CE Marking – Stockholder / Distributor

Steel stockholders generally purchase steel sections which have been CE Marked by the steel manufacturer to EN 10025-1 for I and H sections, EN 10210-1 for hot-finished structural hollow sections and EN 10219-1 for cold-formed structural hollow sections.

WHAT DO I NEED TO DO?

Steel stockholders generally purchase steel sections which have been CE Marked by the steel manufacturer to EN 10025-1 for I and H sections, EN 10210-1 for hot- finished structural hollow sections and EN 10219-1 for cold formed structural hollow sections.

Sometimes these sections are then cut to exact length, drilled, blast cleaned and painted by the stockholder before being supplied to the steelwork contractor. All of these activities are fabrication activities which are covered by the CE Marking standard EN 1090-1. For example, it is important that the section is cut into exact length and holes are drilled into accordance with the tolerances given in BS EN 1090-2.

Stockholders who provide these services will therefore need to extend the CE Marking for the modified steel sections in accordance with the fabrication CE Marking Standard EN 1090-1. This will require initial type testing (ITT) and the setting up a certified factory production control (FPC) system as described in section 10.

Sometimes stockholders re test steel sections to re-evaluate fracture toughness, Fracture toughness is one of the performance values declared on the CE Marking by the steel manufacturer. Therefore a change to the product’s original performance values for the fracture toughness will require the section to be re-CE Marked.

The stockholder will therefore have to perform ITT for the change in the performance value for the fracture toughness and set up an appropriate FPC System. In this case, setting up an FPC system cannot be based on the original steel production process as the stockholder has no control over the raw materials or the production process.

The FPC system will be based on documentary controls and testing of the finished product. The laboratory testing will need to be checked by the NB as described above.

DISTRIBUTORS

A distributor is a person or organisation which stores and distributes a CE Marked product that has already been placed on the EU market. Some steel stockholders fall in to this category. The distributor does not alter the product in any way nor does it put its name on the product. For example, some stockholders re-test steel sections or the plates in order to establish improved CVN values. This process changes the declared propertied of the product and the stockholder then becomes a manufacturer.

Although distributors do not have any responsibilities under the CPD they do have a duty to ensure that the correct CE Marking is associated with the correct CE Marking is associated with the correct product and that clearly non-compliant products are not placed on the EU market.

The issue of an organisation buying a CE Marked product changing some of its declared properties and putting it back on the market is worth exploring further with reference to certain parts of the steel construction supply chain. For example some steel stockholders offer a service to steelwork contractors which involves modifying the original CE Marked steel section. Steel benders provide a service which bends the original steel beam modifying some of declared properties. In both cases the stockholders and steel benders are classed as manufacturers.

Is your Steel Stockholder Compliant ?

It is a legal requirement for your Steel Stockholders to have Certification, Traceable & FPC’s.

If you, as a Fabricator purchase steel that is cut, blasted or painted from non-certified Stockholders / Distributors, you run the risk of failing your audit and/or losing your Certification.

You need to ensure your steel is identified with Heat Numbers and relates to the Certs given.

You will be asked to prove this at your Audit.

Stockholders Requirements:

Your delivery must have identification.

A beam, for example, will have the Heat Number printed or label affixed.

That beam marked/numbered with a Heat Number will relate to the Heat Cert.

It is good practice that the delivery docket will have the purchase order number on it as well as the Heat Numbers. For example see Bentley Steel, Blue Steel and D. Kennedy Steel Supplies.

You, as a Fabricator, need to know that the beam has a Birth Cert and that is your Heat Cert.

Don’t leave the Auditor find the problem for you.

USEFUL DOCUMENTS / READING

Understanding Compliance in Structural Steel EN 1090 and Eurocodes Practical Information for Designers

A very useful document by Jim Mansfield (Kavanagh Mansfield & Partners) for Engineers, Fabricators, Site Management, Auditors and End Users.

Members excel in Welding standards

With the help of EIS who are the Leaders in NDT and Inspection Specialists. Jimmy Byrne explained visual inspection procedures, relevant codes of practice, terms and definitions; welding processes and typical welding defects, weld measurements, typical documentation and requirements as well as practical inspection and reporting to our Members.

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2024 President's Letter

Hello everyone,

I’d like to begin this letter by expressing my immense pride and privilege in being the inaugural President of Irish Steel. Our organisation is dedicated to aiding SMEs in the metalwork fabrication and manufacturing industry across Ireland, aiming to fortify and advance their businesses. We are committed to supporting our members in enhancing their business performance and competitive edge by fostering connections for the exchange of knowledge, ideas, and experiences.

The term “Knowledge sharing” may seem abstract, but in the context of Irish Steel, it translates to empowering industry professionals to achieve success! Our focus is on aiding industry members in becoming more professional, profitable, connected, and organised.

My initial encounter with the benefits Irish Steel offers was in 2016 when I joined and was added by Pat to the WhatsApp group he established to connect fabricators nationwide. Shortly after joining, while on a job in Cork, we faced a shortage of 16 special bolts. Despite efforts, no supplier could fulfil our need. I reached out through the WhatsApp group, and remarkably, within hours, a fellow member whom I'd never met before drove over a hundred miles to assist me. This experience truly showcased the incredible potential of connecting individuals who share similar day-to-day challenges.

Such instances are a daily occurrence at Irish Steel, where the team actively provides practical support to its members.

The organisation experienced challenges during the Covid lockdowns, which impacted many people and businesses. However, Irish Steel has now reinvigorated itself, moving past the dark days of Covid. The Association is investing heavily, emerging stronger, more focused, and better than ever. I am honoured to be part of this team, which organised the first-ever awards ceremony tailored for the metalworking industry in Ireland. It was extraordinary to witness so many like-minded individuals gathered, celebrating achievements, and fostering business relationships. I eagerly anticipate the 2024 Irish Steel Awards Dinner & Gala Night.

Earlier, I mentioned the power of connections. Being allied with this team, benefiting from their knowledge, experience, and network, is something that industry members should earnestly consider.

Irish Steel is managed by industry veterans who have established a vast network of members, both domestically and internationally. They have also convened a cadre of technical and business expert consultants aligned with Irish Steel to serve our members. This team, proficient in steel fabrication, manufacturing, and various aspects of running successful manufacturing and contracting businesses, is dedicated to helping members reduce waste, avoid errors, prevent financial losses, build resilience, stimulate growth, innovate, ensure safety, comply with legal requirements, boost profits, diversify, innovate, and scale – the list is extensive.

Kind regards,

Fergus Naughton

2024 President of Irish Steel

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