Introduction to UKCA marking of structural metalwork: BS EN 1090-1 and the Construction Products Regulations.
EU & UK Law
As of January 1st 2021 structural metalwork in the mainland Britain is to be UKCA marked under the Construction Products Regulations (CPR), which were adopted in the UK in March 2011 to enforce the European Construction Products Directive. In Northen Ireland the CE mark continues to apply, along with a new UKNI mark. The aim of the directive was to harmonise the safety performance of construction products across the EU trading bloc and they apply to anything placed on the market, whether imported or manufactured in the EU. The CPD defines six principles for materials that are to be used in civil engineering:-
- Mechanical resistance & stability
- Safety in case of fire
- Hygiene, health & the environment
- Safety in use
- Protection against noise
- Energy economy & heat retention
As of July 1st 2014 any “series” manufactured structural metal components or kits that have been either made in the UK or imported, and to which a harmonised European standard applies, needed to comply with the CPR & CE marking requirements. The harmonised European standard that applies to structural metalwork is BS EN 1090-1:2009 +A1:2011 and it has been a criminal offence to supply structural metalwork after the 1st of July 2014 unless it conforms to this standard and carries a legitimate mark.
Further legislation was introduced in 2013 to allow the CPR to be enforced by the Trading Standards authority, which has the power to stop a business from trading and to withdraw any products supplied after July 1st 2014, until the company has shown that it complies with the Regulations. This will be costly for businesses that are discovered not to be complying with CPR, as they will be unable to trade during the long period needed to implement BS EN 1090-1 (see below) and will have to carry the cost of product recalls and fines. In severe cases Directors may also be imprisoned.
Who needs to comply?
The regulations apply to a wide range of activities involving “series” manufactured items:-
- Importers of structural metalwork kits or components
- Stockholders and metal processors that modify stock – for example by drilling, painting, bending, galvanizing etc.
- Manufacturers of metal components or kits that have a structural use in civil engineering
By “series”, the regulations mean any activity that an organisation carries out more than once, not just the production of a series of standard items. For example a factory that makes bespoke staircases is in the business of “series” manufacture of staircases and all of them will need to carry an appropriate mark. If the same factory produces a single platform as a special commission, this will be exempt. However if the factory decides to diversify into platforms and makes more than one, BS EN 1090-1 & appropriate marking will be required.
How do I comply?
Organisations covered by CPR will need to show that they comply with BS EN 1090-1, which involves a number of steps that culminate in certification by a third party, known as a Approved Body (AB). In the UK all ABs must be accredited themselves by the United Kingdom Accreditation Service (UKAS), many of which are familiar as certifying ISO 9001, ISO 14001 and other international management standards.
BS EN 1090-1 requires a number of actions to be in place, many of which will already be standard practise in well-run companies:-
- Purchasing systems will need to buy only UKCA or CE Marked sections, bolts and welding consumables where these are available.
- Designers must identify the execution class of the product, as defined in the companion standard BS EN 1091-2, which is determined by the potential risk to the public if the component or structure fails. The designers will also need well-defined specifications for components and kits.
- Prototypes will be subjected to initial type testing. Where type testing is impractical, for example on bespoke designs, the company can use calculations to serve the same purpose.
- Type testing is used to define Key Control Checks. These are monitored within a quality control system, called Factory Production Control (FPC). The FPC system also covers design and drawing controls; competence and training of staff; equipment maintenance & calibration; control of non-conforming product & keeping of records. If a company has ISO 9001 this is likely to contribute towards the requirement for a FCP system, but it may need to be modified extensively to comply with EN 1090-1.
- Where welding is part of the process, a Welding Quality Management system is needed and this must conform to BS EN ISO 3834. The company should either employ, or have access to, a Responsible Welding Coordinator to control their welding quality management system.
- Once the above in place the company is ready to become certified by a notified inspection body.
The organisation may decide that it has the skills, experience & free-time to meet these commitments in-house. Depending on the existing level of experience of putting management systems in place, an organisation should budget for up to 60 person-days to get BS EN 1090-1 up & running. As an alternative the organisation may decide to appoint a consultant to cover gaps that it has identified in skills & experience or time availability. An experienced consultant will be able to short-cut much of the planning process, which should lead to faster implementation and a major reduction in the time committed by the organisation’s own people.
Once the resources have been allocated then, apart from some straight-forward documents and procedures that any quality management system would need to work effectively, BS EN 1090-1 isn’t prescriptive and can be designed to be very light-weight and easy to maintain. Most well-run manufacturers of structural metalwork will already have the elements needed to conform to BS EN 1090-1 and a skilled practitioner can take what an organisation already does and demonstrate how it meets the standard, rather than having to write completely new processes from scratch. This avoids the need for employees to learn new ways of working and cuts down the time needed for implementation.
How can I get help?
The HSQE Department Ltd has years of experience helping companies in construction & allied trades to implement quality, environmental & safety management systems and so can reduce the time and cost needed to achieve certification. We can carry out gap analyses to identify what you need to do to comply with BS EN 1090-1, help you to define a plan to implement any changes, guide the preparation of Factory Production Control, carry out pre-certification checks on the compliance of your systems and manage the certification visit by the NB.