The legislation for CE marking of all construction products has been set out by the European Parliament and the Council of the European Union in regulation No 305/2011. Emma Freckingham discusses EN 1090 with Stuart Doleman and Alan Powney.
TWI Certification Limited (TWI CL) is a Notified Body under the Construction Products Regulation (CPR). TWI CL's CAESAS certification of Factory Production Control (FPC) systems, in accordance with EN 1090-1, enables manufacturers to CE mark structural steel or aluminium products placed on the market.
For welded products, compliance with EN 1090-1 also requires full compliance with ISO 3834, and TWI CL's long involvement in assessment of welding quality management brings significant additional value to their FPC assessments and provides the manufacturer with ISO 3834 certification alongside the FPC certificate.
A common reaction from industry is that CE marking legislation is cumbersome and counterproductive. Nonetheless, RJD Engineering Ltd's Managing Director Stuart Doleman and Head of Design and Engineering Alan Powney have found dealing with critical operations such as subsea and bridge construction definitely requires products conforming to current legislation. They envisaged a rush for this certification before 1 July 2014 and felt "getting in front of the competition by having TWI CL certify RJD to EN 1090 would best meet client expectations."
The revised legislation is regarded by RJD as complementing ISO 3834 and ISO 9001, as they already conform to those standards. Stuart Doleman considers, "meeting the requirements and advertising our conformity to EN 1090 is of great importance. We can advertise it as a feature and sell that as a quality system within the company."
The first step for a company to achieve certification is to complete the online application document. Upon receipt, the application is analysed and, if accepted, contracts are drawn up and assessment dates agreed. A preliminary visit is conducted to confirm the scope of work and highlight possible shortfalls prior to the main assessment.
To apply CE marking the manufacturer is required to operate to a certified Factory Production Control (FPC) system. Following completion of all appropriate conformity assessment tasks for the product(s), the manufacturer is required to complete a Declaration of Conformity (DOC). FPC certificates can only be issued after an outline of the manufacturer's DOC has been received by the Notified Body (TWI CL), and verified as compliant with the requirements of EN 1090-1.
Following certification of a company a copy of the certificate and company details will be published on the website in the 'Register of Certified Companies' section.
Alan Powney maintains membership with The Welding Institute for his professional registration and to keep up to date with new developments. For Alan, the next logical step was to employ TWI CL as the Notified Body to assess RJD, "because TWI Ltd is the world centre for metals joining, it seemed logical for us to go to the top of the tree which would mean more to clients. It is a practical application with TWI CL, which is what we look for. We get a more realistic approach."
Feedback on the assessment process is positive but from across the company size spectrum it would appear there is a lack of understanding of CPR, and even resistance to the new legislation. Reasons for this are varied including a hope that due to issue date, postponements enforcement may never happen. "It is probably down to the attitude of the companies and senior members of staff envisaging it is just a cost exercise and sticking their heads in the sand, naively thinking the legislation will not be enforced," added Alan.
On the positive side, CE marking should open up new business opportunities, and compliance with ISO 3834 should have a positive influence on product quality. Non-compliance may well result in a natural selection process, thus eliminating sub-standard businesses. Although a section of the construction world has a resistive attitude of suspicion towards the CPR legislation, a controlled conformity to EN 1090 standard must in time produce increased confidence in the ultimate users.
Contact Emma Boggust for more information or visit the website.
Manufacturer Certification Officer,TWI Certification Ltd, Granta Park, Abington, Cambridge CB21 6AL. Tel: 01223 899398. Fax: 01223 892588