07-06-2011
31th meeting of the EUROLAB-CEOC
Joint Technical Committee on
Product Testing and Certification (JTC PTC)
7 June 2011
at CEOC - Brussels
ca. 10:00 - 15:00
Draft Minutes
1. / Opening of the meetingIntroduction of members and guests
Christian Priller opened the meeting thanking Guy Jacques for his dinner invitation on the day before and handing over a farewell gift from the whole JTCPTC group.
2. / Approval of this agenda
The draft agenda was approved.
3. / Approval of the minutes of the JTC PTC meeting on 29-10-2010
Matters arising from the minutes
The draft minutes were approved.
Political issues – for more monitoring in general
Drewin Nieuwenhuis re-launched discussion if JTCPTC should become more political/ issue position papers etc.
Example: current food crisis in Germany.
Guy Jacques answered that topical position papers could be a good solution.
Christian Priller confirmed that more active monitoring of political issues suggested by Drewin Nieuwenhuis would be beneficial, but that for this purpose the specific knowledge should be made available.
For instance several of JTCPTC members around the table work for companies active in the field of food testing (SVTI, TÜV NORD, Vinçotte etc.).
Herbert Egolf suggested to focus also on process safety issues.
Guy Jacques confirmed that food safety in Belgium is a booming business (Vinçotte just bought a company in the sector with around 80 people staff).
Daniel Pflumm supported the idea of having more position papers etc., but not to forget the gathering of specific knowledge as mentioned by Christian Priller.
GuyJacques: we always have to have the know-how and to present a solution.
Specific issues
Problem of fake products – no progress regarding a proposed survey:
GPSD – attendance of a CEOC delegation in the International Product Safety Week in December 2010.
New Legislative Framework on the marketing of goods/ NLF – D. Pflumm underlined that we want to keep consistency in this and not re-open the process again by rewriting the regulation (which could occur in the process of harmonising market surveillance). The Schaldemose report etc. are of course welcomed in order to close the gap with the GPSD.
C. Priller as convenor of ISO WG29 reported on the work of the group. There is a seat in the CPC group open for A-liaison members, so CEOC International as one of the most active A-liaison members could/ should apply for this. Proposal supported by H. Schaub.
ISO-CASCO plenary meeting in October 2011.
ACTION -D. Nieuwenhuis suggested to discuss this personally with Sean MacCurtain and/ or to send a letter to ISO-CASCO formulating the justification for CEOC’s candidacy.
Information on the keymark by CEN
EAAB meeting – sector schemes
Short overview by Hoang Liauw.
4. / European Commission – Regulation 765/2008 – Concerns of the Industry
Orgalime Position Paper on assessment and surveillance of Notified Bodies using subsidiaries and subcontractors in third countries
Normapme position paper on accreditation of proportionate procedures
BusinessEurope letter for the promotion of equivalence and equal reliability of the accredited conformity assessment services
Discussion on the interest to prepare a position paper expressing the views of the conformity assessment bodies with regards to the related issues and the contradictory expectations formulated by the stakeholders
Discussion of the three above mentioned documents.
Orgalime Position Paper
Criticism from Guy Jacques saying that the Orgalime position paper is technically not correct.
C. Priller: We should be careful not to take over Orgalime positions.
H. Egolf: Orgalime is saying that the system is not working and blame other players, such as the TIC sector.
D. Nieuwenhuis: the danger if we do not react is that the voice/position of the TIC sector is not heard at all and that only the Orgalime position paper will be recognized.
H. Schaub advised not to refer directly to the Orgalime position paper in a JTCPTC position paper to be drafted.
C. Priller: JTCPTC should move from a reactive to a proactive approach. Demonstrate the added value of third parties.
D. Nieuwenhuis: JTCPTC should come up with some facts and figures to underline the arguments.
JTCPTC response
ACTION: create a general position paper. Guy Jacques and Philippe Dewolfs will provide input for this position paper (by end of August). D. Pflumm suggested to use part of a VdTÜV briefing on the latest RAPEX report.
5 / EA - Information / Discussion on political and technical issues
5.1Report on the latest EAAB meeting
Key topic the conformity assessment schemes: their acceptability for conformity assessment purpose, the way EA should handle them….. (see introduction document and fitrst set of resolutions at EAAB level)
5.2Report on the latest EA HHC meeting with special focus on EA 2/11 (acceptance of schemes), EA 2/13 (cross frontier policy).
5.3Report on the latest EA IC and CC meetings
5.4Report on the latest EA General Assembly
5.5. Development of EA competences in the field of accreditation of notified bodies
Summing up the key topics of EAAB by Guy Jacques: new chairman is needed. Next EAAB meeting will be Guy Jacques’ last meeting. No volunteer at the moment.
Key topics for the next meeting:
1. Enhancing the EU peer evaluation system
2. EA strategy 2010-2015. Make EA more professional (having a Secretary General, Treasurer etc.)
3. Promotion of the EA MLA in the market
4. SMEs in accreditation bodies (Guy Jacques: convinced that it should not be mandatory to have accreditation bodies in very small countries. Example Luxembourg: accreditation body with only 3 people staff, all additional staff recruited/ paid from COFRAC).
H. Egolf: Mid-term strategy of EA; only goal should be to create a unified EU accreditation system.
C. Priller: at the end of the day we have a system that is not working. The EU economy needs a suitably running EU accreditation system (see JTCPTC views on the NLF when it was drafted). Jacques McMillan is not fully aware of what EA is doing. JTCPTC should claim what is necessary from our side. JTCPTC should address EA and the Commission on this point.
C. Priller referred to the outcome of the CC questionnaire on the implementation of the NLF. Question: What has changed since?
C. Priller: Accreditation bodies are sending more and more auditors (large number of auditors not necessary in the view of JTCPTC).
G. Jacques: The quality of the auditors of the accreditation bodies is becoming lower and lower. This does not justify the price.
Annual costs for all issues related to accreditation, mentioned by C. Priller from TÜV SÜD: around 100,000 EUR or more.
H. Schaub: EA is exporting article 7 to accreditation bodies outside the EU.
EA 2/ 11: EA started discussion three years ago on schemes. Basic idea is to ensure that one scheme owner should get the same answer from all accreditation bodies.
Acceptance is different. Merih Malmquist (EA HHC) wanted to achieve that all national schemes should comply with EA2/11.
G. Jacques introduced the key topic of acceptance of the schemes during the last EAAB meeting.
A lot of people said that we should avoid the proliferation of schemes.
EA is not able to say what is the purpose of the document (binding, optional etc.) and to specify whether it should be compatible with …
Over 440 voluntary schemes for food safety in Europe; 30 in Belgium.
EA should define a strategy within one year, but will this happen?
UK and France do accredit schemes that are not compliant with the 17000 series.
EA 2/ 13 – cross frontier
Procedure of EA to accept the multisite.
Difficulty: very small tensions between accreditation bodies.
EA should finalise 2/13 within a reasonably short time, due to G. Jacques.
EA 2/ 17 – accreditation of NBs
Scope of accreditation should be closely linked to the scope of notifications.
The auditor of an accreditation body should not only know about the product, but also about the related directive.
To sum up: G. Jacques strongly advises to focus on these three priority issues during the next EAAB meeting.
Report on the revision of ISO 17020 by H. Schaub
Reintroduce the old requirement that inspection should normally not be subcontracted (was in the old standard, should be possible to reintroduce it without any problems).
For information: CEOC Inspection committee is dealing with all these questions.
Report from the last EA General Assembly by H. Schaub
New faces within EA:
Rolf Straub from Swiss Accreditation body (replacing Norbert Müller from the Austrian Accreditation body);
Paolo Bianco from the Italian Accreditation body.
Developing a new paper on the impartiality of governmental accreditation bodies (not necessary according to H. Schaub).
New work item to revise 409;
New work item concerning Accreditation for Non-Destructive Testing.
5.5. – Status quo of EA competences in the field of … - already discussed.
6. / Issues / information from standardisation
6.1 Development of ISO/IEC 17020
6.2 Development of ISO/IEC 17065
6.3 Development of ISO/IEC 17067
6.4 ISO CASCO and CPC
6.5 CEN / CENELECT TC 1
D. Pflumm mentioned a regulation and consultation on European standardisation published on 01 June 2011.
H. Liauw: The whole discussion is not new. The single market act has a chapter on services. One objective is to make the standard-setting process more transparent.
For standards in the ICT sector or sectors where there are no EU standards yet …, other consortia/ standard-setting bodies should be permitted. This would undermine the work of the EU standard-setting bodies. CEN and CENELEC will respond to this proposal.
Free access to standards. CEN/CENELEC made a survey with its members.
NORMAPE position paper: NBs should also be mentioned.
C. Priller: great concerns about all approaches to weaken the position of the so-called national delegates. JTCPTC should strengthen that we are in favour of the national delegates as first point. We have to avoid different wording at the EU and international levels.
H. Egolf: be careful with the proposal of allowing other consortia in the standard-setting process.
H. Liauw: invited JTCPTC to formulate our view.
G. Jacques summed up the JTCPTC point of view:
1. Keep the principle of national delegates;
2. transparent system;
3. avoid different wording on EU and international levels;
4. avoid alternative consortia.
D. Pflumm: VdTÜV already commented on the standardisation issue (in German) and is willing to provide input.
G. Jacques: we should of course have a common understanding of what we do not want.
MEPs: Edvard Kosuznik; Andreas Schwab; Italian MEP etc. competent in standardisation.
Decided: JTCPTC will support the CEN/CENELEC position.
ISO 17020 standard
Normally, the revision of the standard was not necessary from a CEOC point of view.
At the end of the day there will be some small improvements according to C. Priller. But the biggest aim from CEOC side was to protect the existing standard. Avoid a guidance paper from IAF/ILAC maybe the most crucial thing. Compared to the risks facing during the revision the outcome of the revision is rather satisfying for JTCPTC.
ISO 17065 standard
Report by Christian Priller. See also PPT.
In delay with the revision; but process cannot be faster at the moment respecting voting periods.
German translation is done and will be published within the next two weeks, then voting period until the end of October, followed by a drafting group meeting. Next March: F-DIS version, then two months balloting. Work should be closed in June/July 2012. Then two years transition period. In summer 2014 the process will be fully finished.
There were a lot of working drafts, too many.
All CEOC comments accepted without difficulty (except for comment on impartiality mechanism).
CEOC should propose to proceed to an F-DIS version.
C. Priller mentioned that 17065 (requirements for NBs) and 17067 (guidance document) are no combination!
“Shall” means a requirement, “should” a recommendation. This will be explained in the standard according to H. Schaub.
6.4. – CPC
6.5. – CEN/CENELEC TC 1 report by G. Jacques – next meeting in September in Brussels.
Communicate the results of HHC to CEN/CENELEC.
7. / Any other matters
7.1 ILAC / IAF
Discussion on where “inspection” should be placed.
Elaborate a common document (E 4), there was also discussion about merger. In the end, it was decided to put inspection on the ILAC side.
8.. / Date of next meeting
Closing of the meeting
Upcoming meetings
EA HHC, Dublin, 27/ 28th of September
10th of October – next EUROLAB General Assembly;
EAAB – 20th of October
EA General Assembly - 23/24 of November
Date for the next JTCPTC meeting: 29 of September. Location tbc.
JTCPTC Secretariat
BAM Federal Institute for Materials Research and Testing
Unter den Eichen 87
12205 Berlin Germany / Telephone:
Telefax:
E-mail: / ++49 30 8104 1306
++49 30 8104 1317
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