REVISION OF ISO/IEC 17025- - snv.ch · PDF fileOverview Part I 28.09.2016 EUROLAB-CH...
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REVISION OF ISO/IEC 17025-
DIRECT VOICE FROM THE STANDARDIZATION GROUP
Dr. Gabriele DudekBundesanstalt für Materialforschung und –prüfung (BAM), Berlin, Germany
Dipl.-Ing. Christian Müller-SchöllMettler Toledo GmbH, Greifensee, Switzerland
EUROLAB-CH International Seminar, 28th September 2016
Overview Part I
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International Standardization on general aspects of conformity assessment -What happens in the ISO CASCO toolbox?
Standard development in ISO CASCO
Revision of ISO/IEC 17025- Aims and main focus, timeline
The impact of ISO 9001
ISO/IEC 17025 in the context of other CASCO standards -The Common Elements
Structure and process approach
The Scope
Overview Part II
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New clauses and important technical changes (2nd committee draft):
Terms and Definitions
General an structural requirements
Resource requirements
Process requirements
Management requirements
Risk-based approach: Risks and Opportunities
Still under Discussion- The hot potatoes!
Outlook
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Part I
Standards' development work
CASCO is the ISO committee that works on issues relating to conformity assessment
CASCO develops policy and publishes standards related to conformity assessment
It does not perform conformity assessment activities
Membership in CASCO is open to full and correspondent members
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Standards for conformity
assessment-
The ISO CASCO Toolbox
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What happens in the Toolbox? -
CASCO Road Map
Standards under development:
ISO/IEC 17011 (Accreditation bodies)
ISO/IEC 17021-x (e.g. x=2, x=3 und x=9
(Certification bodies for UMS, QMS, Anti-bribery MS)
ISO/IEC 17025 (Testing and calibration laboratories)
ISO 17034 (Reference material producers)
ISO/IEC TR 17028 (Model scheme for certification
bodies for services)
New work item proposal 2016:
ISO/IEC 17029 Conformity assessment –
General requirements for bodies performing
validation and verification activities
important with regard to ISO 14065
approved: August 2016
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19991st edition
2005Adaption to
ISO 9001
2010
?
Document control and processing
Section 5 “Technical requirements” unchanged since 1999
Have laboratories, testing and calibration laboratories changed??
Graphiken: m. freundl. Genehmigung von H. Schorn (I2PS)
ISO/IEC 17025 -
Historical development
ISO/IEC 17025 -
The New work item proposal
In Germany and Switzerland: only minor problems in application Last review in 2010; text of the standard obsolete Further development of standardization on conformity assessment
(structure, management requirements, etc.)
Proposal on revision :
Submitted in summer 2014 (ILAC and SABS)
Survey among ILAC members revealed the
following result: 84% approval (DAkkS: rejection)
Foundation of ISO CASCO WG 44
Convenors: Warren Merkel (ILAC),
Steve Sydney (SABS) ,
Heribert Schorn (IEC)
~140 experts reported
high percentage from emerging and developing countries
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The old standard-
Clauses in need for change
5.4 Test and calibration methodsand method validation
5.5 Equipment (possibly)5.6 Measurement traceability
(Inclusion of the ILAC documents P9, P10 and P14)
5.7 Sampling5.9 Assuring the quality of test
and calibration results5.10 Reporting the results
- ISO/IEC 17025:2005 was obsolete(structure and terminology)
- Revision of ISO 9001(compatibility is important)
- Accreditors wanted an early revision
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NWIP
AdoptionWorking draft
(WD 1, WD 2)
Committee
draft (CD1)
Committee
draft (CD2)
Publication
August
2015
August
2015May
2016
May
2016End
2017
End
2017
October
2014December
2016
December
2016
Draft
(DIS)
Final Draft
(FDIS)
ISO/IEC 17025 –
Timeline of Revision
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Commenting on the 2nd Committee Draft completed internationally WG will prepare the publication of the DIS, Publication of the DIS expected in Dec 2016/Jan 2017 Total time of the revision: 36 months FDIS is basically optional, but probable
Vote on ISO/IEC CD2 17025 and further action
89 countries participated in the vote
Proceeding to the next stage (CD2 -> DIS)
Result:
- More than 2300 comments were discussed in September 2016
(20 -23 Sept 2016)
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YES
YES with
commentsNO
Abstain
New ISO 9001:2015
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5th edition, German-English version, November 2015
New structure: High Level Structure
Important changes include in particular the following topics:
Context of the organization
Commitment of top management
Interested parties
Process approach
Quality manager
Risk-based approach
Knowledge
Documented information
ISO 9001:2015 - Impact on the
ISO CASCO Toolbox
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New structure: High Level Structure and new terminology(e. g. products -> products and services)
Reinforcing the process-based approach: Processes related to product quality and customer satisfaction more strongly emphasized
Strengthening the responsibility of leadership responsibility for effectiveness of the QMS No obligation to formally appoint a quality manager, instead obligation
to employ, instruct and support appropriate persons
Promoting the risk-based approach: especially in the context of planning
Risk analysis and emergency planning as well as consideration/use of opportunities arising
Documented information Classic Quality Manual no further explicitly required Sufficient flexibility in handling the documentation (electronic, paper-
based, etc.)
©www.kweaus.com
‒ Process-based approach and structure Separation of the requirements for structure, resources and
testing or calibration process split of the processes in core processes and supporting processes
--> difficult to handle and therefore not included
‒ Risk-based thinking and acting In principle, nothing new More flexibility in the process
requirements and in the extent of documentation
Consider risks and opportunities
Impact of the new ISO 9001 on ISO/IEC 17025
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The Common Elements
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Former ISO/PAS documents 17001-17005 written on an
understandig of some common elements:
impartiality,
confidentiality,
complaints and appeals,
use of management systems
intended for use by ISO/CASCO WGs in the development of
ISO/CASCO standards
two categories of requirements:
obligatory text: element has to be addressed, without
modification, except for substitution of more specific terms
recommended text: working groups (WGs) may use if they
wished to have a greater degree of specification on the
particular topic
general, structural and resource requirements
Requirements for
management systems
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ISO/CASCO working groups shall not write management system
requirements that contradict these established requirements where
they exist (e. g. ISO 9001, ISO 14001)
MS is an internal mechanism to assure consistent fulfilment of
requirements
Bodies that choose to have a QMS that fulfils all of the
requirements of ISO 9001 shall gain benefit from this fulfilment
(no conflicts!)
Options A und B
Option A: minimum management system requirements shall be
addressed in the standard
Option B: management system, in accordance with ISO 9001 that is
capable of supporting/demonstrating the consistent
fulfilment of the requirements of clauses 4 to 7 of ISO/IEC
17025
Implementation of COMMON ELEMENTS
Results of discussion in the working group:
No types of independency A, B, C (such as for inspection bodies)
More emphasis on the importance of impartiality
Appeals:have no relevance in the daily laboratory work - deletion
Management system requirements:
Keep connection to the latest ISO 9001
Consider principles of ISO 9001
Options A and B have to be integrated
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The new structure
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Scope
Normative references
Terms and definitions
General requirements
Structural requirements
Resource requirements
Process requirements
Management system requirements
Annexes
The Process Approach
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The Scope
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Basic requirements for the competence of all organizations that carry out laboratory activities
Laboratory activities are :
tests calibrations sampling associated with subsequent
calibration or testing
Activities using standardized and non-standardized methods (in-house methods)
Applicable to all forms of organizations, without distinction in terms of the organizational independence
Independent of the size of the company
Difference to ISO 9001: technical competence requirements!
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Part II
Terms and Definitions –
Changes
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New Terms/Definitions:
• Laboratory
• Intralaboratory comparison
• Decision rule
• Impartiality
Obsolete Terms:
• Quality manager
• Technical manager
• Accomodation -> Facility
• Preventive actions -> risk and opportunities
Still under Discussion:
• Method/procedure
"General" and "Structural"
Requirements
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General:
• Mostly based on common elements
• Adoption of mandatory requirements which are unchanged
Structural:
• Nothing new but influenced by new ISO 9001:2015;
• e. g. establishement of communication processes
Provision to cover liabilities:
Clause 5.4: The laboratory shall have adequate provision
(e.g. insurance or reserves) to cover liabilities arising from its
activities)
No competence criterion!
It concerns liability … (previous ISO/IEC 17025 clause 4.1.1)
CLAUSE DELETED
Definition of Impartiality
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impartialitypresence of objectivity
Note 1 to entry:
Objectivity is understood to mean that conflicts of interest do not
exist, or are resolved so as not to adversely influence the activities of
the laboratory.
Note 2 to entry:
Other terms that are useful in conveying the element of impartiality
are freedom from conflicts of interest, freedom from bias, freedom
from prejudice, neutrality, fairness, open-mindedness, even-
handedness, detachment and balance.
[SOURCE: ISO/IEC 17021-1:2015, 3.2]
Impartiality
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(Obligatory wording, adapted to laboratories)
The laboratory shall not allow commercial, financial or other pressures to compromise impartiality
Laboratory activities shall be structured and managed so as to safeguard impartiality
all personnel of the laboratory, either internal or external, that could influence the conformity assessment activities, shall act impartially
Resource Requirements -
Externally Provided Products
and Services
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Basic idea:
- Procurement and subcontracting are considered as externally
provided services, in conformity with ISO 9001:2015
- No explicit reference to "subcontracting" anymore
- External testing and calibration services are basically treated like
external services
- summarized in one section.
Therefore:
Requirements also for control of the ext. provider
and communication to the customer (acceptance
criteria are to be communicated to the customer)
Definition of criteria for reviewing external products
and services is needed
Range of laboratory activities
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Subcontracting
Own personnel +
equipment =
competence
Claim conformity with this
International Standard
5.4
Range o
f la
bora
tori
es
act
ivit
ies
Externally provided products
and services on ongoing basis
Metrological traceability (I)
In revision of ISO/IEC 17025, accreditors require an
appropriate alignment with the ILAC policy (ILAC P10)
-> Prioritizing the traceability paths
Text held deliberately shorter than
previously
If technically possible traceability
to SI System through comparative
measurement or use of certified RM
If technically not possible traceability to another suitable
reference (certified RM, reference methods, consensus-based
standards etc.)
Provision of calibrations through competent actors
Explanations in an informative Annex A
Annex A consists mainly of current "NOTEs"
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Metrological traceability (II)
Main points of Discussion:
Prioritization from ILAC P10 not fully
implemented
Text in the new ISO/IEC 17025 is
more flexible and risk based
Not everything is traceable to SI
with a reasonable effort, this is
possible
Consensus-based standards or
reference methods shall be accepted
by duly authorized bodies
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Process Requirements -
Fundamental considerations
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Greater involvement of the customer, especially in case of changes during the process and whenincluding external bodies
Validation is always used in the context of „Validation of methods“
Much discussed question: Sampling can be a stand alone activity (provided it isassociated with testing or calibration)
Sampling as a
stand alone activity (I)
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Problem: "External samplers" are often no "laboratories" (separation from
laboratory activity) Applicability of ISO/IEC 17025 outside the laboratory is questioned No international harmonization in accreditations
Discussion results so far: Scope of the standard: laboratories
connection to the process in the laboratory that produces the results is important
Possibly separate standard for otherorganizations (special expertise)?
Worldwide survey started in 2015(as input for the working group)
Sampling as a
stand alone activity (II)
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Worldwide survey(09-11/2015):
80 countries and 8 organizations got involved Question: "Should the revised ISO/IEC 17025 be explicitly applicable
to organizations that perform sampling without the subsequent testing or calibration?“
Result: 41 x YES; 39 x NO
Justifications (excerpts):
Supported because :
Sampling is essential for the whole
testing and calibration process
Applicability of ISO/IEC 17025 for
sampling organizations needs to be
improved
ISO/IEC 17025 should be t h e
standard for sampling
Rejected because :
- Sampling activity is
not a conformity assessment
- Sampling is carried out also in
connection with other conformity
assessment activities (ISO/IEC
17020, ISO 17034, ISO/IEC 17065)
- Modification of the scope was no
intention of the revision
- better an own standard
Requirements for sampling –
2nd CD
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laboratory shall have a sampling plan and documented procedures for sampling
analyzed as received:
• Disclaimer, where the laboratory has not been responsible for the sampling stage
• it shall be stated in the report (testing labs)
Record of relevant data: the laboratory shall detail all parameters to be recorded
Statements of Conformity
Laboratories often makestatements on conformity of the results with certainspecifications(compliance with limits, testpassed (yes/no), etc.)
Clear decision rules are to becommunicated, documentedand to be applied
Decision rules have to relateto associated risks
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Foto: © JrCasas
Opinions and interpretations
Opinions and interpretations shall be clearly identified
Always keep reference to the result of the tested or
calibrated item
To be given only by authorized personnel (experience)
Bases for the statements made have to be documented
Clear dissociation from assessments/evaluations in the
context of inspections and product certifications has to
be required
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Duck or rabbit?
Quality assurance of the results
Laboratory shall have procedures for regular monitoring of the effectiveness of QA measures
Selection of surveillance measures:
Use of reference materials Intermediate checks Repetition of tests and calibrations Internal comparisons Blind tests
Comparisons with other laboratories (e. g. PT and comparative tests): whenever available and suitable
Results shall be analyzed to achieve improvements (interaction)
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Reporting of results
Content given by the customer shall be identified
No "signature" required anymore (but an "identification" of a person authorising the report)
Texts on "statement of conformity" now in this section together with "opinions and
interpretations"
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Documentation
Determine necessary degree of documentation
Stronger link to electronic data (data protection, monitoring changes, storage)
Requirements for information management systems (interfaces, verification of functionality, etc.), target: data integrity
Software changes: Modification of commercially available systems requires validation, authorization and documentation
Technical records shall be maintained in a way which allows the repetitionof laboratory activities
A "procedure" can be documented or not(ISO 9001, based on risk etc.)
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Management System
Requirements
"Quality Management
prinicples" are generally
implemented:
- Customer focus
- Leadership
- Engagement of people
- Process approach
- Improvement
- Evidence-based decision
making
- Relationship management
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Minimum management
system requirements of the
laboratory (Option A):
- management system
documentation
- control of management
system documents
- control of records
- actions to address risks and
opportunities
- improvement
- corrective action
- internal audits
- management review
Risk based approach – (I)
Actions to address
risks and opportunities
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Objectives:
give assurance that the management system can achieve its
intended results
enhance opportunities to achieve purpose and objectives
prevent, or reduce, undesired impacts and potential failures
achieve improvement
Actions:
shall be planned and evaluated
shall be proportionate to the potential impact
shall be updated when a nonconformity occurs
Risk based approach (II)
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Options to Address:
identifying and avoiding threats,
taking risk in order to pursue an opportunity,
eliminating the risk source,
changing the likelihood or consequences,
sharing the risk or retaining risk by informed decision
Consequences:
„preventive measures“ no longer explicitly stated, because
prevention is a core task of quality management and risk based
approach
No formalized risk management required
Expression of measurement uncertainty as conceptual basis for
dealing with the risk of a measurement result
Accreditation: difficult to assess
Summary/Key points
• Scope: laboratory activities
• Emphasis on "impartiality"
• Process orientation: Results of processes instead of process
steps and how something needs to be done
• Emphasis on the competence of staff
• Identical rules for “externally provided services”
and “subcontracting”
• Risks and opportunities (no risk management!)
• IT: risk assessment, data integrity, data security,
data protection, confidentiality, software and
their validation
• Allowing "electronic documents"
• Metrological traceability incl. measurement uncertainty
• "Decision rules" for passed/not passed {statement of
conformity}
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Outlook
Publication expected for end 2017
There is still some time left, but:
Substantial impact on many other standards:
more than 300 ISO standards reference to ISO/IEC 17025
Transitional period for accreditation will be determined by ILAC
(usually 2 years, possibly 3 years), harmonized worldwide
Training will be needed
Adaptation of many international (ILAC and EA) and national
documents (accred.-bodies) is to be expected
Due to risk concepts, less "black and white" and
more "grey" -> challenge for accreditors
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Thank you
for your attention!