Factory production control (FPC) under EN 1090-1

Anyone placing load-bearing steel or aluminium structures on the EU market needs certified factory production control. FPC is the system that shows your structural components consistently meet their declared performance. It underpins the declaration of performance and CE marking under EN 1090-1.

Many fabricators treat FPC as paperwork dusted off once a year for the audit. That is a missed opportunity. A well-designed FPC prevents errors in the workshop, limits disputes at handover and makes the notified body's audit considerably easier. This article explains what belongs in it and how to set it up in practice.

1. What FPC under EN 1090-1 is

EN 1090-1 is the harmonised product standard for steel and aluminium structural components under the Construction Products Regulation (EU) 305/2011. Structural components fall under assessment system 2+. The manufacturer is responsible for production and the declaration of performance, while a notified body assesses, certifies and monitors the FPC.

FPC covers all procedures, instructions and records through which the manufacturer controls production. The certificate states, among other things, the highest execution class for which the company has been assessed. Work in a higher class cannot be CE marked under that certificate. Our article on CE marking of steel structures explains how the marking itself works.

2. What an FPC system must cover

EN 1090-1 sets out the elements an FPC must address as a minimum. In practice these are:

• Personnel: tasks, responsibilities and documented qualifications, including the welding coordinator and welders.
• Equipment: machine maintenance and calibration or verification of measuring and test equipment.
• Design: if you carry out structural design yourself, that process falls under FPC as well.
• Materials: goods-in inspection, inspection documents and traceability of steel, bolts and consumables.
• Production: work preparation, cutting, drilling, welding and corrosion protection to EN 1090-2.
• Inspection and testing: dimensional checks, visual testing and supplementary NDT, with records.
• Non-conformities: handling of non-conforming products and corrective action.
• Identification, storage and transport: marking of components and protection against damage.

3. Setting up FPC in practice

Start with how your company actually works, not with a manual. A workable approach:

• Map the process from contract review to handover and decide where checks and records are needed.
• Choose the execution class you want certification for. EXC2 covers most commercial building work; EXC3 asks considerably more of the system, personnel and testing.
• Lay the welding foundation: qualified WPSs backed by WPQRs, qualified welders and a nominated welding coordinator with the right level of knowledge under ISO 14731.
• Create simple forms for goods-in, dimensional checks, weld inspection and non-conformities, and use them on the shop floor.
• Run one or two projects through the new system before the notified body visits, so there are records to show.

Keep the system as lean as possible. A procedure that is not followed in the workshop is more likely to produce an audit finding than to help.

4. The role of the notified body

The notified body is designated by a Member State and listed in the European NANDO database. Under system 2+ it has two tasks:

• Initial inspection of the plant and the FPC, assessing the system, workshop, records and welding organisation. For welding companies, an auditor with welding expertise also assesses welding coordination.
• Continuous surveillance through periodic audits, at a frequency that depends on the execution class and is higher for EXC3 and EXC4 than for EXC1 and EXC2.

The notified body does not approve individual products and does not apply CE marking. That responsibility stays with the manufacturer, who draws up and signs the declaration of performance.

5. How FPC relates to ISO 3834

Welding is a special process: its quality cannot be fully verified afterwards. EN 1090-2 therefore refers to ISO 3834 for welding quality requirements, with the part depending on the execution class:

• EXC1: ISO 3834-4, elementary quality requirements.
• EXC2: ISO 3834-3, standard quality requirements.
• EXC3 and EXC4: ISO 3834-2, comprehensive quality requirements.

The notified body assesses these requirements as part of the FPC audit. A separate ISO 3834 certificate is not required for EN 1090, but can be worthwhile if you also supply pressure equipment, machinery or other welded products outside construction. Our article on the parts of ISO 3834 explains the differences.

6. How FPC relates to ISO 9001

ISO 9001 is not mandatory for EN 1090-1, but the standard does state that a quality management system to ISO 9001, made specific to the requirements of EN 1090-1, satisfies the FPC requirements. If you already hold ISO 9001, build the FPC into it, using the same document control, internal audits and non-conformity handling, supplemented by the product-specific requirements of EN 1090-1 and EN 1090-2.

Conversely, FPC need not be a full ISO 9001 system. For a smaller workshop, a compact FPC focused on materials, welding, dimensions and records is often the most workable. To get the set-up right from the start, consider targeted EN 1090 support.