The question is related to the application of the definitions of permanent site or temporary site (§2.2 and §2.3 of IAF MD 1).
There are some situations where the certified company provides a service through sites/installations that belong to another administration but are completely managed by the certified company (e.g. waste water treatment, gas supply, etc.). The certified company has an operating contract for a finite period of time (20 years) to manage/deliver the service.
In these situations, (which we consider different from §9 of IAF MD 5) it is our understanding that the CB shall apply the site sampling rules as per §6.1.3 or §6.2 or §6.3 of IAF MD 1, as the provision of the service (scope of certification) is only possible if the sites are functioning. If any of the sites are disabled, the activity cannot be provided.
Do the other members have this same understanding?
September 2020
The case as presented would indicate the sites to be considered Permanent, due to the long term nature of the activity and the responsibilities of the certified company.