1 MB = Member Body (Enter the IAF Member Acronym, E.G. Rva)

IAF/ILAC Template for comments – Certification of Multiple Sites Date: 2007-05-17 Document: IAF-GM-07-012 (NCD Z:200X)1 2 (3) 4 5 (6) (7)MB1 Part, Clause Paragraph/ Type Comment (justification for change) by the MB Proposed change by the MB Convener observations No./ List item/ of on each comment submitted Subclause Note com- No./ (e.g. Note 2) ment2 Annex/Figur e/Table (e.g. 3.1, Table 2)CAI No comment. CNAS No comment EMA No comment INMETRO No comment JAS-ANZ No comment. MAURITAS No comment OLAS OLAS has no particular comment to propose on this document. SANAS No comment. Standards No comment Malaysia COFRAC Whole ed This document is an “IAF normative and informative Replace “guidance” by “document” wherever Agreed. "guidance" replaced with document criteria…” I remember we had a rather long it appears "document" or "criteria" as appropriate discussion in the IAF TC in march 2007 on the way to designate this kind of document, and “guidance” had not been selected to be appropriate; then it is preferable not to refer to “guidance” in the document FINAS All ge Certification of multiple sites especially the sampling To collect all the conditions for multi site Nice idea. However, this is a minimum procedure is one of the most misused guides by the procedure and where sampling can be change document and resources are not CBs. Also the clients expect sampling to be used in applied, which are now separated in the currently available to carry out the any situation where the company has activities on document, into one paragraph and maybe proposed exercise. more than one site. The restriction for use of partly reformulate to make the conditions sampling, although in a way stated in 3.1.6, should more clear. be further clarified. IQNet All All te Document lacks clarity and distinction between This recommended text may be included for The proposal mixes definitions and 1 MB = Member Body (enter the IAF Member acronym, e.g. RvA) 2 Type of comment: ge = general te = technical ed = editorial NB Columns 1, 2, 4, 5 are compulsory. Page 1 of 26 IAF electronic balloting commenting template/version 2002-10 IAF/ILAC Template for comments – Certification of Multiple Sites Date: 2007-05-17 Document: IAF-GM-07-012 (NCD Z:200X)1 2 (3) 4 5 (6) (7)MB1 Part, Clause Paragraph/ Type Comment (justification for change) by the MB Proposed change by the MB Convener observations No./ List item/ of on each comment submitted Subclause Note com- No./ (e.g. Note 2) ment2 Annex/Figur e/Table (e.g. 3.1, Table 2) requirements for multi-site certification [irrespective definitions of multi-sites and certification requirements. Standards writing protocol of whether sampling is employed] and requirements documents prevents meeting this proposal although for auditing by sampling. I have sympathy with it. That is why the definitions and explanatory requirements Microsoft Word have been separated. Document .ANAB Page 2 ge Paragraphs edited to reflect the recent Accreditation reduces risk for business and Incorporated understanding that ‘certified once-accepted its customers by assuring them that everywhere’ applies only where there is an MLA for accredited bodies are competent to carry out the framework standard and the specific conformity the work they undertake within their scope of assessment standard or scheme. accreditation. Accreditation bodies which are members of the International Accreditation Forum, Inc. (IAF) are required to comply with appropriate international standards and to require the bodies they accredit to comply with appropriate international standards and IAF Guidance normative criteria to for the consistent application of those standards. Accreditations granted by Accreditation body members of the IAF Multilateral Recognition Arrangement (MLA) , based on have regular surveillance to assure the equivalence of their accreditation programs. , allows companies and persons with an accredited conformity assessment certificate in one part of the world to have that certificate recognized everywhere else in the world. Therefore certificates in the field of 1 MB = Member Body (enter the IAF Member acronym, e.g. RvA) 2 Type of comment: ge = general te = technical ed = editorial NB Columns 1, 2, 4, 5 are compulsory. Page 2 of 26 IAF electronic balloting commenting template/version 2002-10 IAF/ILAC Template for comments – Certification of Multiple Sites Date: 2007-05-17 Document: IAF-GM-07-012 (NCD Z:200X)1 2 (3) 4 5 (6) (7)MB1 Part, Clause Paragraph/ Type Comment (justification for change) by the MB Proposed change by the MB Convener observations No./ List item/ of on each comment submitted Subclause Note com- No./ (e.g. Note 2) ment2 Annex/Figur e/Table (e.g. 3.1, Table 2) management systems, products, services, persons or other similar programs of conformity assessment issued by bodies accredited by members of the IAF MLA are relied upon in international trade. An organization or person with a certificate of conformity to a specific standard or scheme that is accredited by an IAF MLA signatory accreditation body for that standard or scheme can be recognized everywhere else in the world thereby facilitating international trade. SCC Page 2 ge The three paragraphs on accreditation should be Harmonize Agreed. Propose this task fall to IAF TC harmonized for all documents. These three convenor to ensure harmonization paragraphs are different from the once reproduced in the IAF Normative Criteria for Advanced Surveillance and Recertification Procedures ANAB Page 4 First ed For consistent wording with the normative criteria for This document provides normative criteria for Agreed sentence transfers the consistent application of… after the Title JAB Page 4 Title in the te Should be consistent with the title on the cover page IAF Normative and Informative Criteria for Reference to "informative" deleted – text (P.4) the Certification of Multiple Sites Based on although clearly the document is both Sampling normative AND informative JAB Page 4 1st te Although ISO/IEC 17021 is applicable to all types of This document provides criteria on Clause Disagree. The intention is to widen the paragraph management systems, this document is not the 9.1.5. of ISO/IEC 17021:2006 and covers use of this document, although there are in the text case, which should be clarified. criteria on certification of multiple sites several standards for which the sampling (p.4) previously provided in IAF GD2: 2005, Annex technique cannot be applied. It is based 3 and IAF GD6:2006, clause G.5.3.5 – on GD2 and GD6 – but several 1 MB = Member Body (enter the IAF Member acronym, e.g. RvA) 2 Type of comment: ge = general te = technical ed = editorial NB Columns 1, 2, 4, 5 are compulsory. Page 3 of 26 IAF electronic balloting commenting template/version 2002-10 IAF/ILAC Template for comments – Certification of Multiple Sites Date: 2007-05-17 Document: IAF-GM-07-012 (NCD Z:200X)1 2 (3) 4 5 (6) (7)MB1 Part, Clause Paragraph/ Type Comment (justification for change) by the MB Proposed change by the MB Convener observations No./ List item/ of on each comment submitted Subclause Note com- No./ (e.g. Note 2) ment2 Annex/Figur e/Table (e.g. 3.1, Table 2)G.5.3.6. This means that this document is management system standards can intended for only Quality Management follow the same principles. System (QMS) and Environmental Managements System (EMS), in which IAF members have had experience of accredited certification of multiple sites based on sampling. For other management systems, relevant standards may provide specific requirements for multiple sites (e.g. ISO/IEC 27006 for ISMS, ISO 22003 for FSMS). HKAS Title Page4 ed The title on page 4 is : Delete “and Informative” from the title. Agreed “IAF Normative and Informative Criteria for the Certification of Multiple Sites Based on Sampling” It cannot be normative and informative. KAB Title ed Need to unify title IAF Normative Criteria for the certification of Agreed. Reference to "informative" Multiple Sites Based on Sampling deleted – although clearly the document IAF Normative Criteria for ~ is both normative AND informative IAF Normative and Informative Criteria for~ SWEDAC Title ED Not correct references: G.5.3.5- G5.3.6 G5.3.6- G5.3.13 Agreed, but G.5.3.5 included as it defines "site" UKAS 0 0.1 te Insert “across all the sites listed” after relevant Agreed Line 4 standard DAR/ TGA 0 0.2 ge This Guidance document distinguishes between 0.2 should read: “... a certification body shall Agreed. Documented procedures “procedures” and “documented procedures” (see put into operation appropriate documented referred to throughout clause 4.2.1). From that, procedures need not to be procedures for sampling the sites at the initial documented in the CRB. The Guidance document audit and subsequent surveillance and should be reviewed accordingly. recertification audits.”1 MB = Member Body (enter the IAF Member acronym, e.g. RvA) 2 Type of comment: ge = general te = technical ed = editorial NB Columns 1, 2, 4, 5 are compulsory. Page 4 of 26 IAF electronic balloting commenting template/version 2002-10 IAF/ILAC Template for comments – Certification of Multiple Sites Date: 2007-05-17 Document: IAF-GM-07-012 (NCD Z:200X)1 2 (3) 4 5 (6) (7)MB1 Part, Clause Paragraph/ Type Comment (justification for change) by the MB Proposed change by the MB Convener observations No./ List item/ of on each comment submitted Subclause Note com- No./ (e.g. Note 2) ment2 Annex/Figur e/Table (e.g. 3.1, Table 2)KAB 0 0.2 Change to criteria This Criteria addresses the conditions~ Agreed. Have used criteria or document 7th line as appropriate throughout This guidance addresses the conditions~ DAR/ TGA 0 0.3 te Multiple site organizations shall be ruled under “The criteria in this document do not apply to Not agreed. Similar processes may be similar processes, activities and products. the audits of organizations that have multi- used to produce different products. An sites where fundamental dissimilar MS audit is of a process, not a product. processes, activities or products are used or produced at the different sites.” IQNet 0. 0.3 te This particular statement has been surrounded by 1.6 Dissimilar processes Not agreed. See above. Similar 1st much controversy. Suggest a better explanation of argument applies. Dissimilar processes sentence dissimilar processes. Dissimilar processes are the processes is self explanatory. They may be based which are based on different technologies on different technologies, which may or We recommend to include definition of dissimilar and produce different products. may not produce different products. processes in section 1 “Definitions” UKAS 0 0.3 te Combinations of sites may have similar processes Amend line 3 to read Agreed Line 3 at the different sites or a combination of sites, COFRAC 0 0.4 ed grammar Replace “under condition they are” by “under Agreed condition it is” UKAS 0 0.4 te Refer to the confidence in the management system …same level of confidence in the conformity Agreed Line6 of management system across all the sites listed, can be obtained JAB 1 1.1 te Consistency with 17021. The term organization is used to designate Not agreed. "client organization" only any company or other client organization used in ISO/IEC 17021 where there is owning a management system subject to the possibility of confusion audit and certification. COFRAC 1 1.2 ed For clarification and consistency with the following Replace “A site is a location where a client Agreed text carries out work or a service” by “A site is a 1 MB = Member Body (enter the IAF Member acronym, e.g. RvA) 2 Type of comment: ge = general te = technical ed = editorial NB Columns 1, 2, 4, 5 are compulsory. Page 5 of 26 IAF electronic balloting commenting template/version 2002-10 IAF/ILAC Template for comments – Certification of Multiple Sites Date: 2007-05-17 Document: IAF-GM-07-012 (NCD Z:200X)1 2 (3) 4 5 (6) (7)MB1 Part, Clause Paragraph/ Type Comment (justification for change) by the MB Proposed change by the MB Convener observations No./ List item/ of on each comment submitted Subclause Note com- No./ (e.g. Note 2) ment2 Annex/Figur e/Table (e.g. 3.1, Table 2) permanent location where a client carries out activities (work or a service) DAR/ TGA 1 1.2 ed The Guidance document should not divide between A site is a location where an organization Agreed “organization” and “client” carries out work or service. COFRAC 1 1.3 ed For clarification and consistency with the following Replace “to perform specific work for a finite Partially agreed. Consistent with 1.2 as text period of time and which will not become drafted, but amended to include permanent site” by “to perform specific "service" activity for a finite period of time and which will not become a site HKAS 1 1.3 te Who sets up a temporary site is irrelevant. It may Use the definition in GD2:2005: GD2 is now obsolete and therefore no be set up by a party other than the certified need to make us of an old definition organisation. The definition for “temporary site” in “A temporary site is a location other than the the draft document is different from that in sites/locations identified in the certification GD2:2005. document where activities, within the scope of certification, are implemented for a defined period of time. These sites could range from major project management sites to minor service/installation sites.” COFRAC 2 ge For clarity make a fusion of § 2 with the Merge 2.1 with 1.2, 2.2 with 1.3, and 2.3 with Standards writing protocol prevents corresponding §1 subparagraphs, in one § entitled 1.5 meeting this proposal “definitions” JAB 2 te Do we need to say ‘explanatory’ requirements? EXPLANATORY REQUIREMENTS Unchanged. Clear as drafted COFRAC 2.1 2.1.2 ed For harmonisation Replace “certification/registration” by Agreed. Complete “certification” JAB 2.1 2.1.2 te - For consistency with 17021, Where it is not practicable to define a Agreed. All references to certification/registration should be certification. location (e.g. for services), the coverage of certification/registration amended to the certification/registration should take into certification - Examples would be appreciated to justify account the organization’s headquarters ‘special cases.’ 1 MB = Member Body (enter the IAF Member acronym, e.g. RvA) 2 Type of comment: ge = general te = technical ed = editorial NB Columns 1, 2, 4, 5 are compulsory. Page 6 of 26 IAF electronic balloting commenting template/version 2002-10 IAF/ILAC Template for comments – Certification of Multiple Sites Date: 2007-05-17 Document: IAF-GM-07-012 (NCD Z:200X)1 2 (3) 4 5 (6) (7)MB1 Part, Clause Paragraph/ Type Comment (justification for change) by the MB Proposed change by the MB Convener observations No./ List item/ of on each comment submitted Subclause Note com- No./ (e.g. Note 2) ment2 Annex/Figur e/Table (e.g. 3.1, Table 2) activities as well as delivery of its services. Where relevant, in special cases (e.g. Example can be inserted if provided. ………………..), the Certification Body may decide that the certification/registration audit will be carried out only where the organization delivers its services. In such cases all the interfaces with its central office shall be identified and audited. OAA 2.1 2.1.2 ED The term registration is no longer use. Where it is not practicable to define a Agreed. Complete location (e.g. for services), the coverage of the certification should take into account the organization’s headquarters activities as well as delivery of its services. Where relevant, in special cases, the certification body may decide that the certification audit will be carried out only where the organization delivers its services. In such cases all the interfaces with its central office shall be identified and audited IQNet 2.2 2.2.1 te Disagree with this statement. What if a site is Delete this sentence and replace with: Good idea. Agreed Second temporary for 1, 2, 3 years etc. Temporary sites Sentence should be managed by the CB and it should be the They may be however included within the CB’s/Client decision as to whether a temporary site scope of a multi-site certification subject to is included on a certificate agreement between Certification Body and client. DAR/ TGA 2.3 2.3.1 te The multi site approach shall be restricted to Add: “Manufacturing companies producing Not agreed. The sales process could be Second companies producing similar products – even if similar products with a network of sales similar for different products item certification is limited to the sales network. offices (this guidance would apply to the sales network)”. INAB 2.3 2.3.1 Ed Consistency of style Semi-colons after each bullet All commas etc removed from lists1 MB = Member Body (enter the IAF Member acronym, e.g. RvA) 2 Type of comment: ge = general te = technical ed = editorial NB Columns 1, 2, 4, 5 are compulsory. Page 7 of 26 IAF electronic balloting commenting template/version 2002-10 IAF/ILAC Template for comments – Certification of Multiple Sites Date: 2007-05-17 Document: IAF-GM-07-012 (NCD Z:200X)1 2 (3) 4 5 (6) (7)MB1 Part, Clause Paragraph/ Type Comment (justification for change) by the MB Proposed change by the MB Convener observations No./ List item/ of on each comment submitted Subclause Note com- No./ (e.g. Note 2) ment2 Annex/Figur e/Table (e.g. 3.1, Table 2)JAB 2.3 2.3.1 te - As well as continuous surveillance, reference to A multi-site organization need not be a Agreed internal audits would be necessary. unique legal entity, but all sites shall have a legal or contractual link with the central office - Normally the central office will require the sites to of the organization and be subject to a implement corrective actions rather than the central common management system, which is laid office’s direct implementation at the site. down, established and subject to continuous surveillance and internal audits by the central office. This means that the central office has rights to require that the sites implement corrective actions when needed in any site. Where applicable this should be set out in the contract between the central office and the sites. JAB 2.3 2.3.1 te We agreed to change the term from ‘guidance.’ Manufacturing companies with a network of Agreed. Complete 2nd bullet sales offices (this document guidance would apply to the sales network), UKAS 2.3 2.3.1 te Delete the contract, these may not exist between Add - a formal agreement Agreed Line 6 sites ANAB 3 te Additional wording is needed to clarify that this is 3. Eligibility criteria for the organization Agreed criteria for determining the eligibility of an organization for sampling Change to “3. Criteria for determining the eligibility of the organization for sampling” ANAB 3 3.1.1 te As this relates to the certificate and not to eligibility, Relocate 3.1.1 to 4.4.1 and renumber the Agreed it better fits in section 4.4 subsequent clauses of this section After relocation of the clause to 4.4.1, renumber the clauses in section 4.4 COFRAC 3 3.1.1 ed For harmonisation Replace “registration” by “certification” Agreed. Complete HKAS 3 3.1.1, ed This “Normative Criteria” is not “guidance”. Replace the word “guidance” with Agreed. "guidance" replaced with 1 MB = Member Body (enter the IAF Member acronym, e.g. RvA) 2 Type of comment: ge = general te = technical ed = editorial NB Columns 1, 2, 4, 5 are compulsory. Page 8 of 26 IAF electronic balloting commenting template/version 2002-10 IAF/ILAC Template for comments – Certification of Multiple Sites Date: 2007-05-17 Document: IAF-GM-07-012 (NCD Z:200X)1 2 (3) 4 5 (6) (7)MB1 Part, Clause Paragraph/ Type Comment (justification for change) by the MB Proposed change by the MB Convener observations No./ List item/ of on each comment submitted Subclause Note com- No./ (e.g. Note 2) ment2 Annex/Figur e/Table (e.g. 3.1, Table 2)4.0.1 “document”. "document" or "criteria" as appropriate Note under 4.4.6 Inmetro 3 3.1.1 This document is intended to be a “Normative “... in this normative criteria”. Agreed. "guidance" replaced with Last line criteria”, however the term “guidance” appears on "document" or "criteria" as appropriate this item JAB 3 3.1.1 te We agreed to change the term from ‘guidance.’ Certification documents can be issued Agreed. "guidance" replaced with covering multiple sites provided that each "document" or "criteria" as appropriate site included in the scope of registration has either been individually audited by the certification body or audited using the sample approach outlined in this document guidance. OAA 3 3.1.1 ED The term registration is no longer use. Certification documents can be issued Agreed. Complete covering multiple sites provided that each site included in the scope of certification has either been individually audited by the certification body or audited using the sample approach outlined in this guidance. SCC 3 3.1.14 te “in accordance with the audit standard” may create Replace “audit standard” by “ the standard Agreed. See JAB note confusion as the audit standard is often ISO 19011. under audit” This does not seem to be intent of this statement. COFRAC 3 3.1.2 te For clarity and harmonisation for the implementation After first sentence add “If it is not the case, Interesting concept and worth trying. of the document the processes shall be categorised by the CB in groups on similar processes and the multi- site sampling realized on each group” DAR/ TGA 3 3.1.2 te Products and activities shall be included. Add: The activities and products provided Disagree. Processes is used in from or produced at site have to be similar. preference to activities and these have to be similar. Products may be different. 1 MB = Member Body (enter the IAF Member acronym, e.g. RvA) 2 Type of comment: ge = general te = technical ed = editorial NB Columns 1, 2, 4, 5 are compulsory. Page 9 of 26 IAF electronic balloting commenting template/version 2002-10 IAF/ILAC Template for comments – Certification of Multiple Sites Date: 2007-05-17 Document: IAF-GM-07-012 (NCD Z:200X)1 2 (3) 4 5 (6) (7)MB1 Part, Clause Paragraph/ Type Comment (justification for change) by the MB Proposed change by the MB Convener observations No./ List item/ of on each comment submitted Subclause Note com- No./ (e.g. Note 2) ment2 Annex/Figur e/Table (e.g. 3.1, Table 2)INAB 3 3.1.2 Ge To ensure sites performing fewer but more providing that the site(s) which conduct the Agreed important processes are audited. most processes, or critical processes, are subject to full audit. IQNet 3 3.1.2 te Many multinationals, particularly in the semi- This has an effect on two areas: Interesting concept and worth trying. 4.1.3 conductor business, conduct their manufacturing using many linked locations which do not have the 3.1.2 / 4.1.3 same processes (e.g. Wafer fab in USA, Assembly or businesses which conduct their business in Far East). These are often candidates for multi- through linked processes taking place in site although technically locations are carrying out different locations. different (but linked) processes. 5 Sampling Where processes in each location are not similar but are linked, the sampling, each year, shall include at least one example of each process conducted by the organisation. UKAS 3 3.1.2 ed Reword ---providing that all the sites that See INAB comment above. May be Line 4 conduct the substantial processes are several sites conducting substantial subject to full audit processes which could be sampled DAR/ TGA 3 3.1.3 ed Wording of the first sentence is not unclear. The organization’s management system shall I find the original clearer than the be centrally administered under a centrally proposal controlled plan and be subject to central management review. EGAC 3 3.1.3 ge The organization’s management system shall under The organization’s management system shall Agreed. Different text a centrally controlled and administered plan and be be under a centrally controlled and subject to central management review. All the administered plan and be subject to central relevant sites (including the central administration management review. All the relevant sites function) shall be subject to the organization’s (including the central administration function) internal audit program and have been audited in shall be subject to the organization’s internal accordance with that program prior to the audit program and have been audited in 1 MB = Member Body (enter the IAF Member acronym, e.g. RvA) 2 Type of comment: ge = general te = technical ed = editorial NB Columns 1, 2, 4, 5 are compulsory. Page 10 of 26 IAF electronic balloting commenting template/version 2002-10 IAF/ILAC Template for comments – Certification of Multiple Sites Date: 2007-05-17 Document: IAF-GM-07-012 (NCD Z:200X)1 2 (3) 4 5 (6) (7)MB1 Part, Clause Paragraph/ Type Comment (justification for change) by the MB Proposed change by the MB Convener observations No./ List item/ of on each comment submitted Subclause Note com- No./ (e.g. Note 2) ment2 Annex/Figur e/Table (e.g. 3.1, Table 2) certification body starting its audit. accordance with that program prior to starting of the certification body’s audit.INAB 3 3.1.3 Ed Typographical error Shall be under Agreed Inmetro 3 3.1.3 It seems as though the verb “be” is missing “... system shall be under ....” Agreed First line UKAS 3 3.1.3 ed ---shall be under--- Agreed Line 1 UKAS 3 3.1.3 ed ----internal audit programme and all shall Agreed Line 4 have DAR/ TGA 3 3.1.4 ed It should be clear that the “audit standard” is the “It shall be demonstrated that the central Agreed. Simpler text used management system standard. office of the organization has established a management system in accordance with a related management system standard and the whole organization meets the requirements described in the standard. Internal audit report have to be available for the CB prior to the audit.” JAB 3 3.1.4 te ‘Audit standard’ could be misunderstood to mean It shall be demonstrated that the central Agreed. Amended 19011. office of the organization has established a management system in accordance with the relevant management system requirements audit standard … EGAC 3 3.1.5 ge The organization should demonstrate its ability to The organization should demonstrate its Agreed collect and analyse data (including but not limited to ability to collect and analyse data (including the items listed below) from all sites including the but not limited to the items listed below) from central office and its authority and ability to initiate all sites including the central office and also organizational change if required: demonstrate its authority and ability to initiate1 MB = Member Body (enter the IAF Member acronym, e.g. RvA) 2 Type of comment: ge = general te = technical ed = editorial NB Columns 1, 2, 4, 5 are compulsory. Page 11 of 26 IAF electronic balloting commenting template/version 2002-10 IAF/ILAC Template for comments – Certification of Multiple Sites Date: 2007-05-17 Document: IAF-GM-07-012 (NCD Z:200X)1 2 (3) 4 5 (6) (7)MB1 Part, Clause Paragraph/ Type Comment (justification for change) by the MB Proposed change by the MB Convener observations No./ List item/ of on each comment submitted Subclause Note com- No./ (e.g. Note 2) ment2 Annex/Figur e/Table (e.g. 3.1, Table 2) organizational change if required: EGAC 3 3.1.5 ge Differing legal requirements. (Different or changing) legal requirements. Agreed Last bullet point JAB 3 3.1.5 ed Add EMS as abbreviation, which would be more Changes to aspects and associated impacts Agreed familiar (as used in 5.1.4). for environmental management systems (EMS) and JAB 3 3.1.6 te These clauses should be stated much earlier in the Suggest to move 3.1.6 - 3.1.7 to 1.5 or Notes Not agreed. In the section on eligibility 3.1.7 text. to 1.5. as drafted. DAR/ TGA 3 3.1.7 ed Delete AS in the brackets or mention also the ..(9100 series)… Not agreed. Referring to "AS" aids documents of the other sectors ..(AS 9100 series)... clarity. INAB 3 3.1.7 Ge Where specific rules apply, option provided by Shall take precedence Agreed “should” shouldn’t be available IQNet 3 3.1.7 te Delete reference to these two schemes. Not Not agreed. Use of examples aids 2nd appropriate for this document understanding. sentence OAA 3 3.1.7 ED The sectors schemes mentioned should only work Not all management systems standards are Agreed as examples. suitable for consideration for multi-site certification. Specific rules apply for some sector schemes, for example those including automotive (TS 16949) and Aerospace (AS 9100 series) and the requirements of such schemes should take precedence. PCA 3 3.1.7 ge The specific requirements of ISO 22000 and ISO Specific rules apply for some sector schemes Noted. However, they are only examples 27001 was not taken into account . including automotive (TS 16949), Aerospace which can never be exhaustive (AS 9100 series), FSMS (ISO 22000) and ISMS (ISO 27001) and the requirements of 1 MB = Member Body (enter the IAF Member acronym, e.g. RvA) 2 Type of comment: ge = general te = technical ed = editorial NB Columns 1, 2, 4, 5 are compulsory. Page 12 of 26 IAF electronic balloting commenting template/version 2002-10 IAF/ILAC Template for comments – Certification of Multiple Sites Date: 2007-05-17 Document: IAF-GM-07-012 (NCD Z:200X)1 2 (3) 4 5 (6) (7)MB1 Part, Clause Paragraph/ Type Comment (justification for change) by the MB Proposed change by the MB Convener observations No./ List item/ of on each comment submitted Subclause Note com- No./ (e.g. Note 2) ment2 Annex/Figur e/Table (e.g. 3.1, Table 2) such schemes should take precedence. UKAS 3 3.1.7 te Multi site sampling for OHSAS is not appropriate Insert new sentence at end of paragraph. Noted. However, need to avoid Multi site sampling for health and safety specifying too much for specific management systems cannot be applied schemes. Text amended to reflect the where processes, buildings, facilities, local intention relating to local variations factors (eg transport, public contact etc) storage are very likely to be variable for each site. DAR/ TGA 3 3.1.8 ge See comment to 0.2. Certification bodies should have documented Agreed procedures ... SCC 3 3.1.8 te Change to Shall Certification bodies shall have procedures to Not agreed. A CB shall have procedures restrict…. for what it does, not what it does not do UKAS 3 3.1.8 ed Delete site, replace with “such” Agreed Line 1 UKAS 3 3.1.8 Delete which replace with “that” Agreed 4th bullet Inmetro 4 4.0.1 This document is intended to be a “Normative “... set out in this normative criteria...” Agreed. "guidance" replaced with Second criteria”, however the term “guidance” appears on "document" or "criteria" as appropriate line this item IQNet 4 4.01 te Do not agree with statement. The obligation should The certification body shall obtain information Agree in principle only. However, CB 1st be for the certification body to obtain the relevant from the organization about the way they must provide information to the client. sentence information from the organization to determine if the structured and operate and make decision on Clause amended slightly. organization meets the criteria and to inform the compliance of the organisation with any of organization as to the audit approach and reasoning the criteria set out in this guidance and the behind the approach. relevant audit standards before starting the audit process. The Certification body and should not proceed if any of the criteria are not met 1 MB = Member Body (enter the IAF Member acronym, e.g. RvA) 2 Type of comment: ge = general te = technical ed = editorial NB Columns 1, 2, 4, 5 are compulsory. Page 13 of 26 IAF electronic balloting commenting template/version 2002-10 IAF/ILAC Template for comments – Certification of Multiple Sites Date: 2007-05-17 Document: IAF-GM-07-012 (NCD Z:200X)1 2 (3) 4 5 (6) (7)MB1 Part, Clause Paragraph/ Type Comment (justification for change) by the MB Proposed change by the MB Convener observations No./ List item/ of on each comment submitted Subclause Note com- No./ (e.g. Note 2) ment2 Annex/Figur e/Table (e.g. 3.1, Table 2)JAB 4 4.0.1 te ‘Audit standard’ could be misunderstood to mean The certification body shall provide Agreed. Simpler text used 19011. information to the organization about the criteria set out in this guidance and the relevant management system requirements audit standards before starting the audit process, INAB 4.1 4.1.2 Ed Full stop (period) missing at end of clause. Agreed Inmetro 4.1 4.1.2 The period is missing “ activities.” Agreed. Last line COFRAC 4.1 4.1.3 ed numbering Replace 2.1.2 by 3.1.2 Agreed. Now 3.1.1 HKAS 4.1 4.1.3 ed Incorrect cross reference “Clause 2.1.2” should be “clause 3.1.2” Agreed JAB 4.1 4.1.3 ed - Incorrect reference See clause 3.1.2 2.1.2 for sites of which Agreed conduct fewer, but similar processes than - Comma should be placed for readability other sites. Only after a positive examination by the certification body that all the sites proposed for inclusion in the multi-site exercise meet the criteria, may the sampling procedure be applied to the individual sites. EGAC 4.1 4.1.4 ed the organization shall be required to inform the the organization shall be required to inform Agreed certification body in advance of the sites that it the certification body in advance of the sites wants to be included in the certification and those that it wants to be included in the certification which are to excluded and those which are to be excluded INAB 4.1 4.1.4 Ed Two full stops at end of clause – remove one. Agreed Inmetro 4.1 4.1.4 There are two periods in the end of the sentence “.... excluded.” Agreed Last line JAB 4.1 4.1.4 ed - For improved clarity If information on all the sites of a service Not agreed. Original is more clear than organization where the activity subject to 1 MB = Member Body (enter the IAF Member acronym, e.g. RvA) 2 Type of comment: ge = general te = technical ed = editorial NB Columns 1, 2, 4, 5 are compulsory. Page 14 of 26 IAF electronic balloting commenting template/version 2002-10 IAF/ILAC Template for comments – Certification of Multiple Sites Date: 2007-05-17 Document: IAF-GM-07-012 (NCD Z:200X)1 2 (3) 4 5 (6) (7)MB1 Part, Clause Paragraph/ Type Comment (justification for change) by the MB Proposed change by the MB Convener observations No./ List item/ of on each comment submitted Subclause Note com- No./ (e.g. Note 2) ment2 Annex/Figur e/Table (e.g. 3.1, Table 2)- Punctuation certification is performed are not ready to be the proposal submitted for certification at the same time, the organization shall be required to inform the certification body, in advance, of the sites that it wants to be included in the certification and those which are to excluded.. SCC 4.1 4.1.4 and ed Extra period in last sentence. Remove extra period. Agreed 4.4.3 DANAK 4.2 4.2.1 ed Reference to clause 2 should be clause 3 “2” to be replaced by “3”. Agreed HKAS 4.2 4.2.1 ed Incorrect cross reference “Clause 2” should be “clause 3” Agreed JAB 4.2 4.2.1 ed Incorrect reference … and that all the eligibility criteria for the Agreed organization in clause 3 2 above are met. SCC 4.2 4.2.1 ge “where electronic documents and/or process Suggest using this statement: “where Not agreed. Proposal is more confusing control, and/or other electronic processes are used” information management and/or process than the original may lead to confusion. Are we talking about controls through electronic means are used” electronic process controls or simply process controls? UKAS 4.2 4.2.1 te The rationale for CB being satisfied must be Insert new sentence at end of paragraph. Mostly agreed. No need to refer to stage recorded 1, but other elements included Comprehensive information shall be detailed in the stage1 audit reports including the rationale and justification for proceeding with a multi site approach. KAB 4.2 4.2.1 ed Misquote Eligibility criteria for the organization in Agreed 5th line clause 3 above are met. Eligibility criteria for the organization in clause 2 above are met. INAB 4.3 4.3.1 Ge Organisation should not have option not to review Therefore the Certification Body shall require Disagree. Proposal is very negative. If 1 MB = Member Body (enter the IAF Member acronym, e.g. RvA) 2 Type of comment: ge = general te = technical ed = editorial NB Columns 1, 2, 4, 5 are compulsory. Page 15 of 26 IAF electronic balloting commenting template/version 2002-10 IAF/ILAC Template for comments – Certification of Multiple Sites Date: 2007-05-17 Document: IAF-GM-07-012 (NCD Z:200X)1 2 (3) 4 5 (6) (7)MB1 Part, Clause Paragraph/ Type Comment (justification for change) by the MB Proposed change by the MB Convener observations No./ List item/ of on each comment submitted Subclause Note com- No./ (e.g. Note 2) ment2 Annex/Figur e/Table (e.g. 3.1, Table 2) impact of NCs at other sites the organisation to review the ncs … an organization can improve its MS, it should be allowed to do so. SCC 4.3 4.3.1 te Change should to shall … from auditing by the certification body, Not agreed. Proposal is a prescriptive investigation shall take place to determine "how" whether the other sites may be affected. Therefore, the certification body shall require the organization to review the … UKAS 4.3 4.3.1 te Verification of corrective action --should be performed and verified.both at Agreed – but must refer to NCRs as Line 7 ---. defined in 9.1.15 (b) of ISO/IEC 17021 – not 9.1.15 (c) EGAC 4.3 4.3.2 te 4.3.2 The certification body shall require evidence of This phrase needs to be further explained Not agreed. Proposal is a prescriptive these actions and increase its sampling frequency e.g., in a note. This note should explain how "how". The document should not specify and/or the size of sample until it is satisfied that this sampling frequency be increased. how an action is carried out. control is re-established Examples should be given e.g., decreasing the surveillance period.DAR/ KBA 4.3 4.3.3 te According to 17021:06, clause 9.1.15, the At the time of the decision making process, See UKAS comment certification can be denied only if a certain kind of clause 9.1.15 of ISO/IEC 17021:2006 must non-conformities (see subclause b) has not been be applied to any single site. settled by verified corrections and corrective actions. In any other case, the certification must be granted if only plans for corrections/corrective actions are accepted (i.e. non-conformities are not settled yet) IQNet 4.3 4.3.3 te This does not comply with ISO17021 which only At the time of the decision making process, if Not agreed. CARs (majors) must be requires a corrective action plan to be submitted and any site has a nonconformity and corrective verified – reference to 17021 now approved prior to granting of certification action plan is not submitted and not included. approved, certification shall be denied to the whole network pending satisfactory corrective action.1 MB = Member Body (enter the IAF Member acronym, e.g. RvA) 2 Type of comment: ge = general te = technical ed = editorial NB Columns 1, 2, 4, 5 are compulsory. Page 16 of 26 IAF electronic balloting commenting template/version 2002-10 IAF/ILAC Template for comments – Certification of Multiple Sites Date: 2007-05-17 Document: IAF-GM-07-012 (NCD Z:200X)1 2 (3) 4 5 (6) (7)MB1 Part, Clause Paragraph/ Type Comment (justification for change) by the MB Proposed change by the MB Convener observations No./ List item/ of on each comment submitted Subclause Note com- No./ (e.g. Note 2) ment2 Annex/Figur e/Table (e.g. 3.1, Table 2)SCC 4.3 4.3.3 ge A definition of “network” would be useful here. Are Define “network” "of listed sites" inserted we talking of a network in the sense of communications or multi-sites?? UKAS 4.3 4.3.3 te Ensure/re enforce nature of non conformities Insert at end of line 1 (ref ISO/IEC 17021 Agreed Line 1 section 9.1.15 b) COFRAC 4.3 4.3.4 ed numbering Replace 3.1.4 by 4.1.4 Agreed HKAS 4.3 4.3.4 ed Incorrect cross reference “Clause 3.1.4” should be “clause 4.1.4” Agreed JAB 4.3 4.3.4 ed Incorrect reference Such exclusion can only be agreed in Agreed advance (See clause 4.1.4 3.1.4). OAA 4.3 4.3.4 TE I should be better clarify in which moment the It shall not be admissible that, in order to Resolved by change of reference as exclusion should be agreed. overcome the obstacle raised by the above existence of a nonconformity at a single site, the organization seeks to exclude from the scope the "problematic" site during the certification process. Such exclusion can only be agreed in the contract review. DANAK 4.4 4.4.2 ed Reference to the certification documents seems to Underlined text to be added: Agreed. be missing in the second sentence. The scope or other reference on the certification documents shall make clear that the certified activities are performed by the network of sites in the list. If the certification scope of the sites is only issued as part of the general scope of the organization, its applicability to all the sites shall be clearly stated. HKAS 4.4 4.4.2 te To avoid misleading scope. Add at the end of clause 4.4.2 the following: Text amended more simply “For situation mentioned in clause 4.1.4, the 1 MB = Member Body (enter the IAF Member acronym, e.g. RvA) 2 Type of comment: ge = general te = technical ed = editorial NB Columns 1, 2, 4, 5 are compulsory. Page 17 of 26 IAF electronic balloting commenting template/version 2002-10 IAF/ILAC Template for comments – Certification of Multiple Sites Date: 2007-05-17 Document: IAF-GM-07-012 (NCD Z:200X)1 2 (3) 4 5 (6) (7)MB1 Part, Clause Paragraph/ Type Comment (justification for change) by the MB Proposed change by the MB Convener observations No./ List item/ of on each comment submitted Subclause Note com- No./ (e.g. Note 2) ment2 Annex/Figur e/Table (e.g. 3.1, Table 2)The third line, “The scope or other reference on..” is certification scope should indicate that the incomplete. certification is for a limited number of sites.” Replace the incomplete phrase by “The scope or other reference stated on the document..”. INAB 4.4 4.4.2 Ed Remove ‘on’ - Typographical error The scope or other reference No. Words were missing – see below Inmetro 4.4 4.4.2 The particle “on” does not make sense on the “...or other reference shall make clear...” No. Words were missing – see below Third line sentence JAB 4.4 4.4.2 ed Words missing? The scope or other reference on the Agreed. See below documents shall make clear that … OAA 4.4 4.4.2 ED There are some word missing in “The scope or other The documents shall contain the name and Agreed. Simpler text used reference on … shall make” address of the central office of the organization and a list of all the sites to which the certification documents relate. The scope or other reference on the certification document shall make clear that the certified activities are performed by the network of sites in the list. If the certification scope of the sites is only issued as part of the general scope of the organization, its applicability to all the sites shall be clearly stated. SCC 4.4 4.4.2 ed Second sentence seems to be missing something Other reference on what? See above UKAS 4.4 4.4.2 ed Delete “on” No. Words were missing – see above Line 3 Inmetro 4.4 4.4.3 There are two periods in the end of the sentence “.... documentation.” Agreed. Last line PCA 4.4 4.4.3 ge The problem of contracts with all sites is not The certification body shall have legally Not necessary. Covered by 17021 which 1 MB = Member Body (enter the IAF Member acronym, e.g. RvA) 2 Type of comment: ge = general te = technical ed = editorial NB Columns 1, 2, 4, 5 are compulsory. Page 18 of 26 IAF electronic balloting commenting template/version 2002-10 IAF/ILAC Template for comments – Certification of Multiple Sites Date: 2007-05-17 Document: IAF-GM-07-012 (NCD Z:200X)1 2 (3) 4 5 (6) (7)MB1 Part, Clause Paragraph/ Type Comment (justification for change) by the MB Proposed change by the MB Convener observations No./ List item/ of on each comment submitted Subclause Note com- No./ (e.g. Note 2) ment2 Annex/Figur e/Table (e.g. 3.1, Table 2)Add clause addressed. Suggestion is made to include extra enforceable agreement, directly or through applies in full. after point after 4.4.3 central office, with all the sites covered by the scope of the certification as required by 5.1.2 of ISO/IEC 17021. SCC 4.4 4.4.3 ge A definition of “sub-certification documents would be Define “sub-certification” documents Simplified to "Certification…." useful. EGAC 4.4 4.4.4 ed The certification documentation will be withdrawn in There is no need for do not in this sentence. Agreed. its entirety, if the central office or any of the sites does not/do not fulfil the necessary criteria for the maintenance of the certification DAR/ TGA 4.4 4.4.6 ge See comment to 0.2. The Certification bodies shall have Agreed. documented procedures for the addition of new sites. INAB 4.4 4.4.6 Ge It conflicts with clause 2.2 which state that Leave as is but remove conflicting statement Disagree. Some temporary sites could Note temporary sites shall not be included. in clause 2.2 be quasi permanent (IQnet) – eg. in existence for a year or more. Note A risk analysis should be done of processes done at deleted. temporary sites to determine their inclusion in the scope. Inmetro 4.4 4.4.6 This document is intended to be a “Normative “...this normative criteria”. Note deleted Note criteria”, however the term “guidance” appears on this item HKAS 5.1 5.1.1 te The samples selected should be representative. Replace the words “a range of different” with Agreed. “a representative range of different” in the second line. COFRAC 5.1 5.1.4 ed Consistency with text Replace “activities” by “processes” Agreed. 5th bullet DANAK 5.1 5.1.4 te Differing legal requirements may also be criteria for To be added: OK, but not included. List is not intended 1 MB = Member Body (enter the IAF Member acronym, e.g. RvA) 2 Type of comment: ge = general te = technical ed = editorial NB Columns 1, 2, 4, 5 are compulsory. Page 19 of 26 IAF electronic balloting commenting template/version 2002-10 IAF/ILAC Template for comments – Certification of Multiple Sites Date: 2007-05-17 Document: IAF-GM-07-012 (NCD Z:200X)1 2 (3) 4 5 (6) (7)MB1 Part, Clause Paragraph/ Type Comment (justification for change) by the MB Proposed change by the MB Convener observations No./ List item/ of on each comment submitted Subclause Note com- No./ (e.g. Note 2) ment2 Annex/Figur e/Table (e.g. 3.1, Table 2) selection of sites.  Differing legal requirements to be exhaustive "may include among others" INAB 5.1 5.1.4 Ed Clarity (addition of commas), consistency of style may include, among others, the following All commas etc removed (semi-colons after each bullet ) aspects SWEDAC 5.1 5.1.4 point ED Change wording to get the way of writing the Change to: Significance and extent of Amended. See OAA comment Significanc document more harmonized environmental aspects and associated e…. environmental impacts. SWEDAC 5.1 5.1.4 point TE Clarification of geographical dispersion needed Change point to: Geographical dispersion, Not agreed. Separate issues Geographic including legal requirements al… SWEDAC 5.1 5.1.4 TE Important point in IAF GD 6/2006 for EMS has been Add to list: - potential interaction with 9th bullet amended taken out. sensitive environment PCA 5.1 5.1.6 Te The problem of time gap between visits in central 5.1.7 The certification body shall have Not agreed. Proposal too prescriptive Add clause office and local offices is not addressed procedure(s) for determining the time frame and no argument to necessarily audit the after for completion audit in all the sites. The central office first. central office shall be visited first, followed by the sites in any order chosen by lead auditor. SWEDAC 5.1 5.1.6 TE Important point in IAF GD 6/2006 for EMS has been Add to this clause : the surveillance program Not agreed. This is not sampling of sites taken out. should include visits, within a reasonable time, to all sites of the organization in accordance with the certification body’s sampling method. OAA 5.1 5.1.4 ED Environmental Management System reference is Significance and extent of aspects and Agreed, but (EMS) is retained for clarity Item 8 incorrect . associated impacts for environmental management systems DAR/ TGA 5.2 5.2.1 ge See comment to 0.2. The Certification bodies shall have a Agreed documented procedure for determining..1 MB = Member Body (enter the IAF Member acronym, e.g. RvA) 2 Type of comment: ge = general te = technical ed = editorial NB Columns 1, 2, 4, 5 are compulsory. Page 20 of 26 IAF electronic balloting commenting template/version 2002-10 IAF/ILAC Template for comments – Certification of Multiple Sites Date: 2007-05-17 Document: IAF-GM-07-012 (NCD Z:200X)1 2 (3) 4 5 (6) (7)MB1 Part, Clause Paragraph/ Type Comment (justification for change) by the MB Proposed change by the MB Convener observations No./ List item/ of on each comment submitted Subclause Note com- No./ (e.g. Note 2) ment2 Annex/Figur e/Table (e.g. 3.1, Table 2)Inmetro 5.2 5.2.1 This document is intended to be a “Normative “... in this normative criteria”. Agreed. "guidance" replaced with Last line criteria”, however the term “guidance” appears on "document" or "criteria" as appropriate this item DAR/ TGA 5.2 5.2.2 ge Records on how the sample approach has been Delete the need for records in 5.2.2 and add: Agreed adapted to the company shall be available in any “The certification body shall have records on multi-site certification – not only restricted when the each application of multi-site sampling certification body’s procedures result in a smaller justifying that it is in accordance with this sample as required from the guidance. guidance.” Inmetro 5.2 5.2.2 This document is intended to be a “Normative “...of the normative criteria set out...” Agreed. "guidance" replaced with Second criteria”, however the term “guidance” appears on "document" or "criteria" as appropriate line this item Inmetro 5.2 5.2.3 The square root symbol is missing “ y = x “ Not understood. Square root sign Second, appeared normal when I downloaded third and from IAF web-site. May be a "WORD" fourth problem paragraphs JAB 5.2 5.2.3 te Consistency with 17021 Surveillance audit visit: … Agreed Recertification audit: … JAB 5.2 5.2.3 te The letter ‘v’ is substituted for the square root. Correctly represent the square root (√) Not understood. Square root sign appeared normal when I downloaded from IAF web-site. May be a "WORD" problem UKAS 5.2 5.2.3 te Low to medium risk activity. This is not defined .It Reword as follows. Noted. However, brief was to produce Line 1 will be different for different management system document without significant change. standards. The following calculation is based on the The proposal re-opens the whole debate example of a single, or series of simple on risk. Much of the proposal is covered For environment and health and safety management production/service processes with less than in clause 9.1.4 of ISO/IEC 17021 systems, risk is a fundamental aspect of the fifty employees at each site. Eg ? ? ?provide1 MB = Member Body (enter the IAF Member acronym, e.g. RvA) 2 Type of comment: ge = general te = technical ed = editorial NB Columns 1, 2, 4, 5 are compulsory. Page 21 of 26 IAF electronic balloting commenting template/version 2002-10 IAF/ILAC Template for comments – Certification of Multiple Sites Date: 2007-05-17 Document: IAF-GM-07-012 (NCD Z:200X)1 2 (3) 4 5 (6) (7)MB1 Part, Clause Paragraph/ Type Comment (justification for change) by the MB Proposed change by the MB Convener observations No./ List item/ of on each comment submitted Subclause Note com- No./ (e.g. Note 2) ment2 Annex/Figur e/Table (e.g. 3.1, Table 2) standard and the scope of the standard i.e low typical examples… medium risk of , for example, environmental pollution or harm to an individual’s occupational The minimum number………. Note added to require CBs to define risks of activities health and safety  Initial For quality management systems what is low to  Surveillance medium risk,? Is it of the product failing to meet the customer requirements, or are we confusing the  Re -certification likely impact/consequence of a product failing. Eg a Add at end of 5.2.3 carpet or a bridge. ( or a small switch in the new motor car) The purchaser expects both to meet the An increased sample size will be required specified requirements. where complex processes are involved. For QMS and FSMS there should be no low/medium risk of the system failing, certification is confidence that the product meets customer requirements. Many “low risk “products have very complex processes Establish a minimum number of sites based on a single process then CB will be required to increase the sample size based on more complex operations DANAK 5.2 5.2.5 te Other relevant factors may indicate the need for Underlined text to be added in the list of increase of the sample. factors: . Variations in working practices, e.g. shift working  Agreed . Differing legal requirements  Not a factor on sample size . Significance and extent of aspects and  Agreed associated impacts for EMS management systems 1 MB = Member Body (enter the IAF Member acronym, e.g. RvA) 2 Type of comment: ge = general te = technical ed = editorial NB Columns 1, 2, 4, 5 are compulsory. Page 22 of 26 IAF electronic balloting commenting template/version 2002-10 IAF/ILAC Template for comments – Certification of Multiple Sites Date: 2007-05-17 Document: IAF-GM-07-012 (NCD Z:200X)1 2 (3) 4 5 (6) (7)MB1 Part, Clause Paragraph/ Type Comment (justification for change) by the MB Proposed change by the MB Convener observations No./ List item/ of on each comment submitted Subclause Note com- No./ (e.g. Note 2) ment2 Annex/Figur e/Table (e.g. 3.1, Table 2)EGAC 5.2 5.2.5 te 5.2.5 The size or frequency of the sample should be This phrase needs to be further explained Disagree. Proposal is for prescriptive increased where the certification body’s risk analysis e.g., in a note. This note should explain how "how" of the activity covered by the management system this sampling frequency be increased. subject to certification indicates special Examples should be given e.g., decreasing circumstances in respect of factors such as the surveillance period. INAB 5.2 5.2.5 Ed Consistency of style Semi-colons after each bullet Agreed. All commas etc removed DANAK 5.2 5.2.6 ed The number of National offices is missing The number to be added: Agreed 4 National offices: sample = 2: minimum 1 at random Inmetro 5.2 5.2.6 The number of “national offices” is missing “4 national offices “ Agreed Second line from the example JAB 5.2 5.2.6 ed Typo (The number 4 is missing.) 4 national offices: sample=2 Agreed OAA 5.2 5.2.6 ED The number of National offices of the example is Example: Agreed Example missing (4). 1 head office: visited at each audit cycle (initial/surveillance/recertification) 4 National offices: sample = 2: minimum 1 at random 27 regional offices: sample = 6: minimum 2 at random 1700 local branches: sample = 42: minimum 11 at random.1 MB = Member Body (enter the IAF Member acronym, e.g. RvA) 2 Type of comment: ge = general te = technical ed = editorial NB Columns 1, 2, 4, 5 are compulsory. Page 23 of 26 IAF electronic balloting commenting template/version 2002-10 IAF/ILAC Template for comments – Certification of Multiple Sites Date: 2007-05-17 Document: IAF-GM-07-012 (NCD Z:200X)1 2 (3) 4 5 (6) (7)MB1 Part, Clause Paragraph/ Type Comment (justification for change) by the MB Proposed change by the MB Convener observations No./ List item/ of on each comment submitted Subclause Note com- No./ (e.g. Note 2) ment2 Annex/Figur e/Table (e.g. 3.1, Table 2)COFRAC 5.3 5.3.2 ed For clarity to express that the calculation of audit “Normally the number of man-days per site, Agreed duration time is realised site per site, using the including the central office, should be appropriate IAF guidance on each site. “Normally “ consistent with the most recently published is not necessary, the criteria is already a “should” IAF guidance calculation of man-days for the one relevant standard.” By “The number of man- days per site, including the central office, should be calculated using for each sit the most recently published IAF guidance for calculation of man-days for the relevant standard.” HKAS 5.3 5.3.2 ed The document on auditor manday is not guidance Replace the word “guidance” with “criteria Agreed. for” SCC 5.3 5.3.2 ed Use of “man-days”. This is no longer acceptable as Please use “person days.” Disagree. Man days is common a term. parlance worldwide and is not gender specific DANAK 5.3 5.3.3 te Reductions is a common used possibility for Text to be added: Agreed certification bodies and any justification need to be recorded in order to maintain historical records, that “Reasons justifying reductions shall be will be present when there are change of personnel. recorded by the certification body. “ DAR/ TGA 5.3 5.3.3 te Not all clauses of standard could be applied in the “Reductions can be applied to take into Agreed in part. Last sentence not audit of central office – as it is the case for the local account the clauses that are not relevant to justified sites. the central office and the local sites, or where there is considerable commonality of activities, products and processes at sites. However, certification body shall consider, that auditing the central office requires additional time when multi - site is applied.” HKAS 5.3 5.3.3 te The reduction in audit time for “commonality of Delete the following from clause 5.3.3: Agreed activities and processes at sites” has been “, or where there is considerable 1 MB = Member Body (enter the IAF Member acronym, e.g. RvA) 2 Type of comment: ge = general te = technical ed = editorial NB Columns 1, 2, 4, 5 are compulsory. Page 24 of 26 IAF electronic balloting commenting template/version 2002-10 IAF/ILAC Template for comments – Certification of Multiple Sites Date: 2007-05-17 Document: IAF-GM-07-012 (NCD Z:200X)1 2 (3) 4 5 (6) (7)MB1 Part, Clause Paragraph/ Type Comment (justification for change) by the MB Proposed change by the MB Convener observations No./ List item/ of on each comment submitted Subclause Note com- No./ (e.g. Note 2) ment2 Annex/Figur e/Table (e.g. 3.1, Table 2) accounted for by sampling. No further reduction commonality of activities and processes at should be allowed. sites” HKAS 5.3 5.3.4 te Clause 4.3.6 of GD2:2005 should be included for Insert a new clause: I do not support this clause, but it has New clause setting a minimum. been retained in simplified form after 5.3.4 The total time expended on initial objections from several parties. The last assessment and surveillance (understood as sentence is superfluous. the total sum of the time spent at each site plus the central office) should never be less than that which would have been calculated for the size and complexity of the operation if all the work had been undertaken at a single site (i.e. with all the employees of the company in the same site). In most cases it will be considerably more. NAC 5.3 - Te 1. There are no man-day requirements for Multiple 1. It should be added man-day Noted. This will be addressed in the new Sites and Temporary Sites as in GD2 and GD6. requirements for Multiple Sites and "stand alone " document for man day Temporary Sites in this IAF Normative calculations 2. The reductions for auditor time requirements are Criteria. not clear. 2. It should be clarified for reductions for auditor time requirements. NAC 2.2 - Te There are no assessment requirements for It should be added and clarified. Not agreed. The calculation should be Temporary Sites and also how to sampling as in the same for any sites if they are GD2 and GD6. included in the network of sites. Late Comments NABCB Cl 4.3.1 Line 3 Ed “Evaluation” is preferable to “investigation” Replace “investigation” with “evaluation” Noted but considered unnecessary (ICL) NABCB Cl 4.3.3 Line 1 Te Make a reference to ISO 17000 for definition of non- Add after non-conformity (refer to ISO Not agreed. Refereed back to 17021 as 1 MB = Member Body (enter the IAF Member acronym, e.g. RvA) 2 Type of comment: ge = general te = technical ed = editorial NB Columns 1, 2, 4, 5 are compulsory. Page 25 of 26 IAF electronic balloting commenting template/version 2002-10 IAF/ILAC Template for comments – Certification of Multiple Sites Date: 2007-05-17 Document: IAF-GM-07-012 (NCD Z:200X)1 2 (3) 4 5 (6) (7)MB1 Part, Clause Paragraph/ Type Comment (justification for change) by the MB Proposed change by the MB Convener observations No./ List item/ of on each comment submitted Subclause Note com- No./ (e.g. Note 2) ment2 Annex/Figur e/Table (e.g. 3.1, Table 2)(ICL) conformity 17000:2004) the relevant reference for certification NABCB Cl 4.4.6 Line 2 Te Additional sites may be added as a part of Add after “surveillance/recertification” – Agreed (ICL) enhancement of scope activities “enhancement of scope” NABCB Cl 5.1.4 Bullet point Te This does not seem to be a relevant criteria for Delete the bullet point Noted, but others think it is relevant (ICL) 8 sampling of sites NABCB Cl 5.1.4 Te Add 2 new bullet points regarding differences in Add 2 bullet points – “Differences in Agreed, but combined in other bullet (ICL) language, social norms etc, regulatory requirements language, work culture, social norms” points “Any differences in applicable regulatory/statutory requirements for different regions/countries NABCB Cl 5.3 Entire Te The document should clearly define the criteria to be Noted. However, it is considered that (BVCI) clause used [viz. whether the mandays should be one example is enough. This is a calculated individually per site and added OR should minimum change document and be calculated for the total cumulative manpower and changes have been kept to a minimum distributed OR should be calculated based on the manpower in the sampled sites] for calculating the audit time. In the absence of uniform guidance, each CB will define its own criteria and hence the purpose of the guidance will be defeated. An example shall be provided for manday calculation under all possible scenarios to avoid any misinterpretation or come out with a manday calculator like IATF has for TS scheme1 MB = Member Body (enter the IAF Member acronym, e.g. RvA) 2 Type of comment: ge = general te = technical ed = editorial NB Columns 1, 2, 4, 5 are compulsory. Page 26 of 26 IAF electronic balloting commenting template/version 2002-10

1 MB = Member Body (Enter the IAF Member Acronym, E.G. Rva)

Details

Download

Copyright

We respect the copyrights and intellectual property rights of all users. All uploaded documents are either original works of the uploader or authorized works of the rightful owners.

Support