We met with Alex Murphy, DCLG, Roy Fishwick, Cleveland Steel and Tubes and Tim Yates, BRE on 15th July to flag up our concerns that CE marking was a potential barrier to reuse. DCLG administer the Construction Products Regulations. We also met with BSI who have tabled our document.
Early on in our Innovate UK project, we identified CE marking as a potential barrier to reuse more generally, so we prepared a discussion piece on this, which we posted out for comment. The overwhelming response was that clarification was required, so we discussed this with Tim Yates at the BRE, who kindly suggested we should meet up with DCLG, who noted our concerns.
Clearly, structural steel that was manufactured before the introduction of the Construction Products Regulation (CPR) will not be CE-Marked and is likely to have been manufactured to a (now withdrawn) national product standard.
Decoated surplus steel pipeline. Image credit: Cleveland Steel and Tubes Ltd.
We have investigated, with advice from steel certification experts, the requirements of the relevant harmonised standards for hot rolled structural steel products and fabricated steel structures (EN 10025 and EN 1090). Our conclusion is that under EN 1090-2 reclaimed structural steels do not need to be to the relevant product standard; in this case EN 10025-1, as long as their properties are specified. However, this view appears to be subject to interpretation of the relevant clauses in the relevant standards.
Whether real or perceived, certification of reclaimed structural steel is a significant barrier to their reuse. In terms of overcoming this barrier therefore we propose the following:
- Obtain a more definitive interpretation of the standards concerning reclaimed structural steel (it is noted that both EN 1090 parts 1 and 2 are currently being redrafted).
- Include a relevant clause(s) in the standards and the CPR that specifically address the requirements for reclaimed structural steel so that this option is proactively encouraged in line with the EU’s circular economy strategy.
As part of this project, we have discussed certification and use of reclaimed structural steel with BSI and as a consequence, produced a note on our understanding of the certification of previously used structural steel. BSI has circulated this note to the following BSI committees:
- CB/203 – Design and execution of steel structures
- ISE/103 – Structural steels other than reinforcements
- B/558 – Sustainability of construction works
With a request for comments specifically on:
- a definitive interpretation of EN 1090 with regard to use of reclaimed steel
- the possibility of revising EN 1090 to allow for the use of reclaimed steel
- any other comments on standardising for the use of reclaimed steel
The deadline for the receipt of comments is 1st August therefore we will include a summary of these comments in the final deliverables for the Innovate UK steel reuse projects.
For further information about the Reusable Buildings Network and to get involved, contact Simon Corbey at firstname.lastname@example.org.