- Thread starter matt1978
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Kent
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Yes why keep stuff that ain't duel purpose. For me it's wortj while finding non ce but fewer suppliers can give them shelf space over ce and other certified
Mid Wales welder
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Passed MPI tests for my WPS's so I'm now finally an RWC, yay!
Mid Wales welder
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It's suppose to be 900mm of weld for each WPS but he didn't want that much so just did a few pieces from each one, there's 3mm and 10mm butt, 3mm, 10mm single run fillet, 15mm multi run fillet and 50mm box to 6mm plate. Leg lengths ranging from 5mm to 10mm. Welded them all yesterday and all got MPI'd today.
Mid Wales welder
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Thanks, been a stressfull few days finishing paper work and getting those test done lol, can relax a little now until audit time lol
Mid Wales welder
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The testing was done by the guy who I took the RWC course with, he has his MPI ticket so just did them at our place when he came to do the gap analysis. I think as MPI can detect slight sub surface cracks its proffered over DPT, but not sure.
well done to you.
now i have a query regarding ce work, i've been asked to remove 2 columns[ & upgrade the corresponding lintel ] on a workshop,initially i declined & recommended another local firm,however i later thought maybe as its site work i maybe exempt & i have contacts of S/engineers that i used before to do the calks'.
now i have a query regarding ce work, i've been asked to remove 2 columns[ & upgrade the corresponding lintel ] on a workshop,initially i declined & recommended another local firm,however i later thought maybe as its site work i maybe exempt & i have contacts of S/engineers that i used before to do the calks'.
Mid Wales welder
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I think you should be ok if it's all Site work. Where in Powys are you?
i moved over the border near hay since i joined the forum ,as i find computer stuff difficult haven't braved the challenge of updating it,hence why i still haven't uploaded photos.
Sparkmaster
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Hi this is my first post and I see this thread has gone a bit quiet for a while now so perhaps I am joining the debate a bit late. I have read through the thread and by the time I had finished I had forgot a lot from the start due to its length, however what strikes me is how clued up some people were about the whole process a year ago. It has taken a lot longer for things to sink in for me.
My question to the OP and other learned contributers is why there has been no further mention of the derrogations to the CE marking other than 'site work,? The problem I am having is as far as I can see other are three areas that would exempt a 'product' from CE marking. I am working from memory here as I can't flick between tabs while writing so I will paraphrase and say what I recall...
1. Its made on site.
2. Its a heritage job using traditional methods.
3. Its bespoke, non series, & installed in a specific address by the manufacturer.
It is my understanding that these derrogations (or exemptions if you prefer) were specifically included as an attempt to further define the scope of CE. With specific reference to the third point, take for example a fabricator who wholly produces structural steel for small projects, they receive structural calculations and architects drawings via their builder customers who place orders. It is my understanding that it is this exact sort of situation that the third derrogation were designed for. It is trying to say that one off fabricated jobs with specific designs that cannot simply be applied to other sites, in the way that a brick or a bag of sand, or a furfix, or a catnic lintel etc can are not 'products'. And if they are not products they can't be treated as such.
The problem with the derogation 3 for most general fabricators of structural steel in small works is that traditionally the builders install the steel. They treat it as a 'product' I.e they want to just buy it and use it. If you are a company that only supplies and fits then I think you don't need to CE mark structural steel as long as its not a series produced, or series produced with dimensional variation type product. If you can demonstrate it fulfills the criteria set out in the guidance papers (I think that's where I saw it) for being non series and unique to that specific structural set of conditions, and you install it to ensure it complies with the design brief by the engineer then you are golden.
I think this does not exempt the work from being to the bsen standards as previously mentioned.
I am still trying to get my head around where 1090 etc stops and CE begins. People seem to speak of the two as if they are interchangeable, are they not 2 very different things?
The thing that annoys me is that people have suddenly got the impression that they need CE accreditation to validate the fact they are executing 1090. As far as I can tell most of the industry who don't make and sell products designed to be consumed by the general building public probably shouldn't or don't have to CE mark but feel they need to do so because of those specifiers who are incorrectly suggesting that ALL structural steel must be CE. It is my understanding that all structural steel should be to relevant European standards which is the requirement of building regulations I believe but not CE, unless it falls within scope.
I am yet to see a situation that could not be exempted from CE using the third derogation because as a fabricator working in the domestic extensions and bespoke architect designed new build housing market, as well as general fabrication gates railings, etc. We haven't been asked to make a 'product' that is a repeat order type deal.
I am aware of other fabricators nearby who DO fabricate and market heir own products such as companies who make only stairs or platforms or barriers or something, where you can call them up and order an xx type stair or whatever and they will do the rest. These folk are making a product in the true sense of the word and must CE mark it. As far as I can see its all about stating the performance characteristics of the product so it can be used by anyone, anywhere, without much chance of comeback to the manufacturer. If the company can prove the manufacturing process was closely monitored with FPC, tested welders, recorded consumables from approved suppliers there is high probability of quality and low probability of comeback.
Those choosing to not CE mark structural steel must install it because they are not stating its performance characterists, and therefore its intended use so I believe a purchaser cannot know how to properly use it. That's the argument from a product point of view.
Of course in the case of bespoke structural steel for a knockthrough to create a new open plan kitchen at no. 27 super duper street its unlikely the builder who ordered it and who is all set to install it dissent known how to use it?
So the dilemma is to either CE mark it as a 'product', which is near impossible because it actually isn't, just so he can fit it just the way he has always done. Or I have to tell him he has to pay me to fit it for him because his 25 years of experience building lintels into walls pales in comparison to my ability to weld which seemingly qualifies me to install steel better.
Pardon me if I think this is a complete load of tosh.
It applies to some and to others its totally unworkeable.
By the way we have always welded to the bs and now en standards, quite why everyone seems to think you need CE to prove this is beyond me. Up until last June it as up to someone else to prove I WASNT welding to standard, now all of a sudden this CE is being used as a way to make people self regulate.
My question to the OP and other learned contributers is why there has been no further mention of the derrogations to the CE marking other than 'site work,? The problem I am having is as far as I can see other are three areas that would exempt a 'product' from CE marking. I am working from memory here as I can't flick between tabs while writing so I will paraphrase and say what I recall...
1. Its made on site.
2. Its a heritage job using traditional methods.
3. Its bespoke, non series, & installed in a specific address by the manufacturer.
It is my understanding that these derrogations (or exemptions if you prefer) were specifically included as an attempt to further define the scope of CE. With specific reference to the third point, take for example a fabricator who wholly produces structural steel for small projects, they receive structural calculations and architects drawings via their builder customers who place orders. It is my understanding that it is this exact sort of situation that the third derrogation were designed for. It is trying to say that one off fabricated jobs with specific designs that cannot simply be applied to other sites, in the way that a brick or a bag of sand, or a furfix, or a catnic lintel etc can are not 'products'. And if they are not products they can't be treated as such.
The problem with the derogation 3 for most general fabricators of structural steel in small works is that traditionally the builders install the steel. They treat it as a 'product' I.e they want to just buy it and use it. If you are a company that only supplies and fits then I think you don't need to CE mark structural steel as long as its not a series produced, or series produced with dimensional variation type product. If you can demonstrate it fulfills the criteria set out in the guidance papers (I think that's where I saw it) for being non series and unique to that specific structural set of conditions, and you install it to ensure it complies with the design brief by the engineer then you are golden.
I think this does not exempt the work from being to the bsen standards as previously mentioned.
I am still trying to get my head around where 1090 etc stops and CE begins. People seem to speak of the two as if they are interchangeable, are they not 2 very different things?
The thing that annoys me is that people have suddenly got the impression that they need CE accreditation to validate the fact they are executing 1090. As far as I can tell most of the industry who don't make and sell products designed to be consumed by the general building public probably shouldn't or don't have to CE mark but feel they need to do so because of those specifiers who are incorrectly suggesting that ALL structural steel must be CE. It is my understanding that all structural steel should be to relevant European standards which is the requirement of building regulations I believe but not CE, unless it falls within scope.
I am yet to see a situation that could not be exempted from CE using the third derogation because as a fabricator working in the domestic extensions and bespoke architect designed new build housing market, as well as general fabrication gates railings, etc. We haven't been asked to make a 'product' that is a repeat order type deal.
I am aware of other fabricators nearby who DO fabricate and market heir own products such as companies who make only stairs or platforms or barriers or something, where you can call them up and order an xx type stair or whatever and they will do the rest. These folk are making a product in the true sense of the word and must CE mark it. As far as I can see its all about stating the performance characteristics of the product so it can be used by anyone, anywhere, without much chance of comeback to the manufacturer. If the company can prove the manufacturing process was closely monitored with FPC, tested welders, recorded consumables from approved suppliers there is high probability of quality and low probability of comeback.
Those choosing to not CE mark structural steel must install it because they are not stating its performance characterists, and therefore its intended use so I believe a purchaser cannot know how to properly use it. That's the argument from a product point of view.
Of course in the case of bespoke structural steel for a knockthrough to create a new open plan kitchen at no. 27 super duper street its unlikely the builder who ordered it and who is all set to install it dissent known how to use it?
So the dilemma is to either CE mark it as a 'product', which is near impossible because it actually isn't, just so he can fit it just the way he has always done. Or I have to tell him he has to pay me to fit it for him because his 25 years of experience building lintels into walls pales in comparison to my ability to weld which seemingly qualifies me to install steel better.
Pardon me if I think this is a complete load of tosh.
It applies to some and to others its totally unworkeable.
By the way we have always welded to the bs and now en standards, quite why everyone seems to think you need CE to prove this is beyond me. Up until last June it as up to someone else to prove I WASNT welding to standard, now all of a sudden this CE is being used as a way to make people self regulate.
Kent
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Heritage job that's also made on site makes it exempt the way I see it. If your talking traditional forge work it can't be ce or rather shouldn't be because it's been changed during forging
It's all so confusing because there are no lest cases imo. Most law has exceptions but eu stuff is riddled with contradictions.
It's all so confusing because there are no lest cases imo. Most law has exceptions but eu stuff is riddled with contradictions.
voldwelder
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Hi, I am new to the forum but been welding and weld inspecting a very long time. I am a LRQA approved auditor and have developed and written weld procedures to ASME IX many times.
What do I think of having to have CE approval? Having seen stuff fall apart due to lack of fusion when MIG welding was used it is a good idea to try to do something to prevent it. The big drawback is the cost for small businesses particularly when only a small percentage of their work is structural steelwork. Another concern that although fabricators may achieve the required quality on test day they may not adhere to it on a continual basis. I was recently asked for advice by the owner of a small business. Up until last year he (assisted by one employee) had fabricated and erected small agricultural buildings up to about 400 sq meters. The cost of complying with the CE welding requirements are for him quite probably prohibitive. One option I am looking at is redesigning the steelwork so no welding is needed on the most of the components. Where welded joint pieces are needed they will be fabricated and tacked up by this none CE business and then sent to a company that already has codes in place for welding. These joint pieces will then be bolted to the main sections.
What do I think of having to have CE approval? Having seen stuff fall apart due to lack of fusion when MIG welding was used it is a good idea to try to do something to prevent it. The big drawback is the cost for small businesses particularly when only a small percentage of their work is structural steelwork. Another concern that although fabricators may achieve the required quality on test day they may not adhere to it on a continual basis. I was recently asked for advice by the owner of a small business. Up until last year he (assisted by one employee) had fabricated and erected small agricultural buildings up to about 400 sq meters. The cost of complying with the CE welding requirements are for him quite probably prohibitive. One option I am looking at is redesigning the steelwork so no welding is needed on the most of the components. Where welded joint pieces are needed they will be fabricated and tacked up by this none CE business and then sent to a company that already has codes in place for welding. These joint pieces will then be bolted to the main sections.
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CE marking is not just about the 'welding bit' though....
Dimitri De Spiegeleer
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That's a sure way for going out of business...
They would still need an FPC system, as mentioned above, which is a time consuming and costly bit, and this additional step will come at a cost where in this market nowadays, nobody will want to pay for as competition kills right now. And if they can't get this right, the welding mild steel part, even with a mig gun, they shouldn't be making structural components at all.
They would still need an FPC system, as mentioned above, which is a time consuming and costly bit, and this additional step will come at a cost where in this market nowadays, nobody will want to pay for as competition kills right now. And if they can't get this right, the welding mild steel part, even with a mig gun, they shouldn't be making structural components at all.
Wendelspanswick
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Yes buildings were falling down all the time round here before they bought in the new regulations!
Kent
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It's not about being able to weld it up right at all! Their are small firms all over this country that are very capable of doing this but lack the manpower to comply correctly with procedures administration wise as much as anything else
Yes they are stuffed can't do pretty much anything with that job - unless it's all made on site that is!!
Yep fabricated items brought to site is the remit right
Yes they are stuffed can't do pretty much anything with that job - unless it's all made on site that is!!
Yep fabricated items brought to site is the remit right
