Without EN1090 your structure might kill someone
We’re EN1090 approved and keen to help engineers, architects and buyers understand and comply with this life-saving regulation. Many people – customers and fabricators alike – are unaware of EN1090, let alone understand when and how it applies to their structures.
Apart from the protection it guarantees everyone involved, there are clear commercial advantages: effective systems and processes lead to efficiency, cost control and fit-for-purpose fabrication. It’s more than just dotting ‘i’s and crossing ‘t’s, it’s a safety net for everyone. EN1090 is a no-brainer.
Steel fabrication regulations save lives
Many professionals, familiar with EN1090, confess to having trouble deciding if and when it applies to their projects. Architects, civil and construction engineers, QA, procurement, even testing personnel, are often unclear about the definition and application of EN1090.
At Alroys, we have great respect for the purpose of EN1090 which, like many regulations, exists for reasons of safety. Quite simply, it regulates the fabrication and assembly of steel and aluminium structures to prevent them from collapsing or failing in some way thereby causing injury or death. It comes down to load-bearing and designing a structure that provides mechanical resistance and stability.
Why is EN1090 so confusing?
Let’s start with examining the regulation. EN1090 is broken down into 2 parts:
1. The execution class of the product according to the potential risk to the public – from farm buildings to long span bridges.
2. CE Marking of steel and aluminium to comply with EN1090.
1. Which execution class does your structure fall into?
Confusion arises in deciding if a structure falls into any of the Execution Classes. To Alroys, this is no grey area – you just need to consider carefully whether the structure poses a risk to the public.
Take, for example, a basic external canopy, above a doorway or protecting an area where equipment (such as gas canisters) is kept. No one’s going to stand on the canopy are they? No, unlikely. So no risk to human life. Well yes there is – snow might collect on the canopy and snow’s heavy. There’s your risk to human life. It’s a structure that comes under Execution class 1.
2. CE Marking needs monitoring
The other misunderstanding with EN1090, is a little less obvious and threatens the whole fabrication process if ignored: CE Marking (item 2 above).
The CE Marking on your aluminium and steel must comply with EN1090 throughout the process. So, if welding is part of the process, you need a welding quality management system which, amongst other things, will help you maintain the integrity of your materials’ original CE Marking. The reality is that even if welding isn’t involved, you will be altering the physical properties of the metal in some way by simply drilling or bending. This means your metal no longer conforms to its original CE Marking. Easy to remedy – you just need to know what you are doing.
EN1090 makes you plan your fabrication
The question of whether EN1090 applies must start at the design stage. We query – interrogate even – the purpose of the ‘structure’ and the fabrication process it will go through because EN1090 cannot be applied retrospectively – this process is called the technical review.
Let me repeat that: EN1090 cannot be applied retrospectively. So, if you discover some way down the production process that the structure does fall into an Execution Class, you have to start again. And that’s costly.
The regulation is simple enough, it’s the interpretation and application that takes experience and knowledge:
Execution Classes for EN1090
First, decide into which (if any) Execution Class your project falls. There are 4 ranging from basic farm buildings and general commercial structures, to bridges and nuclear sector frames. Then you need a fabrication specialist who’s approved to undertake the relevant class of work.
CE Marking is the manufacturer’s declaration that all the products meet the requirements of the applicable European directives, not just the steel or aluminium. EN1090 compliant CE Marking applies to bolts, fixings and welding consumables. Remember it’s not just welding that can compromise a CE Marking – drilling a single hole means you need to follow a process to maintain the integrity of your metal.
Welding has its own EN1090 quality control system to ensure the process doesn’t compromise the load-bearing features of the structure or affect CE marking in any way.
Quality control systems
There are 2 quality control systems relating to EN1090:
1. Factory Production Control (FPC) which covers design and drawing controls, competence and training of staff, equipment maintenance and calibration, control of non-conforming products, and record keeping.
2. Where welding is part of the process, you’ll need a management system that conforms to EN ISO 3834 Quality Requirements for Fusion Welding of Metallic Materials.
Process, process, process
We believe very strongly in process – not just to demonstrate compliance. We study carefully every customer’s brief or design to ensure it’s fit for purpose and the process is sound. If we believe EN1090 applies, we alert the customer. Then our EN1090 quality control system kicks in. It monitors the entire process, equipment and staff competency, and enables us to demonstrate compliance.
It could be that your structure involves multiple regulations. Glass for example has its own conformity. However, any bracket or chemical fix used would need to be EN1090 compliant.
We appoint a structural engineer to approve every single detail of our plans and the structural components we’re planning to use – right down to the chemical fixing we’ve selected.
EN1090 gives you traceability which means peace of mind
Traceability demonstrates compliance and verification throughout the manufacturing and fabrication process. Essentially, it gives everyone peace of mind – the customer, the fabricator and everyone coming into contact with your structure.
BS EN 1090 ensures that appropriate controls are in place and embraces every process from the procurement of raw materials through to final inspection and testing. For example:
- Material certification of analysis, testing and storage.
- Staff training, testing and qualification.
- Equipment calibration.
- Consumable certification and control.
- Quality control and testing of product.
- Control of records and documents, including control off issue.
- Product identification and marking.
- Internal audit.
- Control of non conforming product.
Your EN1090 conformity pack
At the end of the project you should have full traceability that your structure complies fully with EN1090 and any other relevant regulation:
Certificate of Conformity (CofC)
This certifies that the metal (steel, aluminium, brass) and all products (bolts, welding consumables, etc) meet the required standards or specification. It’s issued by an authorised party (e.g. the manufacturer). If we buy 10 sheets of S275 grade steel, for example, we need a CofC that ties up with our purchase order (PO). If the 10 sheets come from different batches, then the CofC must identify these different batches, usually by the Mill Test Certificate batch number – see below.
Mill Test Certificate (MTC)
This is a quality assurance document that goes into more depth, certifying the material’s chemical and physical properties, including year of manufacture. The MTC batch number must be referenced in the CofC as mentioned above which, in turn, ties in with our PO.
The above two certificates prove traceability of purchasing. Then the Declaration of Performance certifies that the actual fabrication of the structure conforms to EN1090.
Declaration of Performance (DofP)
Having CofCs and MTCs are evidence of traceability of the materials. As an EN1090 approved fabricator, we then create a DofP to confirm that the structure itself has been created in accordance with the regulation. All the required information to comply with EN1090 is then collated into a data pack which is available to the customer. This includes information such as:
- The technical review.
- Equipment calibration and maintenance logs.
- Employee qualifications.
- Evidence of a structural engineer’s report attesting to its load-bearing, reaction to fire, durability, etc.
EN1090 protects people from harm
To our mind there is no grey area about what constitutes a ‘structure’. The main picture at the top of this blog is a case in point. Is that handrail at ground level or higher up? If the latter, then there’s definitely an opportunity for catastrophe if it buckled under the weight of several people leaning on it and falling to the floor below. If the handrail is at ground level, however? What then, does EN1090 apply? A ‘grey’ area? Then question – add some colour!
Always question. We look at a project from every angle because we have a duty of care – to our customers, the public and ourselves – to fabricate structures that are fit for purpose including safety.
If it’s not EN1090 it’ll come under another regulation – glass, for example has its own certification. If there’s the slightest chance that someone (public or otherwise) could be harmed by a steel or aluminium ‘structure’ of some kind why would you ignore it?
Know your way round EN1090 or find a fabricator (like us!) who does. Not knowing that you are cutting a corner isn’t a good enough excuse.
Clarification on the execution classes: https://alroys.com/en1090-2-steel-fabrication/