CROSS Safety Report
Documentation for imported large diameter steel pins
This report is over 2 years old
A reporter raises concerns over the possibility that foreign steel with poor, confusing or misleading documentation, is being used on safety critical structures in the UK.
Key Learning Outcomes
For steel fabricators and design engineers:
It is good practice to check the adequacy, completeness and authenticity of all certification of structural steelwork, particularly when safety-critical items are involved
For the construction team:
It is good practice to have a quality control procedure in place to inspect incoming steelwork to ensure it meets the required standard
Where a defect is identified in a product covered by a harmonised European Standard, the trading standards department of the local authority should be notified in order that they can investigate and take any necessary action
Find out more about the Full Report
The Full Report below has been submitted to CROSS and describes the reporter’s experience. The text has been edited for clarity and to ensure anonymity and confidentiality by removing any identifiable details. If you would like to know more about our secure reporting process or submit a report yourself, please visit the reporting to CROSS-UK page.
When designing a large pin connection for an external walkway bridge a reporter specified 60mm diameter solid circular bar for the pin. Due to the loads, higher grade S355 material was selected, and due to the thickness and external exposure, J2 subgrade was selected. As the quantities were small and timescales tight, the reporter took the precaution of ensuring suitable material was available from a stockholder. They were assured that it was.
Since the specification (S355J2G3) is not common-place and the element was of critical importance the reporter requested a certificate confirming the grade. When received, this indeed certified S355J2G3 material and revealed the material had originated outside the UK. However, a note on the form stated that the material was tested normalised and supplied as rolled. The implication is that the required ductility was not available from the material as supplied, and in fact no information on the ductility / brittle fracture performance of the as supplied material was available.
In short, the supplied material was not as advertised by the certificate and would only achieve the specified grade if subjected to normalising - a heat treatment process. The layout of the form had misled both the stockholder and the steel fabricator, neither of whom were aware that the material was potentially unsuitable. The problem was resolved by heat treating (normalising) the steel pins. However, it highlights the possibility that foreign steel with poor, confusing or misleading documentation, is being used on safety critical structures in the UK.
Expert Panel Comments
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Expert Panels comment on the reports we receive. They use their experience to help you understand what can be learned from the reports. If you would like to know more, please visit the CROSS-UK Expert Panels page.
The comments on Report 254 emphasise the importance of having both ductility and toughness (the two are related but separate qualities) This report, 299, highlights how easily the need to have ductility and toughness (the property implied by J2G3) can be overlooked and may not actually not provided. Although it is not a case of forgery, there was a lack of clarity, and the example shows that those in receipt of certification must be competent to judge its adequacy, completeness and authenticity. Designers should be particularly vigilant when safety-critical items are involved.
Reports 259, 331, and 284 follow a common theme and reveal a worrying trend. The fact that there are reports concerning different products suggests that these incidents are not rare. Designers and contractors may need to consider as a matter of ensuring structural safety whether to instigate routine testing of any product purchased from a source which is not well known.
CE marking raises issues
The globalisation of material supply and the introduction of CE marking are raising issues about the quality of material received on site. It is clear that CE marking alone may not offer the same level of confidence as quality schemes that have been used historically. CE marking is a standardised method of giving product characteristics against a harmonised EN. It is not a declaration of fitness for purpose in any particular circumstance of use and a reputable product manufacturer's technical information may be more useful if it gives advice on the use of the product in service.
There is confusion over when and if CE marked products need to be used especially in projects which are publicly procured. In fact, CE marking is a significant topic for Public Procurers. A related issue is the readiness of clients, designers, contractors, suppliers and manufacturers for the introduction of the Construction Products Regulation (CPR) in July 2013. The Construction Products Regulation (305/2011/EU - CPR) – replacing the Construction Products Directive (89/106/EEC – CPD,) is laying down harmonised conditions for the marketing of construction products.
There is confusion over when and if CE marked products need to be used especially in projects which are publicly procured. In fact, CE marking is a significant topic for Public Procurers.
Also, of concern is whether in the UK the 'market surveillance' required is in place (via Trading Standards Organisations) and that they have the necessary resource and expertise. Detecting forgeries is not easy and in 2010 the UK Department for Business innovation and Skills issued a warning about organisations falsely claiming to be notified bodies which included the following:
‘The Department is aware of some cases where organisations either claim or present themselves so as to appear to be notified bodies (e.g. in websites and in their publicity materials), when they actually hold no such appointments. Such claims are misleading manufacturers and importers into using the services of organisations promoting themselves as notified bodies authorised to undertake conformity assessment and certification process, when in fact, they are not authorised to do so’.
Practical guidance is needed and as an example BCSA has issued some simple, practical advice guidance to its members (memorandum No 193-10) on how to check a CE marked certificate. With their permission it is reproduced below:
‘For most Steelwork Contractors purchasing CE Marked steel sections, bolts and welding consumables is still relatively new. It is therefore important that those ordering and checking goods are able to identify a valid CE Mark. All manufacturers of CE Marked products (steel sections, structural bolts etc.) are required to have an "EC certificate of conformity ‘.
This should be signed by the ‘Notifying body’ and show the specific range of grades & products covered. It is not a blanket certificate for all products. The manufacturer should only be CE marking those products listed on the Certificate. A copy of the certificate can be obtained from the manufacturer or the supplier.
- EC Certificate of Conformity
- The EC Certificate is produced by the Notified Body and should include:
- Name and address of Notified Body
- Name and address of the manufacturer or his agent in the European Union
- Description of the product (type, identification, use…)
- Provisions to which the product conforms
- Particular conditions applicable to the use of the product
- The certificate’s number
- Conditions and period of validity – where applicable
- Name and position of the person empowered to sign the certificate.
The Notified body must be approved by the European Commission and the following website can be used to check this: http://ec.europa.eu/enterprise/newapproach/nando/. The manufacturer is also required to produce a "Declaration of conformity”. Once again, a copy can be obtained from the manufacturer or the supplier.’
From the reports and the comments of the CROSS Expert Panel it would seem that guidance on the confidence given by, and the acceptability of, CE marking and the use of the Construction Products Regulation would be timely.
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