Subcontracting Inspections and Tests - ISO 17020:1998 clause 14.2

[amanbhai]

Though we subcontract certain inspections & tests related to inspections but don't like to mention that to our customers (our company policy). All we say is that we don't have the capability to do the tests so we have may have to subcontract that one. We do not specify any subcontractor nor we take any approval from the customer.
How do we address this particular clause of ISO 17020:1998 clause 14.2

 

[Hershal]

The Clause specifically states "The sub-contractor shall be acceptable to the client." so there are several ways to address the requirement. The one that seems to be directed here is to inform your customer of the sub, but alternate approaches such as finding out if the customer specifically does NOT want any organization(s) to sub for you is another approach. There are many ways possible to fulfill this requirement, but make sure you document any acceptance or challenge to the subs that you may use, as you can rest assured the accrediting body will want to see evidence of compliance.

 

[amanbhai]

We have an internal audit CAR regarding subcontracting register. Again we do subcontracting but don't mention it to our customers. Also, in some cases we do not have the capability to judge the subcontracted jobs. What do we do?
Any help is appriciated.

 

[DietCokeofEvil]

What do you mean that you don't have the capability to judge subcontracted jobs? I'm not understanding that.

Any subcontracter you use either has to be 17025 accredited or shown to be the only source for a specific service, even if they are not accredited. (E.G. the manufacturer of some of our equipment calibrates and services our machines every year because its proprietary- but they aren't accredited).

17025 states that the customer has be be informed of any subcontracting. To me, its straightforward- if you can't do the job and you need to send it out, the customer has to be informed first. Part of this is liability. Part of it is giving the customer a chance to deny the service. I had a customer who denied a subcontract- we had to send her fixtures out for rework and only one place could do it- and she wouldn't do business with them.

JMO

 

[Hershal]

For a sub-contractor for inspection, the sub must be able to support an organization's ISO/IEC 17020 accreditation.....and the evaluation of an inspection sub is radically different than a lab sub.....so this means potentially field observations and related activities.....but this MUST be done in order to establish the competence of the sub.....or the AB may and should investigate the sub-contracting.....

 

[siawo]

We are an inspection company going for ISO/IEC 17020:1998, previously we are ISO 9001 certified for last 10 years. We have problem dealing with Clause 14.2 Subcontracting. Usually we do not subcontract, but for one of the specialized service we do subcontract, after getting approval from client. I would like to know the procedure for the same as following:

"If we hire the services of a person (not a company) for specialized services for execution of a part of inspection contract, Shall we describe it in subcontracting clause. If yes, What is the procedure for that."​

 

[Hershal]

Yes, it must be described in your sub-contracting caluse in your manual. Additionally, the sub-contractor must be acceptable to the client.

The specific procedures need to describe how you actually do the sub-contracting.

Hope this helps.

 

[amanbhai]

We are an inspection company going for ISO/IEC 17020:1998, previously we are ISO 9001 certified for last 10 years. We have problem dealing with Clause 14.2 Subcontracting. Usually we do not subcontract, but for one of the specialized service we do subcontract, after getting approval from client. I would like to know the procedure for the same as following:

"If we hire the services of a person (not a company) for specialized services for execution of a part of inspection contract, Shall we describe it in subcontracting clause. If yes, What is the procedure for that."​

As long as my knowldge is concerned free lancers are not subcontractors! correct me if i am wrong. thanks.

 

[Hershal]

As long as my knowldge is concerned free lancers are not subcontractors! correct me if i am wrong. thanks.

You are correct, and this is how.

Under the accepted interpretations of ISO/IEC 17020 and also under ILAC/IAF A4, an individual is not considered a sub-contractor. However, a company is.

There may be some interpretive room if the individual has his own company and is the sole employee, but the generally accepted interpretation there would still be that it is sub-contracting.

Hope this helps.

 

[zamclachia]

For me 17025 is very clear - The customer must be informed of any subcontracted work. If you are not informing the client I believe you are misrepresenting yourself. By not informing the customer, do you not open a can of worms should a legal challenge to 'your' submitted results arise?