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

2. 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.

3. 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

4. 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

5. 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

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

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

8. 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

9. 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?

10. 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.

11. 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

12. 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

13. Thank you