TC/07/04

Accreditation Scopes for EMS – discussion paper

IAF has been asked to consider the following issues:

  1. Does ISO/IEC Guide 61 (clause 2.3.3 b) require that an AB must define accreditation scopes for EMS in accreditation documents issued to a CRB with more information (e.g. “technical areas” as referred to in G.4.2.9 and G.4.2.10 of IAF Guidance on Guide 66) than just “ISO 14001 EMS certification”?
  1. IAF Guidance on Guide 62, G.3.5.5 and G.3.5.6 (decisions on certification/registration) refers to an accreditation scope system based on technical sectors. In comparison, there is no mention of an accreditation scope system in IAF Guidance on Guide 66 under clause 5.5 (decision on certification registration). Do the two IAF Guidance documents have fundamental differences for requirements of accreditation scopes for both QMS and EMS?

Discussion:

IAF Guide 61 clause 2.3.3 b) states:

“ The accreditation body shall provide to each of its accredited bodies accreditation documents…(which)… shall identify, for the body and each of its sites covered by the accreditation, the scope of the accreditation granted, including as appropriate.”

1)The type of certification/registration scheme,

2)The standards and/or any normative documents and regulatory requirements against which products, services or systems are certified or registered,

3)Industry sectors,

4)Product categories.

From this requirement, it can be deduced that an AB does not have to define scopes in terms of all four of 1),2),3) and 4). It must define scopes in terms of at least one of them. However, 1) “the type of certification scheme” cannot be interpreted as just “EMS” or “QMS”. The word “scheme” must mean at least something like a sector scheme. It should not be interpreted as a whole field of management system certification.

For QMS, the IAF Guidance provides Annex 1 as a model. But it is not mandatory. This ties up with Guide 61 clause 2.3.3 b) 3). There are other possibilities.

For product certification 2) and 4) are the usual categories, though 1) may also be relevant.

For EMS, the IAF Guidance provides no model but G.4.2.9 and G.4.2.10 refer to “technical areas” which are normally used as the basis for scoping. There are parallels with G.2.2.2 of the Guidance on Guide 62.

However, in both cases, we are careful to distinguish “technical areas” from “industry sectors”, the Guide 61 term on which the 39 QMS scopes were built.

In conclusion, an AB is free to define its scopes in accordance with any one of the four headings in Guide 61, but “EMS” is too broad and not sanctioned by G 61 clause 2.3.3. b). We have tried to harmonise for QMS around the 39 scopes, but these are not mandatory. We have no equivalent for EMS, and although some ABs use the 39 scopes for EMS also, there is no support from IAF for doing this.

Further discussion:

Should we seek to harmonise EMS scopes within IAF? Possibly, particularly with a view to increased cross-frontier accreditation activity.

Should we discuss adopting the same 39 scope headings as for quality? Possibly, but only if we have a common understanding that these are “shop window scopes”, and not descriptors of the technical areas that we should use for investigating the competence of CRBs.

How do we match the assessment of the competence of CRBs with the granting of accreditation scopes? This should be an important subject for discussion in the Workshop on 27 February.

I believe we need to develop a deeper common understanding on how we assess the competence of CRBs (the new IAF Guidance in the QMS field) and how we relate this assessment to the granting of accreditation scopes.

In the early days of accreditation we (UKAS) used to insist on witnessing activity within the scope applied for before we granted accreditation. This is the maximum safety option, and may be a necessary control to exert over new or immature certification bodies. However, it is not a reasonable way to operate an accreditation system where certification/registration bodies have proved their ability to manage accreditation scopes. It is also unreasonable to expect accredited certification bodies to perform unaccredited certification.

For discussion!

Roger Brockway