TheStructuralEngineer Opinion

›

54

October 2015 CE marking

taken the opportunity to fully embrace it, using it as a catalyst to introduce a quality scheme for both fabrication and installation. • Ready-mixed concrete is not traded across national boundaries so the European Committee for Standardization (CEN) agreed CE marking would not apply at all. This is why there are no harmonised standards – no Annex ZA – and ready-mixed concrete cannot be CE marked. • Perhaps other products have seen CE marking as a way of ‘protecting’ the European construction industry from inferior imported products and have introduced complexity in the Annex ZA?

The three examples listed here give an indication of how diff erent product sectors have responded to CE marking and more critically how they have developed the Annex ZA of the European product standard. This is important when

considering what it means for a structural engineer, because the structural engineer has little, or perhaps no, infl uence over what is or is not CE marked and what the CE marking actually means.

Manufacturers

Within the constraints of the standards, manufacturers still have some fl exibility over application of the regulations relating to CE marking. The most relevant of these is that CE marking applies to products placed on the market. A bespoke product, not manufactured in a serial process, does not need to be CE marked. There is a detailed explanation of this available in document CPR 07/07/11.

There is also interpretation relating to the importance, or not, of the project site boundary. Does CE marking only relate to products as they cross the site boundary? For example, does mortar delivered to site need to be CE marked, whereas for mortar from a site silo, only the constituents delivered to site need to be CE marked?

What does CE marking mean?

Following on from the previous thoughts, particularly the variation in diff erent product sectors, it will come as no surprise that a CE mark on one product type may have completely diff erent signifi cance to CE

Andrew Minson does not believe that the requirement to receive a CE marked product

where possible should change the way structural engineers specify products (with one

notable exception), but is keen to hear what others think.

Viewpoint

What does CE marking mean for structural engineers?

Much has been written about CE marking, but what does it mean for a structural engineer? In discussions, whether in committees or privately, there is little consensus. The purpose of this article is to prompt responses in the hope that some agreement can be reached. This matters as CE marking falls within a legal framework: the Construction Products Regulation (CPR).

CE marking applies to the placement of construction products on the market in the European Economic Area (EEA). It has been introduced over the last decade but is now mandatory throughout the EEA. The UK has been among the slowest on this journey, with very little voluntary adoption prior to July 2013, when it became mandatory for all products with a harmonised European standard to be CE marked. Harmonised standards are those with an Annex ZA, which generally address essential characteristics, conformity and CE marking of the product.

Product sectorsDiff erent product sectors have chosen to respond to CE marking diff erently (i.e. the CPR and the Construction Products Directive before).

• The structural steel industry in the UK has

"THE STRUCTURAL ENGINEER HAS LITTLE, OR PERHAPS NO, INFLUENCE OVER WHAT IS OR IS NOT CE MARKED"

TSE46_54-55 Viewpoint Marketing.indd 54 24/09/2015 11:20

www.thestructuralengineer.orgwww.thestructuralengineer.org

55

marking on a diff erent product type. I suggest that a good default position

for an engineer is that, while it is a legal requirement to receive a CE marked product when possible, this should be viewed as something extra; it is not a reason to change any of the current means of ensuring the right product or the necessary quality. The approach of the UK steel industry is a notable exception, and the steel industry can provide guidance on what CE marking means for its products (see box and ‘Further reading’).

A CE mark has an associated Declaration of Performance (DOP). What is included in the DOP is determined by the Annex ZA, and sometimes leaves choices for the manufacturer. How can you trust what is written in the DOP? This depends. There are four levels of attestation (i.e. checking) from self-audit to onerous, regular third-party audit. The level of attestation for a product is detailed in the Annex ZA. Therefore, there may be little comparability between CE marks on diff erent types of products.

Structural engineers

Structural engineers (and other designers) do have some obligation to ensure that products incorporated into the works are appropriately CE marked if relevant. But how much? Is this obligation fulfi lled by specifying that “all products are to be CE marked where possible”. This is not necessarily ducking responsibilities, because the CPR places legal responsibility

on the manufacturer to CE mark the products appropriately and on suppliers and distributors to have all products CE marked if it is possible to do so.

Or should the structural engineer do more: consider each product and how CE marking does or does not apply for the product in this project? This does not seem particularly onerous, although it is far from a trivial task. I would be interested to know whether architects do this, given the greater range of products they specify, and for them it is certainly not a trivial task.

Or should the structural engineer go even further? In London a pedestrian swing bridge was CE marked in November 2014 by the structural engineer. This is not only a case of structural steelwork being CE marked once erected, but a complete project being CE marked. Is this an indication of future application of CE markings to completed projects? I do not think so, but what views do fellow members have?

Acknowledgments

This article was requested by the Institution’s Design Practice, Risk and Structural Safety Committee in response to a desire to provide guidance to members.

Author biographyAndrew Minson

BEng, DPhil, CEng, MIStructE, FICE

Andrew is Executive Director at MPA

responsible for The Concrete Centre and

British Precast.

It is a legal requirement since 1 July 2014 for all fabricated steelwork delivered to site to comply with CE marking. As structural engineers we have to ensure we comply with our responsibilities under this directive. These are not arduous since our responsibility is to defi ne the Execution Class of the structure for the fabricator to work to. We will fi nd most building structures will fall within Execution Class 2, although some with greater consequences if they fail and some with dynamic loading will fall within Class 3 and ultimately Class 4.

How does one defi ne the Execution Class? Very simply. The SteelConstruction.info website has a CE marking guide which is based on the defi nitions in BS EN 1090-2:2008+A1:2011 (www.steelconstruction.info/uploads/ftpin/Steel_construction__CE_Marking_

v4/pubData/source/Steel_construction_-_CE_Marking_v4.pdf).

Let’s look at some simple examples:

A college building in a city centre, eight

storeys high with 2500m2 per fl oor

Consequence Class CC2Service Category SC1Production Class PC2

(most steel procured in the UK is S355)

From these three parameters one gets Execution Class 2 for this building

A 10-storey residential building

Consequence Class CC2Service Category SC1Production Class PC2

From these three parameters one gets Execution Class 2 for this building

A shopping mall with three storeys and

a car park, where the ground fl oor is

7500m2

Consequence Class CC3Service Category SC1Production Class PC2

From these three parameters one gets Execution Class 3 for this building

So, what do we do for fabricated steel components going forward?

• We make our clients aware of the directive requirements.• We note the Execution Class within the project specifi cation.

Angus Cormie

BSc, CEng, FIStructE, FICE, FIES, MWeldI

Chief Engineer, J&D Pierce (Contracts) Ltd,

Structural Steel Fabricators

CE marking of steel

E 1) European Commission (2014) 0707/1:

Explanations on Art 5(a) of the CPR [Online]

Available at: www.kwaliteitbouwprodukten.

nl/wp-content/uploads/2014/04/CPR-

07-07-1-Individual-and-non-series.pdf

(Accessed: June 2015)

Reference

Construction Products Association (2014)

Guidance Note on the Construction Products

Regulation, Version 3 [Online] Available

at: www.constructionproducts.org.uk/

publications/industry-aff airs/display/

view/construction-products-regulation/

(Accessed: June 2015)

British Constructional Steelwork Association

(2015) CE Marking [Online] Available at:

www.steelconstruction.org/resources/

technical/technical-ce-marking.html

(Accessed: June 2015)

The Concrete Centre (2013) CE Marking:

Guidance for Engineers [Online] Available

at: www.concretecentre.com/default.

aspx?page=1560 (Accessed: June 2015)

TRADA (2013) Eurocode 5 and CE Marking

[Online] Available at: www.trada.co.uk/

publications/download/?id=8BE07B28-

F2E2-4041-B209-62162B9398D8

(Accessed: June 2015)

Further reading

TSE46_54-55 Viewpoint Marketing.indd 55 24/09/2015 11:20