CE Marking of structural steelwork – stakeholder responsibilities

Author: Gerry McCarthy, BEng, MSc, DipFM, IWE, CEng, MIEI, MWeldI, international welding engineer and director of WQMS – Welding Quality Management Services

The Construction Products Regulation (CPR) places new legal obligations on manufacturers, importers and distributors of construction products being placed, or being made available, on the EU marketplace. It is essential that all parties to the steel construction supply chain (and other relevant supply chains in the construction products sector) learn and understand the new requirements, in order to allow sufficient preparation time for compliance. (Refer to the following CPR Information Note published by the Department of the Environment, Community and Local Government, available here.) This article discusses the implications of the CPR on the relevant stakeholders within the structural steel supply chain in Ireland, but focuses on the requirement for fabricated steelwork to be CE Marked from 1 July 2014. At a rough estimate, there are up to 100 steelwork fabricators in the Republic of Ireland, all of whom need to be working towards achieving compliance with their new obligations. As a first step, many fabricators may need to improve their knowledge of the new standards and increase their awareness of how compliance may be achieved. It is estimated that it could take anything from six to 12 months to achieve certification. There are now less than 15 months to the date of 1 July 2014, after which it will be unlawful to place, or make available, non-compliant steelwork products on the market. CE MARKING OF FABRICATED STRUCTURAL STEEL The CPR (amongst other requirements) requires CE Marking for all construction products, covered by a harmonised European standard or conforming to a European Technical Assessment. A full list of harmonised standards can be found on the EU’s NANDO website, while a full list of ETAs can be found on the EOTA website. From 1 July 2013, CE Marking will be mandatory for the following range of steel products:

Open sections – I.S. EN 10025-1;
Hollow sections (Hot finished) – I.S. EN 10210-1;
Hollow sections (Cold formed welded) – I.S. EN 10219-1;
Plates – I.S. EN 10025-1;
Structural bolts (Non-preloaded structural bolting assemblies) – I.S. EN 15048-1;
Structural bolts (High strength structural bolting assemblies for preloading) – I.S. EN 14399-1.

[caption id="attachment_3843" align="alignright" width="1024"] Suppliers can only supply CE-marked steel, bolts and welding consumables to steel fabricators[/caption] This means that suppliers can only supply CE-marked steel, bolts and welding consumables to steel fabricators. These products must be accompanied inspection certificates to the appropriate standard. For steel sections, this is a type 3.1 inspection certificate to I.S. EN 10204 and the certificate must be traceable to the steel supplied. This involves labelling or marking the unique heat number/cast number on the steel. The surface condition of the steel is also required meet certain requirements as defined by the standard. These conditions become more stringent with increasing levels of Execution Class. From next July, CE Marking will be mandatory for fabricated structural steelwork in accordance with I.S. EN 1090-1 delivered on or after 1 July 2014. The requirement for steel products and, in particular, fabricated steelwork to be CE Marked represents a major development for engineers, contractors and steelwork specialists and demands careful attention to the new obligations imposed. RESPONSIBILITIES FOR STEEL FABRICTORS/CONTRACTORS Notwithstanding the steel products covered above, which will require to be CE Marked from 1 July 2013, a steelwork fabricator will be treated as a manufacturer under the CPR from 1 July 2014. This will require all fabricated structural steelwork delivered to site to be CE Marked. In order to be able to CE Mark the fabricated structural steelwork that they produce, steelwork contractors are required to follow the procedures outlined in Annex ZA of I.S. EN 1090-1. The system of assessment and verification of constancy of performance required for structural steel components with an intended use in construction works is System 2+ (as described in Annex V of the CPR). This requires the manufacturer to undertake Initial Type-Testing of the product and Factory Production Control (FPC). A third-party assessment must also be carried out by a notified production control certification body, who shall issue a certificate of conformity of the factory production control on the basis of:

Initial inspection of the manufacturing plant and of factory production control;
Continuous surveillance, assessment and evaluation of factory production control.

A FPC system conforming to the requirements of EN ISO 9001 quality management system and made specific to the requirements of EN 1090-1 shall be considered to satisfy the above requirements. There are two key elements required that are specific to EN 1090-1 which relate to welding activities. They include the appointment of a responsible welding co-ordinator (RWC) and the implementation of a welding quality management system (WQMS). The term ‘responsible welding co-ordinator’ is used to identify the person who is competent to control and supervise the fabricator’s welding activities. Fabricators need to appoint at least one RWC with the technical knowledge and experience appropriate for the range of steelwork being manufactured. I.S. EN 1090-2 sets out the technical knowledge requirements for the RWC, based on the fabricator’s declared execution class and materials used. It makes reference to the International Standard for Welding Co-ordination (I.S. EN ISO 14731), which specifies three categories of technical knowledge – i.e. comprehensive, specific and basic – and links these respectively to international welding engineer (IWE), international welding technologist (IWT) and international welding specialist (IWS). Due to the requirement of these qualifications, this position is more likely to be a sub-contracted position. There is no requirement for an RWC for fabricators working to Execution Class 1. [caption id="attachment_3847" align="alignright" width="1024"] Fabricated steelwork must be CE Marked from 1 July 2014[/caption] The implementation of a WQMS in accordance with the relevant part of I.S. EN 3834 is a major requirement of I.S. EN 1090. The relevant part of I.S. EN 3834 is determined by the Execution Class declared by the fabricator for its fabricated steel. This is where the most work will be required by fabricators, as there are a lot of standards that need to be adhered to in order to demonstrate compliance with I.S. EN 3834. The following items need to be addressed in order to implement a WQMS to I.S. EN 3834:

Requirements and technical review
Sub-contracting
Welding personnel
Welders and welding operators
Welding co-ordination personnel
Inspection and testing personnel
Equipment
Welding and related activities
Production planning
Welding procedure specifications
Qualification of welding procedures
Work instructions
Procedures for preparation and control of documents
Welding consumables
Storage of parent materials
Post-weld heat treatment
Inspection and testing
Inspection and testing before welding
Inspection and testing during welding
Inspection and testing after welding
Inspection and test status
Non-conformance and corrective actions
Calibration and validation of measuring, inspection and testing equipment
Identification and traceability
Quality records

The amount of procedures and level of documentation required to demonstrate compliance with the standard increases with each increasing level of Execution Class. When the above systems have been put in place, the fabricator must make arrangements with a Notified Body to carry out a certification audit. The initial certification audit is a two-stage process. Stage 1 is an audit of the fabricator’s management system documentation (procedures, qualifications etc) and to evaluate the fabricator’s resources and the preparedness for the stage 2 audit. The stage 1 audit will be reduced for companies with: a certified quality management system to I.S. EN 9001:2008 and a certified welding quality management system to I.S. EN 3834. Stage 2 audit covers the following areas:

Evaluation of the implementation of the management system.
Is the work being done in the manner documented in the procedures?
Are records being kept to demonstrate the work is done as per the procedures?
What procedures are in place for handling non-conformances?
What procedures are in place to prevent recurrence of non-conformances?

The Notified Body will then issue a FPC certificate and Welding Certificate, identifying the Execution Class that the steelwork contractor has achieved. The Notified Body will also carry out continuous surveillance, assessment and approval of the FPC, which will typically include an annual audit to ensure continued competence to the declared Execution Class (Table B.3 of I.S. EN 1090-1 sets out minimum levels for the routine surveillance intervals). Compliance with the requirements of EN 1090-1 is no small task and places obligations on the steelwork contractor that are onerous and take significant time to put into place. Most industry membership organisations are suggesting that the process to achieve CE Marking certification will take about 12 months from start to finish. However, the number of Notified Bodies for EN 1090-1 is limited and, as the skills needed by the assessors are quite specialised, it is likely to become more difficult to book a certification audit as the deadline approaches. Steelwork fabricators and contractors are encouraged to engage with their obligations under the CPR and allow sufficient preparation time to ensure compliance. RESPONSIBILITIES FOR DESIGNERS AND SPECIFIERS Since the implementation of the Structural Eurocodes in Ireland in March 2010, Eurocode 3 (I.S. EN 1993) became the relevant design code for the design of building and civil engineering works using structural steel. Conflicting standards with the same scope and field of application, e.g. BS 5950 and BS 5400 were withdrawn by the relevant standards body on that date. This became the main driver for the review of Part A of the Building Regulations and created the requirement to update references in Technical Guidance Document A. Where works are carried out in accordance with this guidance, this will, prima facie, indicate compliance with Part A of the Building Regulations. Other bodies such as the National Roads Authority have also updated their requirements and specifications accordingly. Designers should use I.S. EN 1993 when designing with structural steel. In order to help secure the safety of the designed structure using the Eurocodes, designers are also required to follow the relevant execution code which specify the requirements for all activities performed for the physical completion of the works, i.e. procurement, fabrication, welding, mechanical fastening, transportation, erection, surface treatment and the inspection and documentation thereof. The relevant execution standard covering fabricated structural steelwork is I.S. EN 1090: Execution of steel structures and aluminium structures.

Part 1 of the standard is the Requirements for Conformity Assessment of Structural Components. It describes how manufacturers can demonstrate that the components they produce meet the declared performance characteristics (the structural characteristics which make them fit for their particular use and function).
Part 2 is the Technical Requirements for Steel Structures. It specifies the requirements for the execution of steel structures to ensure adequate levels of mechanical resistance and stability, serviceability and durability. It determines the performance characteristics for components that the manufacturer must achieve and declare through the requirements of Part 1.

For any project, the required quality of fabrication or Execution Class must be specified. I.S. EN 1090-2 requires the Execution Class to be specified for the works as a whole, an individual component, and a detail of a component. [caption id="attachment_3849" align="alignright" width="1024"] Responsible welding co-ordinators control and supervise the fabricator’s welding activities[/caption] In some cases, the Execution Class for the structure, the components and the details will be the same while in other cases the Execution Class for the components and the details may be different to that for the whole structure. There are four execution classes that range from Execution Class 1 (e.g. farm buildings), which is the least onerous, through to Execution Class 4 (e.g. stadia and long span bridges), which is the most onerous. The procedure for determining the Execution Class is a straightforward, four-step process:

Determine the Consequence Class – Table B1, I.S. EN 1990 or Table A.1, I.S. EN 1991-1-7: The purpose of categorising the Consequence Class is to ensure that buildings (and other structures) are constructed with the appropriate level of quality control within the fabrication process. [Usually 2a or 2b]
Define the Service Category – Table B.1, I.S. EN 1090-2: Service categories are the method used in I.S. EN 1090-2 to consider the risk from the actions to which the structure and its parts are likely to be exposed to during erection and use, such as fatigue and likelihood of seismic actions. They also consider the stress levels in the components in relation to their resistance. [Usually SC1].
Define the Production Category – Table B.2, I.S. EN 1090-2: Production categories are the method used in I.S. EN 1090-2 to consider the risk from the complexity of the fabrication of the structure and its components, e.g. application of particular techniques, procedures or controls [either PC1 or PC2].
Derive the Execution Class – Table B.3, I.S. EN 1090-2: Having determined the Consequence Class, Service Category and Production Category for a building, derive the required Execution Class.

Whilst each building needs to be considered on its own merits, Execution Class 2 (EXC2) will be appropriate for the majority of buildings constructed in Ireland. If the Execution Class is not specified on a project, Clause 4.1.2 of I.S. EN 1090-2 states that EXC2 shall apply. It should be noted that steelwork contractors with EXC3 capability can be used for EXC1, 2, & 3; and a steelwork contractor with EXC2 capability can only be used for EXC1 & 2. Designers and specifiers should amend their project specifications to include references to the new standards. RESPONSIBILITIES FOR CLIENTS AND MAIN CONTRACTORS The client or main contractor engaging the steelwork contractor should carry out due diligence before appointing any steelwork contractor who will be delivering fabricated structural steelwork to site and should only appoint a steelwork contractor with an Execution Class equal to that required for the project, as determined by the designer through I.S. EN 1090-2. For all fabricated structural steelwork delivered to site from 1 July 2014, there is a legal requirement under the CPR that it is CE Marked. In order for a steelwork contractor to demonstrate their right to CE Mark their products, they must provide the following three documents: Factory Production Control Certificate, Welding Certificate and Declaration of Performance. It is advised that the client or main contractor check that the CE Marking and the Declaration of Performance of such products are appropriate for the works and meet the designer’s specification when they are delivered to site. ENFORCEMENT OF THE CPR IN IRELAND Draft National Regulations (currently out for public consultation at the time of this article) are required to facilitate the full implementation in Ireland of the CPR. (Refer to the Department of the Environment, Community and Local Government website.) They include, amongst other things, the following:

Provisions for the market surveillance of construction products;
Building control authorities shall be the market surveillance authorities although the Minister may also appoint other competent authorities to undertake market surveillance in respect of specific products areas;
Provisions for the appointment of authorised officers and their powers in respect of market surveillance;
Provisions for offences, penalties and prosecutions;
Provisions for the destruction or disposal of construction products where a person has been convicted on indictment of certain offences under the regulations.

SUMMARY

From 1 July 2013, CE Marking will be mandatory for all construction products covered by harmonised European Construction Product Standards. A full list of harmonised standards can be found on the EU’s NANDO website.
From 1 July 2014, it will be a legal requirement for all fabricated structural steelwork delivered to site to be CE Marked.
Steel work fabricators and contractors need to immediately engage with their obligations under the CPR in order to allow sufficient preparation time for compliance as it could take anything from six to 12 months to achieve certification.
It will be unlawful to place structural steel products or fabricated structural steel on the market after these respective dates if they are not CE Marked.
Clients and main contractors should only consider steelwork contractors with an Execution Class equal to that required for a project and ensure that the declared performance meets the specification/design.
Clients, contracting authorities, designers and specifiers should amend their project specifications to include references to the new standards.

The Welding Institute Annual Conference for 2013 is set to deal with 'CE Marking of Welded Construction Products'. The conference will take place on Wednesday, 5 June 2013 at the Bessemer Conference Centre, Advanced Manufacturing Park, Wallis Way, Catcliffe, Rotherham S50 5TZ. For more details, see the conference website.