CE Marking / BS EN 1090

[Derry93]

Thanks for your reply Dimitri On the audit report he references
Clause: 6.3.2 and 6.3.7 We already paid £1600.00 for the RWC course alone. We are a very small, family business with only two operatives in the workshop. To send one of them to Scotland for a few days for this course is a big ask nevermind the cost involved. The auditor also give us a non conformance for the our WPS as they did not exactly match BSCA blue book templates. All the information was there but was in a slightly different layout.

 

[Kent]

Thanks for your reply Dimitri On the audit report he references
Clause: 6.3.2 and 6.3.7 We already paid £1600.00 for the RWC course alone. We are a very small, family business with only two operatives in the workshop. To send one of them to Scotland for a few days for this course is a big ask nevermind the cost involved. The auditor also give us a non conformance for the our WPS as they did not exactly match BSCA blue book templates. All the information was there but was in a slightly different layout.

well I do hope it ends up worth it and you recoup all the final costs and more, the system just aint set up for smaller companies

 

[Hitch]

I did the CSWIP Visual course as part of our 1090 setup, I did it and so did our RWC, so there is virtually always someone there to check the smaller fast turn-around jobs.
It was something that the guy who setup our 1090 stuff said one of us would need to do.

 

[Dimitri De Spiegeleer]

Clause 6.3.2 and 6.3.7 of EN1090-1 talk about the responsibilities of the men in your firm.
Clause 12.4.1 from the EN10910-2 says that there is no requirement for VT.

You do have to declare in your FPC handbook that person X or Y can perform VT, but you have to do so for every activity in your firm who can or cannot do so.
for a weldor, you typically say: his responsabilities are preparing workpieces, sawing, cutting, ..., grinding, welding, performing VT, reading plans, fitting, ... and general activities in the workplace (putting new ordered plates, tubes, ... in stock, ...)

That's all you have to do. there is NO requirement for any course regarding VT (unless the british version of the EN1090-2 has altered the EN version, but I doubt so. check § 12.4.1)


As for the layout of your WPS's is not conform whatever version, you have to check EN15607 or EN15609 (don't know by heart), where the general lay-out of a WPS is mentioned in an annex, and it is called "informative" and not "normative" (there are only 2 choices for these annexes), meaning that whatever layout is good, as long as all required data has a place somewhere.

 

[Kent]

Clause 6.3.2 and 6.3.7 of EN1090-1 talk about the responsibilities of the men in your firm.
Clause 12.4.1 from the EN10910-2 says that there is no requirement for VT.

You do have to declare in your FPC handbook that person X or Y can perform VT, but you have to do so for every activity in your firm who can or cannot do so.
for a weldor, you typically say: his responsabilities are preparing workpieces, sawing, cutting, ..., grinding, welding, performing VT, reading plans, fitting, ... and general activities in the workplace (putting new ordered plates, tubes, ... in stock, ...)

That's all you have to do. there is NO requirement for any course regarding VT (unless the british version of the EN1090-2 has altered the EN version, but I doubt so. check § 12.4.1)


As for the layout of your WPS's is not conform whatever version, you have to check EN15607 or EN15609 (don't know by heart), where the general lay-out of a WPS is mentioned in an annex, and it is called "informative" and not "normative" (there are only 2 choices for these annexes), meaning that whatever layout is good, as long as all required data has a place somewhere.

That's very clear and there is no chance of your average welder or supervisor getting mixed up there with their actual responsibilities within a smaller firm.

Takes me back to the book Tornado down when the author describes how much the Americans longed to find out exactly were destination MMFD was

 

[Dimitri De Spiegeleer]

Dear Kent,

I am fully aware of how much BS this contains, having gone through all of this multiple times, but as it's required by law, it is what it is. and it is most certainly NOT my fault.

If the time you spent whining on here about the 1090 or on my replies, you actually spent on completing your certification, you'd already be certified for EXC4.

kindest regards,
D.

 

[Kent]

Dear Kent,

I am fully aware of how much BS this contains, having gone through all of this multiple times, but as it's required by law, it is what it is. and it is most certainly NOT my fault.

If the time you spent whining on here about the 1090 or on my replies, you actually spent on completing your certification, you'd already be certified for EXC4.

kindest regards,
D.

No I am not doing it I am currently watching others spend more than they honestly should, I will of course fight most things brought on us from the EU as we were conned into these things by our MPs and MEPs (the latter nobody honestly cared about till it started to effect them). What happened when it did effect them we started replacing our MEPs with full on Euro sceptics in a move to end the fiasco.

Its not a personal attack on you at all rather a questioning of the logic (law in the UK is useless until we have test cases and frankly I doubt the powers that be want a lot of this stuff testing in court just yet ) but do you honestly think the average welder or fab boss gets all this because its apparent in the thread they do not. Even someone who does "get it" has to be sharp because things keep getting changed as someone puts more mud into things upstream, craftsman made, forged, repair- made on site etc. etc.

I am a one man band time served and eminently qualified to do most of what is covered (or not as the case might end up) I don't want to quote for football grounds etc, and neither do I want to employ people just to increase my costs and then pay for consultants (many of whom will have nothing like my experience on the actual job) this is apparent of recent having been reading the thread they their own ideas on the correct procedure. This is nothing like "gas safe" with its centralised testing and re-cert, this is actually the sort of thing that could make sense within the industry.

 

[Derry93]

Thanks again for all your replies, I really appreciate you all taking the time. We spent a lot of money and time developing our system and we really did believe we had all areas of 1090 covered. Dimitri, I think I will argue your point with the auditor. If there is no requirement in the standard to undertake a VT course, he should not have given us a non conformance. Our RWC was in our competence matrix for visual inspection that should of been suffice. Thanks again.

 

[Derry93]

P.s. I do agree with you Kent that a lot of this CE stuff is just a money making exercise for a lot of people. Our RWC course cost £1600.00, our welding procedures/testing etc cost £2500.00, our auditor charged an extra half day for off site report writing which was not on his original quotation, For a small business it's very difficult to try and recoup this. We would have to do a lot of jobs to try and make that type of profit back. Which is why if we don't have to do the Vt course I don't think we should.

 

[Dimitri De Spiegeleer]

our welding procedures/testing etc cost £2500.00

Welder's certificates cost some, but wpqrs can be free if you get them using EN15610 and/or EN15612.

For VT, you must know the EN5817 really well, but this is very doable on your own or with a bit of help.

 

[Mid Wales welder]

Hi, just a quick question for anyone that has been through their CE Audit. We had a minor non-conformance that our RWC (one of our welders who did the RWC course) didn't have a CSWIP visual inspection qualification. We have been told he has to do the course. We are based in Northern Ireland and apparently it is not run here, he would have to go to Scotland. The course itself is about £800.00 plus travel and accommodation. Is this a requirement of the 1090 standard? We honestly thought the visual inspection was covered by the RWC course as our RWC was conducting visual weld inspections and ticking off a quality sheet. Many thanks for any help,

I was told that the CSWIP visual inspection course was only if you are doing EXC3 or higher, not sure if this is the case for you. I am the RWC at my place of work and my boss is in the same situation as u. I was just a welder that got sent on the course in Newtown Powys, not sure if that was the same one. Did you find the guy who did your audit was very strict? We are wanting to get everything as close as possible so we only get one audit, but I doubt that's going to happen lol. Is the company you are dealing with called CDL?

 

[Kent]

P.s. I do agree with you Kent that a lot of this CE stuff is just a money making exercise for a lot of people. Our RWC course cost £1600.00, our welding procedures/testing etc cost £2500.00, our auditor charged an extra half day for off site report writing which was not on his original quotation, For a small business it's very difficult to try and recoup this. We would have to do a lot of jobs to try and make that type of profit back. Which is why if we don't have to do the Vt course I don't think we should.

This is really my point, we had BSI a quality std with a kite mark that basically invented quality standards world wide. There was no problem to be fixed. I do hope your firm gets all that back and more because at the end of the day that's the reason we go to work "to earn a living"

BSI let us make things around the globe in our colonies and ex-colonies and know that component parts will work and fit to others made elsewhere, be safe in use etc.

Perhaps I am turning into Victor Meldrew but when you have seen enough WPs in your time and learn that most were just copy and paste from another job that was rarely the same etc you become a little cynical when some bod want to charge you an ever growing amount of thousands to say your good for the job!

Lets be fair though this EN 1090 does not actually benefit the UK because we already had many other things in place it helps lesser EU countries Quote for work in the UK. I don't know how many know this but certain works have to go out to the rest of the EU for tender- you cant just use a British firm. If your talking government funded or part funded the threshold is actually quite low

 

[Derry93]

Hi Mid Wales Welder - I work in the office so a lot of the admin of this has been left to me. But we are Exe 2 class as well. we are a very small company, just my dad, brother (who is our RWC and welder) another workshop operative and myself in the office. My brother is a time served welder (over 20years) and we have a very good reputation among our customers for a good, quality job. Yes, I think our auditor was very strict. I know other companys who have flew through this and have not put in half as much money or time but have went with a different nb and had no trouble. As Dimitri pointed out, it doesn't actually specify in the standard that a welder has to be CSWIP qualified to inspect welds, however we received a non conformance because our welder didn't have the qualification and the course doesn't even run here in Northern Ireland. I find that very strict. Good luck with your audit and I hope you have a better experience that ourselves. Last week, I was so stressed about this I couldn't even sleep!!!

Dimitri - would knowing BS EN970 be enough to VT welds?

Many thanks again,

 

[Dimitri De Spiegeleer]

970 has been replaced bij 17637, if I'm not mistaken, but either way no, as this only describes on how to perform VT (what tools you can or should use, what lightning you need at a minimum, ...)
5817 describes all the faults and the acceptance criteria, this is the part you absolutely need to know and to execute. You will need to know how to evaluate all possible faults and their tolerances.
this is almost never a problem, as the tolerances are quite loose, but you still need to document that all welds are within their respective tolerance zone.

 

[Derry93]

Thank you - I'll get a copy 5817 and make sure my brother knows it inside out. I'll try to draft a more detailed VT check list for the inspection part of our quality sheet. You have no idea how much I appreciate you taking the time to reply. If I can offer any help to any of the rest of you I'll do my best.

 

[Derry93]

Sorry again - but can I also ask what kind of on-going NDT programme is required for EXE 2? We have a minimum monthly NDT schedule. Does this fulfil the requirement??

 

[Dimitri De Spiegeleer]

depends on what your requirements are. If you stay below certain thicknesses and have a U < 0.5 (see table 24 of the EN1090-2), you can go a whole year or longer without the need for any external NDT.
Sometimes choosing the next larger steel profile (adding only a few lbs / m) eliminates the need for NDT. This is to be considered per project, not on a monthly/weekly/... basis.

 

[Derry93]

Dimitri, I am so sorry to be a pain. I am sure by this stage you have worked out I'm female and don't have a lot of welding knowledge, I've been threw into sorting this out. We only do fillet welds (normally 6mm) and the material welded would not be anymore than 20mm/25mm thick. I had thought looking at the standard we really wouldn't require a lot of NDT throughout the year, however the auditor has said on his report that we are implement a minimum monthly NDT schedule to be reviewed on his next audit visit. Could you (or anyone else) explain simply the requirements for NDT in simple terms?

 

[Dimitri De Spiegeleer]

I work with a checklist per project.
It checks for the obvious (exc class, base material, calculation, method of DoP, ...)
and for the not so obvious (amongst others the necessary NDT).

This works for every NoBo in Belgium I've already dealt with.

There is ABSOLUTELY NO requirement for time based NDT schedules. I begin to think that your NoBo either isn't up to par about the 1090, or that they just try to make it unnecessary difficult for you.
Show them your method of working, on a "per project" basis, and if they won't accept it, ask them to show you were it is required on a timely schedule. They cannot ask for more stringent requirements than what's in the standards. make sure to point that out to them.

And don't ever apologize for being female, all of us guys wouldn't be worth squat if it weren't for you girls ;-)

 

[Dimitri De Spiegeleer]

and btw, the requirements are what is mentioned in table 24. that's it.