Date: Tue, 6 Apr 1999 15:33:36 -0400
From: "Peter S. Unger"
To: 'Greg Gogates'
Subject: RE: Thinking caps required!
Cindy Lawson raises an interesting issue which some in-company labs face (i.e., the use of facilities by personnel outside of the control of lab management).
The scope of a lab's desired accreditation plays an important part in answering this question. How an accreditor would assess this type of lab situation would depend on whether the R&D engineers were performing tests for which accreditation is desired. If the tests done by the R&D engineers (they are just borrowing the lab's equipment and facilities) are outside the scope of the lab's desired accreditation, then the accreditation body would only concern themselves with how the lab maintains effective control and integrity of those facilities and equipment used for accredited tests that might also be affected by the R&D intervention. Accreditation bodies would also want to be assured that R&D engineers are not issuing reports and misrepresenting them as coming from an accredited laboratory.
On the other hand, if the R&D engineers were taking part in carrying out accredited tests, they would have to demonstrate relevant Guide 25 compliance and competence to carry out those tests, just as if they were full-time lab staff. In addition, the lab's organization structure and quality system controls would be examined to see how these "subcontractors" (the R&D engineers) were trained and supervised to ensure reliable performance.
Peter Unger
A2LA President
5301 Buckeystown Pike
Frederick, MD 21704-8373
From: "Peter S. Unger"
To: 'Greg Gogates'
Subject: RE: Thinking caps required!
Cindy Lawson raises an interesting issue which some in-company labs face (i.e., the use of facilities by personnel outside of the control of lab management).
The scope of a lab's desired accreditation plays an important part in answering this question. How an accreditor would assess this type of lab situation would depend on whether the R&D engineers were performing tests for which accreditation is desired. If the tests done by the R&D engineers (they are just borrowing the lab's equipment and facilities) are outside the scope of the lab's desired accreditation, then the accreditation body would only concern themselves with how the lab maintains effective control and integrity of those facilities and equipment used for accredited tests that might also be affected by the R&D intervention. Accreditation bodies would also want to be assured that R&D engineers are not issuing reports and misrepresenting them as coming from an accredited laboratory.
On the other hand, if the R&D engineers were taking part in carrying out accredited tests, they would have to demonstrate relevant Guide 25 compliance and competence to carry out those tests, just as if they were full-time lab staff. In addition, the lab's organization structure and quality system controls would be examined to see how these "subcontractors" (the R&D engineers) were trained and supervised to ensure reliable performance.
Peter Unger
A2LA President
5301 Buckeystown Pike
Frederick, MD 21704-8373