QS-CAS-PROC/31

November 2013

ISO/CASCO
CLARIFICATION REQUEST FORM

Date of submission: 2017-04-05

1. Requesting ISO Member or A liaison member: NEN

2. Contact person: Thamar Zijlstra

3. Position:

4. Email address: Thamar.Zijlstra@nen.nl

5. Please specify the ISO/CASCO document by name and number (ISO/IEC 17XXX) and clause number:
ISO/IEC 17065:2012 “Conformity assessment -- Requirements for bodies certifying products,
processes and services”

Clause 6.2.1 Internal resources

When a certification body performs evaluation activities, either with its internal resources or with other
resources under its direct control, it shall meet the applicable requirements of the relevant International
Standards and, as specified by the certification scheme, of other documents. For testing, it shall meet the
applicable requirements of ISO/IEC 17025; for inspection, it shall meet the applicable requirements of
ISO/IEC 17020; and for management system auditing, it shall meet the applicable requirements of
ISO/IEC 17021. The impartiality requirements of the evaluation personnel stipulated in the relevant standard
shall always be applicable.

and

Clause 6.2.2 External resources (outsourcing)

6.2.2.1 The certification body shall outsource evaluation activities only to bodies that meet the applicable
requirements of the relevant International Standards and, as specified by the certification scheme, of other
documents. For testing, it shall meet the applicable requirements of ISO/IEC 17025; for inspection, it shall
meet the applicable requirements of ISO/IEC 17020; and for management system auditing, it shall meet the
applicable requirements of ISO/IEC 17021. The impartiality requirements of the evaluation personnel
stipulated in the relevant standard shall always be applicable.

6. Clarification request, please formulate the request clearly and where possible in a format that enables
a YES or NO answer:

ISO/IEC 17065:2012 article 6.2.1 requires the certification body that performs inspection activities,
either with its internal resources or with other resources, it [the certification body] shall meet the
applicable requirements of ISO/IEC 17020. ISO/IEC 17065:2012 article 6.2.2.2 requires the
certification body that subcontract inspection activities, it shall do so to a body that shall meet the
applicable requirements of ISO/IEC 17020. Both 6.2.1 and 6.2.2.2 state that the impartiality
requirements for evaluation personnel (inspectors in case of ISO/IEC 17020) are always
applicable. This however does not mean that the other requirements in ISO/IEC 17020 are not
applicable.

ISO/IEC 17020 has impartiality requirements, including independence requirements, stipulated in

chapter 4 with reference to Annex A. These requirements are on the inspection body as such and
QS-CAS-PROC/031 Annex1
Page 2

on its personnel (for example read the text in annex A.1 and A.2 “The inspection body and its
personnel shall not engage in any activities that ….”. ISO/IEC 17020 gives requirements (4.1.6) for
different types of independence: type A, B or C bodies from which only the type A is a third party
inspection activity.

Given the fact that certification is by definition (ISO/IEC 17000) a third party conformity
assessment activity, ISO/IEC 17065 could be understood that the reference in article 6.2.1 and
6.2.2.2 to “applicable requirements” of ISO/IEC 17020 implies that when conducting inspection
activities or when subcontracting inspection activities, the articles for type A inspection bodies
apply, because the type B and C requirements are not ensuring third party evaluation of the
products, processes or services. ISO/IEC 17020 article 4.6.1 states “The inspection body shall be
independent to the extent that is required with regard to the conditions under which it performs its
services”. This extent that is required could be understood that only third party inspection can
result in third party attestation (certification).

Question 1)
Based on the above reasoning ISO/IEC 17065 requires that each inspection activity that is
undertaken for certification of a product, process or service shall be a third party inspection activity
to which the requirements for a type A inspection body as referred to in 4.1.6 of ISO/IEC 17020
apply. Is this a correct interpretation?

Question 2)
If the answer to question 1 is “yes”, does this mean that the internal or “other resources under its
direct control” (article 6.2.1 of ISO/IEC 17065) which are involved in inspection of products,
services or processes to certify products, processes or services, shall meet all of the requirements
of Annex A, clause A.1, implying that a contracted external inspector shall not be engaged in the
design, manufacture, supply, installation, etc. of the products certified?

Question 3)
If the answer to question 1 is “yes”, does this mean that the bodies to which inspection activities
are subcontracted (article 6.2.2.2 ISO/IEC 17065) when certifying products, services or processes,
shall be inspection bodies to which the requirements of Annex A, clause A.1 in ISO/IEC 17020
apply?

Question 4)
If the answer to question 1 is “no”, is that because the requirements in Annex A, clause A.1 of
ISO/IEC 17020 are not at all to be considered for a certification body that conducts or
subcontracts inspection activities to certify a product, process or service?

7. Consensus position of the maintenance group (This section is only to be completed by the
maintenance group members)

Question 1) No
Question 2) n/a as 1) no
Question 3) n/a as 1) no
Question 4) No, it is up to the CB to decide which are the applicable requirements of ISO/IEC
17020 based on the specific circumstances, but in line with the scheme requirements and
impartiality requirements for the personnel

Send the filled form to casco@iso.org

 Page 3

To be completed by maintenance group members only

Date request sent maintenance panel

Is the clarification request formatted in an yes
acceptable manner? no
yes
Is it clearly and unambiguously worded?
no
Do you have a conflict in participating in this yes
request if so please specify. no

/O:\CAS Management\03- CAS quality docs\QS-CAS-PROC-31 clarification process\CASCO QS-CAS-PROC

031Annex 1 Clarification request form.docx