IAF Informative Guidance for the Transition to ISO /IEC 17021
Response to Comments by IAF Members
General
All comments received during the comment period were reviewed and considered by
the TF and the text amended considerably to reflect these comments before it was
considered suitable for ballot.
The letter ballot on the adoption of the above document was approved by 32 votes
(for) to 9 votes (against). The text of the guidance can therefore not be amended
without further ballot. However, the TF believes the attached clarification should
resolve any uncertainty. Its text has been agreed with the TF members and reviewed
by the Chairman of the IAF Technical Committee.
Comments were received from 12 IAF members.
In the majority of cases, these comments related to clauses 3.4 and 5 of the
document. The TF has therefore attempted to respond to these comments by clause,
rather than to each individual, and similar, comment.
Clause 3.4 – Phased Approach
Comments received from ema, IPAC, COFRAC, CNAS, BELCERT, FINAS
Clause 3.4 does not mean that transition date of 15 September 2008 is extended in
any way. However, there are occasions where a CB may not have finished the full reissue of, for example, new certificates with expiry dates or revised contracts by that
time.
This clause is intended to help avoid disruption to these customers and will mostly be
for situations where (mostly large CBs) with 1000s of customers/ certificates may just
not have the resources or time to completely reissue all certificates/contracts etc by
15 September 2008. However, the PROCESS for reissues/ etc must be complete
(and that is what an AB accredits against) by 15 September 2008 – and any
accreditation body should expect that many contracts/certificates etc should have
been reissued by then.
For example - some CBs did not previously have an expiration date on their
certificates - if such a CB immediately changes its system to add an expiration date
to certificates, and then re-issues each certificate upon re-certification to include an
expiration date, then the CB has demonstrated conformance to the new standard---there is no extension. The aim is for the AB to be reasonable in recognising that to
avoid disruption to CB clients and unnecessary cost and administration burden on
CBs, the re-issuance should be allowed to fit with the normal re-certification cycle.
Note that clause 3.2 proposes that CBs agree a transition plan with their AB and
agree a date by which transition should have been completed, (ie. Before 15
September 2008), and clause 3.4 also proposes that CBs advise the date by which
re-issues of certificates etc will have been completed.
There should be no room for ambiguity and both AB and CB should be clearly aware
of when the CB is in compliance with ISO/IEC 17021 and also when any outstanding
issues such as the re-issue of certificates with expiry dates will be complete.
Clause 5 - Nonconformities
Comments received from ema COFRAC, SAS, CNAS, BELCERT, RVA, OAA, FINAS
relating to the second paragraph. As indicated above, a CB must be in full
compliance with ISO/IEC 17021 by 15 September 2008.
Any nonconformities relating to ISO/IEC 17021 must have been closed down by that
date before a new accreditation certificate can be issued. However, for example,
where the re-issue of certificates with expiry dates or revised contracts is being
conducted within the normal three year business cycle and has not been completed
by 15 September 2008, this is an observation, not a nonconformity, noting that the
date by which such issues will have been completed will have been agreed in
advance with the AB.
The TF would therefore contend that the door is not "wide open" (RvA) , as
everything should have been agreed in advance with the AB.
The proposal by SAS on clause 5 is more succinct and would have been
incorporated had it been received earlier. Nonetheless, the intention of the clause is
as described above and put more clearly by SAS.