Draft Reporton the 27th Meeting of the EA Advisory Board
held on20 October 2011(10:00 am to 3:30 pm)
at the EFTA Secretariat, 12-16 Rue Joseph II, B-1000 Brussels
Participants:
G. Jacques (EUROLAB) - EAAB Chair
M. Stadler (BUSINESSEUROPE), M. Nitsche (NA, Germany) - EAAB Vice-Chairs
H. Egolf (CEOC International), A. Dalrymple (IQNet), N.Kleinjan (EEPCA)
K. Stochholm (ORGALIME), H. de Pauw (NORMAPME), Jörg Hartge (ZVEI/ORGALIME),
A. Evans (CAPIEL)
P. Vrtacnik (NA, Slovenia), A.Korou (NA, United Kingdom)
I.Jachwitz (ETSI)
J. Drnovsek(EURAMET)
J. McMillan (EC), Nike Bönnen(EC), T.N. Thomassen (EFTA)
G. Talbot (EA Chair), D. Pierre (EA Vice-Chair)
M.Blum (EA Secretary)
Apologies were received from K. Rud Michaelsen (NA, Denmark), F. Farrugia (NA, Malta) and F. Laudinet (EA Secretariat).
- Opening of the meeting; Introduction of members and guests
G.Jacques (GJ), the EAAB Chairman, opened the meeting.
He especially welcomedN.Bönnenrepresenting the European Commission together with J. McMillan.
T.N. Thomassen (TNT) informed the Board that this would be his last EAAB meeting. He has made the necessary arrangements for the next meeting in April 2012 to be held at the EFTA Secretariat. The Chair thanked TNT and EFTA for their hospitality.
2.EAAB Interim Chairmanship in 2012
The Chair reported that M. Nitsche (MN) accepted to chair the next meeting in April 2012 on an interim basis. This was unanimously approved.
It was clarified that the nomination process for the next term of the Board will start after the April 2012 meeting.
Action Secretariat to initiate the call for nominations in due time
3.Approval of agenda; Report on 26thMeeting of the EA Advisory Board;
Action list(actions not covered elsewhere)
The agenda was approved with the following additional items:
- proposal to establish an EAABTFGon sector schemes (newAgenda Item 4.3);
- appointment of a new EAAB observer in the HHC (under Item5.1);
- use of successful results of laboratories in PTs to extend the period of surveillance, including information on the ILAC/BIPM document on accreditation of NMIs(new Agenda Item 5.7). ;
- transparency of EA’s decisions towards the marketplace (underAgendaItem 9).
The Chair reviewed the actions list and confirmed that all actions had either been completed or would be discussed at the meeting.
The report of the last meeting was approved.
Action Secretariat to publish the approved report on the EAAB public webpage
4.Key topics for discussion
4.1 EA Strategy 2010-2015
The EA Chair introduced the two papers onto the EA Strategy and Strategic Objectives for the years 2010-2015 as approved by the EA General Assembly in May 2011.
Graham Talbot (GT) first explained the background: since the previous strategy put in place in 2002, EA developed a strategic plan initiated within 5 sub-project (SP) groups. An extra General Assembly was held in May 2008 to approve employing new staff and restructuring the Secretariat. For EA to becomebest geared to its new role, a strategy session was organised in January 2010 in the Executive Committee to look at the EA strategy for 2010-2015. Full SWOT and PEST analyses werecarried out. The Executive Committee looked at a vision for the future of the Secretariat and EA management. A draft strategy was presented to the General Assembly in November 2010, based on abalanced scorecard approach. Key strategic objectiveswereidentified and approved in May 2011. The Executive Committee has been working on activities to be put in place in order to meetthese strategic objectives.
GT highlightedsome key points elaborated on in the documents:
-the prime importance is that EA increases its influence in Brussels, on the European Commission in particular, including a possible representation of EA in Brussels;
-the EA management should be enhanced by an Executive Secretary or equivalent to carry outmanyof the responsibilities currently taken by the EA Chair, Vice-Chair, Treasurer and Quality Manager, due to the fact that it will be more and more difficult for ABs to provide EA with such a level of resources in the future;
-the EA Central and MAC Secretariats will be put together into one single EA management system;
-finally, training and harmonization will continue to be focal points for EA in order to maintain and optimisethe value of accreditation and the EA MLA.
All participants congratulated EA on the very good, solid papers giving a clear idea of EA’s ambitious objectives.
The CABCollegefully supported the strategy.
For theIndustryCollege, the strategic objectives are fully in line with the expectations of industry. The proposal to appoint an Executive Secretary in Brussels was given explicitsupport as this was considered abasic need for any professional organisation operating at European level such as EA.The IndustryCollegewas pleased to note that EA is fully aware of the challenges the conformity assessment system faces with regard to competition byother product approval systems.
It was found regrettable thatEA’s role in the harmonisation of national practices is somewhat missing and should be reinforced as a major objective.
EA has to ensure that its services are efficient and fully correspond with the needs of both the market place and the regulators. For this purpose, it is necessary to communicate the benefits of accreditation and of the conformity assessmentsystem placed under it to regulators on a continuous basis. The IndustryCollegewill support EA in coping with this challenge.
The NA College especially welcomed thefocus placed on EA as a learningorganisation as well as the secondment of EA Members to stimulate cooperation amongst NABs. This was regarded as a very good way for small and new EA ABs to fulfil requirements.
The strategy was also supported by I.Jachwitz (IJ). He referred toexperience in the standardisation area that showsthat it is more difficultto get the Members to contributeto and get involved in fulfilling the actions.To be realistic with this great number of objectives, not all of them might be achieved within the set timeframe.The Secretariat and the Executive Committee are the ones who really do the job. Obtaining the involvement of the majority of EA ABsshould be seen as a success factor.
The EA Chair thanked the Board for its feedback, confirming that harmonisation of national practices was implicit and wouldbe pursued.
GT also clarified that a balanced approach has beenadopted in adeliberate attempt to make sure that EA would not concentrate on only one area, i.e. EA’s role in supporting the regulated sector.GT agreed with Board members that the objectives are very ambitious as shown by the draft action list.However, even if EA realises that all the objectives may not be completed within the timeframe, they would have been at least clearly identified. EA is also quite aware that Members will have to be involved.
J. McMillan (JMcM) referred to the introductorypart of the strategy document, which looks too technical in his view. EA has a political dimensionwhich should be highlighted in the introduction to avoid accreditationfrom being regarded as a purely technical matter. The stronger the political visionis, the less risk there would be for parallel systems to develop.
The EA Chair fully supported the comment. He clarified however that it is a living document, and although it will not be changed at the moment, the point would be incorporated in the future. Moreover, it is an EA internal document, not an external one to be communicated outside. GT recognized that a short policy document may be needed.An EA communications plan would be published which should also address this issue. Furthermore, material as to the specific benefits that theconformity assessment system under accreditation can deliver to the economy is needed, for use by stakeholders.
MN advocated stressing the links between conformity assessment, accreditation, EA and the national authorities.IJ pointed out that, as with standardisation, it isdifficult to present and explain the benefits of accreditation. He supported to have another document to promote accreditation and its values. This goal is even more important now that EA has been given a new role.A.Korou (AK) very much appreciated the last part of the document as, in addition to technical aspects, it shows dynamics and values people.
The EA Chairconfirmed that EA is revising its EA brochureand developing an EA MLA brochure in line with the comments made.
Conclusions
The Board:
- congratulated EA onthe documents and expressed its full support for the ambitious objectives set out;
- supported the proposed strengthening of theinvolvement of EA member ABs;
- considered that harmonization of national practices is a key issue to be stressedfurther;
- recommended that additional material should be produced, notably to support thepolitical goals towards external audiences, and was pleased to note that EA is already elaborating supporting documents to be used for external communications, such as a Communications Plan, in line with the Board’s comments.
Action EA
4.2Enhancing the EA peer evaluation system: EA update
The EA Chair explained that the Executive Committeeresolved to focus on enhancing the value that the EA MLA provides to the market and regulators, as a slight change from the initial project on strictly enhancing the system.
The IndustryCollege thanked EA for the update. M. Stadler (MS) clarified that the purpose was for the Board to receive a debriefing on the state of implementation of the actions proposed by EA in the various documents presented to the Board during the last years, and on the recommendations made by the Board. Herecalled the main drive behind the project of enhancing the EA peer evaluation system, which is to enhance the visibility of the MLA towards the regulators and the market.Regulators may have specific interests with regard to the schemes under their responsibility, and they want to be sure that these have been really taken into account during the peer evaluation process, all the more so in light of article 11 paragraph 2 of Regulation 765 which obliges NAs to accept certificates issued by foreign ABs signatories to the MLA, and attestations issued by CABsaccredited by them.
The IndustryCollege was pleased to note that many of the EAAB recommendations have been taken on board by EA and would like to see them incorporated in the relevant EA documents.It was clarified that even if the Sub-Projectin charge has outlived its usefulness, the recommendations are certainly being further elaborated on.
The NA College advocated reinforcingthe involvement of the directive networks with whichcloser relationships should be establishedduring the peerevaluation process.
The CABCollege pointed to the Board’s recommendation that NAsshould participate in peer evaluations, and recognised that this is difficult to achieve. There would be nothing much that EA could do to improve this.
JMcM was generally satisfied with the progress made. He indicated that the EC as well should try to motivate NAs to be more present; the point would have to be discussed in the SOGS.
The EC has a concern with the peerevaluation process itself. Regulation765 introduced a major change: accreditation is used in the notification process and consequently requests for accreditationareincreasing. This generatesa certain time pressure on the peer evaluation system.The process in place creates some concern as itis quite time-consuming. The process at the TFG’s level and discussions between the TFG and the evaluation team are adding to the time taken and sometimes causes some confusion. It is recognised that the TFGisin charge of preparing the process, but its recommendationmay be different to that of the evaluation team. There is a need to look at the processesof the evaluation team and the TFG, and between the TFG and the MAC. There is a temptation to use a perceived lack of information to delay the decision.JMcM agreed it is necessary toreinforce the individual parts of the system, but EA should also be careful thatthe process does notconsume too much time. Some balance has to be found not to undermine the value and perception of the whole process.
The EA Chair replied that DNs are tasked with identifying the specificities to be looked at during the peer evaluation. KPIs arise from international requirements and are not specifically geared to the EC Directives.
GT also noted the IndustryCollege’s request that regulatory schemes are looked at and confirmed thatregulators have to get reassurance that their specificneeds are addressed. But he recommended avoidingentering too much intothe detail, which would definitively undermine the process.
Conclusions
The Board:
- thanked EA for the comprehensive analysis provided at the meeting, taking into consideration that a lot of actions are or will be taken on board;
- encouraged EA to look at how the information flow could be further improved so as to speed up the decision-making process without undermining the value and rigour of the process;
Action EA
- invited the EC to encourage further the involvement of regulators in the peer evaluationprocess;
Action EC
- agreed to continue reviewing the progress made in enhancing the EA peer-evaluation system in the future.
4.3 How to handle sector schemes from a strategic point of view
The CABCollege suggested setting up a TFG mandated with identifying issues on sector schemesfrom the user’s or scheme owner’s points of view. After identifying one scheme to be used as an example, the proposal would be to work out a list of questions and challenges for further discussion in the EAAB with a view to comingup with proposals for solutions.
Decision
The Board agreed that the Industry, CAB and NA Colleges, as well as the EC and EFTA as regulators, should think over problems or difficulties they experience with sector schemes and the possible role for the EAAB to solve them. If at the next meeting, there appear sectors where issues are identified for which accreditation could bring some progress, then a future EAAB TFG would have a role in looking at solutions or improvement routes.
Action EAAB members to report at next meeting
IJ raised a question about a statement from the report of the previous meeting:
“It is possible to deviate from the requirements of ISO/IEC17000 series provided the accreditation body uses a different logo.”
The point was addressed under Item 5.4 of the agenda.
5.EAAB matters
5.1Reports from the EAAB MAC and EAAB HHC observers
- Report from the EAAB HHC Observer
The Board thanked the Chair for his report on the last HHC meeting on 27 and 28 September 2011.
A communication issue between the HHC and the EAAB, as well as from DNs, was spotted at the HHC meeting.It was agreed that the issue should be addressed bilaterally with the persons involved, whileEA will discuss the point internally.
Decision
The Board appointed Jörg Hartge, from the IndustryCollege, as the future EAAB observer in the HHC.
- Report from the EAAB MAC Observer
JMcM reported on the last MAC meeting on 18 and 19 October 2011. Hehad been positively impressed by this interesting meeting which had given many reassuring elements.
After confirming thatthere is room for improvement in the MAC decision-making process, JMcM stressed the following:
-There is a lack of visibility of a possible sanction when an AB does not provide responses to the evaluation report in due time.
-Serious attention was given to a number of issues following the entry into force of Regulation 765 (single NAB, no competition, impartiality, conflicts of interest, etc.) which were carefully checked. There is control by EA and this is reassuring.
-It is ensured that all EA members go through the same loop.
-The selection of critical sites is looked at, andcross-frontier accreditation is a key issue in the MAC and for all EA ABs.
-The separation between the MAC and the HHC proves to be very effective. Horizontal issues came up that will be forwarded tothe HHC and this is the proper process.
-The issue of existence of other ABs at the national levelis not within EA’s control. It is for the EC to reconsider the issue, including organisations that call themselves an AB.
-Regarding NABs carrying out programs that do not come under the EA MLA, there is a riskthat this develops into “light” accreditation.
-The MAC has also to make sure not to fall into the practice to delay a decision on the basis that more information seems to be needed.
-It seems that the different evaluation teams and the TFGEvaluationperform benchmarking. A common culture is being started to be put together.
JMcM concluded that all this provesthat there issubstantial benefitfor the EC and the EAAB in having observers in the MAC.
MN raised a resource issue for governmental bodies. JMcM argued that EA ABs shall make EA work, which means that it is also the NAs’ duty to provide NABs with the necessary resources for EA to do its work. The issue will be raised with the SOGS.
Conclusions
The Board:
-thanked JMcM for his report, which overall confirms the robustness of the system in place,strengthened further by EA’s response to Regulation 765;
-noted with appreciation that some on-going benchmarking is performed amongst evaluators and that EA is on a continuous improvement route.
JMcM added that only one NA representativehad attended the MAC meeting when 10 ABs had their evaluation reports being discussed. JMcM recommended that additional EAAB representatives should attend MAC meetings in addition to the EC.MN confirmed he would commit to attend at least one out of two MAC meetings.
Decision
The Board appointed Nike Bönnen, from the EC, as the EAAB observer in the MAC.
5.2Accreditation to verify proportionality of conformity assessment: progress report
Discussions on the NORMAPME Position Paper on “Accreditation of Proportionate Procedures” had been initiated at the last meeting, where it was agreed that the issue of proportionality of conformity assessment should be developed further within the entire EAABIndustryCollege so as to develop a common document. For this purpose, a meeting with other industry organisations is plannedon 4 November 2011.
The Board noted that:
-preparation of the envisaged common paper will start after the meeting, with a view to highlighting practical elements, as agreed at the last meeting;
- drafting and agreement on the paper by the various industry constituencies will require time and therefore the final draft may not be ready for submission to the next EAAB meeting.
ActionIndustryCollege
5.3IAF Product Certification MLA (for information)
Please click on:
GT explained that at present no specific product certification schemes are covered by the IAF MLA, highlighting the difference between the EA and IAF MLAs. Product certification is covered by IAF only when the supportive scheme is endorsed by IAF.