CE marking comes to steel sector

New rules introducing European conformity marking for steel fabrications will bring an extra tier of quality management to the sector.  Paul Thompson  reports.

The Construction Products Directive had its most recent impact on the steel sector in 2006 when CE marks were introduced for structural steel manufacturers such as Corus

European product conformity marks have become widespread throughout the construction industry over recent years thanks to the introduction of the Construction Products Directive (CPD) and the tightening of regulations across the European Union.

Intended to ensure that products manufactured for the permanent inclusion in construction works are reliable and safe the CPD had its most recent impact on the steel sector in 2006 when European conformity or CE marks were introduced for structural steel manufacturers such as Corus.

But the next European standard to be introduced to the sector (BS EN 1090-1) will cover the CE marking of fabricated steelwork and all those businesses that fabricate, weld or bend steel for use in the construction industry. There is some time yet before the standard comes into force, indeed a definite date for its introduction has yet to be finalised, but it is expected to be laid down in May 2010.

Once in force member states can CE mark fabricated steelwork and although it will not be enforced immediately by the end of its period of co-existence where it runs alongside existing standards, probably in May 2012, CE marking will become mandatory.

Non compliance could see contractors and fabricators spending time at Her Majesty's pleasure, so far better to spend some time getting the quality management systems in place now than developing them in a rush closer to the deadline.

For many the requirements will mean variations to existing quality management systems but with a greater emphasis on the quality of the final product than any of the existing quality systems currently in use.

"If companies already have the BS EN ISO 9001 Quality Management System up and running then they are 80% of the way to meeting requirements for a certified Factory Production Control system under the new standards," says David Moore, director of engineering at industry body the British Constructional Steelwork Association. "Existing systems will probably just need a little tailoring.

"It is all about producing the same product to the same quality and possessing the same properties time and again."

Welding Quality

Any Factory Production Control system will see steelwork contractors required to have a specific Welding Quality Management System in place and someone responsible for all welding activities - a Responsible Welding Co-ordinator.

This newly created role could be just about the most important position anyone could have within an organisation (see Welders co-ordinate responsibility, below) and is vital to the success of the WQMS which must be run in accordance to BS EN ISO 3834 - the certification scheme for all fusion welding of metals.

But the rigidity of this is determined by the classification of its fabrications that a contractor declares. This is a new departure for the steel construction sector and the Execution Classes range from EXC1 to EXC4 with the level of requirements increasing with every class.

It is vital that contractors state the correct capability for the work they carry out and work within those classes. Failure to do so could see them in breach of the directive.

Contractors declaring EXC2 will be certified to carry out most building work but for those installations where a greater degree of quality is required such as bridges or within nuclear power stations only contractors declaring the higher execution classes of EXC3 or EXC4 can be used.

Fabricators can carry out work in lower execution classes than those declared but not in a higher class. There are fears that these execution classes could be misinterpreted by clients as a competence mark and lead to some insisting on contractors with a declared class of EXC4 despite only requiring work of an EXC2 contractor.

"It is going to be an ongoing part of the education process," admits Moore. "But a building that requires welds to EXC2 doesn't mean the client is getting poorer quality, it just means that they are right for that application."

Others are concerned that there may be some element of competitive advantage or disadvantage for those contractors that are running CE marking processes during the co-existence period.

"At the moment what we are most concerned about is whether it will give us any advantage or disadvantage over others during that period," says Bone Steel business development director Stephen Ewer. "There shouldn't be too many problems though given the time frame."

Is marking necessary?

The frustration is that the CE marking has to be introduced at all given that most of the work carried out by UK contractors is within the UK. Even if work is carried out beyond these shores then a local certificated production facility would surely suffice given that the accreditation is factory-specific and non-transferrable.

"The reality is who needs it in the UK? What value does CE marking add to our product?" says Erle Andrews, director at Oldbury-based cold rolled steel fabricator and manufacturer Metsec.

"Having it doesn't bring anything to the table, it doesn't bring me or my customers any added value."

It is a point that is countered by Jeff Garner, recently appointed welding manager at the British Constructional Steelwork Association.

"Primarily it is a mark for clients. It is a quality reference that will give them confidence to specify products or systems from a producer and be safe in the knowledge that they have specified the correct quality," he says.

But despite these misgivings there is a confidence throughout the industry that the introduction of the new CE marking procedure will be trouble free. It has to be. It's on its way like it or not.

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Welders co-ordinate responsibility

With contractors needing to appoint staff to the newly created post of Responsible Welding Co-ordinator (RWC) before they can even be considered for certification the race is on to find the right calibre of personnel to this important role. It is one of the points that is causing most concern to businesses and is an area where BCSA welding manager Jeff Garner is focusing his efforts.

"The biggest hurdle to most businesses will be identifying the person who is capable of becoming the RWC," says Garner. "It will be a challenge to find the right person with the right level of competency and sufficiently versed in quality management systems and everyday data management.

"It's not just a question of promoting your best time-served welder, they also have to be competent to be able to manage these systems. They will be responsible for control procedures, ensuring the workforce have the correct qualifications and carrying out technical reviews. It is a very important post."

Often many companies will already have staff carrying out similar roles but the difficulty is on identifying the potential. Some such as Bone Steel have already taken the decision that the promotion will come from within and are thankful that the training programme it has in place is already helping highlight potential RWCs.

"We took the decision to upskill and train our existing staff to a high level of weld certification and we are happy that we will be able to find our RWCs from our existing personnel," says business development director Stephen Ewer.

But for those smaller companies that may not need a full-time RWC the likelihood is that they will have to subcontract out the role. In this instance always look for freelancers with a recognised International welding qualification, says Garner.

"Subcontracting the role out is fine but not the preferred option. As a note of caution we would recommend only use those with the appropriate International welding engineer, technologist or specialist qualification", he says.