THE PEC GROUP - FAQ

CE MARKING - A Legal Requirement

 

In 2014, our sector faced one of the most substantial legal changes in its history; as CE Marking of all our products became mandatory in all European Union Member States and throughout the EU Economic Area. In order for companies to legally provide manufactured components and steelwork they must be Accredited by a UKAS Certification Body; such as Llyods, BBA, BSI etc.

Compliance with the requirements of BS EN 1090 is no small task, and places obligations on companies in our sector that are onerous and take significant time to put into place. To eliminate the risk of non-compliance with the CPR and CE Marking it is recommended that clients and main contractors only award projects that will have fabricated components and structural steelwork to companies who have already achieved CE Marking accreditation.


When did the CE Mark become Law?

All companies in our sector must, since July 1st 2014, be accredited by a UKAS Certification Body - in our case, this will be BBA.

Important - For the Construction Industry?

For all fabricated structural steelwork delivered to site from July 1st 2014, there is a legal requirement under the CPR that it is CE Marked. In order to achieve this, the client or main contractor should appoint a steelwork contractor with an Execution Class equal to that required for the project, as determined by BS EN 1090-1.

 

It should be noted that steelwork contractors with EXC2 capability can be used for EXC1 & 2; Compliance with the requirements of BS 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. To eliminate the risk of non-compliance with the CPR it is recommended that clients and main contractors only award projects that will have fabricated structural steelwork delivered to site after July 1st 2014 to steelwork contractors who have already achieved (or are close to achieving) CE Marking accreditation.

 

If a non-EU steelwork contractor is used on a project, the CPR puts liability on clients and/or main contractors. In that instance, the party engaging the steelwork contractor would be classed as an importer under the CPR and must comply with ‘Obligations of Importers’ given in Article 13 of the regulations.

Who is affected by the new Legal Requirement of CE Marking?

CE Marking places legal obligation on every company that supplies or modifies any components or structural steelwork covered by BS EN 1090 - the importance and impact of this new legal requirement places an onus on all those listed below, to ensure the engineered products and steelwork sourced for their projects conform to the new Law.

 

  • Architects
  • Acoustic Enclosure Suppliers
  • Builders
  • Construction Companies
  • Container Modifiers / Suppliers
  • Plant Room Suppliers
  • Quantity Surveyors
  • Re-sellers
  • Structural Engineers

 

Any project that involves the protection of human life - from Balustrading to Blast Rooms, from Machinery Tables to Mainframes; engineering products and components must carry the CE MARK.

 

What if I use components or steelwork not CE Marked / Supplied from a non-UKAS accredited supplier?

As of July 1st 2014, it has been illegal to supply, manufacture or use any component or structural steelwork within the EU, if it does not carry the CE Mark required by the new Harmonised European Standard. CE Marking brings in its arsenal both civil and criminal liability for failure to comply with the legal requirements as set out in the new Harmonised European Standard.

 

In the construction industry, for example, a building cannot be signed off by building control unless all components and steelwork are accompanied by the relevant CE Certification, this can only be provided by a UKAS Accredited Manufacturer, such as The PEC Group.

 

Other sectors may find it difficult or impossible to obtain insurance on manufactured products that do not conform, and if, in an unfortunate event, a person is injured (fatally or otherwise) criminal prosecutions could be brought against the individuals responsible, or the company itself in the form of Corporate Manslaughter.

 

Whilst CE Marking in our sector places several burdens on manufacturers and suppliers, The PEC Group is ensuring that it follows the Standards closely; therefore, we are vetting all suppliers to us, and ensuring we implement our CE procedures on all of our products from July 1st 2014.

 

It should be noted that if a non-EU steelwork contractor is used on a project, the CPR puts liability on clients and/or main contractors. In that instance, the party engaging the steelwork contractor would be classed as an importer under the CPR and must comply with ‘Obligations of Importers’ given in Article 13 of the regulations.

What must Steelwork and Engineering Companies have in place to conform?

In order to supply manufactured components and structural steelwork, the company must have the following in place:

 

  • UKAS Accreditation
  • Factory Production Control Certificate (FPC) - including initial type testing
  • Welding Certification
  • Declaration of Performance
  • A Welding Quality Management System (WQMS) in accordance with ISO 3834
  • A Quality Control System compliant with BS EN ISO 9001
  • A Responsible Welding Co-ordinator
  • Employ / Sub-contract an International Welding Engineer / Technologist (IWE/IWT)
  • A Purchasing Management System, in line with the above, which ensures all products used in a manufactured components or steelwork are themselves CE Marked and accompanied by a compliant Test Certificate - this includes welding consumables.
What are "Execution Classes" and "Consequence Classes"?

The new Standard contains several different types of classifications, all of which inter-link.

 

There are Consequence Classes 1-3 (CC), Service Categories 1-2 (SC), Production Categories 1-2 (PC) and Execution Classes 1-4 (EC).

 

The PEC Group will be accredited to Execution Class 2, this will cover the group for all work contained within the following classifications and categories:

 

  • CC1 | SC1 and SC2 | PC1 and PC2
  • CC2 | SC1 | PC1 and PC2

 

See Below for an explanation on what each of the above abbreviations cover.

Note, on the approval of a Structural Engineer, The PEC Group may be able to provide CE Marked Products in Categories not listed above.

Classifications

 

Consequence Class Description
CC1 High consequence for loss of human life

or economic, social or environmental consequences very great

CC2 Medium consequence for loss of human life;

economic, social or environmental consequences considerable

CC3 Low consequence for loss of human life

and economic, social or environmental consequences small or negligible

 

Service Category Description
SC1
  • Buildings and components designed for quasi static actions only (Example: Buildings, Enclosures, Plant Rooms)
  • Structures and components with their connections designed for seismic actions in regions with low seismic activity and in DCL
  • Structures and components designed for fatigue actions from cranes (class S0)

 

SC2
  • Structures and components designed for fatigue actions according to BS EN 1993. (Examples: Road and railway bridges, cranes (class S1 to S9 ), structures susceptible to vibrations caused by wind, crowd or rotating machinery.)
  • Structures and components with their connections designed for seismic actions in regions with medium or high seismic activity and in DCM and DCH.

 

 

Product Category Description
PC1
  • Non welded components manufactured from any steel grade products
  • Welded Components manufactured from steel grade products below S355
PC2
  • Welded Components manufactured from steel grade products from S355 and above
  • Components essential for structural integrity that are assembled by welding on site
  • Components with hot forming manufacturing or receiving thermic treatment during manufacturing
  • Components of CHS lattice girders requiring end profile cuts

DCL, DCM, DCH: Refer to Ductility classes according to BS EN 1998-1

For classification of fatigue actions from cranes, see BS EN 1991-3 and BS EN 13001-1.

Can I find out more information?

You may contact our Legal Department on +44 (0) 1179 820 235 for additional advice in relation to CE Marking in our sectors. Alternatively, you may wish to contact one of our sales team to discuss your requirements for a specific job on +44 (0) 1179 820 201