A type A Inspection Body hires external inspectors (not exclusively) who are otherwise engaged in design or manufacture of products. These external resources are salaried and employed by a company engaged in the design and manufacturing of these products. The external inspectors perform a full inspection work with a complete judgment of conformity of these products. The IB doesn’t appoint these external inspectors to inspect products designed or manufactured by themselves or by the company which employs them. The IB appoints these external inspectors to inspect similar products which are designed or manufactured by other manufacturers. The IB argues that it complies with the requirements for type A independence of ISO/IEC 17020 (Annex A – A1 b/) and ILAC P15 (Annex A – Aa). Considering the application guidance provided in ILAC P15, is the situation acceptable?
STANDARD: ISO/IEC 17020 · CLAUSE: 6.1 · TOPIC: Type A independence
The situation described is not acceptable if the inspection has to be carried out by a type A inspection body, and if the similar designed or manufactured products referred to fall within a product category defined in the scope of accreditation of the inspection body. The requirements to independence apply equally to all personnel involved in inspection activities, whether external or internal to the CAB. In fact, there are no requirements in section 6.1 of the standard applying exclusively to internal personnel, as the standard is indifferent to the channel used by the CAB in contracting its personnel.
On the issue of whether the inspectors may be engaged to perform inspection of products similar to those produced by the organization where they are employed, the requirements in A.1b) apply. Here it is stated that “The inspection body and its personnel shall not engage in any activities that may conflict with their independence of judgment and integrity in relation to their inspection activities.” Working for an organization marketing competitive products to those subject to inspection may constitute such an activity. Further, in the 2nd sentence of A.1b) it is specified that “In particular, they shall not be engaged in the design, manufacture, supply, installation, purchase, ownership, use or maintenance of the items inspected.” ILAC P15 states that “The items in this case are those items that are specified in the accreditation body’s certificate/annex with respect to the accredited scope of the inspection body”. It follows that ILAC P15 expects that the field and range of inspection listed in the scope for accreditation provides information that suffice to define the item inspected as referred to in Annex A of ISO/IEC 17020. This means that if the products inspected, and the products produced by the organization employing the contracted inspectors, constitute the same object of conformity assessment thus specified in the scope of accreditation, then the requirement in the 2nd sentence of A.1b) applies.