I looked in my "draft" version of ISO 17025, and in 4.1.4 j., NOTE 3 it said that "..in laboratories with a small number of personnel, individuals may have more than one function and it may be impractical to appoint deputies for every function."
I am not a 17025 expert. But it doesn't appear to be an issue. There are probably many companies out there with one man labs (I have run a few of them over the years). And even in mid-size labs, there aren't always enough people around to have a separate person fill each job title.
I think one of the key issues is that there shouldn't be conflicts of interest. You may need to be sure and have an auditor from another area (if you have dedicated QA auditors in a QA dept or equivalent) audit the lab periodically. That would be the external person to assure conformance.
In 4.13.1, it says, "...audits shall be carried out by trained and qualified personnel who are, wherever resources permit, independent of the activity being audited."
The part about "...wherever resources permit..." is the allowance for smaller operations, who don't have resources for separate personnel to be able to audit themselves. The hard line philosophy seems to me to have come from the MIL-STD days when DCAS was really hard lined about believing all contractors were out to steal from the government (some of them were).
But I think times have changed in that it is expected that people have integrity, and we should reasonably guardband when it makes sense. But not in all cases does it actually make sense.
So my layman's take on this is that it is acceptable to wear multiple hats within the lab. The un-acceptable course would be that the lab can't be run by production departments, marketing, finance, or other departments who would have a potential conflict of interest (i.e.: production needs to get product out the door, finance has to keep costs as low as possible, etc.).
Hope this is of some help.
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I am not a 17025 expert. But it doesn't appear to be an issue. There are probably many companies out there with one man labs (I have run a few of them over the years). And even in mid-size labs, there aren't always enough people around to have a separate person fill each job title.
I think one of the key issues is that there shouldn't be conflicts of interest. You may need to be sure and have an auditor from another area (if you have dedicated QA auditors in a QA dept or equivalent) audit the lab periodically. That would be the external person to assure conformance.
In 4.13.1, it says, "...audits shall be carried out by trained and qualified personnel who are, wherever resources permit, independent of the activity being audited."
The part about "...wherever resources permit..." is the allowance for smaller operations, who don't have resources for separate personnel to be able to audit themselves. The hard line philosophy seems to me to have come from the MIL-STD days when DCAS was really hard lined about believing all contractors were out to steal from the government (some of them were).
But I think times have changed in that it is expected that people have integrity, and we should reasonably guardband when it makes sense. But not in all cases does it actually make sense.
So my layman's take on this is that it is acceptable to wear multiple hats within the lab. The un-acceptable course would be that the lab can't be run by production departments, marketing, finance, or other departments who would have a potential conflict of interest (i.e.: production needs to get product out the door, finance has to keep costs as low as possible, etc.).
Hope this is of some help.
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