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

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Equipment – maintain measuring equipment via calibration

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Raw materials and components – inspection scheme for ensuring conformity

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Production process – document the various stages

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Product testing and evaluation – test and inspect non-finished and finished product

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Traceability and marking

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Non-conforming products – deal with and record non-conforming products

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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.

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Ordering Process which reflects the customers’ requirements, including compliance to prescribed product standards, Building Regulations and whole window and door u-values.

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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.

 

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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).

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Inspection of incoming product

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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.

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Record of Customer Complaints.

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Record rejected goods, windows, IGU’s, components, etc.

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Keep a record of what action has been taken to resolve complaints and deal with rejected or non-conforming items.

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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

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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.

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Have a