Just received a letter from our registrar. The just of it was that ISO/IEC Guide 62 (QMS) & 66 (EMS) has been changed and effective July of 2002, a reassessment will be required every 3 years. More $$$$$$$$. Who was that in a previous thread wanted to start a registration company?????

I am not sure what you mean by "reassessment" but if you mean re-registration, that's pretty standard now. However, by the looks of your post, you probably mean that the registrar wants to do a complete and full-blown (including doc review) registration-type audit every 3 years. That's the first that I've heard of that, especially based on a change to ISO guide 62!

From my understanding it is a reassessment of the entire system. This applies to ISO 94, 00 and 14001.

Historically, you could meet this requirement by scheduling surveillance audits so that the entire system is audited within 3 years. I’ve not heard anything from any of my registrar contacts that this has changed. I will ask them at the next opportunities.

Yes db, thats what we had been doing. I had heard in May that some changes were coming. This is a result of the ISO/IAF teaming to crack down to clean up registration process?

I hope you are not referring to the Internal Automotive Task Force, the mere thought of the IATF getting involved in ISO stuff frightens me to no end!:eek:

I just finished auditing a full system reassessment after the initial 3 year cycle under 14K.

IAF is International Accreditation Forum

I know, but I have been doing a lot with 16949 lately, and I misread it the first time. It still is a scarey thought.

Like db, I have not heard that a full-blown reassessment is necessary. They may jumping the gun a little bit. Again, like db, I think the norm is to consider the reassessement like another surveillance if the other surveillance audits have covered the other elements of the standard. It doesn't make much sense to me to do the full-blown reassessment if the entire system has been checked over the 3 year period. This seems like unnecessary money paid to the registrar for little added value.

Re-assessment has always been required under IAF guidance. It was my understanding that only RAB broke from the group and allowed "continuous" or "rolling" certification. The other accreditation bodies recognized and abided by the guidance and did not recognize continuous approvals. In other words, UKAS could not appear on the certificate of a company with a "continuous" approval because it is not a recognized accreditation scheme by UKAS (or RVA, etc.). RAB is the only accreditation that could appear. To be "legal".

A "continuous" approval means that in addition to surveillance activities, there is a complete re-assessment of 1/6 of the system performed at the visit. The paperwork for that visit must then be reviewed by a technical authority at the registrar's office in order to grant continued certification. At the end of the three year period, it is deemed to have had all elements completely re-assessed- in ADDITION to the surveillance activities. And thus the certificate could be re-issued.

The amount of time for surveillance plus re-assessment is the same whether you have simply surveillance and then re-assessment at the end of the three years, or if you build that re-assessment time into the three years on the up-front. So 5 days surveillance plus a 3 day reassessment at the end of three years is 8 days, right? For a continuous surveillance approval those 8 days are supposed to be divided into the 6 visits. Same amount of time. I have witnessed in very very small companies a one day or so savings - only because their recert would have only been one day anyway. Otherwise, no time savings at all.

A continuous approval is a rip-off in the first three years of a certification. This is because you end up doing an indepth reaudit of the same areas you just did an indepth audit of just 6 months ago, or a year ago, etc. After the initial three years, it pretty much evens out.

IAF hasn't changed. I've been out of the biz for 2 years but this is the same thing we abided by for the four years I was there. What might have changed is that your registrar is cleaning up its act. They may have issued UKAS accreditated certs under a continous scheme by error. Or what might have changed is that RAB has decided to make peace with the rest of the group.

Don't be alarmed to move to a traditional scheme. You should see a reduction in your surveillance time to account for the time they will spend on your reassessment. And you won't be paying for your next accreditation "in advance"! Think about it: not only were you paying for the surveillance needed to retain your current certification, you were also paying on the upfront for the reassessment to qualify for the next three year's worth of certification also!

I'll be happy to expand my comments if anyone has any questions.

Lucinda - thanks for the explanation. I see many of your points, although, like you said, it evens out after the initial 3 years. A couple of IMO points: I know of certificates done with rolling certifications that had RvA on them, so I don't think it was just RAB that broke away. After all, guide 62 is a guide. I think that means that an organization may or may not use it completely. Secondly, although I see your point about why would you go indepth on something during a surveillance that was just done at the registration audit, a surveillance audit allows to go into more detail. A registration audit does not allow for the same depth that a surveillance audit does. I still think the rolling certification is the best deal.

Roger,

I was informed that only RAB broke from the group. And there was a good deal of angst over whether or not a cert for a continuous approval that carried RAB accreditation could also feature another accreditation on it, seeing as how the approval could not possibly be granted under the other accreditation body's accepted schemes. To be on the safe side and play absolutely straight, any client requiring/requesting continuous approval was moved to RAB-only accreditation on the certificate. I can't speak for what any other registrar did in displaying accreditation on a certificate. I do believe that they would have to have been in error to use anything other than RAB according to my understanding of the situation.

There could be one other explanation: is it possible that the cert was for QS9000? QS was a continuous approval regardless of the accreditation - again, my basic understanding and subject to error. I have no idea of why the exception was made.

I didn't care for the continuous approvals and never saw the benefit. To me it was hard to see how an assessor could adequately draw a distinction between the surveillance activities and the re-assessment activities during the visit. And of course it was a headache to administer in the office too. We did enjoy getting more money upfront (sitting in the bank drawing interest), which was supposed to make up for the inconvenience.

Do not know much about guide 62. The one I have shows an issue date of Dec 4,01 and an application date of July 1,02. According to my letter, registrars were required to audit all elements within a three year period and if that was done no reassessment was required,continuous as you said.
Now this is where I may be getting confused. I have a table that gives guidance (IAF) on the number of days based on company size for auditor days for assessment,surveillance and reassessment. For our plant size it is 3 days for sur. and 6 days for the reassess. At present we do 2 days every 6 months. So, according to the letter and the table, we will get 4 days per year and at the end of 3 years we would get an 8 day audit?? Of course the registrar has some flexability with this. Just received an e-mail from our registrar, will be talking with them tomorrow. I will post the results.

From NSF:

"It is necessary for all accredited registrars to conform to the requirements of ISO/IEC Guide 62 for Quality Management Systems (QMS) and ISO/IEC Guide 66 for Environmental Management Systems (EMS) registration. Recent IAF Guidance to Guide 62 and the IAF Guidance to Guide 66,which became effective July of 2002, require registrars to conduct a reassessment audit three years after the initial registration regardless of the surveillance interval ” (emphasis is theirs, not mine)

So you have it:

I'm getting old and memory isn't what it used to be, but I recall that the RAB guidance on days for visits closely followed the IAF guide and we could only vary from the days by 10%. Any more and we would have to provide written justification to RAB on why the variance was made. Not as much flexibility as you might imagine. Multi-site registrations were particularly fun to quote - you had to determine whether the activities at each site were "substantially similar" and then the additional sites could be given a time break, etc. and if you had a really large account with design at some places, manufacture of various things at others, it was quite a challenge to get it all right.

For re-assessments, a typical re-assessement is from one-half to possibly two-thirds of your initial assessment time. Depends on the growth of your org and if the scope has changed, etc. also the history of your certification and if there have been numerous issues over the certification period. I can't see where an 8 day reassessment would EVER be the case for a company that has 2 day surveillances!! More likely the 8 days reflects an initial assessment duration that includes 1 day for doc review. And then reassessment would be more in the neighborhood of 4 days.

But if you should have been having 3 day surveillances instead of 2, then someone messed up somehow.... Still shouldn't affect your reassessment time. MHO only.

db said:

From NSF:

"It is necessary for all accredited registrars to conform to the requirements of ISO/IEC Guide 62 for Quality Management Systems (QMS) and ISO/IEC Guide 66 for Environmental Management Systems (EMS) registration. Recent IAF Guidance to Guide 62 and the IAF Guidance to Guide 66,which became effective July of 2002, require registrars to conduct a reassessment audit three years after the initial registration {I} regardless of the surveillance interval {/I]” (emphasis is theirs, not mine)

So you have it:

Dave,

Exactly. I sure would like to see Sidney post something because he's still in the biz and can help my memory out.

As I posted before, IAF always rejected continous surveillance. Guide 62 was interpreted by IAF to mean that a reassessment must be done in a single visit. All accreditation bodies with the exception of RAB, agreed to follow that guidance. RAB said that it could be done by breaking it out over multiple visits and refused to follow the IAF guidance on this point.

Then there was discussion over whether a continuous approval could have annual surveillances vs. the traditional 6 monthly visits. Some people thought yes, some thought no. I don't want to go into all the reasonings but it was a matter of debate, certainly within our organization anyway, for a time.

It looks like the new guidance (which I have not seen) is trying to clear up some of the issues. That can only be a good thing. In order for registrars and accreditation bodies to play on a level field, they should all be using the same rules.

I'm glad this subject was raised to bring us current on what's happening out there.

Question:

QS-9000 has Appendix H, which is the table that delineates the number of audit days required for initial registration and surveillance audits according to number of associates at a facility. Where is this defined for TS:2002?

In the "automotive certification scheme" manual available from AIAG.

Just got off the phone with the registrar. This applies to ISO only. At the last surveillance audit there will be a reassessment audit. E.G. if your surveillance is 3 auditor days a year the last surveillance of the 3 year period will be 6. Increase your budget for audits!!!

See attached the letter that the RAB sent to all ANSI-RAB accredited EMS/QMS Registrars.
The requirement is compulsory. However, as we all know some registrars are more disciplined than others in following the rules.

This letter addresses other topics, as well. The reassessment audit is supposed to be 2/3 of the certification audit duration.

Thank you Sidney. That RAB letter is pretty clear.

Has anyone heard whether the merger of the RAB (now the RABQSA) will induce any changes?