CE marking of structural steel – an update for engineers
31 January 2017
Since 1 July 2014, CE Marking of structural steelwork has become mandatory for fabricated structural steelwork in accordance with EN 1090-1. It is essential that all parties to the steel construction supply-chain learn and understand the new requirements in order to ensure compliance.
Non-compliance is clearly catered for within the Regulations, with fines up to €500,000 and/or imprisonment. However, the implications for the end user are also significant and not so obvious. If a building is handed over to the client and it is determined that the steelwork has not been fabricated in accordance with the harmonised standard and engineers specification, then it cannot be put into service until the steelwork has been replaced.
In this case, any claims or penalties imposed on the owner or builder by the Health & Safety Authority would not be covered by insurance and the steelwork contractor (along with whoever else had a role in building the structure) could be found negligent.
Alternatively, if a building collapsed (in the winter of 2010-11, more than 5,000 buildings collapsed after a heavy snowfall in the UK) and someone was injured, and a claim was subsequently made for these injuries, the owners’ insurance company could be liable for the losses under the third-party liability section of their insurance which covers the owners legal liability as property owner.
The insurances of any other contractors involved in the build are also likely to be called on.
The Construction Products Regulation (CPR) came into force on 1 July 2013 and has direct legal application across the entire European Union since then, but each Member State is responsible for regulating for its own market surveillance activities in accordance with the specific requirements of the CPR.
In Ireland, the CPR provide for:
- The market surveillance of construction products having regard to the requirements of the CPR and Regulation (EU) No. 765/2008;
- The establishment of building control authorities as the market surveillance authorities for construction products (although the Minister has power to appoint other competent authorities to undertake market surveillance in respect of specific products areas);
- The appointment of authorised officers and their powers in respect of market surveillance;
- Offences, penalties and prosecutions.
Correct CE Marking of structural steel
In order to satisfy the general assumptions stated in I.S. EN 1990, relating to the execution of structures designed to the Eurocodes, all structural steelwork shall be undertaken by a steelwork contractor who has the necessary technical capability and competence for the type of work to be undertaken.
These requirements would be satisfied by registration and audit through a notified body such as the Steel Construction Certification Scheme (SCCS), National Standards Authority of Ireland (NSAI), TÜV Nord Group or similar reputable notified bodies, to the levels appropriate for the technical complexity of the structural steelwork.
It should be noted that not all notified bodies are auditing to the same level and there is an onus on the engineer or main contractor engaging the steelwork contractor to carry out due diligence before appointing any steelwork contractor who will be delivering fabricated structural steelwork to site.
Contractors should only appoint a steelwork contractor with an Execution Class equal to (or higher than) that required for the project and has the necessary technical capability and competence for the type of work to be undertaken as determined by the designer.
Depending on the criticality of the structure, and specifically for Execution Class 3 & 4 contracts, it may be prudent to appoint an independent inspection authority whose role is to ensure the fabrication is completed in accordance with I.S. EN 1090 and the project specification.
The steelwork contractor should undertake a review to confirm that their technical capability and competence is sufficient for the execution of the works. The review should be documented and be submitted for the approval of the Employer’s Representative in advance of execution. The review should include supporting evidence that includes but not be limited to:
- Details demonstrating compliance with I.S. EN 1090-2;
- Type and size of construction works;
- Product forms and thicknesses;
- Material grades;
- Welding processes;
- Welding procedure specifications and welder qualifications;
- Painting processes;
- Level of welding control in accordance with the relevant part of I.S. EN ISO 3834;
- Qualifications of the responsible welding co-ordinator;
- Qualifications of visual weld inspector.
In order to satisfy the requirements the steelwork contractor should have an independently certified quality management system complying with I.S. EN ISO 9001 in place for all structural steelwork. A quality plan setting out all specified quality practices, resources and sequences of activities relevant to the contract should be submitted to the designer for approval. The quality plan shall be developed using the list of recommended items in Annex C of I.S. EN 1090-2 for guidance.
Responsible welding co-ordinators and welding quality-management system
The manufacturer shall implement a written inspection and test plan for checking and recording that manufactured components conform to their component specification and this shall be submitted to the designer for approval.
There are two key elements which relate to welding activities. These are the appointment of a responsible welding co-ordinator (RWC) and the implementation of a welding quality-management system (WQMS).
The RWC is 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.
For Execution Class 2, the RWC shall have been trained and assessed by a qualified international welding engineer (IWE). For Execution Class 3 & 4, the RWC should be a qualified IWE. It is important for main contractors and engineers to check these qualifications meet the requirements of the project specification.
Due to the requirement of these qualifications, this position is more likely to be a sub-contracted position for Execution Class 3 & 4 structures. There is no requirement for an RWC for fabricators working to Execution Class 1.
The implementation of a welding quality management system (WQMS) in accordance with the relevant part of I.S. EN ISO 3834 is a major requirement of I.S. EN 1090-2. The relevant part of I.S. EN ISO 3834 is determined by the Execution Class declared by the fabricator for its fabricated steel.
Specifier selects the Execution Class required
For any project, the required quality of fabrication or Execution Class (EXC) must be specified. The procedure to determine the EXC must be determined according to the requirements of Annex C of I.S. EN 1993-1-1 and its associated National Annex. The EXC must be specified for:
- The works as a whole;
- An individual component;
- A detail of a component.
The engineer is responsible for specifying the EXC for the structure (the works as a whole) and for components and details where it is appropriate to specify an Execution Class different to that specified for the structure.
Where different, the Execution Class for a component or detail should not be lower than that specified for the works as a whole. The EXC for a component or detail should be clearly identified in the execution specification if it is different to the Execution Class for the structure.
There are four execution classes which range from EXC 1 (e.g. farm buildings) which is the least onerous through to EXC 4 (e.g. stadia and long-span bridges) which is the most onerous. Designers and specifiers should amend their project specifications to include references to the new standards.
The procedure for determining the EXC for buildings is a straightforward two-step process:
- Determine the Consequences Class;
- Select the Execution Class.
Whilst each building needs to be considered on its own merits, EXC 2 will be appropriate for the majority of buildings constructed in Ireland. Designers need to fully familiarise themselves with the requirements of I.S. EN 1090 and should amend their project specifications to include references to the new standards. They should employ the services of an independent inspection authority to ensure compliance with the project specification when the structure is in the higher execution classes.
The following steel and aluminium products are covered by the scope of EN 1090-1, when the intended use comprises a structural function. This list of structural components is indicative and non-exhaustive:
- Balconies and balustrades (barrier/edge protection), fire escapes, handrails (barriers/edge protection), walkways, including open mesh flooring (if integral part of the load-bearing structure of the construction works);
- Bridges, sign and gantry girders;
- Buildings, mezzanine floors, canopy framing, carports and catwalks, structural frames for shelters, winter gardens and green houses;
- Bended products from hot rolled beams and steel plates, cellular beams, curved and bent beams and girders, plate girders;
- Crane-supporting structures including crane runway beams and crane rails;
- Grandstands and stadia;
- Machinery supports, pipeline supporting structures and pipe supporting structures;
- Structural frames for buildings, warehouses, schools, hospitals, dwellings, industrial and agricultural sheds;
- Silos and tanks that are not covered by EN 12285-2;
- Towers and masts.
How to ensure steelwork is legally CE Marked
Since 1 July 2014, it has been a legal requirement for all fabricated structural steelwork delivered to site to be CE Marked. It is now unlawful to place structural steel products or fabricated structural steel on the market if they are not CE Marked.
Placing structural steelwork the market that is not CE marked (or incorrectly CE marked) is catered for within the regulations with fines up to €500,000 and/or imprisonment. Building control officers should perform market surveillance of construction products having regard to the requirements of the CPR and Regulation (EU) No. 765/2008.
Clients and main contractors should only consider steelwork contractors with the execution class and technical competence required for the project. Existence of a Factory Production Control Certificate and Welding Certificate does not guarantee competence or compliance for a project. This should be done by audit prior to contract award and subsequent surveillance audits by competent personnel depending on the criticality of the structure/execution class.
Clients, contracting authorities, designers and specifiers should amend their project specifications to include references to the new standards. As structural steelwork is a safety critical product clients, main contractors and engineers should also ensure that the work is performed in accordance with EN 1090-2 and the project specification. In certain cases, an independent inspection authority should be appointed to verify compliance with the technical requirements.
Engineers, main contractors, building control officers and farm building inspectors need to gain technical knowledge on how to assess the competencies of steelwork contractors, specifically relating to welding of structural steelwork.
Insurance companies that insure suppliers of structural steel should ensure that these suppliers are fully compliant with the required standards and are working within their technical capability and correctly CE Marking their products.
Gerry McCarthy, BEng, MSc, IWE, CEng, MIEI, MWeldI, international welding engineer
- CE Marking of Structural Steelwork for Engineers (Thursday, 16 February 2017:Clarion Hotel Cork, Lapps Quay, Cork)
- Understand the requirements of CE Marking of structural steelwork
- Understand the content of a range of technical documentation and be able to assess such documentation for compliance.
- Be in a position to develop contract specifications to ensure compliance with the Construction Production Regulation.
- Interpret welding procedure specifications (WPS) welding procedure qualification records (WPQR) and welder qualification test certificates (WQTC).
- Understand the terminology used in welding, testing, quality assurance and quality control.
- Appreciate the need for welding communication including the correct use of weld symbols and their advantages and limitations.
More information can be found on www.wqms.ie.
- Construction Products Regulation:
- Structural Eurocodes:
- Building Regulations:
- Market Surveillance: