How are applicable requirements for 17020 and 17025 assessed for witnessing of factory production control (Construction Products Regulation). For example, a manufacturer that has its own laboratory, which 17025 requirements are relevant and how do other ABs assess CBs follow up of these requirements? Is participation in interlaboratory comparisons too much? How thoroughly/strict should clauses 6.3/6.4/6.5 from 17025:2017 be assessed? Does the system make a difference in assessment, for example 1 vs 2?
March 2021
This issue was the subject of one of the strategic discussions of EA CC.
At least the following requirements of ISO/IEC 17025:2017 and/or ISO/IEC 17020:2012 should be concerned during AB witnesses whenever applicable by NB and the manufacturer:
ISO/IEC 17025:2017
6 Resource requirements
6.2 Personnel
6.3 Facilities and environmental conditions
6.4 Equipment
6.5 Metrological traceability7 Process requirements
7.2 Selection, verification and validation of methods
7.3 Sampling
7.4 Handling of test or calibration items
7.5 Technical records
7.6 Evaluation of measurement uncertainty
7.7 Ensuring the validity of results
7.8 Reporting of results
7.8.1 General
7.8.2 Common requirements for reports (test, calibration or sampling)
7.8.3 Specific requirements for test reports
7.8.4 Specific requirements for calibration certificates
7.8.5 Reporting sampling – specific requirements
7.8.6 Reporting statements of conformity
7.8.7 Reporting opinions and interpretations
7.8.8 Amendments to reports
7.10 Nonconforming work
7.11 Control of data and information managementISO/IEC 17020:2012
6 Resource requirements
6.1 Personnel
6.2 Facilities and equipment
6.3 Subcontracting
7 Process requirements
7.1 Inspection methods and procedures
7.2 Handling inspection items and samples
7.3 Inspection records
7.4 Inspection reports and inspection certificatesThe system of AVCP (Assessment and Verification of Constancy of Performance) like 1, 1+, and 2+ makes a difference in terms of testing and inspection coverage;
According to CPR Regulation 305/2011:
1.1. System 1+ – Declaration of the performance of the essential characteristics of the construction product by the manufacturer on the basis of the following items:
(b) the notified product certification body shall issue the certificate of constancy of performance of the product on the basis of:
(i) determination of the product-type on the basis of type testing (including sampling), type calculation, tabulated values or descriptive documentation of the product;
(ii) initial inspection of the manufacturing plant and of factory production control;
(iii) continuous surveillance, assessment and evaluation of factory production control;
(iv) audit-testing of samples taken before placing the product on the market.
1.2. System 1 – Declaration of the performance of the essential characteristics of the construction product by the manufacturer on the basis of the following items:
(b) the notified product certification body shall issue the certificate of constancy of performance of the product on the basis of:
(i) determination of the product type on the basis of type testing (including sampling), type calculation, tabulated values or descriptive documentation of the product;
(ii) initial inspection of the manufacturing plant and of factory production control;
(iii) continuous surveillance, assessment and evaluation of factory production control.1.3. System 2+ – Declaration of the performance of the essential characteristics of the construction product by the manufacturer on the basis of the following items:
(b) the notified production control certification body shall issue the certificate of conformity of the factory production control on the basis of:
(i) initial inspection of the manufacturing plant and of factory production control;
(ii) continuous surveillance, assessment and evaluation of factory production control.The latest answer coming from HHC is given below:
Due to the nature of the question which is more a request for sharing practices with other ABs, the following response is the description of one practice without any assurance that it is the common practice of the majority of ABs.
As mentioned in EA 2/17 :
For AVCP 2+ system, only the requirements of ISO/IEC 17020 :2012 ( 6.1.2, 6.1.3, 6.1.6 up to 6.1.10) should be concerned during AB witnesses.
For AVCP 1 and 1+ systems, the same requirements of ISO/IEC 17020 :2012 apply added with the concerned requirements of ISO/IEC 17025 :2017 (§§ 6 and 7 entirely except of the § 7.9).The expectations in terms of assessment of the CB’s competence should be the following :
As far as the requirements of ISO/IEC 17020 :2012 are concerned, it’s important for the AB’s assessor to observe the CB’s auditor answering the questions of the manufacturer, as it will provide a basis to appreciate the clauses 6.1.2 and 6.1.3 in matter of regulation knowledge of the auditor.In the case of 1 and 1+ systems, with respect to the additional requirements related to ISO/IEC 17025 : 2017, it’s important for the AB’s assessors to verify metrological knowledge of CB’s auditor via his/her capacity to explore a test/calibration report or to follow tests being carried out on site.