This Bulletin is intended to clarify the requirements for surveillance activities under the CPR for organisations operating to EN 1090 – Structural Steel and Aluminium.
This clarification follows discussions at the recent UK CPR Notified Bodies meeting with regard to the need for an annual surveillance visit and has been drafted in cooperation with MHCLG and the Chair of the UK CPR NB Group.
There is no mandate for a compulsory annual surveillance audit; this can be offered as an option/recommendation but none of the currently published regulatory or guidance includes such a requirement.
Requirements for the minimum frequency of surveillance visits are included within Table B.3 of EN 1090.
Notified Bodies should also take note of Article 52 (2) of the CPR which states that “Assessments and verifications of constancy of performance shall be carried out with transparency as regards the manufacturer, and in a proportionate manner, avoiding an unnecessary burden for economic operators. The notified bodies shall perform their activities taking due account of the size of the undertaking, the sector in which the undertaking operates, its structure, the degree of complexity of the product technology in question and the mass or serial nature of the production process.
In so doing, the notified bodies shall nevertheless respect the degree of rigour required for the product by this Regulation and the part played by the product for the fulfilment of all basic requirements for construction works.”
It should be noted that there had been a recommendation for annual EN 1090 surveillance visits from the GNB CPR Sector Group 17, and a draft guidance/position paper was prepared (see GNB CPR SG17 minutes dated August 24, 2018). However, this position was not yet accepted and, as such, the paper was never published.
Should you require any clarification on the subject covered by this bulletin, please contact; [email protected].
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