STANDARDS INTERPRETATION REQUEST
Section: 3.1

REQUEST:

Does Environmental Sampling include sampling at water and wastewater plants?

TNI FINAL RESPONSE:

3.1 Environmental Sampling: Equivalent to "Field Sampling." See Clause 3.5.

3.2 Field: Any location outside the controlled environment of a laboratory.

3.5 Field Sampling: The process of obtaining a representative portion of an environmental matrix suitable for laboratory or field measurement or analysis.

In the definitions of the terms "Environmental Sampling" (3.1) and "Field Sampling", the operative term is "Field". In Clause 3.2 "Field" is defined as distinct from the "controlled" laboratory environment. It follows that the sampling sites for waste and drinking water treatment plants would be outside of a controlled environment so the answer to the question is "yes".

If the FSMO seeks accreditation to the TNI FSMO Volume 1 standard then the requirements in this standard apply.

STANDARDS INTERPRETATION REQUEST
Section: 6.1.1.1

REQUEST:

In regards to the 8/10 meeting minutes the requirement reads that the application must be completed within 9 months. This is in direct violation of ISO/IEC 17011. An application for accreditation is completed when accreditation is granted and it take at times 12 months to get accredited even without undue delays caused by the AB and/or the CAB (FSMO). An AB is required to have a policy in place to handle delays with assessments and make a judgment based upon action and/or non-action of the CAB. I do not read the requirement any other way. Section 6.1.1.1 states "... [an AB must] complete action on an application within nine (9) months from the time a completed application is first received from the FSMO. This time period shall not apply if delays are caused by the FSMO responses to the accreditation process, on-site assessment or proficiency testing requirements beyond the required time limits set forth in this standard."

The second sentence which ties back to the first sentence talks about the entire accreditation process therefore this requirement means that from the time the application is received the FSMO must be accredited within 9 months unless delays are caused by the FSMO. As I already mentioned, it can take up to 12 months if not longer especially if follow-up visits are necessary to accredit a CAB and neither the AB or the CAB is causing any delays.

TNI FINAL RESPONSE:

Section 6.1.1.1 and the reference to 9 months are additions to ISO/IEC 17011 language and provide a timeline for the completed process of the application and not accreditation. This is not in violation of ISO/IEC 17011 which identifies having sufficient competent personnel available. These are two different issues (completing action on an application versus completing accreditation). Accreditation may take longer.

STANDARDS INTERPRETATION REQUEST
Section: 7.11.3 Note

REQUEST:

Is there a requirement for an accreditation body to establish a 2 year cycle to re-accredit the FSMO. Are the options in ISO/IEC 17011 7.11.3 b) available for the accreditation body?

TNI FINAL RESPONSE:

Volume 2 Section 7.11.3 does establish a requirement for a two year cycle for re-qualification if the accreditation is based on reassessments alone.

The word "typically", in the note section of 7.11.3 in Volume 2, is used instead of "shall" or "must" and is thus not considered a requirement.

STANDARDS INTERPRETATION REQUEST
Section: C7.9.2.1.4b

REQUEST:

This clause restricts the AB from imposing additional fees. Suspensions often require follow-up assessments resulting in the FSMO incurring additional costs for assessor time and travel.

I suggest that clarification be provided on the term fees, application fees not assessment costs or remove the phrase (and pay any fees).

TNI FINAL RESPONSE:

(Field Activities Committee / NEFAP Executive Committee, 11-11-10)

The clause in the above referenced section was intended to prevent accreditation bodies from assessing FSMO applicants with an additional application fee in cases where they were seeking re-instatement within six months of a suspension. It was not intended to prevent accreditation bodies from assessing fees for services rendered to the FSMO to verify that the FSMO now meets the requirements of the standard.