Referring to ISO/IEC 17011:2017, clause 8.2.2 – is it responsibility of NAB to publish (where applicable) on the website (or in other way to make publicly available without request) information on suspension or withdrawal of accreditation in whole or in part, including dates and scopes?
(1) How the condition “where applicable” should be understood?
- publication should be implemented whenever there is suspension and withdrawal of accreditation?
- publication should be realized in every case of suspension and withdrawal of accreditation due to lack of fulfilment of accreditation requirements by CAB (not including cases of suspension and withdrawal on request of CAB, not related to the lack of fulfilment of requirements)?
- publication should be carried out when accreditation is withdrawn or suspended in its full scope?
- publication should be carried out when accreditation is withdrawn (reduced) or suspended in part of the scope? Is it reasonable for reducing of the scope of accreditation to be treated in the same way as withdrawal?
(2) Are there any other restrictions (circumstances) concerning publication of information on suspension and withdrawal of accreditation resulting from the condition “where applicable” leading to non-publication ?
(3) What type of information shall be published by NAB regarding withdrawn and suspended accreditations ?
- should it be full information as in clauses 7.8.1 and 7.8.3 of ISO/IEC 17011:2017, taking into account the NOTE to clause 8.8.2 ?
- how long should information be publicly available?
- should information on the date and scope of suspension continue to be publicly available even after reinstatement or withdrawal?
HHC TFG Withdrawals/Suspensions Communication – understanding of clause 8.2.2 of ISO/IEC 17011:2017
ISO/IEC 17011 8.2.2 “As a minimum the accreditation body shall make publicly available without request, information on conformity assessment bodies as described in 7.8.1 and, where applicable, information on suspension or withdrawal of accreditation, including dates and scopes.
NOTE In exceptional cases, access to certain information can be limited upon the request of the conformity assessment body (e.g. for security reasons).”
General
The aim of 8.2.2 clause is to make publicly available the information on the scopes of CABs which are accredited. This information shall be accurate and up to date in order not to mislead the users of accredited services. The NAB implementing related actions or tools should have regard to prevent unauthorized reference to accreditation and to enable users of accredited services to verify information on the current accreditation status of the CAB.
Publicly available information
With regard to withdrawal of accreditation as well as to full or partial suspensions, the NAB shall provide publicly available information as described below, together with the unique accreditation identification of the CAB.
For a total suspension, the tool used to publicly inform the suspension is to be decided by the NAB – some may choose to keep the detailed scope visible as long as it is clearly marked as suspended, while others may prefer to just declare that the CAB is under (total) suspension. Whatever the tool chosen, it must be clearly publicised the date that the total suspension started.
For a partial suspension, the NAB can also choose the mechanism that it uses: some continue to provide the full scope, but clearly marking or identifying the conformity assessment activities under suspension, while others prefer to present only the scope that is ‘active’ under accreditation, omitting the suspended scope. Independently of the mechanism used, it must be clear which is the date that each accredited conformity assessment activity was suspended, either by:
explicitly stating the date for each suspended scope presented, or
implicitly stating it, by showing the accreditation decision date corresponding to the ‘active’ scope being presented.
Although the NAB needs to be able to confirm the validity of a given accredited scope in the past, it is recommended not to publish past suspensions no longer in force, since it can be misused and misinterpreted by the market and readers.
Regarding withdrawals (ISO/IEC 17011:2017 clause 3.19 considers them to be for the full scope, not partial), the NAB shall maintain that information publicly available for a period of time compatible with the view of the interested parties and legal requirements. The period for maintaining the information publicly available shall be determined by the NAB although a minimum period of 1 year is recommended (taking into account easy access to information for users of previously accredited services that might still be available on the market). The period shall commence from the date of withdrawal.
It is noted that ISO/IEC 17011:2017 does not require that the scope reduced to be made publicly available, nevertheless the NAB shall ensure that the information on the accredited scope is up to date.
Exceptions and additions
The NAB shall take into account any additional requirement in schemes or regulations regarding publication of information on suspension or withdrawals (e.g. for EU ETS see EA-INF/09).
According to the NOTE to clause 8.2.2 of ISO/IEC 17011:2017, the NAB may exceptionally apply limited access in the publication of information upon request of the CAB (e.g. security reasons). In addition, some schemes may have justifiable reasons for requesting that scopes of accreditation do not present certain data relating to the scheme. Such action shall be justified and measures need to be taken to ensure that it does not mislead the users of accredited CABs where such exceptions have been applied.