What is CE Marking? st
From July 1 2013 under the EU Construction Products Regulation (previously Construction Products Directive), CE Marking of window and doors will become mandatory. Products will have to achieve prescribed levels of performance as outlined in BS EN 14351-1:2006 but also be manufactured in line with a factory production control system (FPC). This will create something a problem for those customers who buy-in frames and glass separately. Companies or individuals who fall within the above category and who market products under their name or trademark will have the responsibility to CE Mark that product. So what does this mean? Apart from ensuring your supplied products conform to their relative harmonised standards, you will need to formulate a factory production control (FPC) system. (There is a Checklist at the end of this guidance document that can guide manufacturers to compliance).
Guide to Factory Production Control Most companies will already have procedures for dealing with their customers and suppliers but may not have them documented. BS EN 14351-1:2006 section 7.3 outlines the elements required for a documented FPC and include: •
Personnel – define responsibilities and authority
Equipment – maintain measuring equipment via calibration
Raw materials and components – inspection scheme for ensuring conformity
Production process – document the various stages
Product testing and evaluation – test and inspect non-finished and finished product
Traceability and marking
Non-conforming products – deal with and record non-conforming products
Corrective action – eliminate non-conformities.
At first sight this may seem daunting but if you stick to a simple rule of ‘say what you do, and do what you say’ the process becomes easier. If applied correctly and adhered to it should make you safe from prosecution. In simple terms your FPC should have documented procedures for:•
Surveying process that ensures the correct window or door is ordered.
Ordering Process which reflects the customers’ requirements, including compliance to prescribed product standards, Building Regulations and whole window and door u-values.
Purchasing specification for compliant products for example windows and doors to BS EN 14351, safety glass’ to BS EN 12150 or BS EN 14449 (Laminated) and Insulating Glass Unit’s (IGU) to BS EN 1279.
Ordering procedure for IGU’s from a compliant manufacturer. Remember you will need to obtain a Declaration of Conformity or Performance to BS EN 1279 (and BS EN 12150 – toughened glass) from your suppliers(s).
Inspection of incoming product
Training Records for all staff – a simple matrix that records workplace skills of individual employees will suffice. You can go further and have a record of experience and qualifications but remember to include health & safety aspects in all training for example manual handling and working at height etc.
Record of Customer Complaints.
Record rejected goods, windows, IGU’s, components, etc.
Keep a record of what action has been taken to resolve complaints and deal with rejected or non-conforming items.
The calibration of measuring devices. By using tape measures that are marked Class (II) and by using a measuring method from 100mm will overcome the need to calibrate tapes regularly and only use tapes that are marked
Introduce a checking procedure that ensures the correct IGU is matched to the correct frame and to make sure these agree with the original order or specification.
Have a method of satisfying the CE Marking requirements. Placing the CE Marking onto frames is not mandatory but may be commercially desirable.
Installation procedure or guidelines that is specific to a particular window system.
Factory Production Control Template We at Sierra Windows believe we have a responsibility to guide our customers through this process and have developed a simple FPC template. The template, which can be downloaded from the web portal, can be modified to suit your processes. You can download a sample FPC Manual that shows how it should look when completed. In addition we can supply form format templates that you may find useful as part of your FPC. The documents provided on the portal have been produced to provide comprehensive guidance and assistance to our customers but, should you have any questions or require additional support, please contact your Area Sales Manager or your Sales Co-ordinator; they will be able to guide you through the process. Once all this is in place you can CE Mark the product. BS EN 14351 gives you four options on how you mark your product. The Rules and conditions for affixing of CE Marking are that it must be affixed visibly, legibly and indelibly to the construction product or to a label attached to it. Where this is not possible, or warranted on account of the nature of the product, it must be affixed to packaging or to the accompanying documents. We believe at Sierra Windows that it is not practical to place labels on the products and therefore will be printing it on our invoices. Our unglazed customers will have to make up their own mind.
Instructions for the Factory Production Control Manual Template [Insert Job Title] insert as appropriate ( i.e. Managing Director, Manager, Installer or Qualified Employee or Company. (Job titles are inserted because individual named persons may change, but job titles will not). -
[Insert …..] indicates the need for you to insert text outlining procedures etc.
Italics indicate explanations and can be removed from the document.
Glossary CE - Conformité Européenne (European Conformity) DoP – Declaration of Performance (available at www.sierrawindows.co.uk) FPC – Factory Production Control (Quality Management System) IGU – Insulating Glass Units
References BS EN 14351-1:2006+A1:2010 - Windows and doors. Product standard, performance characteristics. Windows and external pedestrian door sets without resistance to fire and/or smoke leakage characteristics BS EN 12150-1:2000 - Glass in building. Thermally toughened soda lime silicate safety glass. Definition and description BS EN 14449:2005 - Glass in building. Laminated glass and laminated safety glass. Evaluation of conformity/product standard BS EN 1279-5:2005+A2:2010 - Glass in building. Insulating glass units. Evaluation of conformity
CE Marking Factory Production Control (FPC) checklist This checklist can be used to create your own FPC system (using the CE Marking FPC Manual template) or to confirm that your existing one meets the requirements of the Product Standard. A
Have you appointed the person who is responsible for FPC?
Have you defined the responsibility and authority of and relationship between personnel that manage, perform or verify work affecting product performance?
Have you identified those individuals responsible for all stages of production?
Are personnel performing work affecting product performance competent?
Do you have documented procedures for the calibration of testing and measuring equipment?
Do you have documented procedures for the inspection of testing and measuring equipment?
Do you have documented procedures for the inspection and maintenance of manufacturing equipment?
Do you have records of manufacturing equipment inspections and maintenance?
Raw materials and components
Have you documented the specifications of all incoming materials and components?
Do you have a documented procedure for the inspection of materials and components?
Have you documented the various stages of production?
Is the checking procedure identified?
Do you have records of all checks, their results and corrective action taken?
Product testing and evaluation
Do you have procedures to ensure that the declared values of the relevant characteristics are maintained?
Do you have a test plan for the testing and/or inspection of parts and products?
Do you have records of the results of inspections, tests or assessments and action taken?
Traceability and marking
Are your products identifiable?
Can you trace your products to their production origin?
Do you have procedures to ensure that the processes for affixing traceability codes and/or markings are inspected regularly?
Do you have documented procedures specifying how non-‐conforming products are dealt with?
Do you have records of non-‐conformities and how they have been dealt with?
Do you have documented procedures that instigate action to eliminate the causes of non-‐ conformities?
Example of Declaration of Performance
Declaration of Performance [DoP No.] 1.
Double-‐glazed PVCu casement sash window
Product type number:
Not on escape route
[Name and address]
[Name] – address as in point 4
System of assessment of performance:
Reference harmonised standard:
BS EN 14351–1:2006 + A1:2010
[Notified body and NB code] performed [task(s)] and issued [report nos.] 8.
European Technical Assessment:
Resistance to wind load
Load-‐bearing capacity of safety
Harmonised Technical Specification
BS EN 14351-‐1:2006 + A1:2010
Ability to release
< 1.6 W/(m².K)
10. The performance of the product identified in points 1 and 2 is in conformity with the declared performance in point 9. This declaration of performance is issued under the sole responsibility of the manufacturer identified in point 4. Signed for and on behalf of the manufacturer by: ..................................................................................................................................................... (name & title) .................................................................................. ......................................................... (place and date of issue) (signature)