According to ISO 17065:2012 §6.2.2.1: “note 2 The use of external personal under contract is not outsourcing”.
According to ISO 17065:2012 §6.2. 1:” When a certification body performs evaluation activities, either with its internal resources or with other resources under its direct control, it shall meet the applicable requirements of the relevant International Standards and, as specified by the certification scheme, of other documents. For testing, it shall meet the applicable requirements of ISO/IEC 17025; for inspection, it shall meet the applicable requirements of ISO/IEC 17020; and for management system auditing, it shall meet the applicable requirements of ISO/IEC 17021. The impartiality requirements of the evaluation personnel stipulated in the relevant standard shall always be applicable”
Question :
When performing inspection activities by using external personal under contract, shall the certification body apply the requirements on independence of ISO/IEC 17020 (and applicable guidance as ILAC P15) or only those ones of ISO/IEC 17065 and its associated schemes?
Note: It is understood, that the requirements on independence and impartiality are to be regarded as different aspects within the standards ISO/IEC 17020 and also in ISO/IEC 17065.
March 2023
When performing inspection operations under contract with external personnel, the certifying body shall apply independence requirements of ISO/IEC 17065 rather than ISO/IEC 17020.
This statement is based on the six-eyes principle (evaluation (in this case: inspection), review, and decision-making), which does not apply to inspection bodies. Furthermore, clause 6.2.1 only applies to the impartiality criteria of the applicable standard (17020), not the independence requirements.
In fact, although the concepts of impartiality and independence appear to be intertwined in many standards, they are handled somewhat differently in ISO/IEC 17020. Therefore, impartiality requirements shall be taken into account, not the independence requirements (especially given in clause 4.1.6) according to ISO/IEC 17020.
As a result, when the certification body performs inspection activities under contract with external personnel, the corresponding documentation providing information on the implementation of ISO/IEC 17020 (e.g. ILAC P15) shall not be considered, only those of ISO/IEC 17065 (e.g. clause 6.1.3 a) and its associated schemes shall be considered.