for the contentof a quality plan for structural steelwork with reference to the general guidelines in BS ISO10005 Quality management - Guidelines for quality plans.Prepare the fabrication drawings from design information/specification.

10.3.6 Product evaluationThe list of declared characteristics for fabricated steelwork from BS EN 1090-1 is givenbelow:

• Tolerances on dimension and shape• Weldability (as CEV for constituent products)• Fracture toughness (as CVN for constituent products)• Load bearing capacity• Fatigue strength• Resistance to fire• Reaction to fire (as Class A1)• Dangerous substances

• Release of cadmium and its compounds• Emission of radioactivity

• Durability of performance characteristics (given with respect to therequirements for surface treatment for corrosion protection as specified in BSEN 1090-2).

For steelwork used in most buildings in the UK you need only evaluate those characteristicsthat are highlighted in bold above. These are the characteristics that you will be declaringon your CE Marking.

10.3.7 Non-conforming productsSet up a written procedure that states how your company will deal with non-conformingproducts (i.e. steel frames/members that do not comply with the specification). Thisprocedure must comply with the principles of BS EN 1090-1 as amplified by therequirements of BS EN 1090-2. Non-conformities must be recorded when they occur.Records of non-conformities must be retained for the period of document retention.


11 ROUTES TO CERTIFICATION

11.1 IntroductionFor safety critical products like structural components, the manufacturer is not allowed to fixCE Marking without having a factory production control (FPC) system in place which has avalid certificate from an approved notified body (NB). This requires a NB to assess andsatisfy itself that the manufacturer's FPC system is able to produce products that complywith the relevant harmonised standard. Once satisfied, the NB will issue the manufacturerwith an FPC certificate. If the manufacturer undertakes welding, the NB may issue either aseparate welding certificate or include the required scope of welding certification in the FPCcertificate. These certificates enable the manufacturer to produce a Declaration ofConformity, and the Declaration of Conformity permits the manufacturer to affix CE Markingto its products, provided that the products fall within the scope of certification given on thecertificate(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 therelevant requirements of BS EN 1090-2 where invoked in BS EN 1090-1. A typical FPCsystem 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, designoperations. 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 arereferred to in BS EN 1090-2 and are described in the relevant part of BS EN ISO 3834 (seesections 3 and 5).Part 3 is that part of the FPC system dependent on the competence of the ResponsibleWelding Coordinator in terms of the RWC's technical knowledge and experience. The levelof technical knowledge required is linked to the Execution Class and the role of the RWC isdescribed 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 FPCsystem comply with the harmonised standard BS EN 1090-1 before it issues an FPCcertificate or a welding certificate. Part 1 will always be assessed by the NB. For Part 2 thereare two ways in which the manufacturer can demonstrate to the NB that its weldingoperations are properly controlled. Similarly there are a number of options available fordemonstrating the competence of the RWC. The different options available for Parts 2 and3 are described below.

11.2 Assessment of the WQMSThe manufacturer can demonstrate that its welding operations are properly controlled inaccordance 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 acceptableto the NB would normally be issued by an Authorised National Body for CompanyCertification (e.g. The Welding Institute in the UK).Alternatively the NB can assess the manufacturer's WQMS as a part of the manufacturer'sFPC system. Under this option the WQMS is an embedded part of the FPC system. Thecertification of the FPC for welding may be identified within the general FPC certificate orissued as a separate welding certificate. A separate certification explicitly according to ENISO 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 ofthe WQMS in particular may be found in a guidance document issued by the Structural

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Metallic Products Sector Group 17 of Notified Bodies for the Construction Products Directive89/106/EEC (GNB CPD SG17) entitled Guidance for the FPC assessment according toAnnex B of EN 1090-1. An abstract of this document is included in Appendix D.

11.3 Assessment of the RWCAssessment of the relevant competence of the RWC requires the NB to:

• Assess the RWC's experience. This can be demonstrated by employment evidenceover at least the last four years.

• Assess the RWC's technical knowledge. There are three ways in which this can bedemonstrated and these are explained further below.

• Check that the manufacturer's FPC has defined a suitable role and has given theRWC suitable responsibilities to enable the RWC to coordinate the manufacturer'swelding operations. This requires the NB to know the scope of certification of thewelding operations for which the manufacturer is seeking certification.

• Assess whether the RWC is acting competently in the defined role. This can be donein parallel with the NB's assessment of the manufacturer's WQMS by questioning theRWC about the manufacturer's portfolio of WPSs, WPQRs and WQTs. Also, duringthis technical interview the RWC will need to demonstrate to the NB the ability todetect and assess defects, to instruct repairs and know how to avoid defects, as wellas knowledge about the relevant standards, regulations and specifications to beobserved.

There are three ways in which the RWC can demonstrate the necessary technicalknowledge. In the first two routes described below the RWC can either be a subcontractoror a member of the manufacturer's staff.Route 1The first and simplest approach is where the RWC has an appropriate International Instituteof Welding (IIW) qualification. In this case the RWC will need to supply the NB with evidenceof this qualification. Clearly this qualification is portable and is not specific to the RWC'scurrent employer or post, but the level of this qualification (Basic, Specific orComprehensive) 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 ISO14731 is as follows:

• Comprehensive requires a level of technical knowledge of all tasks andresponsibilities in welding fabrication - International Welding Engineer (IWE);

• Specific requires a level of technical knowledge that is sufficient within a selective orlimited technical field - International Welding Technologist (IWT);

• Basic requires a level of technical knowledge that is sufficient within a limitedtechnical field involving only simple welded constructions - International WeldingSpecialist (IWS).

IIW qualifications are valid indefinitely and are fully portable within and beyond the steelworkindustry.Route 2In recognition of the fact that some welding coordination functions do not require the breadthof knowledge provided by the IIW qualifications, TWI Certification has developedRequirements for the Certification of Welding Coordinators in accordance with BS EN ISO14731: 2006 under the Certification Scheme for Welding and Inspection Personnel (CSWIP).


This allows a manufacturer's nominated RWC to gain appropriate, industry-specific, CSWIPcertification as a welding coordinator working in structural steelwork. The scheme assessesthe knowledge, experience and competence of the nominated RWC by assessing a portfolioof evidence, interview, additional training where necessary and examination. The successfulcandidate will, in this case, be issued with a CSWIP certification.The CSWIP process includes both an off-the-job knowledge examination, and a job-specificassessment focussing on the competence of the RWC to fulfil the job specification. Thislatter step could take place during the certification process when a manufacturer is seekingindependent certification of its WQMS to BS EN ISO 3834.Under this option the RWC will need to supply the NB with a copy of the RWC's CSWIPcertificate to demonstrate the RWC's technical knowledge. A technical interview with the NBmay be required to demonstrate the RWC's competence in the context of the weldingoperations covered by the manufacturer's WQMS. Again, the level of this qualification mustmatch the scope of the RWC's employer's WQMS. This certification is valid for review afterthree years and re-assessment after six years. It has limited portability as it would only besuitable for another manufacturer with a congruent scope of WQMS certification.Route 3The third route is available to those manufacturers working within a limited scope of operationsand whose RWC is a directly employed member of staff. The assessment may differ fromcertification body to certification body but it is likely to involve an assessment of the individual'sexperience based on a typical portfolio of information (see Appendix A). A successfulassessment would lead to company-specific qualification of the nominated RWC who wouldbe embedded in its WQMS and, as such, not transferable should they decide to leave.The table below summarises how the required level of technical knowledge relates towelding processes and the grades and thicknesses of parent materials for buildingsteelwork in EXC2 undertaken in accordance with the NSSS.

With respect to this table, Appendix A describes the limited scope of operations to whichroute 3 might typically apply.

11.4 Surveillance auditsTo maintain its declaration of conformity, the company's FPC system is subject to regularsurveillance audits. The interval between these audits is related to the Execution Class. ForEXC1 and EXC2 surveillance audits will take place one year after the initial assessment,two years after that and then every three years. These periods are only applicable in thecase of no major non-conformities. If major non-conformities are identified the regime must


50

TECHNICAL KNOWLEDGE OF RWC

Scope of welding operations Maximum parent metal thickness t (in mm)being supervised t ≤ 25(1) 25 < t ≤ 50(2) t > 50

Welding of S275 steel products Basic Specific Specific

Welding of S355 steel products Basic Specific Comprehensive

Welding of S420 steel products Specific Specific Comprehensive

(1) Column base plates and endplates ≤ 50mm.(2) Column base plates and endplates ≤ 75mm.



51

be at such intervals that give confidence that the non-conformity has been corrected. ForEXC3 and EXC4 the audits will take place at yearly intervals for the first two years, the thirdaudit will be two years after that and then every three years. The table below shows therelationship between Execution Class and audit inspection intervals:

In periods where the interval between surveillance is two or three years audits themanufacturer must make an annual declaration to the NB that none of the followingchanges have been made:

• New or changed essential facilities;• Change of RWC;• New welding procedures, change to the type of parent material and associated

WPQRs;• New equipment, where it affects the declared characteristics.

There is no formal requirement for the FPC system to be re-certified at each surveillanceaudit as it is merely a confirmation that the manufacturer still has the FPC system undercontrol as was the case at the initial inspection. Thus the FPC certification does not havean “expiry date” as such. However, it is likely that the NB will wish to state the date of thenext required surveillance audit in accordance with intervals stated in BS EN 1090-1 andthis is shown in the example documents in Appendix C.If a separate welding certificate is issued this also does not have an expiry date as such asit is indefinitely valid in terms of time but not in terms of circumstances. Hence, if any of thefour changes listed above do occur this automatically means that the details listed on theexisting welding certificate will become either invalid or incomplete. For instance, a changeof RWC or move of factory location and hence site address would render the wholecertificate invalid. On the other hand, the addition of a new factory, new welding process ormanufacture using materials not listed would not invalidate the existing certificate, but thosenew additions would not be covered. Hence, CE Marking could not be applied to weldedcomponents manufactured using those new facilities etc until the welding certificate hadbeen updated.In practice the company needs to agree a suitable programme of certification with therelevant NB. Audit visits to BS EN ISO 9001 would often be undertaken on a six-monthlybasis. In those circumstances, and with the need to keep a close watch on changes inwelding circumstances, the practical way would be to undertake FPC surveillance on anannual basis using the intervening six-monthly visit to audit the other aspects of the qualitymanagement system covered only by BS EN ISO 9001. Thus, welding changes could beidentified and dealt with within a maximum of six months. In terms of the latitude allowed byBS EN 1090-1 to extend the FPC surveillance intervals beyond a year, the practical waywould be to use that latitude not to extend the interval but to reduce the scope of the annualFPC audit in terms of which facilities or processes are audited.

11.5 Steel Construction Certification SchemeThe Steel Construction Certification Scheme (SCCS) is the steel construction industry's

Execution Class Intervals between inspection of manufacturer'sFPC after ITT (years)

EXC1 and EXC2 1 - 2 - 3 - 3

EXC3 and EXC4 1 - 1 - 2 - 3 - 3


dedicated certification scheme. SCCS will become a notified body for CE Marking ofstructural steelwork and is already able to offer FPC gap analysis of FPC systems to BS EN1090-1. Within the limited but common scope of operations explained above, SCCS hascompetent welding and fabrication assessors which allow it to assess WQMSs and theassociated RWC as an integral part of the FPC assessment. SCCS may be contacted viathe BCSA's website www.steelconstruction.org.


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12 IMPLICATIONS FOR DESIGNERS, SPECIFIERS ANDCONSTRUCTION MANAGERS

12.1 IntroductionCE Marking already appears on some construction products and CE Marking in general hasbeen with us for many years. Most of the manufactured products that we buy have CEMarks on them. It is therefore important that all parts of the supply chain, includingspecifiers, designers and construction managers are aware of their responsibilities and thebenefits of CE Marking. In essence CE Marking is a declaration by the manufacturer that the product meets certainminimum public safety requirements. Although CE Marking is currently not a legalrequirement in the UK it is in most other European countries and under the UK'sConstruction Products Regulations a CE Marked product is assumed to comply with the law.For fabricated structural steelwork CE Marking, applies both to the steel constituentproducts (steel sections, structural bolts, purlins, cladding and propriety products such ascellular beams) and to the fabricated steelwork itself. This imposes implications on thedesigner when specifying steel components, designing the structure and when choosing anappropriate steelwork contractor. It also has implications for construction managers.

12.2 Designers and specifiers

12.2.1 RolesFor building steelwork in the UK there are generally two design roles that are fulfilledseparately. In terms of the NSSS one role is allocated to the engineer who is the responsiblefor the design of structural members and will prepare design drawings. The engineer maybe appointed by the purchasing client, or on design-and-build projects the engineer will beappointed by the steelwork contractor.The design drawings and the associated project specification will form the design brief thatincludes all information necessary for the design of connections and completion of thefabrication drawings. The latter design work is generally undertaken by designers anddetailers working for the steelwork contractor.The completed fabrication drawings and associated project specification agreed betweenthe engineer and the steelwork contractor comprise a portfolio of component specificationsfor the structural steelwork to be manufactured.

12.2.2 ComponentsCE Marking is already in place for steel products such as rolled steel beams to BS EN10025-1, and their inspection documents (test certificates) are now endorsed with a CEMarking. Similarly structural fasteners to BS EN 14399-1 and BS EN 15048-1 now have CEMarking on their packaging.One of the benefits of CE Marking is that it includes technical information in the form of theproduct's declared characteristics (in the case of steel sections one of the declaredproperties is its grade - e.g. S275). Hence the CE Marking can be seen as a technical datasheet. The information given in the CE Marking together with the appropriate harmonisedstandard gives the information needed for the specifier to judge whether the product issuitable for a particular intended use in terms of the requirements in the building regulations


related to materials and workmanship. Furthermore because CE Marking is a legalrequirement in most European countries specifiers can have confidence in the declaredcharacteristics.Another benefit of CE Marking is that there is only one set of requirements and procedureswith which to comply. The various national regulations are eliminated. As a result theproduct no longer has to be adapted to the specific requirements of the different memberstates, such as the U-Marking scheme used hitherto in German building construction.Designers and specifiers are therefore strongly advised to keep abreast of the developingCE Marking standards (called harmonised standards) for construction products and tospecify CE Marked materials and products where appropriate.

12.2.3 Fabricated steelworkThe new European fabrication standard introduces the concept of Execution Class (EXC)for steel structures. The choice of EXC is a design issue and sets the level of qualityrequired for different types of structure. EXC can be applied to the whole structure, part ofa structure and individual details. Recommendations for determining the EXC are give in BSEN 1090-2 and it is linked to Consequences Class (risk to life and the environment),Production Category and Service Category (static or fatigue). The link betweenConsequences Class and type of structure is still being discussed with national authoritiesbut it is likely that the following simple relationship between EXC and type of structure willbe the basis:

• Execution Class 1 - Farm buildings.• Execution Class 2 - Buildings (similar to the scope of the National Structural

Steelwork Specification).• Execution Class 3 - Bridges.• Execution Class 4 - Special structures (power stations, long span bridges etc.).

The designer will need to specify the Execution Class for each structure. This also hasimplications for choosing a steelwork contractor. Under the CE Marking rules for fabricatedsteelwork each steelwork contractor will be assessed against a chosen Execution Class andwill only be able to use CE Marking on its products for certain Execution Classes. Thereforea steelwork contractor will need to be selected both on the ability to do the job and on theExecution Class related to its certified manufacturing facilities. BCSA is developing a webbased facility listing the execution class for steelwork contractors who are members ofBCSA. BCSA has also developed a CE Marking Edition of its National Structural SteelworkSpecification based on EXC2 as the most common basis for building steelwork in the UK.

12.3 Construction managersConstruction managers have a duty of care to ensure that the correct CE Marking isassociated with the correct product and that they are not using clearly non-compliantproducts that have been placed on the EU market. This means developing a purchasingsystem that requires CE Marking of products and checking that the appropriate CE Markingis on products which are delivered to site. CE Marking standards are continuously beingdeveloped for new and existing products, therefore construction managers need to keepabreast of these developments and update their procedures accordingly.When choosing a steelwork contractor construction managers need to select one with thecorrect certified Execution Class. BCSA is developing a web based facility listing theExecution Class for steelwork contractors who are members of BCSA.

SECTION 12 : IMPLICATIONS FOR DESIGNERS, SPECIFIERS & CONSTRUCTION MANAGERS

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Fabricated steel components are often bespoke products made to a particular purchasingclient's order and specification and designed for a particular project site. It is current practicefor the purchasing client to select the steelwork contractor rather than choose an off-the-shelf product. On this basis CE Marking might seem to add little, however this would bewrong as CE Marking does add the following:

• The regulatory imperative from the Construction Products Directive ensures attentionis given to key public safety concerns;

• The requirement for certification of the manufacturer's FPC provides assurance ofcomparable and appropriate controls across the market place;

• The declared characteristics can be relied upon as being accurate;• A consistent technical language is used by authorities, specifiers and manufacturers

to describe the characteristics of products.


APPENDIX A – ASSESSMENT OF THE RWCManufacturers working within a limited scope of operations may choose to ask the NB to assessthe knowledge and competence of the RWC as an “embedded” part of the WQMS (i.e. the thirdroute to assessment described in section 11)In adopting this route the RWC may only be assessed for evidence of Basic or Specific technicalknowledge in accordance with BS EN ISO 14731. Assessment of Comprehensive technicalknowledge is not possible. As a NB, SCCS also generally applies the following limitations:

• The RWC has to be a directly employed member of staff;• Manufacturing operations are limited to EXC2;• Steel grades up to and including S355 for qualities JR, J0 or J2;• Parent metal thicknesses up to a general maximum of 50mm with column base plates and

endplates up to 75mm;• Use of MMA or MAG welding (processes 111 and 135) for general welding or SAW (process

121) for mechanised “automatic” production.Where all of the above apply, the following five step procedure is appropriate:Step 1 - The manufacturer provides a written declaration confirming:

• The Execution Class of its fabricated product range (EXC1 or EXC2).• Its product range and the welding processes and materials used in fabrication.• The level of knowledge required for its RWC - Basic or Specific.• A job specification for the RWC.• The RWC's roles and responsibilities.

Step 2 - The nominated RWC provides for review/assessment:• A detailed authenticated CV highlighting the RWC's technical knowledge and experience in

welding and fabrication.• Documentary evidence of training and qualifications (e.g. photocopy of certificates).• Examples of job-related documents that the RWC has been responsible for (e.g. WPSs,

WPQRs, WQTs, project-specific quality plans etc.)Step 3 - Professional InterviewA suitably qualified welding specialist acting on behalf of SCCS will interview the RWC focussingon the RWC's knowledge and competence to fulfil the job specification during discussion. As partof the interview process, the candidate would also be required to complete a technical questionpaper tailored to suit the manufacturer's declared product range and welding activities.Step 4 - Successful candidatesIf the candidate is successful they will form an integral part of the company's WQMS. This routedoes not provide the RWC with separate certification and, as with other routes to certification, achange in job specification or the nominated RWC will invalidate both the WQMS and FPCsystems and will require reassessment by SCCS.Step 5 - Unsuccessful candidatesIf the candidate is unsuccessful the company can either retrain the candidate, or nominate anotheremployee or engage the services of a suitably qualified and competent external RWC. If the RWCis engaged on a subcontract basis by the manufacturer the RWC will be expected already to holda recognised and appropriate IIW or CSWIP qualification in welding or equivalent.

APPENDIX A : ASSESSMENT OF THE RWC

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APPENDIX B – ISSUES ASSOCIATED WITH BRIDGES

IntroductionThe use of CE Marking for bridge components in the UK is an additional requirement to theexisting contractual provisions for quality management. This Appendix is based on thosearrangements that currently exist between steel bridgework contractors and the Highways Agency(HA), although similar provisions underpin steel bridgework contracts for Network Rail and theCounty Surveyors.It is already mandatory for steel bridgework contractors working for the HA to have their qualitymanagement certified to BS EN ISO 9001. Whilst this is a contractual provision and not a publicsafety regulation, the fact that the HA (and most other bridge authorities) is an organisation whoseactivities are covered by the Public Procurement Regulations means in practice that contractualprovisions carry public obligations with them.The HA will wish to make use of CE Marking to implement its obligations to ensure that safe andreliable components are used in its bridges. This is a general policy and will affect how the HAdeals with type approvals, product certification etc for proprietary products and specific itemssupplied for installation such as bridge bearings. This wider context is not considered further in thisAppendix, but additional information can be found on the HA website on standards:http://www.standardsforhighways.co.uk/index.htm.

Quality managementIn order to identify a common interpretation of BS EN ISO 9001 for organisations and certificationbodies engaged in the sector, the HA sponsors the development of Sector Scheme Documents(SSD). National Highways Sector Scheme 20 (NHSS 20) relates to the quality managementsystem requirements for the execution of steelwork in transportation infrastructure assets for thesupply of new steelwork and for work on existing steelwork in new and existing assets. NHSS 20is entitled Sector Scheme Document for the Execution of Steelwork in TransportationInfrastructure Assets. Potentially it can be used for a wider scope of steelwork infrastructureprojects including toll plazas, railway bridges and station buildings.It is expected that NHSS 20 will be published by the end of 2008 to coincide with the publicationof BS EN 1090-1 and -2. Steel bridgework contractors will then be expected to have their BS ENISO 9001 certifications “endorsed” as complying also with the provisions of NHSS 20 when theyare next re-certified. As BCSA steel bridgework contractors have collaborated in its development,its provisions should reflect existing good quality management practice in the sector.

Certification bodiesAs NHSS 20 is one of many National Highways Sector Schemes, there are already manycertification bodies that are familiar with using them. Several of these have already endorsed thedevelopment of NHSS 20. Steel bridgework contractors will need to match the certification bodythey use for their existing BS EN ISO 9001 certification with those able to certify to NHSS 20.Also, it is not necessarily the case that existing certification bodies operating in the sector will seekto become notified bodies under BS EN 1090-1. Hence, steel bridgework contractors need to beaware of this in order to avoid unnecessary duplication of certification audits.

Basis of NHSS 20NHSS 20 clearly states that it is based on the requirements of BS EN 1090-1 for conformity


assessment of manufacturing operations, BS EN 1090-2 as the specification for the execution ofsteel structures and BS EN ISO 3834-2 and -3 as the basis for the welding quality requirements.It should be noted that NHSS 20 covers a much wider scope than FPC to BS EN 1090-1, as itcovers, for instance, all site-based operations including bridge refurbishment. However, withrespect to conformity assessment of manufacturing operations and manufacturing welding qualityrequirements it is congruent in its requirements with BS EN 1090-1. Hence, the guidance providedin the main sections of this document applies directly to the CE Marking of manufactured steelbridgework components.NHSS 20 is also based on using BS EN 1090-2 as the basis for the execution specification. Thissupersedes the use of BS EN 5400-6 Steel, concrete and composite bridges - Part 6: Specificationfor materials and workmanship, steel. In order to assist with the transition between these twostandards, the Steel Bridge Group (on which BCSA sits) has prepared SCI Publication P382Model Project Specification for the Execution of Steelwork in Bridge Structures. The SCI will alsobe issuing updates as relevant to its publication P185 Steel Bridge Group: Guidance Notes onBest Practice in Steel Bridge Construction. As BS EN 1090-2 is the supporting standard for BS EN1090-1, steel bridgework contractors seeking to have their FPC certified as complying with BS EN1090-1 and NHSS 20 should ensure that they follow the guidance in those two SCI publications.

Execution ClassPublication P382 is based on EXC3, whereas the guidance provided in the main sections of thisdocument refers generally to EXC2. The principal implications of this for CE Marking to BS EN1090-1 are for:

• The traceability requirements for constituent products used in manufacture;• The manufacturer's WQMS;• The technical knowledge of the RWC;• Weld inspection and acceptance requirements.

TraceabilitySection 7 defines the requirements for all Execution Classes and P382 provides a detailed definitionof how those requirements are implemented in practice, as follows:

A record shall be maintained of the source of, and test certificates for, main structural steelelements in order to provide traceability for each product. Traceability shall be by piece, by typeor 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 ofone 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 accordingto stock certification, which shall show that the stock material meets the project requirements.

WQMS and RWCEXC3 requires that the manufacturer's WQMS shall be certified as complying with BS EN ISO3838-2, i.e. Comprehensive quality requirements. The technical knowledge for the RWCresponsible for a WQMS to BS EN ISO 3838-2 is as follows:

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BS EN 1090-2 states that the technical knowledge required is with respect to the weldingoperations being supervised. It may be seen that a Specific level of knowledge may be suitablefor bridgework contractors only undertaking the manufacture of footbridges and sign gantries, butotherwise a Comprehensive level of knowledge of welded steel bridgework would be required.

Weld inspection and acceptance requirementsBS EN 1090-2 requires routine supplementary NDT to be undertaken on a more frequent basis forEXC3 than EXC2. BS EN 1090-2 also requires that production welds meet quality level B for EXC3(i.e. as required for WQTs and WPQRs). The implications of these quality level requirements areexplained in section 4.Publication P382 deals with this issue in more detail, as well as recommending an approach fordealing with weld acceptance criteria for welded fatigue details that avoids the difficulties (notedin section 4 above) that would occur with trying to meet the weld quality levels for EXC4 if thesewere specified for general production. The approach requires the execution specification toidentify specific joints that are designed for significant fatigue so that the extent and method oftesting can be chosen to detect imperfections and to characterise them.Assessment of whether such imperfections are non-conforming defects is then judged usingpublished fitness-for-purpose criteria that relate the function of the component to thecharacteristics of the imperfections (type, size, location) in order to decide whether the weld iseither acceptable or shall be repaired. In effect this replaces routine inspection with joint-specificinspection for “fatigue welds” which is based on the same fitness-for-purpose weld acceptancecriteria that underpin BS 5400-6.

TECHNICAL KNOWLEDGE OF RWC

Scope of welding operations Maximum parent metal thickness t (in mm)being supervised t ≤ 25 (1) t > 25 (1)

Welding of S275 or S355 steel products Specific Comprehensive

Welding of S420 steel products Comprehensive Comprehensive

(1) Column base plates and endplates ≤ 50mm.


APPENDIX C – DOCUMENTARY EXAMPLES

APPENDIX C : DOCUMENTARY EXAMPLES

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APPENDIX C : DOCUMENTARY EXAMPLES

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APPENDIX D – SG17 GUIDANCE ON FPC ASSESSMENTThis is an abstract of a draft position paper prepared by SG17, the Structural Metallic ProductsSector Group of Notified Bodies for the Construction Products Directive 89/106/EEC on whichSCCS is represented.

IntroductionThe aim of this document is to give Notified Bodies (NB) and manufacturers of steel or aluminiumstructural components or kits of components➅ guidance for the performance of FPC assessmentaccording to Annex B of EN 1090-1. In addition to Annex B of EN 1090-1 this document identifiesthe tasks of the NB both for the Initial Inspection and for the Continuous Surveillance.➆This guidance applies to factories whether they produce series or non-series production.➇

1 Initial Inspection of the Factory and FPC1.1 General1.1.1The manufacturer shall demonstrate that the FPC fulfils the requirements given in clause 6.3 ofEN 1090-1. The tasks for the NB for the Initial Inspection are given in Table B.1 of EN 1090-1.1.1.2The FPC system shall cover all processes, production lines, units or departments including thoseoutsourced or operated by subcontractors.1.1.3If the manufacturer declares with the CE Marking symbol characteristics influenced by thestructural design (clause ZA 3.3 or ZA 3.5 of EN 1090-1) the assessment of the FPC also includesthe control of tasks related to structural design work in Table B.1 of EN 1090. The manufacturermay be selective in its declaration of the structural characteristics for products provided that themanufacturer's declaration is unambiguous in this respect.➈1.1.4The certificate issued by the NB shall make it clear whether the design process is included or not.1.1.5As specified in 6.3.5 of EN 1090-1, if constituent products or structural components bearing CEmarks 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 in6.3.5 of EN 1090-2 or -3 as appropriate.1.1.6For finished products to be supplied to a Member State where CE Marking is mandatory and aharmonised standard exists for a constituent product, the manufacturer shall use a constituentproduct with a CE mark.

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➅ A manufacturer may make a single declaration of conformity for a kit of components provided that allcomponents are intended for incorporation in the same construction work. ➆ A checklist made by the Notified Body and specific to EN 1090-1 and to this document is stronglyrecommended as a tool for the assessment.➇ Series production may be taken as batch sizes of 10 or more identical components.➈ For instance, the load bearing capacity of a beam's connections could be declared even though themanufacturer's declaration is silent about the capacity of the beam in bending.



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1.1.7The factory covered by a single FPC system may comprise several production units, productionlines and/or departments. The NB shall define the scope of certification in terms of processes,units, lines and departments in all records issued to verify that the FPC system has been certified.1.1.8If the manufacturer is performing any testing in its own laboratory, the testing facilities shall beincluded in the assessment. The capability of the laboratory shall be demonstrated to the NotifiedBody according to one of the following possibilities:

- direct check of the performance of the manufacturer's own laboratory testing operationswithin the scope of the FPC;

- independent accreditation of the laboratory under ISO/IEC 17025 or equivalentaccreditation; the accreditation shall be specific for the tests carried out;

- assessment of a subcontracted laboratory by the Notified Body.1.1.9After a new ITT program based on physical testing has been undertaken the manufacturer shallinform the NB. The NB should review the FPC to ensure that it is capable of controlling theproduction of the new product. The NB does not need to undertake a supplementary assessmentvisit if the method of production is covered by the existing certified FPC system. This requirementdoes not apply where a product type is developed by calculation (ITC).1.1.10If the FPC is part of a certified EN ISO 9001 and/or EN ISO 3834 quality management system andthe NB has satisfied itself that the system is compliant with the requirements of EN 1090-1 andthis document then the NB may use any EN ISO 9001 or EN ISO 3834 certification information insupport of the FPC certification according to the CPD.1.1.11The number of samples used to establish product quality during ITT/ITC is defined as a single itemin Table 1 of EN 1090-1. This is because many structural components are non-series items andwith a unique component specification . If a new product type is developed using physical testingthen suitable statistical techniques shall be used to assess product characteristics based on thenumber of samples tested.1.1.12The sampling procedure to be used during production is given in Table 2 of EN 1090-1.1.1.13The component specification defines the initial type and is thus the primary control document thatlinks ITT/ITC with production requirements. The NB shall check that typical componentspecifications issued for manufacture are fully definitive in terms of the characteristics that supportthe manufacturer's declaration of conformity.1.1.14Special processes shall be assessed according to 1.3.

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There could be a single set of calculations to verify the load bearing capacity of the component. This wouldbe based on verification procedures given in, for example, the Eurocodes which are based on many “type tests”undertaken in support of the codified rules.

Annex D of EN 1990 provides a reference for structural product design assisted by physical testing.11

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1.2 Performance of the Initial Inspection of the Factory and FPC1.2.1During the initial assessment of the factory all processes, units, lines and departments covered bya single FPC system shall be inspected individually. This shall include those outsourced or operatedby subcontractors unless their FPC is certified by a NB for the scope of the work being undertaken.1.2.2During the initial inspection of factory and FPC the NB shall take into account the Initial TypeCalculation (ITC) and/or the Initial Type Testing (ITT) as applicable (see 6.2 of EN 1090-1). Thisalso applies if ITC is outsourced or done by subcontractors.1.2.3The manufacturer or its subcontractors shall make available the records of the ITC if applicableand ITT. The NB shall check that the results of the ITC/ITT procedure are consistent with the scopeof processes, product types, materials and production lines covered (see Annex B of EN 1090-1).1.2.4During the initial inspection the NB shall check that the factory has the necessary resources(premises, personnel and equipment) to achieve conformity of products.1.2.5Initial visits to packaging and warehouse units shall check that the FPC system ensures thatproducts retain their traceability such that the product shall be delivered with a mark that clearlyidentifies it, with reference to the component specification.1.2.6The certificate issued by the NB shall be definitive in terms of the scope and Execution Class ofproduct types, the applicable standards and the facilities covered.1.2.7If the product types produced in a factory do not incorporate welding, the certificate shall explicitlyexclude welding.1.2.8If the product types produced in a factory incorporate welding, the certificate shall be explicitconcerning the welding processes and parent materials covered. Unless the scope of certificationis limited to Execution Class 1, the Responsible Welding Coordinator (RWC) shall also beidentified on the certificate. This may be by means of certification to EN ISO 3834 (see 1.3.2.3).1.3 Initial Inspection for Special Processes1.3.1 General1.3.1.1Special processes are those processes where the conformity of the finished product cannot bereadily or economically verified.1.3.1.2Special processes require special consideration during the initial inspection.1.3.1.3Welding is most widely used special process for products covered by EN 1090-1 and is dealt within detail in 1.3.2.

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The requirement to consider ITC undertaken by others only applies if the manufacturer is using that ITC asthe basis for its declaration of the structural characteristics of the finished product.12



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1.3.2 Initial Inspection for the Special Process “Welding”1.3.2.1The quality requirements are defined in terms of the Execution Class according to EN 1090-2/-3as appropriate.1.3.2.2EN 1090-2/-3 as appropriate also defines the quality requirements for fusion welding according toEN ISO 3834 and the relevant to the Execution Class for the products being manufactured.1.3.2.3The NB shall be satisfied that the manufacturer is deploying suitable resources to ensure properoperation of the FPC for welding with respect to the following:- WeldersFor each main welding process the manufacturer shall have available welder(s) with validqualification according to EN 287-1 for steel or EN ISO 9606-2 for aluminium. Welders for filletwelds should have a suitable qualification for welding fillet welds.- OperatorsFor each main fully mechanised or automatic welding process the manufacturer shall haveavailable operator(s) with valid qualification according to EN 1418.- Welding CoordinationRWCs identified as managing welding coordination should be competent to manage theprocesses under their supervision and understand the limits of their competence . Guidance onsuitable knowledge is given in EN 1090-2/-3 as appropriate in terms of EN ISO 14731 and therelevant Execution Class.- Qualification of Welding ProceduresExcept where welding is undertaken to Execution Class 1, all welding operations shall beperformed according to qualified welding procedures. The welding procedure specifications(WPSs) to be used shall be based on a Welding Procedure Qualification Record (WPQR). Themethod 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”1.3.3.1The requirements for the FPC of the manufacturer's factory where welding is performed are givenin clause 6.3 of EN1090-1.1.3.3.2The NB shall assess whether the personnel, procedure qualifications and equipment of themanufacturer meet the requirements of EN 1090-2/-3 as appropriate.1.3.3.3During the initial inspection of the welding factory it has to demonstrate that the production processis under control in accordance with the requirements for welding given in EN 1090-2/-3 asappropriate.

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Certification to EN ISO 3834 is not required but may be agreed between the manufacturer and the Notified Body.The RWC is permitted to rely on additional assistance from an outside specialist source of welding advice to

coordinate welding operations outside his general scope of competence on a “unit verification” basis (e.g. widerrange of parent materials to be welded).

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1.3.3.4The audit and the independent assessment of the RWC's competence and knowledge shall beperformed by experienced auditors.1.3.3.5With respect to the processes being used, the Execution Class for the products being produced,the constituent products being welded and the welding consumables being used, the assessmentof the RWC's competence shall include the following checks with respect to the RWC's ability tocoordinate the processes etc within the FPC system:- During a technical discussion, check the knowledge of the welding coordinator(s) about therelevant standards, regulations and specifications to be observed.- Check the ability of the welding coordinator(s) to detect and assess defects, to instruct repairsand to know how to avoid defects.1.3.3.6With respect to the processes being used, the Execution Class for the products being produced,the constituent products being welded and the welding consumables being used, the audit of theFPC system shall include the following checks:

- Check that the certificates of welders, operators and NDT-Personnel are appropriate.- Check that the WPSs are based on appropriate WQPRs .- During an inspection tour through the plant, check that suitable equipment is available for

joint preparation, welding, heat treatment (if necessary) and treatment after welding, andthat the equipment is suitably maintained.

- Check that the quality of welding works is being monitored in accordance with the specifiedrequirements.

- Check that relevant standards, regulations and specifications, necessary for the productionare available.

2 Continuous Surveillance, Assessment and Approval of the FPC2.1The frequency of surveillance visits shall be in accordance with B.4 of EN 1090-1. The FPCsystem in every unit, line and department covered by a single FPC system shall be included in asurveillance visit at least once every three years.Subject to inspection of non-conformance reports or irregularities identified during the NB audit,the NB may request more frequent visits from that given in B.4 of EN1090-1. The issues to beconsidered include:

- irregularities in the performance and evaluation of welder, welding operator or weldingprocedure qualification tests;

- irregularities in welding procedure specifications and production weld tests;- incomplete or wrong material inspection documents;- incomplete necessary standards, specifications and regulations for the production;- incomplete technical knowledge of the welding coordinator;

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EA 6/02 gives guidelines for certification to EN ISO 3834.WPQRs and associated WPSs are the equivalent of Initial Type Tests for welds executed within the “family”

defined by the range of qualification given in the WPQR. In this context, the process control of welding defined inEN 1090-2/-3 may be seen as suitable for series production.

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- significant defects in products.An additional surveillance audit may be required due to one of the following reasons:

- new or changed essential facilities;- change of Responsible Welding Coordinator;- new welding processes, parent materials and associated WPQRs;- new essential equipment.

If the NB becomes aware that one of the above reasons applies but the manufacturer has notinformed the NB promptly, then an additional surveillance visit shall be undertaken.2.2The tasks of the NB during the surveillance audit are given in Table B.2 of EN 1090-1.2.3The audit of special process “welding” shall check the following in accordance with therequirements of EN 1090-2/-3:

- the commissioning of new WPSs into production;- plans for the control of production welding are being properly implemented;- the methods and frequency of inspection and testing being undertaken.


APPENDIX E – ABBREVIATIONS

BCSA The British Constructional Steelwork Association LtdCC Consequences classCEN European Committee for StandardizationCEV Carbon equivalent valueCPD Construction Products DirectiveCPR Construction Products RegulationsCSWIP Certification Scheme for Welding and Inspection PersonnelCVN Charpy V-notchDCLG Department for Communities and Local GovernmentETA European technical approvalEXC Execution classFPC Factory production controlHA Highways AgencyHAZ Heat affected zoneIIW International Institute of WeldingITC Initial type calculationITT Initial type testingIWE International welding engineerIWS International welding specialistIWT International welding technologistMPCS Manufacturer provided component specificationNB Notified bodyNDT Non destructive testingNHSS 20 National Highways Sector Scheme 20NPD No performance determinedNSSS National Structural Steelwork Specification for Building ConstructionOJ Official JournalPC Production categoryPPCS Purchaser provided component specificationpWPS Preliminary welding procedure specificationRWC Responsible welding coordinatorSC Service categorySCCS Steel Construction Certification SchemeSCI The Steel Construction InstituteTWI The Welding InstituteUKAS United Kingdom Accreditation ServiceWPQR Welding procedure qualification recordWPS Welding procedure specificationWQMS Welding quality management systemWQT Welder qualification tests

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REFERENCES

BCSA Publications:National Structural Steelwork Specification for Building Construction (CE Marking Edition) (Inpreparation title subject to confirmation)Commentary on the Fourth Edition of the National Structural Steelwork Specification for BuildingConstruction

BSI Publications:BS EN 5400-6 Steel, concrete and composite bridges - Part 6: Specification for materials andworkmanship, steelBS EN 1011 Welding - Recommendations for welding of metallic materialsBS EN 1090-1 Execution of steel structures and aluminium structures - Part 1: Requirements forconformity assessment of structural componentsBS EN 1090-2 Execution of steel structures and aluminium structures - Part 2: Technicalrequirements for steel structuresBS EN 1990 Eurocode - Basis of structural designBS EN 10025-1 Hot-rolled products of structural steels - Part 1: General technical deliveryconditionsBS 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 1Technical delivery conditionsBS EN 10219-1 Cold form welded structural hollow sections of non-alloy and fine grain steels -Part 1 Technical delivery conditionsBS EN 14399-1 High strength structural bolting assemblies for preloading - Part 1: GeneralrequirementsBS EN 15048-1 Non-preloaded structural bolting assemblies - Part 1: General requirementsBS EN ISO 3834 Quality requirements for fusion welding of metallic materials

Part 1: Criteria for the selection of the appropriate level of quality requirementsPart 2: Comprehensive quality requirementsPart 3: Standard quality requirementsPart 4: Elementary quality requirements

PD CEN ISO/TR Quality requirements for fusion welding of metallic materials - Part 6: Guidelineson implementing ISO 3834BS EN ISO 9001 Quality management systems - RequirementsBS EN ISO/IEC 17021 Conformity assessment - Requirements for bodies providing audit andcertification of management systemsBS EN ISO/IEC 17025 General requirements for the competence of testing and calibrationlaboratoriesBS EN ISO 14731 Welding coordination - Tasks and responsibilitiesBS ISO 10005 Quality management - Guidelines for quality plans


Other publications:CE marking under the Construction Products Directive published by DCLG available athttp://www.communities.gov.uk/documents/planningandbuilding/pdf/156006.pdfThe Construction Products Directive - A practical guide to implementation and CE marking, AdamA. Pinney and Stephen J. Rein, published by AuthorHouse, Milton Keynes, 2007. Certification Scheme for Welding and Inspection Personnel (CSWIP), Requirements for theCertification 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 1090-1NHSS 20 Sector Scheme Document for the Execution of Steelwork in TransportationInfrastructure Assets published by the Highways AgencyP185 Steel Bridge Group: Guidance Notes on Best Practice in Steel Bridge Constructionpublished by the Steel Construction InstituteP382 Model Project Specification for the Execution of Steelwork in Bridge Structures published bythe Steel Construction Institute

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