ILAC/IAF JIG Comments on ISO/IEC 17020 (To Feed Into the Revision Process)

ILAC-IAF JIG – 14th October 2008

ILAC/IAF JIG comments on ISO/IEC 17020 (to feed into the revision process)

The text of A4 should be used whenever appropriate.

Also please observe that this standard is very prescriptive in some matters and very abstract in others. There should be a balance in the requirements.

In general, the quality system aspects of this standard should be updated based on the new generation of CAB standards, such as 17021.

The new 17020 should be harmonised with the new generation of CAB standards as far as possible.

ISO PAS should be used as far as possible when drafting requirements.

All references should be updated.

The present 17020 is very engineering oriented.

The standard should be kept generic and should not be product-oriented but competence oriented.

Requirements should not be repeated in different paragraphs.

1. Scope

-A better differentiation between inspection and testing and also inspection and product certification is needed; (1.4)

2. Definitions

-A more generic definition of inspection as an activity is needed without losing technical/professional auditing as part of the definition.

3. Administrative requirements

-We need better description of what is meant by legally identifiable.

-The status of governmental IBs should be discussed in relation to their legal status and impartiality.

-If the term legal entity is to be used, it should be defined.

-The second paragraph of 3.3 is not written properly and does not contribute to the scope of inspection. Drop it.

-3.4 has been difficult to implement in some economies and the drafting WG should discuss a possible global solution.

-3.5 has always been difficult to explain to the inspection bodies. It is necessary to describe what is meant by business conditions on which it does business.

-3.6 Do not mention “independently audited accounts”.That clause should go out of the standard.

4. Independence

We think that the WG drafting the next generation of 17020, should discuss without prejudice the three types.

The standard must continue providing requirements for third party/type A inspection bodies but it must also continue providing requirements for bodies that are not third party.

We need requirements that are far more tangible than the ones we have today and that can be implemented in a harmonised manner. We need very clear requirements.

There may be a need to also give examples of elements which would show that the IB is independent.

The principles of independence should be kept separate from the principles of impartiality.

Impartiality

The principles of impartiality should be kept separate from the principles of independence.

See ISO PAS 1.

5. Confidentiality

We believe that this can be written in better words. Copy the last sentence of A4, G 5.a and see also other newer standards in the 17000-series or ISO PAS 2 for confidentiality.

6. Organisation and management

-There is need to have a requirement asking for the organisational chart/description of the total organisation, including relations to other companies in the group, in order to show that the requirements of independence and impartiality are met and in order to show all of the function of the persons in the total organisation. (6.2)

-Today, it is very difficult to define what is meant by “permanent employee”. (6.3). The local legal framework normally dictates how employments are made. There is need for a better description of what is meant by this. Maybe it is better to describe the conditions which we want to achieve by asking for permanent employment: for example continuity, availability, etc. On the other hand, why is continuity needed?

-There is reason also to comment the situation where the IB has a number of branch offices. The standard should have requirements defining technical management in this case as well. A performance based approach would be welcome.

-(6.4) Supervision is a very abstract word and can be interpreted in many different ways. See the text of A4. Define both the term supervision and the objective of supervision. Is monitoring included in supervision?

-There is nothing said about monitoring in the standard. Monitoring should be a requirement. (NB: to be addressed under personnel?) See the text of A4.

-6.5 is a requirement for having deputies. This eliminates all one person companies by definition. It should be made more flexible, for example, include the phrase “where relevant and necessary”. The standard could request that if an IB decides not to have deputies then it has to describe how it is going to solve the situation when the key persons are away. See A4.

-6.6 repeats what is also said under personnel. Please, do not repeat requirements. Observe that A4 follows the structure of the standard and thus spreads out requirements on the same topic into different paragraph. We suggest that all requirements on personnel and personnel records are kept to the same paragraph of the standard and are written in a generic manner.

7. Quality system

The WG drafting the standard should update the quality terminology and requirements in this standard (see also 17021).

8. Personnel

-Why “permanent”? What requirements are being implied by requesting permanent personnel? “Permanent personnel” may be a solution to a problem but we are not here to solve, we are here to put requirements in place.

-8.2 paragraph 2 is good in the way that it puts competence requirements. However, knowing the procedures for manufacturing may not always be possible or relevant. Therefore, the paragraph should be re-written to provide for more flexibility but definitely kept in the standard.

-(8.3) The standard should also require that the competence of the IB personnel is reviewed regularly.

-(8.3) first paragraph. Put full-stop after “ …up-to-date” because otherwise there is a risk that the policy does not guarantee the competence being up-to-date.

-(8.3) does not seem to require documents for the stages of training even though it requires stages of training for each member of its personnel. Keep stages and require documentation.

9. Facilities and equipment

-The guidance given in 1.4.a of A4 is not relevant in all cases. It talks about analytical testing versus functional testing. The word analytical brings into mind chemical analysis. The description of analytical suggests that it should be performed in a laboratory. There are however testing activities which are not functional and yet need to be performed on site, because they cannot be performed in a laboratory. Even in these cases the IB should meet relevant requirements for testing.

-When the traceability of measurement equipment contributessignificantly to the quality and outcome of the inspection those measurements must be made using traceably calibrated equipment and using documented procedures. The standard should clearly require this.

-9.13 a) is written in an old-fashioned manner and could be changed to read “…ensure that results are adequate and in line with what is expected.”

Requirements on computers should be kept generic and not prescriptive.

-The guidance on traceability and calibration in A4 is relevant and should be taken into account while drafting the next standard (see also 17025).

10. Inspection methods and procedures

See A4.

-10.2 change efficiency into effectiveness

-10.8 The drafting WG should clarify what is meant by carrying out inspections safely.

11. Handling of items

No comments.

12. Records

No comments.

13. Inspection reports and inspection certificates

-(13.1) What is meant by retrievable? Available over a time period?

-WG to consider inclusion of elements of Appendix 3 of A4

14. Subcontracting

-See A4, G14.1. The standard does not state the conditions under which subcontractors can be used. The text of A4 G 14.1 should be considered.