An example of a suitable practice for the review of risks to impartiality would be to combine scheduled periodic reviews with ad-hoc reviews on receipt of advice regarding events potentially impacting the impartiality of the organisation. Such events may include organisational changes, new clients, the launch of new inspection services, new personnel arrangements or changes to scheme or regulatory arrangements.
Even though the inspection body demonstrates that it has eliminated and minimized all identified risks to impartiality, it is difficult to determine whether all risks have been identified. In particular, risks associated with any kind (financial, trade, administrative, moral or other) of pressure exerted on the inspector. How far does the accreditation body need to go to ensure that the requirement is fulfilled?
Clause 4.1.3 requires the inspection body to identify risks to its impartiality on an ongoing basis. In order to demonstrate fulfilment of this requirement the inspection body will need to show that it has a process to accomplish this, and it will need to show that this process generates a credible output. In order to confirm this, the accreditation body may review records such as complaints, management review records, internal audit reports or correspondence directly to the accreditation body, e.g. from regulators or competitors to the inspection body, as indications that there may be risks that have not been recognised or have not been effectively managed. The standard does not require the inspection body to prove that it has identified every circumstance that may pose a risk to the impartiality of the inspection body, but there is an underlying expectation that the major/most likely risks are indeed identified. Failure to do so shall be considered as a non-compliance. Note that clause 4.1.2 explicitly states that “commercial, financial or other pressures” shall not be allowed to compromise impartiality. This can only be ensured if the corresponding risks are identified and managed. Consequently, the inspection body is expected to carefully consider what pressures may be exerted, and how to deal with or prevent them.
The marketing, branding or sales activities of inspections performed by the inspection body or of the items that are inspected by the inspection body could have an influence on those who are involved in developing strategies, policies and methods for inspection and on those who are managing or conducting inspections. E.g., the marketing and sales information could give the impressions to inspection clients that inspections could be performed more efficiently than it is possible to do without compromising the quality of inspections. Such information or commitments by sales/marketing could put undue pressure on those who are directly involved in inspections. This does not mean that sales/marketing activities are prohibited. ISO/IEC 17020:2012 clause 4.1.3 states that “However, such relationships do not necessarily present an inspection body with a risk to impartiality”. The inspection body has a responsibility to identify any risks to impartiality arising from such activities or relationships and demonstrate how it eliminates or minimises such risks.