ISO 17021-1 clause 9.6.1 allows the possibility of maintenance of certification based on a positive conclusion by the audit team leader.
ISO 17065 does not mention such a possibility, but does not disallow it either. And clause 7.9.2 hints that there is a possibility that a decision following surveillance is not necessarily a requirement:
“7.9.2 When surveillance utilizes evaluation, review or a certification decision, the requirements in 7.4, 7.5 or 7.6, respectively, shall be fulfilled.”
So, for product certification where there is a significant QMS element (such as, for example, FPC audits under the construction products regulation), is the CB allowed to maintain certification without an independent review/decision?
September 2022
This question can be answered in 3 different ways, depending on its grounds:
i) If surveillance is defined in the certification scheme and this activity includes review and decision, then review and/or decision-making processes shall be carried out in accordance with ISO/IEC 17065.
or
ii) If the certification scheme envisages surveillance but does not include review and decision as part of surveillance, then review or decision processes may not be carried out. Indeed, in ISO/IEC 17000:2020 clause A.5.6, “In many cases, no special action is taken if the statement continues to be valid.” is called.or
iii) Concerning certification schemes given in ISO/IEC 17067 Table 1,
- If the scheme covers MS audits like type 5 and 6, then the CB can follow requirement 9.6.1 of ISO/IEC 17021-1,
- If the scheme does not cover MS audits like types 2, 3, and 4, then the CB shall facilitate review and/or decision process.

