Sub-contracting by ExTLs Ian Cleare Convenor ExMC/WG2 – TGDs, IECEx Lead Assessor ExTAG meeting Buxton 4 October 2005

Questions arising from IECEx assessments of ExTLs Which of the tests in a standard should an ExTL be allowed to sub-contract* and still keep the standard within its accepted scope? Under what conditions should an ExTL be allowed to sub-contract* tests? * Note: “sub-contracting” in this context relates to tests for which the ExTL has no facilities. It excludes arrangements to augment the ExTL’s capacity (e.g. facility is overloaded or temporarily out of commission) and also excludes tests carried out at manufacturers’ premises under ExTL control.

Points to consider Should the term be “sub-contracting” or “contracting”? 17025 and Guide 65 use “sub-contracting” Outsourcing is a growing trend IECEx needs to adapt without endangering confidence ExTLs work under the control of ExCBs ExCBs have a responsibility where work is sub-contracted by ExTLs

ISO/IEC conformity assessment vocabulary ISO/IEC 17000:2004 defines the conformity assessment process as: Selection * Determination (= “evaluation” in Guide 65) Review and attestation* * functions carried out by ExCB

Responsibilities of ExTL Carry out work specified by ExCB Advise client (ExCB) if work is to be sub-contracted Ensure sub-contractor meets IECEx requirements (including 17025) Maintain records of sub-contracted work Provide test report and definitive product documentation to ExCB

Responsibilities of ExCB Ensure that ExTL meets IECEx requirements (including 17025) Exercise suitable control over sub-contracting by ExTL

Responsibilities of IECEx Ensure that ExCBs and ExTLs meet the IECEx requirements Maintain confidence in the work of accepted bodies

Which tests might be sub-contracted? Tests central to the type of protection e.g. explosion testing for Ex ‘d’ Tests requiring expensive and/or rarely used equipment (“uneconomic”) e.g. on-load testing of large Ex ‘e’ motors Tests which are peripheral to the type of protection e.g. CTI testing of non-metallic materials

Implications of sub-contracting If an ExTL sub-contracts the “central” tests: Does it have sufficient knowledge to assess and control the sub-contractor? Can it define tests and interpret results? How do staff maintain competence? How much can the ExTL rely on accreditation or IECEx acceptance of sub-contractor?

Possibilities for sub-contracting Do not permit any sub-contracting Allow “peripheral” tests to be sub-contracted Allow “uneconomic” tests to be sub-contracted Allow “main” tests to be sub-contracted Declare sub-contracted tests as excluded from ExTL’s accepted scope Require sub-contracting by ExCB not ExTL.

Recommendations Allow “peripheral” tests to be sub-contracted Allow “uneconomic” tests to be witnessed using others’ facilities Allow “main” tests to be sub-contracted provided that the tests are declared as exclusions in the ExTL’s accepted scope

Further considerations How to determine which tests are “central”, “uneconomic” and “peripheral” Where to record the IECEx decision on these terms What conditions need to be specified with regards to sub-contracting Linkage to related issues: Acceptance of results for tests carried out at manufacturers’ premises Acceptance of data from material and component suppliers

Thank you