The trials, tribulations - and certain joys - on the road to compliance with EN 1090

Author: John Hennessy, is managing director of Hentech Fabrication Limited, an SME based in Co Wexford. The bulk of its work is in the area of fabricating stairs and access platforms, plant support steelwork, small structures, balustrades and railings. He has been in the fabrication business for about 25 years and is a fitter/fabricator by trade

n late 2013 we became aware of the fact there were a raft of new requirements been brought into place in the construction industry. After initial inquiries we decided this was something we needed to get our heads around pretty quickly because the requirement to be compliant with EN 1090, i.e. to be CE certified, was going to be a 'legal requirement' unlike other quality control awards or ISOs that companies achieve by choice in order to make their businesses more attractive to clients. Finding information was difficult and the first months were used up trawling the net looking for sample factory production control manuals and any information in relation to EN 1090.

I had decided to work on achieving our certification without the aid of a consultant because the whole thing was so new that it was difficult to find somebody competent who didn’t want a small mortgage to come on board. This turned out to be one of the better decisions to be made in the company in the past few years (albeit by luck only) as I had to work out every detail of our procedures and systems and document all in a systematic way. This allowed me to tidy up what we were already doing and to put in place procedures that we did not have documented. There was a huge amount of work in this area and because we developed ourselves and talked it through we understand the procedures and systems intimately.

Factory production control manual

I did the responsible welding co-ordination course with Gerry McCarthy (www.wqms.ie) whom I found to be very knowledgeable and what I learnt from him allowed me to put the final touches to our factory production control manual and our welding procedures. McCarthy’s site visits and audits were a great help in preparing us for our National Standards Authority of Ireland (NSAI) audit. I went to the UK and did my visual welding inspection course with TWI. This course was very well run and, as I am a tradesman, I found it very interesting. As a company our journey to achieving our certification took us more than a year, with a lot of work involved and quite a considerable amount of expenditure.

Because of the type of work we have been doing and the places we have always worked we were quite well placed to meet the exacting requirements for certification to EN 1090. We would always have had our welders coded and we would always have provided operations and maintenance (O&M) manuals for works completed with bolt spec, paint spec, galvanising spec, mill certs etc but all this needed to be tidied up and put into a formal procedure - and, we also needed to put in place many systems and procedures that we didn’t have as well as additional training and restructuring. There are different notified bodies that can be used to audit and certify fabrication companies. We chose to use the NSAI. We found the organisation to be very exact but fair and helpful. The NSAI has no commercial reason to pass or fail any company - either you meet the standards set down or you don’t.

Putting systems in place and achieving certification has been time consuming

Putting the systems in place and achieving our certification has been time consuming, difficult and expensive but we have found it to be a huge advantage to our company in many ways. Most notably our efficiency - especially with repeat works - and being able to put our hand on any information about any job at any time. Our factory is cleaner and more organised, our plant and machinery is all serviced and up to date. Our office management is so much more efficient and streamlined. We have always been quite busy but we have found ourselves to be even more so as engineers, architects and clients become more aware of the legal requirements to use a certified fabricator.

One huge advantage that we have found that we did not anticipate was the extra effort and pride among our staff. With all the additional training they have received and all the new systems and procedures in place, and because we have involved each and every member of our staff in the process, nobody wants to be the first to make a mistake. Also, because of the company’s commitment to achieving certification all of our staff are aware of the money that has been spent and the time put into it and this gives them confidence and a certain amount of job security in an industry that has been very volatile over the past seven years. In order for any company to maintain its certification it will receive regular audits by its notified body. This should not be a problem as the procedures that are in place need to be used for the whole system to function correctly and if this is being done then your periodic audit should not be an issue (other than paying for the audit and the time taken up doing it).

Some points of interest

When appointing a certified fabricator you would need to ensure that they are certified to the required execution class, that they have the required welding procedures in place, and that these procedures are qualified with the correct grade of material;
A common question would be how is the steel CE marked (is CE stamped on the steel?). Any steelwork that is CE certified needs to have an identifying mark that is traceable back to the drawings, this mark could be C1 referring to column 1, what the mark says is not relevant just that that piece of steel is marked and traceable through the system and is identified on the Declaration of Performance (DoP) issued on completion of works;
There are many procedures in place from technical review to delivery on site but generally what the architect and engineer would be dealing with would be something similar to this:

A drawing would be issued to the fabricator outlining what is attempting to be achieved; this could be two drawings, architectural and structural, and may be limited or quite detailed.
The fabricator then does a site survey and produces fabrication drawings for comment/approval.
At this stage either the fabricator gets their own engineer to sign off, or the clients engineer signs off on the design, member sizes etc, and the architect has commented also.
Subject to approval, fabrication would be carried out and the material delivered to the site.
On site a DoP delivery docket would be checked off by the client’s representative (i.e. site foreman) and the fabrication company’s foreman or driver. This is to ensure that all parts are on site and ready for erection as per the agreed fabrication drawings.
On completion of the works and with everybody being satisfied a DoP would be issued with all the relevant information, (and the fabricator gets paid the next day).

The bulk of work in this country would be execution class 1 or 2 but any works involving bridges, high rise buildings, stadiums etc would probably be execution class 3;
What does and does not need to be CE certified. In most buildings there will be a certain amount of structural steel which needs to be fabricated by a CE certified fabricator, there may also be stairs and platforms, balustrades, plant support steelwork, some of which may need to be CE certified and some of which may be a grey area (at the moment). The question is if you are using a CE certified fabricator for most of the work why would you then revert to a fabricator who isn’t certified and therefore doesn’t meet quality standards required? If there was an issue down the line where would you stand?;
Cost. There is no point in skirting around the financial end of it, achieving and maintaining certification costs money, therefore the product/service is going to cost more money. In a free market it is impossible to quantify what percentage this would be. As a company we have decided to keep our costs as tight as possible, there are not many CE certified fabricators in the system at the moment but over the next few years there will have to be a lot more available and we want to ensure that we don’t burn any bridges by holding people to ransom because of the scarcity of certified fabricators;
How many CE certified fabrication companies are there in Ireland at the moment? Because there are different notified bodies (some based in the UK and on the Continent) it is difficult to get an exact figure, I would estimate between 40 and 50. It is taking between four and eight months to achieve certification successfully but the rate of companies coming into the system should improve as the glitches are ironed out and there are more competent people available to assist in the process.