In November 2020, an EGOLF Member made a question at EGOLF helpdesk asking if there is an existing rule about the requirement for having done at least one test in order to issue classification report of a product. A larger discussion started in the helpdesk forum and it was clear that there are no clear rules on this subject. EGOLF thinks that it is essential that rules are clear so all labs treat clients in the same way.
Our Egolf member asked his national accreditation body for their opinion about this topic and they said: It is a requirement to have done at least one test in order to write a classification report. This because ILAC P8, which is mandatory for all accreditation body’s under EA (due to INF 01), describes:
7.1 Customers of an accredited CAB may request endorsed reports or certificates which contain, or are based upon, some results of conformity assessment activities not performed under the CAB’s scope of accreditation. If an accreditation body allows an accredited CAB to include results, or outcomes based on results, for conformity assessment activities not covered by the scope of accreditation in its endorsed reports or certificates, in order to ensure that results cannot be interpreted as being for conformity assessment activities covered by the scope of accreditation, the policy of the accreditation body shall include:
a) a requirement that the accreditation symbols cannot be used, and that neither reports nor certificates nor any enclosed letters (including the paper on which they are printed) can include any reference to accreditation, if none of the results are for conformity assessment activities within the scope of accreditation; and
b) a requirement that, where any endorsed reports or certificates which contain, or are based upon, some results of conformity assessment activities not performed under the CAB’s scope of accreditation, the reported results or outcomes are clearly identified by a disclaimer (e.g. “The conformity assessment activities marked * are not covered by the scope of accreditation.”; “The result/conclusion is based on conformity assessment activities outside of the scope of accreditation.”)
During the last EGOLF meeting it became clear that not all accreditation bodies had the same interpretation. At least, one NAB allows national labs to issue accredited classification reports based on tests from other accredited labs without having done at least one test.
So what is EA´s opinion? Does EA requirement ILAC P8 clause 7.1 mean that it is mandatory to have done at least one test to perform an accredited classification report?
Similar decisions have been taken elsewhere:
CIRCABC – GNB CPR Guidance Base APPROVED ITEMS item 0014 (only applies to notified bodies) has taken the following decision:
Furthermore, EN 15725 general requirements for EXAP will be revised so there is the following requirement:
Extended application shall be undertaken by an organization accredited for the relevant fire test according to EN ISO 17025 and having also carried out at least one test. If test data are to be used from more than one organization, then the extended application may be undertaken by an organization accredited for the relevant fire test and consultation shall be made with the other organization(s) that performed the test.
The question is about a CAB that is issuing an accredited classification report without perfoming any test, but subcontracting all the tests to another accredited CAB.
Can the CAB issue a classification report as covered by accreditation without performing any test?It should be reminded the according to the decision taken during the LCM42, “accreditation of classification and EXAP standards shall be restricted to those tests the lab is accredited for.”
The question can be splitted in two parts.
1) CAB’s accreditation scope
ILAC P8 cl. 7.1 requires that :
Customers of an accredited CAB may request endorsed reports or certificates which contain, or are based upon, some results of conformity assessment activities not performed under the CAB’s scope of accreditation.
The accreditation symbols cannot be used, and that neither reports nor certificates nor any enclosed letters (including the paper on which they are printed) can include any reference to accreditation, if none of the results are for conformity assessment activities within the scope of accreditation.
As stated in the paragraph, the requiremnt relates to the CAB’s scope, not to the scope of other accredited subcontracted CABs.
So the first conclusion is that the report can be issued as covered by the accreditation (with the Mark or references to it) if the CAB’s scope covers at least one of the tests included in the report.2) Provided that the CAB has at least one of tests included in its accreditation scope, the second issue is if the CAB shall perform at least one accredited test of those included in the test report covered by accreditation or if it can subcontract all the tests to an accredited CAB.
Two related questions have already been discussed during LCM23 and LCM30, where it was agreed that ISO/IEC 17025:2005 does not prohibit the use of external services (there is an acknowledgement that subcontracting is allowed); the same conclusions can be extended to the application of the new edition of ISO/IEC 17025:2017.It is deemed that the following approach shall be followed:
A classification report is based on the results of one or more tests. To ensure coherence between testing and classification, classification reports shall be drawn up by the laboratory conducting the tests.
Consequently, laboratories accredited for the purpose of notification shall only draw up classification reports on the basis of testing conducted fully or partially by themselves, unless otherwise justified by extraordinary circumstances.