Mastering EN 1090 Factory Production Control (FPC): Comprehensive Audit Checklist & Compliance Guide

EN 1090-1 Clause 6.3 outlines the requirements for the Factory Production Control (FPC) system.Here’s a simple summary of what is needed to have a compliant FPC system:

– Documented FPC system (Clause 6.3.1): You need to have a written FPC manual that includes all the procedures you use to control how you make your products.
This manual should explain how you run your production and inspect your items, and it should have records for all the tests and inspections you do.This is like a mini quality manual specific to EN 1090.It doesn’t need to be full ISO 9001, but it usually follows many of its requirements.

– Organizational roles and responsibilities (Clause 6.3.2): Your FPC system should clearly state who is in charge of different tasks that affect your product’s quality.
You must have a qualified Welding Coordinator, and people in charge of materials, inspections, and dealing with problems (Non-Conformance Reports) must have proper training and be fit for the jobs they do.

– Equipment control (Clause 6.3.3): All equipment you use for measuring, testing, and making your products must be properly controlled.
You must check and maintain your equipment so that it doesn’t cause problems with your products.Every activity like calibration or maintenance must be written down and kept as part of your FPC procedures.

– Design (Clause 6.3.4): If your company is responsible for the design of the structures you make, your FPC system must cover that design process.
You need to make sure that the design meets the requirements, and you must document who checks calculations and who is responsible for each part of the design.Not all fabricators do the design, so this may not apply to them.

– Constituent products (Clause 6.3.5): All the materials and consumables you use must meet the standards EN 1090-2 for steel or EN 1090-3 for aluminum.
You must have written procedures to check that everything you receive matches the specifications.Each batch of materials needs to be identified and easily traced back to its certificate of conformity (CoC).The EN 1090-2 standard adds more specific rules, such as for bolting and cutting, and you need to ensure all steel materials, like filler metals and cut edges, meet the right standards.

– Component specification & production control (Clause 6.3.6–6.3.7): For each part of your structure, you must have a “Component Specification” that includes the design details, materials used, execution class, welding process, and inspection plan.
You also need an inspection and testing plan for production.Each component must be checked against its specification, such as size and weld quality, and the results must be recorded.The sampling process must follow the specified performance characteristics in Annex ZA of EN 1090-1, depending on the execution class.

– Welding and bolting operations: EN 1090-2 and EN 1090-3 require strict controls over welding and mechanical fastening. Your FPC system must include approved welding procedure specifications (WPS) that have been tested and certified (WPQR), as well as qualification certificates for welders and operators (ISO 9606-1/14732).You must also define the role of the Welding Coordinator.Bolted connections, where required, must use certified high-strength bolts, proper tools for tightening, and proper documentation, such as torque certificates.You must also have controls for the purchase, identification, storage, and use of welding consumables, following the First-In-First-Out (FIFO) method.It’s important to note that all welding must follow ISO 3834, depending on the execution class, which often means having EN ISO 3834-2 certification or similar quality control processes for EXC3 and EXC4.

– Inspections & Testing: Your FPC system must cover all required inspections, such as visual checks of welds, measuring dimensions, and non-destructive testing (NDT) when necessary.
All inspection results must be recorded.Annex B of EN 1090-1 (for Notified Body use) implies that your audit will check that inspections and tests are properly planned and documented.

– Nonconformity handling (Clause 6.3.8): You must have written procedures to find, record, and deal with any issues with your products.
As soon as a problem is found, it must be recorded (Non-Conformance Report), assessed, and corrected.All records of non-conformities must be kept, including any rework or special approvals.

– Records & Retention: All records related to the above processes must be kept.
EN 1090-1 requires that test and inspection results are recorded and that any issues and their solutions are kept for the time your company decides and documents.The standard does not set a specific retention period, so you must decide and write it down.(In comparison, CPR requires keeping the Declaration of Performance and technical documents for 10 years after the product is sold, and EN 1090-1 requires retaining initial type test and calculation records for at least 5 years.) In practice, many fabricators keep records from 5 to 10 years, or longer, for warranty and regulatory reasons.

– Internal audits & management review: Although EN 1090-1 does not require internal audits or management reviews like ISO 9001, a solid FPC system (often part of an ISO 9001 Quality Management System) might include these.
Regular internal audits help check that FPC procedures are followed and working, while management reviews ensure that the system is reviewed by top management.PZVAR’s audit advice shows that a lack of internal audits and corrective actions is a common problem.Best practice: schedule annual internal FPC audits and regular management reviews to spot issues early and show that you have control.