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Clarification on Clauses 5.2, 5.3, 6.4, and 6.6 of ISO 14065

PUBLIC NOTICE GHG-NT-712 Issued: 2014-7-23, Revision: 0

References IAF MD 12:2013, Assessment of Certification Activities for Cross Frontier Accreditation
IAF MD 14:2014, Application of ISO/IEC 17011 in Greenhouse Gas Validation and Verification (ISO 14065:2013)
IAF MD 6:2014, Application of ISO 14065:2013
ISO 14065:2013, Greenhouse gases - Requirements for greenhouse gas validation and verification bodies for use in accreditation or other forms of recognition
PAC-TECH-004, PAC Mandatory Document - Application of ISO/IEC 17011 in Greenhouse Gas Validation and Verification on Application of ISO 14065
1.1The objective of this notice is to provide clarification on ANSI assessment of a V/VB’s conformance to ISO 14065, clauses 5.2, 5.3, 6.4, and 6.6.
2.1Critical locations: physical locations of the accredited validation/verification body (V/VB), whatever the composition (office, person, etc.) or legal relationship (outsourced body) of such location with the V/VB, where key activities are carried out.
2.2GVAC: Greenhouse Gas Validation/Verification Body Accreditation Committee
2.3Key activities: the following activities are considered key activities for validation/verification:
2.3.1formulation and adoption of policy,
2.3.2development and adoption of processes and procedures,
2.3.3initial selection, training and qualification of validation and verification personnel (including contracted personnel), and ongoing monitoring,
2.3.4review of orders and contracts, including the technical review of validation and verification requests and determining the technical requirements for validation or verification in new technical areas and/or GHG programs,
2.3.5assignment of validation and verification teams,
2.3.6management of periodic verification,
2.3.7review and issuance of validation and verification reports and statements, and
2.3.8final decision on appeals and complaints.
2.4Technical expert: person who provides specific knowledge or expertise to the validation or verification team.
2.5Validation body: body that performs validation of GHG assertions in accordance with ISO 14064-3 and ISO 14065.
2.6Validator: competent and independent person or persons with responsibility for performing and reporting on the results of a validation.
2.7Verification body: body that performs verifications of GHG assertions in accordance with ISO 14064-3 and ISO 14065.
2.8Verifier: competent and independent person or persons with responsibility for performing and reporting on the verification process.
3Effective Date
3.1July 25, 2014
4.1Legal entity
4.1.1ANSI is providing clarification on how it shall assess a validation or verification body (V/VB’s) conformance to ISO 14065 requirements regarding the legal status of the accredited entity, contracted individuals, and outsourcing of validation/verification functions to other legal entities.
4.1.2The V/VB is required to be a legal entity, or part of a legal entity such that it can be held responsible for its actions and decisions.
4.1.3In the case where the V/VB is part of a larger legal entity (e.g. a department or division within a larger company), the V/VB may use resources from other parts of the larger legal entity (e.g. IT support, HR functions, accounting). In such a case the accreditation shall be issued to the legal entity and the boundaries of the V/VB shall be defined (e.g., “XXX, a division of YYY”, where YYY is the parent company and XXX is the identifier of the department, division, etc. that encompasses the V/VB organization). In such a case, the functions and support provided by the larger legal entity are auditable by ANSI. Note that the V/VB must be part of the same legal entity and not separately incorporated.
4.1.4Where the V/VB is a legal entity owned by a separately incorporated parent company which owns other subsidiaries which are separate legal entities and the V/VB intends to use resources or support services from any of these separate legal entities, the V/VB shall have a legal vehicle in place (contract, memorandum of understanding, or similar legal agreement) with each legal entity(ies) that the V/VB intends to use. The legal vehicle(s) must be approved by individuals from the V/VB and the entity(ies) who are authorized to make legal commitments for the entity(ies). Typically this is defined in bylaws or articles of incorporation or similar documents describing the corporate structure for the legal entities. All activities outsourced to contracted legal entities shall be subject to the requirements of ISO 14065, section 6.6, Outsourcing. In addition, contracted legal entities shall be included in conflict of interest evaluation as a related body. If outsourced entities undertake key activities on behalf of the accredited legal entity, such sites shall be determined to be critical locations by ANSI and are thereby subject to audit by ANSI. Note, this section does not apply to contracted individuals which are addressed in section 4.3 below.
4.2.1Responsibility for any activities under the V/VB’s management system that are designated as the responsibility of a contracted entity shall be determined outsourcing . This includes but is not limited to document control, where the V/VB assigns responsibility to a contracted organization to maintain current copies of GHG program criteria, allows the contracted organization to use its own forms as working documents, IT support for document and record maintenance and control and software support, issuing contracts for V/VB activities for the V/VB, scheduling and conducting V/VB activities, and similar activities where responsibility is delegated to the outsourced organization.
4.3.1The accredited legal entity may contract external individuals (validators, verifiers, technical experts) as stated in ISO 14065, clause 6.4. However, in such cases the following shall apply: V/VB must have a legal agreement in place with the individual, V/VB shall maintain records of these external contracted individuals and provide a list of these individuals to ANSI upon request, V/VB shall ensure that the external contracted individuals meet the competency requirements of the accredited V/VB, V/VB agreement with the external contracted individual shall require the individual to comply with the V/VBs policies and procedures, and V/VB agreement shall address confidentiality and independence from commercial and other interests and require that the individuals notify the V/VB of existing or prior association with any company or project they may be assigned to.
4.3.2A V/VB that chooses not to contract with individuals may have a contract in place with another legal entity for provision of specific personnel to support validation or verification activities. The agreement shall specifically name those personnel or allow the other entity to provide CVs for the V/VB to select individuals, and define appropriate terms and conditions (see above), provided the V/VB is responsible for demonstrating and maintaining records of the individual competencies. In such a case this would be considered contracting under ISO 14065, clause 6.4 . In this case, the legal entity where the contracted individuals are employed shall be included in conflict of interest evaluation as a related body.
4.4.1Key activities that are delegated by a V/VB to non-declared locations without providing notice to ANSI shall result in a notice of nonconformity, notice to the GVAC , and shall be subject to suspension.
4.4.2Outsourcing of the full validation/verification activity shall not be allowed under ANSI accreditation. The final validation and verification decision and legal liability shall remain with the accredited entity.

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