Supporting CE-Marking Obligations of Our Customers: The Role of the Galvanizer

Transcription

1 Supporting CE-Marking Obligations of Our Customers: The Role of the Galvanizer NORDIC GALVANIZERS ANNUAL MEETING 8 MAY 2014 COPENHAGEN MURRAY COOK EXECUTIVE DIRECTOR EUROPEAN GENERAL GALVANIZERS ASSOCIATION mcook@egga.com

2 Main EU Directives and Regulations that define our future EU Industrial Emissions Directive (2011) EU Water Framework Directive Construction Products Regulation (2011) New EU-level requirements for operations of galvanizing plants [BREF] Defines the regulatory pressure for zinc levels in EU rivers + common Environmental Quality Standard for zinc CE marking of steel products. Increased focus on environmental performance New BWR7 on Sustainable Use of Natural Resources

3 CE-Marking & Galvanizing Basics of CE Marking Role of the Galvanizer in CE Marking EGGA Guidance Document CE Marking EGGA Guidance Document Controlling Liquid Metal Assisted Cracking QUESTIONS

4 CE Marking Key Issues Product Standards EN (Vehicle Restraint Systems) pren10348 (Steel Reinforcement) Increased focus on technical performance. Less specific requirement for technological solutions (e.g. galvanizing to EN ISO 1461) CE Marking of the Product by the Manufacturer Fabricated Structural Steelwork kits EN 1090 CE Marking to EN by Steel Fabricator. Control of galvanizing done simply.. - extension of Factory Production Control of steel fabricator - simple sub-contract status for galvanizing Implementation deadline - 1/7/2014

5 CE Marking for Structural Steelwork According to EN 1090 Execution of steel structures and aluminium structures Part 1: Requirements for conformity assessment of structural components Part 2: Technical requirements for steel structures

6 CE Marking - Basics CE marking demonstrates compliance with relevant harmonised standard EN for manufactured structural components safety critical Factory Production Control (FPC) System must be independently verified (Notified Body) CE Marking is the responsibility of the steelwork contractor (not the galvanizer) Durability is not an essential characteristic

7 Factory Production Control for Steel Fabrication Certified as being able to produce products that comply with EN after initial inspection (ITT) and continuing surveillance audits. Defined by: Written procedures Regular/routine inspection (quality control) Competent personnel Suitable equipment for production/testing

8 CE Marking - Timing EU Construction Products Directive/ Regulation (Mandatory CE Marking) 1 July 2013 Co-existence of EN 1090 ( Execution of Steel Structures ) with national standards ended on 1 July 2012 but was extended to 1 July 2014 Some Member States (and companies) may act before the deadlines E.g. for tenders for contracts delivered after July 2014.

9 EN Table 2 Frequency of product testing as part of factory production control Surface preparation prior to corrosion protection Characteristic Requirement clause Evaluation method Durability 4.9 Check that manufacturing is done in accordance with EN and EN Sampling Check in accordance with the requirements to inspection in EN or EN Conformity criteria 5.11 Indirect by correct specification

10 FPC for Steelwork Contractor Requirements under EN 1090 related to galvanizing Procedures/equipment/training for: Meeting the requirements of Clause 10.5 (venting/draining) and Clause 10.6 (overlapping surfaces). Surface preparation for galvanizing meets requirements of EN ISO 1461 (not EN ISO 8501). Traceability Cold forming prior to galvanizing (see EN 10025) Post galvanizing inspection Coating thickness inspection (if carried out at steelwork contractor) Tolerances

11 EXAMPLE: EN Clause Galvanizing If pickling is to be used prior to galvanizing, all weld gaps should be sealed prior to pickling to prevent the ingress of acid, unless this conflicts with considerations set out in 10.6 below. If the fabricated component contains enclosed spaces, vent and drain holes shall be provided. The enclosed space shall generally be galvanized internally and if not it shall be specified whether these enclosed spaces shall be sealed after galvanizing and, if so, with what.

12 This is supported by the Galvanizer: Certificate of Compliance to EN ISO 1461 Additional coating thickness checks (if specified) Post galvanizing inspection (if specified) Traceability, etc If required, can be certified as a sub-contract activity as extension of the steel fabricator s FPC

13 EGGA and European Convention for Constructional Steelwork (ECCS) Joint action to develop supporting approach for galvanizing as sub-contract operation. Eg. Procedures for post-galvanizing inspection ECCS Technical Committee 9 Manufacturing and Erection Standards

14 CE Marking to EN 1090: Framework for Galvanizing Prepare the surface / component Clause 10 Surface Treatment EN hen Additional Requirements Annex F Corrosion Protection By the steel fabricator/manufacturer NOT the galvanizer

15 Role of EGGA CE Marking Guidance Prepare the surface / component Clause 10 Surface Treatment General Requirements (eg traceability) EN hen Additional Requirements Annex F Corrosion Protection EGGA Guidance Annex II Checklist for Galvanizers EGGA Guidance Annex I FPC Checklist for Steel Fabricators

16 EGGA CE Marking Guidance - Overview Introduction KEY POINT: FPC of the Steelwork Contractor can easily be extended to cover control of galvanizing as a sub-contract operation Tools for Control of Galvanizing Annex I FPC checklist for steelwork contractor Annex II Checklist for supporting procedures of the galvanizer Annex III Specific procedures to assist implementation of Annex I and II

17 Certification Approach Steelwork Contractor s FPC must be certified (to EN ) Including Annex I checklist (if galvanizing to EN ISO 1461 is carried out). Supporting procedures by Galvanizer - Extension of FPC of Steelwork Contractor are not certified to EN 1090 and do not CE Mark anything. Controlled by customers audit procedures or by a certification of the galvanizer, e.g., under a locally-agreed scheme (to avoid multiple customer audits) e.g. operated by national galvanizers association.

18 EGGA/ECCS Guidance: Annex I - Factory Production Control Requirements for Steelwork Contractor Checklist for Initial Inspection and Surveillance (extract) Requirement EN 1090 Reference Specification, Documentation and Training 1. Relevant standards EN ISO 1461 / EN ISO are available? 2. Employees are familiar with the requirements for design for suitability for hot dip galvanizing according to EN ISO Comments/References To be completed by Steelwork Contractor Audit Results To be completed by Notified Body 10.1 (c) EN ISO (c) Yes EN ISO No Remarks: Preparation of Steel Components for Galvanizing 3. A procedure exists to F.2.2 identify surface preparation requirements for the components to be galvanized? Yes No Remarks: 4. A procedure and suitable equipment exists for assessment and introduction of vent and drain holes, including provisions for consultations with galvanizer? 10.5 Yes No Remarks: 5. A procedure exists to identify the need for sealing of weld gaps with attention to the safety considerations associated with sealing such gaps prior to galvanizing? Yes No Remarks:

19 Annex II - Requirements for Galvanizer to Support the FPC System Operated by the Steelwork Contractor Checklist for Galvanizer (extract) 4. A system to visually assess signs of distortion, beyond agreed tolerances, and communicate any variations to Steelwork Contractor is in place Yes No Remarks: Cold formed components 5. A procedure qualification for galvanizing of cold-formed components is in place, where specified Inspection and testing 6. Records of processing of the components (date, batch, main process parameters) are kept for a minimum of 5 years, with additional reference to the requirements for traceability defined by Execution Class of EN F.6.3 Yes No Remarks: Yes No Remarks: 7. Personnel are suitably trained to carry out post-galvanizing inspection at the level as agreed with Steelwork Contractor only required when inspection is carried out by galvanizer F7.4 Yes No Not Applicable Remarks/Level: 8. Equipment is available to carry out post-galvanizing inspection at the level as agreed with Steelwork Contractor only required when inspection is carried out by galvanizer F7.4 Yes No Not Applicable Remarks/Level: Note this check list is intended for galvanizers wishing to support the FPC system of the steelwork contractor. It can also be suitable as a checklist for certification of that activity.

20 LMAC and EN Load-bearing capacity of the steel fabrication is assured in EN by: post galvanizing inspection (Annex F). Reference to EN ISO (guidance on design for galvanizing)

21 LMAC Guidance is implicit in EN ISO Clause 6.5.5

22 Developed by EGGA Technical and Research Committee with advice from academic experts

23 EN refers to LMAC and requires post-galvanizing inspection unless it is de-specified 23

24 PGI Guidance is therefore needed to implement F7.4

25 The level of inspection is determined by a assessing the material susceptibility ( construction class ) and likely stress in the article ( detail class )

26 CE Marking - Summary CE Marking of constructional steelwork to EN 1090 will be mandatory from 1/7/2014 CE Marking is the responsibility of the customer (steel fabricator) Galvanizers must support the fabricator mainly based on documented procedures for what you are already doing! Guidance and Documents have been provided by EGGA to facilitate national implementation use them..

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