FAQ 62

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A local CAB belongs to a multinational parent CAB. The official website of the local CAB has its subsidiary accredited type A inspection body which inspects the playground according to a national standard. The same website also publishes an advertisement for a performance mark of playground equipment by the same national standard certified by the parent CAB. Furthermore, the website also promotes one playground equipment producer whose playground equipment certified as the performance marker of the parent company. Does this pose an independence or impartiality risk to the type A inspection body according to ISO/IEC 17020?

STANDARD: ISO/IEC 17020  ·  CLAUSE:  4.1.3 ·  TOPIC: Impartiality

Answer:

It appears that that the independence type A could well be challenged due to the common ownership although there could be evidence that they have no influence on the inspection activities.
 
With regards to impartiality there is clearly a risk meaning the inspection body would need to provide a very well detailed risk analysis of organisation and how the risks related to common ownership and other activities related to the playground are managed, e.g. how can they demonstrate that the certification activities and the detailing of a certain playground equipment provider that they certify are not influencing the inspection process.

FAQ 61

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A Type A inspection body provides a list of consultants for its client to choose from, to help the client to correct the non-conformities found during inspection.

The inspection body claimed that the chosen consultant was too busy. So, the inspection body sent the consultant’s improvement suggestions to its client on behalf of the consultant. Does this affect the independence or impartiality of the Type A inspection body according to ISO/IEC 17020:2012? If the inspection body indeed violates the ISO/IEC 17020:2012, which articles of the standard the body violated? The inspection body has not done any risk evaluation before what it has done.

STANDARD: ISO/IEC 17020  ·  CLAUSE:  4.1.3 ·  TOPIC: Independence

Answer:

It is not clear from the question if there is any formal relationship between the IB and the consultant(s) although there clearly is a relationship if the IB is acting as a conduit for information between their customer and the consultant and is therefore involved with the process for consultancy.  There are questions about independence if there is a relationship with the consultant and the relationship with the IB’s customer is also impacted if there could be a perception of the IB providing improvement suggestions to its customer. There is a threat to the CAB’s impartiality as a consequence of their actions and the perceived relationship with the consultant.  It was agreed that there must be a risk analysis in place to examine the relationship and demonstrate that the IB has looked at this possible risk to impartiality.  The outcome of the risk analysis will further inform whether the Type A criteria are met. Clause 4.1.3 is the one that is not being complied with in this situation.  See also Annex A.1.  Also if risks are identified, they need to be mitigated (clause 4.1.4).

FAQ 60

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Regarding requirement 8.6.4 of ISO/IEC 17020 (internal audits):

The requirement states that “internal audits must be performed at least annually.” Does this mean that internal audits must be carried out every 12 months, or can we consider it once per calendar year? For example: can an internal audit in March 2023 then a new internal audit in November 2024 be considered compliant with the standard?). It also indicates “The frequency of internal audits can be adjusted according to the effectiveness and demonstrated stability of the management system”. Can we consider that the adjustment is within the period of 12 months/calendar year or beyond this period?

STANDARD: ISO/IEC 17020  ·  CLAUSE: 8.6.4 ·  TOPIC: Performing Internal Audits

Answer:

The ISO/IEC 17020 Standard does not use the word “annually”, rather it uses the phrase “every 12 months”, which is taken literally in this case. If your internal audit was conducted in March 2023, the expectation is that it is conducted again by March 2024.
 
The same clause also allows you to extend your frequency beyond 12 months, if your QMS is stable. Stable generally means no turnover of key personnel, no ownership changes, no findings in your last few internal and external audits, etc. ILAC P15, clauses 8.6.4 n1/n2 provide examples of when it is or is not appropriate to extend the frequency. It also provides guidance on when the IB should conduct them more frequently. The AB will generally evaluate the frequency vs. the stability during their assessments. If they feel that the frequency is too long (e.g. 5 years) or is not warranted for a variety of reasons, they will identify that and discuss.

FAQ 59

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Can an Accreditation Body carry out consecutive assessments using remote techniques? ISO/IEC 17011 states in 7.9.3 The time between consecutive on-site assessments should not exceed 2 years. However, if the accreditation body determines that an on-site assessment is not applicable, it must utilize another assessment technique to achieve the same objective as the on-site assessment being replaced and justify the use of such techniques (e.g., assessment remote).

a) Therefore, the use of the remote technique can be used in consecutive assessments (at the discretion of the AB), subject to justification?

b) Are there any criteria to justify the use of the remote technique by AB?
c) Can the AB justify the use of the remote technique based on criteria specified by the AB in its procedures?

STANDARD: ISO/IEC 17011  ·  CLAUSE:  7.9.3 ·  TOPIC: Assessment Program and Accreditation Cycle

Answer:

Yes, if the accredited IB’s business model is such that they conduct their inspections remotely, then the AB may also conduct their assessments remotely on a regular basis. However, if the accredited inspections are primarily in person, then the technical witnessing must be conducted on site, if at all possible. These scenarios should be outlined in the AB’s procedures.

FAQ 58

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What’s the potential risk of shared personnel in laboratory activities (under ISO/IEC 17025) and inspection work (under ISO/IEC 17020)? How can we solve it?

STANDARD: ISO/IEC 17020  ·  CLAUSE: 4.1.3  ·  TOPIC: Independence

Answer:

ISO/IEC 17020, clause 4.1.3 requires an accredited IB to evaluate its risks to impartiality on an ongoing basis, taking into account risks from its activities, relationships, etc. It is expected that the IB will identify these risks, as they can be complex and ever changing. Clause 4.1.4 goes on the require that you figure out how to solve it yourself.

FAQ 57

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Could the inspection body type A (that accredited according to ISO 17020 standard) provide services as inspection body type C for a different inspection scheme (without accreditation according to ISO/IEC 17020 standard to type c)?

STANDARD: ISO/IEC 17020  ·  CLAUSE:   ·  TOPIC: Independence

Answer:

It is possible for an IB to be a different ‘Type’ of IB for different inspection activities/schemes.
There is no requirement that prevents an IB performing activities outside of its accreditation for different schemes, as long as it does not present a conflict or risk to the IB’s impartiality for its accredited activities.
See ILAC P15 4.1.6 n1: this refers to the inspection activity on the scope of accreditation
 
Yes, a Type A is allowed to work as a Type C for a different scheme as long it is not for the same item inspected. You have to evaluate your independence and risks to impartiality for every relationship you are engaged in, and if they impact your ability to maintain your impartiality. This is even if you are engaged in unaccredited work, if that relationship has the potential to influence your accredited work.

FAQ 56

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Regarding ISO/IEC 17020 for IB that make inspection of building safety based on national building code;

the process flow starts by receiving the client request including design, soil test report, building details, the first step with design review while design review department study the design and make their comments, and then inspection engineer go to site and make the inspection

My questions:

1. Is the design review stage considered an inspection activity or it will considered as supportive stage? 2. Will the design review engineer also be subjected to mentored work period if he is considered as inspector?

STANDARD: ISO/IEC 17020  ·  CLAUSE:   ·  TOPIC: Monitoring Inspectors

Answer:

The scope of accreditation is the determining factor on if a given activity falls under the requirements of ISO/IEC 17020. If design review is an accredited activity on the scope of accreditation, then:
 
1. Yes the design review would be considered as an accredited inspection activity
2. Persons conducting the design review would be considered to be inspectors and the requirements for competence monitoring will apply
 
It is recognised that there may be local legal requirements that apply as well.

FAQ 55

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In the scope of ISO/IEC 17020 (2012), it mentions “This International Standard contains requirements for the competence of bodies performing inspection and for the impartiality and consistency of their inspection activities.”

So, What does “consistency of their inspection activities” mean? Does  any standardised definition of consistency exist?

STANDARD: ISO/IEC 17020  ·  CLAUSE:   ·  TOPIC: Inspection Activity

Answer:

The term consistency is used as the generally known concept of repeatability and reproducibility although it is not specifically defined in the standard.
Oxford Dictionary defines consistent as an adjective:
1. acting or done in the same way over time, especially so as to be fair or accurate. “the parents are being consistent and firm in their reactions”.
(of an argument or set of ideas) not containing any logical contradictions. “a consistent explanation”.
 
In relation to ISO/IEC 17020 ‘consistency’ relates to ensuring reproducible outcomes from inspection activities, see also ILAC  P15 6.1.8 n1

FAQ 54

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In the context of ISO/IEC 17020 and independence, could you explain the position of ISO/IEC 17020 on a situation where the Inspection Body (Type A) utilises a separate sister company (common ownership, no parent or holding company) to complete the accredited testing used to determine the result of the inspection, where personnel from the IB also have a role in the laboratory testing.

STANDARD: ISO/IEC 17020  ·  CLAUSE: 6.3.1  ·  TOPIC: Independence

Answer:

If a company relies on another legal entity to perform an accredited test or inspection, clause 6.3.1 spells out what must be assured by the accredited inspection body. There are many variables in the situation described to be able to give a comprehensive answer. However, if somebody is performing an accredited test or inspection, they need to meet all of the requirements of the applicable standard. If the individual works for both companies in this scenario, such as a construction inspection company that provides both testing and inspection, then they would need to be authorized by the company to perform the accredited test or inspection. They must also follow the procedures that are laid out by the accredited company, to include training, oversight, etc.

FAQ 53d

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The question is related to requirement 8.6.4 where it establishes that “internal audits must be carried out at least once every 12 months” It also defines that the frequency can be adjusted based on the proven effectiveness of the management system and its stability proven”.

What is the justification or criterion for defining an audit frequency as a rule, if it is understood that this activity is control by management to review and evaluate the status of the management system and therefore it would be at their discretion define the frequency taking into account the criteria defined in numeral 8.6.2 and the ILAC P15 guidelines numeral 8.6.4 n1?

STANDARD: ISO/IEC 17020  ·  CLAUSE: 8.6.4  ·  TOPIC: Internal Audits

Answer:

Yes, the management of the Inspection Body is ultimately the one to set the frequency. However, if the Accreditation Body does not feel the extended durations are appropriate (e.g. an audit every 5 years), or that the management system is not stable (high turnover or major NCs cited during assessments), they have the responsibility to address that with the IB. If for some reason the two sides cannot not come to a reasonable agreement, the Accreditation Body has the right to terminate the accreditation.
 
Refer to ILAC P15, clauses 8.6.4 n1/n2 for guidelines on when it would be prudent to decrease the frequency of internal audits, or when it may be permissible to extend the durations past 12 months.