What is the difference between external source (cl. 6.2.2 ISO/IEC 17065) and subcontractor (for ex. article 45 of CPR together with Blue Guide, article 5.2.5)? Is there any difference based on who is providing education/training or paying the person? What are the criteria, requirements?
September 2018
Use of external resources and subcontracting are essentially the same and are outsourcing of assessment and verification activities. The requirements of clause 6.2.2 of ISO/IEC 17065, Article 45 of the CPR (which refers to Article 43) and clause 5.2.5 of the Blue Guide are consistent.
They all require that external resources/subcontractors:
- are competent to perform the tasks they are allocated;
- shall not be the designer, manufacturer, supplier, installer, purchaser, owner, user or maintainer of the construction products which it assesses, nor the authorised representative of any of those parties;
- shall not become directly involved in the design, manufacture or construction, marketing, installation, use or maintenance of those construction products, nor represent the parties engaged in those activities;
- shall not engage in any activity that may conflict with their independence of judgement and integrity related to the activities for which they have been employed and
- do not affect the confidentiality, objectivity and impartiality of the assessment and/or verification activities they perform..
It is the responsibility of the Notified Body to ensure that the external resources/subcontractors they use have the necessary competence for the tasks they perform on their behalf. Providing it does not affect confidentiality, objectivity and impartiality, how they gained this competence and who paid for their education and training is irrelevant. Where a subcontractor has worked for or with a client of the Notified Body it is appropriate for the Notified Body to establish a minimum time period before the subcontractor can perform assessment/verification activities on that client or its products. For example in the case of management systems consultancy, this is a minimum of two years (ref clause 5.2.7 of ISO/IEC 17021-1)
It is the responsibility of the Notified Body to pay its external resource/subcontractors for the tasks they perform.