Factory Production Control systems are central to BS EN 1090 certification and CE Marking structural steel, under the Construction Products Regulation (CPR). A Factory Production Control system should provide a framework to ensure consistency and traceability in methods, materials, equipment and training. This is achieved through a system of documented procedures, inspections, tests and records relating to everything from purchasing and goods in, to calibration and maintenance of equipment, to final product sign off.
EN 1090-1 states that the FPC (factory production control) system is intended to ensure products conform to ‘declared performance characteristics‘. This means a manufacturer or fabricator must record the means and methods used in consistently producing products that meet relevant technical standards.
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Essential elements of a Factory Production Control (FPC) System
As there are no specific criteria for the contents of a FPC system, the requirements and principles of ISO 9001 can be adopted, meaning those certified to this standard are already a good deal of the way to compliance. However, this QMS standard is less than ideal for fabrication and welding quality management purposes, and ISO 9001 certification/compliance is not compulsory for the issuance of factory production control certificate from a UKAS approved certification body.
A skilfully drafted EN 1090 FPC should not be overly cumbersome, and with experience it is often possible to draft a system that fits around many of the established practices within the steelwork company. As a general rule, the more well run the fabricator, the closer to ready for BS EN1090 certification they will be – any suitable elements already in place simply need to be documented and incorporated into the FPC.
Where current practices do need to be modified or updated to comply with the EN 1090-1 standard, any changes are likely to result in improvements in quality, efficiency and sustainability. Clients who embrace the process often find that these benefits feed through into improved profitability, and that the cost of CE certification is therefore recovered. Investment in an effective ongoing BS EN 1090 FPC is NOT a simple ‘tick box’ exercise.
Factory Production Control Manual
The fundamental basis of any FPC is the Factory Production Control Manual. This is the backbone of the system and initially contains the necessary forms, documents, procedures and work instructions required to ensure everybody is working to the same standard. In order for the system to function properly, the manual should be tailored to suit the company and it’s own particular way of doing things. The other option is to attempt to modify the company’s operation to fit around a boilerplate FPC Manual template. Whilst this can initially be a cheaper alternative to the fees charged by CE Marking structural steel consultants, the process tends to be much less straightforward, usually taking significantly longer than with a helping hand from an expert. Any potential savings may be quickly eaten up by additional days required on site for the nominated certification body to close any major non conformances identified during a certification audit. Similarly, complete DIY EN 1090 certification can be achieved, but depending on previous experience, it usually takes a significant commitment of time and energy toward learning about the CE Marking requirements for structural steelwork, designing and implementing suitable procedures and processes that enhance rather than constrain operations.
Some of the key processes detailed and controlled by the FPC are:
- Organisational structure and management; person responsible for FPC
- Ensure those carrying out key tasks are trained and competent
- Review and prepare product specifications, including drawings as appropriate
- Establish customer requirement; ensure requirement is within scope of approval, e.g. EXC2
- Prepare specification for input materials and constituent products
- Design and operate a stock control system
- Specify and record results of tests and other control measures required in monitoring conformity
- Record all non conformances and identify corrective action taken
- Maintain traceability throughout, i.e:
– verify purchase orders and subsequent deliveries comply with one-another and the project specification
– stock levels, storage and condition/protection
– ensure correct materials (as specified ) are available and used
– ensure non conforming supplies or products are segregated and rectified or disposed of
With the FPC manual in place, successful implementation relies on awareness and adoption throughout the company, which may be achieved via formal training or informal ‘run-through’ of the system, depending on the size of the operation and number of staff involved in the FPC. Time-scales of 12-18 months are often quoted for EN 1090 certification, due to the fact that the Factory Production Control Manual only really becomes a Factory Production Control system once a number of projects have run their course, allowing the resultant records to be prepared and any corrective actions etc. to be carried out. Full certification is often achieved in under 12 months.
EN 1090 FPC Certification
In order for the fabricator to legally CE Mark structural steel, a Factory Production Control system satisfying EN 1090-1 must be in place, and be certified by a UKAS registered certification body (often referred to as a Notified Body, ‘NoBo’ for short). Without this third party audit and factory production control certificate, the requirements of EN1090 are not met, and the product cannot be legally placed on the market.
If the work carried out by the fabricator involves welding (which is usually the case), controls on the welding process are required. Recommended best practice is the use of a welding quality management system (WQMS) in accordance with ISO 3834, although formal audit of the FPC or WQMS against this standard is not a requirement of EN 1090. Notably, certain NoBos have been demanding formal ISO 3834 certification as part of their service; whilst this may lead to higher standards overall, the commercial argument for expenditure on the order of three times the alternative, would not appear to be a particularly favourable one for the majority of steelwork contractors.
Please contact us to discuss the options for your organisation or request a proposal.
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