An authority has developed a scheme and rules are given in a statuary order and there is a guidance document as well.
In the documents conditions for withdrawing of a certification are given, but nothing is mentioned regarding suspension.
It is the understanding by DANAK that it is acceptable that conditions for suspension are not given in the statuary order if the CB has policies and procedures. This corresponds to schemes for certification of welders, where there are no rules for suspension in e.g. ISO 9606.
Regarding this scheme/statuary order: CB A has made their own rules for suspension which are rather close to the rules for withdrawing. CB B has made their own rules for suspension saying they do not suspend certificates, they only withdraw certificates, as there are no requirements in the statuary order regarding suspension.
Q1: Is both the solutions made by CB A and CB B acceptable, as they both have a policy and documented procedures (ISO 17024 clause 9.5)
Q2: Can the scheme owner claim, that suspension is not permitted, as it is not mentioned in the statuary order – or will the normal practice prevail that if there are no specific extra requirements in a scheme the rules in the level 3 standard are valid, i.e., the CB can use suspension as a tool it they fulfill the requirements and have a policy and a procedure?
September 2022
According to §8.3d) of ISO/IEC 17024, the certification scheme shall include criteria for the suspension and withdrawal of certification. Furthermore, ISO/IEC 17024 9.5.1 requires the certification body to have policies and documented procedures in place for the suspension and withdrawal of certification. Considering that no criteria for the suspension of certification are foreseen in the statutory order and the guidance document, the certification scheme is not in compliance with the provisions of EA-1/22 (§1.2a)).
A1: The lack of established requirements for the suspension of certification as part of the certification scheme (statutory order and guidance document) is not in conformance with the respective requirements of ISO/IEC 17024 with regard to the content of a certification scheme. However, in the case of CB A, this deficiency is supplemented by the CB’s own rules and policies on suspension of certification for the specific certification scheme. On the other hand, CB B has missed developing rules and policies specific to the suspension of certification, contrary to the requirements of ISO/IEC 17024. To this end, the approach of CB A can be considered acceptable, which is not the case for CB B.
A2: To proceed with an accreditation towards ISO/IEC 17024, the standard’s requirements applicable to the development of a certification scheme shall be respected, including the requirements imposed by EA-1/22 for the evaluation of conformity assessment schemes (see §1.2a)). Given that no requirement of the standard may be omitted, any claims of the scheme owner that suspension is not permitted because it is not foreseen in the statutory order, are not considered valid.