We began publishing the guidance for you 8 weeks ago, so it probably makes sense to provide a brief reminder of why an FPC system is necessary.
Under the Construction Products Regulations (CPR) manufacturers of construction products for which there is a harmonised European Standard (hEN) will need to produce a declaration of performance (DoP) for their product and apply the CE mark. Joinery manufacturers will be obliged to prepare DoPs for external windows and doorsets from July 2013 and work is underway on harmonised standards for internal doorsets and fire-rated doorsets. There may also be work in the future on developing the existing standard for timber stairs into a harmonised standard.
It will be necessary for manufacturers to demonstrate that they are managing their production processes so that the actual performance of the products they manufacture remains consistent with the declared performance. To do this the CPR has determined that all manufacturers making a DoP and applying the CE mark will need to operate a Factory Production Control System (FPCS).
The last part of our guidance runs through the final instalment of the template document for an FPCS and covers receiving and inspecting materials, and controlling machining operations. These areas are key steps in ensuring consistency from batch to batch. Are the materials delivered of the correct quality, of the correct type, and in the correct number or volume to be consistent with the specification supplied with the order? Is there the correct information provided to the machinist along with enough material of sufficient quality to allow the right components to be manufactured to the right quality and in sufficient volume? These are questions that will all need to be addressed. The inspection guidance documents themselves should give you a pointer on what to look out for.
But don’t consider an FPCS as an unnecessary burden imposed on your business as not only does it cover you for your obligations under the CPR but it can also benefit your business under other areas of legislation. For example, the European Timber Regulations (EUTR) establishes a requirement on a “trader” in timber products (e.g. a joinery manufacturer buying from a UK timber merchant) to identify the organisations who have supplied them with timber or timber products, and, if they are going to supply those materials on to another “trader” they must identify, to whom they supplied the materials. Records of these transactions must be kept for at least five years and made available to the authorities if they so request. If the “trader” sells products to a final consumer, the requirement to identify to whom they have supplied timber or timber products is deemed not applicable.
For a manufacturer operating an FPCS, their usual procedures will cover them for their obligations for record keeping under the EUTR. They will keep records of orders placed with their suppliers, and records of products or materials supplied to their customers. So, not only is the FPCS managing the consistency in the quality of work flowing through the workshop or factory but the records produced can be used for other purposes and not just for CE marking.
Companies making a transaction where they are the first to place a timber product on the EU market will be subject to more comprehensive obligations, but some of these can again be incorporated into their FPCS. You can read more about these obligations in our 'easy guide to the EU timber regulation'.
In our FPC online guidance, we provided information on what a written Factory Production Control System should consist of. In the latest installment we have provided inspection forms for use in a written Factory Production Control System.
The BWF can provide members with advice on CE marking through our technical helpline, and we can also arrange a consultancy visit from an FPC expert, who can visit your workplace and help to set up your FPC system.
