Yes, not that I ever do balustrades! hopefully I can post this without infringing any copyrights?
RE: Classification of Common Balustrades within the Construction Products Regulation
There has been some considerable confusion recently, with specific reference to the scope of EN 1090-1:2009+A1:2011 Execution of steel structures and aluminium structures - Part 1: Requirements for conformity assessment of structural components.
The biggest area of confusion has been identifying which products 'do' and 'do not' fall within the scope of the standard. Not every component or product has been classified as yet and this will be an ongoing cycle of questions to the European Commission. However from the letter referenced below it has been made clear that 'common balustrades' are not structural products and do not fall within the scope of EN 1090-1. It is also clear that 'common balustrades' are within the scope of the Construction Products Regulation but as there are no harmonised standards covering the common balustrade, CE marking is not applicable. As has always has been the case in cases such as this, only national regulations apply i.e. National Building regulations and BS standards for the UK.
All 'Common Balustrades' sold as complete kits by FH Brundle fall within the non-structural balustrade remit and have been tested to ensure compliance with the UK National Building Regulations and National BS Standards. Details of 'kit' construction, is available in FHB literature. Where components for use in 'common balustrades' are sold individually, CE marking is also not applicable, with the responsibility of the construction falling on the installer / customer.
We are aware that many companies (including F H Brundle) have incurred substantial costs and time trying to prepare for CE Marking their hand railing under the scope of EN1090. The hand railing market operates within a very diverse scope of different materials, components and systems. In our opinion, when applying EN1090 to our huge range of 'common balustrade' components it, couldn't be applied in many instances. We have continually pushed for further clarity on behalf of ourselves, our customers and the trade in general, and were often told it is down to "our interpretation". We pride ourselves on running a business on legal and professional lines, and feel very strongly that a piece of legislation should not be down to our personal interpretation. Legislation should be implemented in a well-informed, clear and concise method that everyone understands. In our opinion EN1090 when applied to our 'common balustrades' did not fall into this category.
We very much hope that you find this information clarifies the situation.