The Fabricator Was Approved. The Workshop That Cut the Plates Was Not.

The main contractor was pre-qualified. The structural steel was specified correctly. The documentation arrived on time. The problem was that the connection plates had been cut and drilled at a sub-supplier nobody had approved.

What happened

A tier-two EPC contractor building a process plant module for an offshore floating production unit ordered grating, handrails and structural connection plates from a pre-qualified Chinese structural steel fabricator, to EN 1090-2 execution class EXC2.

The fabricator held a valid factory production control (FPC) certificate for EXC2, issued by a notified body under EN 1090-1. Its main shop had been audited and approved.

During a fabrication progress visit, our inspector found that the connection plates, which involved extensive plasma cutting and drilling, had been subcontracted to a nearby workshop. That workshop was not on the approved supplier list and held no FPC certificate for any execution class, nor the process qualification records for the work it was doing.

The fabricator's position was that the workshop was used informally for overflow capacity and operated under the main shop's quality umbrella. That is not a compliant position. Under an FPC system the manufacturer must control subcontracted processes and ensure the subcontractor meets the same technical requirements as the main shop for those processes.

The outcome

The plates already processed by the unapproved workshop were formally non-conforming under the contract. A documented disposition was required: re-manufacture at the approved shop with full traceability, or an engineering assessment by the notified body confirming the workmanship met EXC2 despite the procedural non-conformance.

The notified body assessment was pursued and took three weeks. Re-manufacture would have taken five.

The lesson

• Approved supplier lists must be contractually binding and must cover subcontracted processes, not only the main fabricator.
• Any change to the subcontractor list during fabrication needs written approval from the buyer or its representative.
• Progress visits should include where each process is physically performed, not only whether the parts exist.

Meritus includes subcontractor control as a mandatory clause in fabrication contracts with Chinese suppliers.

Related: process plant structural steel and platforms, topside modules and China shipyard and fabrication yard access.

Meritus Technology Shanghai
Email: sales@meritustech.com
Phone / WhatsApp: +86 134 8206 1802
www.meritustech.com