DEPARTMENT OF EMPLOYMENT AND LABOUR

TR 83-05

DEPARTMENT OF EMPLOYMENT AND LABOUR AND SANAS

TECHNICAL REQUIREMENTS FOR THE APPLICATION OF
SANS/ISO/IEC 17020:2012 IN THE REGULATORY
ASSESSMENT OF PRESSURE EQUIPMENT
INSPECTION BODIES

Note: This document is NOT applicable to Gas Test Stations as per Pressure
Equipment Regulations (PER) R 743 of 2009, regulations 18 and 19

Approved By: Executive – Accreditation: Mpho Phaloane

Proposed By: Accreditation Manager: Linda Grundlingh
Revised By: Specialist Technical Committee
Date of Approval: 2021-07-13
Date of Implementation: 2021-07-13

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CONTENTS:

0. Introduction ............................................................................................................ 3
1. Scope .................................................................................................................... 4
2. Normative References ........................................................................................... 4
3. Terms and Definitions ............................................................................................ 4
4. General Requirements........................................................................................... 5
5. Structural Requirements ........................................................................................ 6
6. Resources ............................................................................................................. 7
7. Process requirements .......................................................................................... 12
8. Management system requirements ...................................................................... 14
9. List of Approved Inspection Authorities ................................................................ 20

APPENDIX 1: Scope of Accreditation..................................................................... 21

ANNEXURE B – In-Service Inspection.......................................................................... 22
ADDENDUM 1: Amendment Record ............................................................................ 23

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0. Introduction

General requirements for Inspection Bodies specialising in the periodic inspection and investigations of
Pressure Equipment in South Africa is laid down in the National Standard SANS 10227, the Occupational
Health and Safety Act (Act 85 of 1993), the Pressure Equipment Regulations (PER), excluding regulations
18 and 19, and the international standard ISO/IEC 17020. These requirements are comprehensive and
detailed but explanations provided in this document may be helpful to ensure consistent application of the
Standard(s) and Regulation.

The structure of this document reflects that of the standard ISO/IEC 17020 including titles of clauses and
their numbering. To facilitate future reference to the explanations the paragraphs of this document are
consecutively numbered within each commented sub-clause.

The interpretative notes are intended neither to add to nor subtract from the requirements of ISO/IEC 17020.
They are intended to clarify the requirements to assist Inspection Bodies in practically implementing the
standard ISO/IEC 17020 and to minimise differences of interpretation. This document should be read in
conjunction with the standard ISO/IEC 17020.

The term "shall" is used throughout this document to indicate those provisions, which, reflecting the
requirements of ISO/IEC17020, are mandatory. The term "should" is used to indicate those provisions,
which, although they constitute interpretation of the application of the requirements, is expected to be
adopted by all Inspection Bodies. Any variation from the guidance by an Inspection Body shall be an
exception. Such variations will only be permitted on a case-by-case basis after the Inspection Body has
demonstrated to SANAS that the exception meets the requirements of the relevant clause of ISO/IEC 17020
and the intent of this document in some equivalent way.

Note: The terms Manufacturing and In-Service AIA and Inspection Body are considered synonymous
throughout this document.

In case of dispute concerning application of this document, Department of Employment and Labour and
SANAS will adjudicate on unresolved matters.

It is intended that after a certain period of use, the content of this document will be revised.

Copyright

The copyright of this text is held by SANAS / Department of Employment and Labour. The text may not be
copied for resale.

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1. Scope

1 n1 Inspection activities can overlap with testing and certification activities where these activities
have common characteristics. Testing performed by an Inspection Body may fall in two (2)
categories namely functional and analytical. Functional testing is within the scope of ISO/IEC
17020. Analytical testing, for example air or metallurgical analysis, is a Laboratory activity and
therefore does not fall within the scope of ISO/IEC 17020. Inspection Bodies wishing to
undertake such laboratory type analytical testing as part of an inspection will need to do so in
accordance with the relevant requirements in ISO/IEC 17025.

1 n2 If accredited Inspection Body decisions are reliant upon analytical test results or the results of
any sub-contracted specialist service, these tests or services shall, where possible, be carried
out by appropriately accredited bodies/laboratories. To ensure traceability to
national/international standards (physical standards), such bodies/laboratories shall be
accredited by an accreditation body which is a signatory to the ILAC Multilateral Arrangement
(MLA).

2. Normative References

The following referenced documents are indispensable for the application of this document. For dated
references, only the edition cited applies. For undated references, the latest edition of the referenced
document (including any amendments) applies.

2.1 2.4 No. R. 734 - Pressure Equipment Regulations, 2009

2.2 No. R. 79 - Pressure Equipment Regulations Guidance notes, 2012
2.3 ISO/IEC 17000, Conformity assessment — Vocabulary and general principles
2.4 ILAC-G27:07/2019 – Guidance on measurements performed as part of an inspection process.
2.4 ILAC-G28:07/2018 – Guideline for the Formulation of Scopes of Accreditation for Inspection
Bodies.

3. Terms and Definitions

For the purposes of this document the terms and definitions given in ISO/IEC 17000 and ISO/IEC
17020 apply.

3.1 Inspection

3.1 n1 The term “installation” may be defined as “a collection of components assembled to

jointly achieve a purpose not achievable by the components separately”.

3.1 n2 Throughout these interpretative notes the word “product” should be understood to
include the words “product design”, “service”, “process” and “plant” as specified in
clause 3.1 of the standard.

3.1 n3 In recognition of the wide range of industries represented by Inspection Bodies’

alternative terminology could be used for what is inspected.

3.1 n4 For professional judgment to be exercised the staff member responsible for the PER
Inspection Body, referred to in Clause 6.1, shall personally perform the Pressure
Equipment Inspections or effectively supervise the Pressure Equipment Inspection
Body.

3.2 Pressure Equipment Inspection Bodies

A Pressure Equipment Inspection Body is a legal entity approved by the Regulator’s Chief
Inspector. The Pressure Equipment Inspection Body is accredited by SANAS in respect of the

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competence of its personnel, equipment, procedures and environment, in accordance with the
requirements of ISO/IEC 17020 and any additional requirements that might be determined by the
Chief Inspector of Occupational Health and Safety from time to time.

3.2 n1 A Pressure Equipment Inspection Body may consist of one (1) person provided the
requirements of all relevant clauses of ISO/IEC 17020 and SANS 10227 are fulfilled.
An Pressure Equipment Inspection Body can be an organisation, or part of an
organisation.

4. General Requirements

4.1 Impartiality and independence

ISO/IEC 17020 places the highest importance on preventing the undue influencing of inspection
activities. (4.1.2) requires that commercial, financial and other pressures do not compromise
impartiality, and recognises that personal and organisational relationships (4.1.3) potentially
compromise impartiality and may need controls (4.1.4) to maintain impartiality.
Finally, it considers independence and classifies bodies into Independence Types A, B and C to
signal the nature of the relationships between inspection body and the items inspected.
Annex 2 provides additional guidance.

4.1.3 n1 “on an ongoing basis” means that the inspection body identifies a risk whenever events
occur which might have a bearing on the impartiality of the inspection body.

4.1.3 n2 The inspection body shall describe any of its relationships or its personnel that could
affect its impartiality, to the extent relevant, using organisational diagrams or other
means.

4.1.3 n3 Annex 1 gives an example of a Possible format for impartiality risk analysis.

4.1.4 n1 Threats and inducements aimed at inspectors or other inspection body personnel may
represent serious risks to impartiality. Threats and inducements may originate from
inside or outside the inspection body and may happen at any time. The inspection body
should record perceived and explicit risks to impartiality of inspections. All personnel
working on behalf of the inspection body, should be aware of aware of the responsibility
to act impartially, be involved accordingly in the inspection body’s impartiality measures
and have appropriate access to provide records as issues arise. The Inspection body’s
analysis of risks to impartiality should include details of the inspection body’s responses
to such threats.

4.1.5 n1 The inspection body shall have a documented statement emphasising its commitment
to impartiality in carrying out its inspection activities, managing conflicts of interest and
ensuring the objectivity of its inspection activities. Actions emanating from the top
management shall not contradict this statement.

4.1.5 n2 One way for the top management to emphasise its commitment to impartiality is to
make relevant statements and policies publicly available.

4.1.6 n1 An inspection body may have different types of independence (Type A, B or C) for
different inspection activities listed on the scope of accreditation. However, it is not
possible for an Inspection Body to offer different independence types for the same
inspection activity.

4.1.6 n2 Complying with the Type A independence requirements A.1b and A.1.c is binary (yes or
no) meaning that partly complying with Type A independence requirements is not
possible. This also means that a risk analysis resulting in control measures to minimize
the impartiality risks of a situation where there is no compliance with these Type A
requirements is not possible. Hence, only elimination of the situation that is not
compliant with these Type A requirements is possible.

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4.2. Confidentiality

No interpretations of the requirements of ISO/IEC 17020 are required for this clause.

5. Structural Requirements

5.1. Administrative Requirements

5.1.1 n1 The Inspection Body should be a registered juristic person (corporate body). Company
name, address, names of directors, contact numbers and registration number shall be
made available.
No applications from “Sole Proprietors” shall be accepted for accreditation, since a sole
proprietor is not a legal entity, see SANS 10227.

5.1.1 n2 Approval is granted by the Department of Employment and Labour. While accreditation
is a prerequisite for approval, the possession of such accreditation does not imply an
assurance that approval will be granted. The Department may set additional conditions
before approval is granted.

5.1.1 n3 Upon obtaining accreditation and subsequently approval, a certificate that contains the
name, location of the Inspection Bodies, the name of the responsible person (however
named) and approved signatories, and the type (scope) shall be issued. The certificate
of approval issued by the Department, and certificate of accreditation from SANAS shall
be prominently displayed at all times.

5.1.3 n1 The inspection body shall describe its activities by defining the general field and range
of inspection (e.g. categories/sub-categories of products, processes, services or
installations) and the stage of inspection, (see note to clause 1 of the standard) and,
where applicable, the regulations, standards or specifications containing the
requirements against which the inspection will be performed. ILAC G28 gives guidance
for the Formulation of Scopes of Accreditation for Inspection Bodies.

5.1.4 n1 The level of provisions should be commensurate with the level and nature of liabilities
that may arise from the inspection body’s operations.

5.1.4 n2 An assessment of ‘adequacy’ may be based on evidence of agreement between the

parties to the contract and consideration of any relevant statutory requirements or
scheme rules. The inspection body should be able to show what factors have been
taken into account when determining what constitutes “adequate provision”. It is not the
role of an accreditation body to approve the provision held by an inspection body.

Note: Inspection Bodies should pay particular attention to insurance cover when undertaking
inspection work in another country, where legal requirements may differ from those in the body’s
home country.

5.2. Organisation and Management

5.2.1 n1 A one person ‘organisation’ may be accredited provided all relevant clauses of ISO/IEC
17020 are effectively implemented.

Note: The approval of an AIA by the regulatory authorities is conditional upon obtaining and
maintaining accreditation, see SANS 10227 clause 4.2 and PER Regulation 7

5.2.2 n1 The size, structure, composition and management of an inspection body, taken
together, shall be suitable for the competent performance of the activities within the
scope for which the inspection body is accredited.

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5.2.2 n2 “To maintain the capability to perform the inspection activities” implies that the
inspection body shall take steps to keep it appropriately informed about applicable
technical and/or legislative developments concerning its activities.

5.2.2 n3 Inspection bodies shall maintain their capability and competence to carry out inspection
activities performed infrequently (normally with intervals longer than one year). An
inspection body may demonstrate its capability and competence for inspection activities
performed infrequently through ‘dummy inspections’ and/or through inspection activities
conducted on similar products.

5.2.3 n1 The inspection body shall maintain an up-to-date organisational chart or documents
clearly indicating the functions and lines of authority for staff within the inspection body.
The position of the technical manager(s) and the member of management referenced in
clause 8.2.3 shall be clearly shown in the chart or documents.

5.2.4 n1 It may be relevant to provide information concerning personnel which carry out work
tasks for both the inspection body and for other units and departments in order to take
into account the involvement and the influence they may have over the inspection
activities.

5.2.5 n1 In order to be considered as ”available”, the person shall be either employed or

otherwise contracted.

5.2.5 n2 In order to ensure that the inspection activities are carried out in accordance with
ISO/IEC 17020, the technical manager(s) and any deputy(ies), shall have the technical
competence necessary to understand all significant issues involved in the performance
of inspection activities.

5.2.6 n1 In an organisation where the absence of a key person causes the cessation of work, the
requirement for having deputies is not applicable.

5.2.7 n1 The position categories involved in inspection activities are inspectors and other
positions which could have an effect on the management, performance, recording or
reporting of inspections.

5.2.7 n2 The job description or other documentation shall detail the duties, responsibilities and
authorities for each position category referred to in 5.2.7a.

6. Resources

6.1 Personnel

6.1.1 n1 Where appropriate, inspection bodies shall define and document competence
requirements for each inspection activity, as described in 5.1.3a. Some aspects of
competence requirements may already be defined by regulators and scheme owners or
specified by clients. Where this is the case, the inspection body should
incorporate/reference these requirements into their overall competence definitions. The
inspection body remains responsible for the appropriateness of competence definitions
and their compliance with the requirements of ISO/IEC 17020.

6.1.1 n2 For “personnel involved in inspection activities”, see 5.2.7a.

6.1.1 n3 Competence requirements shall include knowledge of the inspection body’s

management system and ability to implement administrative as well as technical
procedures applicable to the activities performed.

6.1.1 n4 When professional judgment is needed to determine conformity, this shall be

considered when defining competence requirements.

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6.1.2 n1 All requirements of ISO/IEC 17020 apply equally for both employed and contracted
persons.

6.1.5 n1 The procedure for formally authorising inspectors shall specify that the relevant details
are documented, e.g. the authorised inspection activity, the beginning of the
authorisation, the identity of the person who performed the authorisation and, where
appropriate, the termination date of the authorisation.

6.1.6 n1 The “mentored working period” mentioned in item b should include participation in
inspections at the locations where these inspections are performed.

6.1.7 n1 Identification of training needs for each person shall take place at regular intervals. The
interval shall be selected to ensure fulfilment of clause 6.1.6 item c. The results of the
review of training, e.g. plans for further training or a statement that no further training is
required, shall be documented.

6.1.8 n1 A major aim of the monitoring requirement is to provide the inspection body with a tool
to ensure the consistency and reliability of inspection outcomes, including any
professional judgments against general criteria. Monitoring may result in the
identification of needs for individual training or needs for review of the inspection body’s
management system.

6.1.8 n2 For “other personnel involved in inspection activities”, see 5.2.7a.

6.1.9 n1 To be considered sufficient, the evidence that the inspector is continuing to perform
competently shall be substantiated by a combination of information such as;

- satisfactory performance of examinations and determinations,

- positive outcome of monitoring (see note to clause 6.1.8),
- positive outcome of separate evaluations to confirm the outcome of the inspections
(this may be possible and appropriate in the case of e.g. the inspection of
construction documentation),
- positive outcome of mentoring and training,
- absence of legitimate appeals or complaints, and
- satisfactory results of witnessing by a competent body, e.g. a certification body for
persons.

6.1.9 n2 An effective program for the on-site observation of inspectors may contribute to fulfil the
requirements in clauses 5.2.2 and 6.1.3. The program shall be designed considering;

- the risks and complexities of the inspections,

- results of previous monitoring activities, and
- technical, procedural or legislative developments relevant to the inspections.
The frequency of on-site observations depends on the issues listed above, but shall be
at least once during the accreditation re-assessment cycle, however see application
note 6.1.9a. If the levels of risks or complexities, or the results from previous
observations, so indicate, or if technical, procedural or legislative changes have
occurred, then a higher frequency should be considered. Depending on the fields,
types and ranges of inspection covered by the inspector’s authorisations, there may be
more than one observation per inspector necessary to adequately cover the whole
range of required competencies. Also, more frequent on-site observations may be
necessary if there is lack of evidence of continuing satisfactory performance.

6.1.9 n3 This requirement applies even in the case the inspection body has only one technically
competent person.

6.1.10 n1 Records of authorisation shall specify the basis on which authorisation was granted
(e.g. the on-site observation of inspections).

Note: As per the STC PER/VUP minutes of 13 April 2007 section 4.2 the Inspection Body
shall ensure and maintain records of:

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1. IPE/CP 3-yearly re-registration as required by SAQCC and

2. Pr. Eng/Pr. Tech re-registration as required by ECSA

6.1.10 n2 The regulator has ruled that the names of ALL inspectors shall also be listed on the SoA
before they may be utilised by the AIA.

SANAS process:
• AIAs have to send a list of all the inspectors employed or contracted by them
to SANAS.
• AIAs will NOT have to apply on-line for the inspectors’ names to be listed.
• SANAS only requires the FULL names of the inspectors and a copy of their
IPE, CP-PV and/or CP-SG registration certificates.
• This has to be done within 60 days from today, i.e. by Monday 9 September
2019 (rounded up to the first weekday).
• SANAS will amend the SoAs of AIAs as soon as we receive the information.

AIAs must please take note that NO inspector shall be utilised by an AIA unless his/her
name appears on the SANAS SoA.
[AIA Association of 05 July 2019]

6.1.11 n1 Remuneration methods that provide incentives to perform inspections quickly have the
potential to negatively affect the quality and outcome of inspection work.

6.1.12 n1 Policies and procedures shall assist inspection body personnel in identifying and
addressing commercial, financial or other threats or inducements which could affect
their impartiality, whether they originate inside or outside the inspection body. Such
procedures shall address how any conflicts of interests identified by personnel of the
inspection body are reported and recorded. Note, however, that while expectations for
inspector integrity can be communicated by policies and procedures, the existence of
such documents may not signal the presence of integrity and impartiality required by
this clause.

Table 1 — Qualification requirements for AIA Manufacturing

1 2 3 4
Qualification /
Function Responsibilities Experience
certification
Design verification a Verification of design calculations Pr. Eng. or Four years of relevant
and related drawings Pr. Technologist or pressure equipment design
Pr. Cert. Eng. experience, with knowledge
of design standards and
statutory requirements in
terms of which the service is
rendered

Technical manager b Management of all AIA technical University degree Four years relevant pressure
(however designated) and quality activities or equipment experience with
Higher National Diploma or knowledge of the relevant
Cert Eng. or Code of Construction, quality
B Tech. management system
requirements and statutory
requirements in terms of
which the service is rendered

Verification and Independent inspection, testing and SAQCC (IPE) Inspection and testing
surveillanced surveillance of items and activities experience with knowledge
of the specific Code of
Pre-commissioning, Inspection and assessment of SAQCC (IPE / Construction and other
inspection and pressure equipment in accordance CP) statutory requirements
pressure testing with the relevant national legislation incorporated in certification
(see foreword) in terms of which the service
is rendered
a Only mechanical engineers are applicable in this context. Foreign qualifications need to be verified by SAQS
b The technical manager (however designated) is not authorised to perform IPE or CP functions unless certified by
SAQCC. The technical manager may delegate the management of the quality system to a qualified person with the
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relevant experience within the organisation.

NOTE Only the following engineering disciplines are acceptable for a Technical Manager:
• Mechanical
• Metallurgical
• Welding

Table 2 — Qualification requirements for AIA In-service Inspections

1 2 3 4
Qualification /
Function Responsibilities Experience
certification
Management of all AIA Technical Manager a University degree 4 years of relevant pressure
technical and quality or equipment design
activities Higher National Diploma or experience, with knowledge
Cert Eng. or of design standards and
B Tech. statutory requirements in
terms of which the service is
rendered

or
A minimum of SAQCC Minimum 5 years as CP
(CP) and Grade 12 or Inspector with relevant
equivalent pressure equipment
experience with knowledge
of the relevant health and
safety standard, quality
management system
requirements in terms of
which the service is rendered

In-service pressure Inspection and testing of SAQCC (CP) Inspection and testing
equipment inspection pressure equipment experience with knowledge
of the in-service and other
statutory requirements
incorporated in certification
in terms of which the service
is rendered

6.2. Facilities and Equipment

6.2.1 n1 Equipment required to carry out inspection in a safe manner may include e.g. personal
protective equipment and scaffolding.

6.2.3 n1 If controlled environmental conditions are needed, e.g. for the correct performance of
the inspection, the inspection body shall monitor these and record the results. If
conditions were outside acceptable limits for the inspection to be performed, the
inspection body shall record what action was taken. See also clause 8.7.4.

6.2.3 n1 Continued suitability may be established by visual inspection, functional checks and/or
re-calibration. This requirement is particularly relevant for equipment that has left the
direct control of the inspection body.

6.2.4 n1 Inspection bodies should document and retain the rationale for decisions on the
significance of influence of equipment on the inspection results as these decisions are
critical foundations for subsequent decisions on calibration and traceability.

6.2.4 n2 In order to enable tracking when items are replaced, the unique identification of an item
of equipment may be appropriate even when there is only one item available.

6.2.4 n3 When controlled environmental conditions are needed, the equipment used to monitor
such conditions shall be considered as equipment that significantly influences the result
of inspections.

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6.2.6 n1 The justification for not calibrating equipment that has a significant influence on the
outcome of inspection (see clause 6.2.4) shall be recorded.

6.2.6 n2 Guidelines on how to determine calibration intervals can be found in ILAC G24 (SANAS
TG 05).

6.2.6 n3 When appropriate (normally for the equipment covered by clause 6.2.6) the definition
shall include the required accuracy and measurement range.

6.2.6 n4 Equipment identified under the criteria in clause 6.2.4, as clarified in 6.2.4a, must be
traceably calibrated to national or international standards where possible. For guidance
on measurement traceability, refer to SANAS TR 25 document.

6.2.6 n5 Where the calibrations are performed in-house, traceability to national standards shall
be assured by using reference standards of measurement for which the Inspection
Body holds a current calibration certificate or equivalent from a competent body. The
certificate or equivalent shall detail an uncertainty of measurement that is appropriate
for the equipment that is to be calibrated from the reference standard. For further
information on uncertainty of measurement, see ISO/IEC Guide 98. www.iso.org

6.2.7 n1 According to ILAC P10 it is possible to perform in-house calibration of equipment used
for measurements. It is a requirement for accreditation bodies to have a policy to
ensure that such in-house calibration services are performed in accordance with the
relevant criteria for metrological traceability in ISO/IEC 17025.

6.2.7 n2 The preferred routes for inspection bodies who seek external services for calibration of
their equipment are defined in ILAC P10.

6.2.7 n3 Where traceability to national or international standards of measurement is not

applicable, the participation in relevant comparison programs or proficiency tests is an
example of how to obtain evidence of correlation or accuracy of inspection results.

6.2.8 n1 When inspection bodies use reference standards of measurement to calibrate working
instruments the reference standards of measurement should have a higher degree of
accuracy than that required of the working instruments they are used to calibrate.

6.2.9 n1 Where equipment is subjected to in-service checks between regular re-calibrations, the
nature of such checks, the frequency and acceptance criteria shall be defined.

6.2.10 n1 The information provided in 6.2.7a, 6.2.7b and 6.2.7c for programs of calibration of
equipment is valid also for programs of calibration of reference materials.

6.2.11 n1 When the inspection body engages suppliers to perform activities which do not include
the performance of part of the inspection, but which are relevant for the outcome of
inspection activities, e.g. order registration, archiving, delivery of auxiliary services
during an inspection, the editing of inspection reports or calibration services, such
activities are covered by the term “services” used in this clause.

6.2.11 n2 The verification procedure shall ensure that incoming goods and services are not used
until conformance with specification has been verified.

6.2.13 n1 Factors that should be considered in protecting the integrity and security of data
include;

- backup practices and frequencies,

- effectiveness in restoring data from backup,
- virus protection, and
- password protection.

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6.3 Sub-contracting

6.3.1 n1 By definition (ISO/IEC 17011, clause 3.1), accreditation is limited to conformity

assessment tasks which the inspection body has demonstrated competence to perform
itself. Thus, accreditation cannot be granted for activities referred to in the fourth bullet
point under note 1, if the inspection body does not have the required competence
and/or resources. However, the task of assessing and interpreting the results of such
activities for the purpose of determining conformity may be included in the scope of
accreditation, provided adequate competence for this has been demonstrated.

6.3.1 n2 Inspection activities can overlap with testing and certification activities where these
activities have common characteristics (See Introduction of ISO/IEC 17020). For
example, examination of a product and testing of the same product can both be the
basis for the determination of conformity in an inspection process. It should be noted
that ISO/IEC 17020 specifies requirements for bodies performing inspection, whereas
the relevant standard to apply for bodies performing testing is ISO/IEC 17025 or ISO
15189.

6.3.3 n1 In note 2 to the definition of “inspection” in clause 3.1 it is indicated that in some cases
inspection may be examination only, without a subsequent determination of conformity.
In such cases clause 6.3.3 does not apply since there is no determination of conformity.

6.3.4 n1 Accreditation is the preferred means to demonstrate the competence of the

subcontractor, but in justified situations (on the basis of qualified evaluation/professional
judgement) results from non-accredited bodies could be accepted.

6.3.4 n2 If the evaluation of the competence of the subcontractor is based partly or in full on its
accreditation, the inspection body shall ensure that the scope of the subcontractor’s
accreditation covers the activities to be sub-contracted.

7. Process requirements

7.1 Inspection method and procedure

7.1.1 n1 If the inspection includes measurements, ILAC G27 provides guidance on how to
determine which requirements may be relevant.

7.1.1 n2 For the development of specific inspection methods and procedures the guidance in
ISO/IEC 17007 can be used.

7.1.1 n3 Many inspection methods use the human eye to perform visual inspections.
Increasingly new technology (e.g. drones, cameras, special glasses, IT, artificial
intelligence, etc.) is introduced to be used during inspections. This could be as a
(partly) replacement of an existing inspection method (like the human eye) or as a new
inspection method.

7.1.2 n1 The Inspection Body’s inspection methods and procedures shall include the
requirements if SANS 10227 clause 6, 7, 8 and Annex A for piping

7.1.3 n1 Aspects that require attention with the introduction of new technology are:
- Validation of the new or changed inspection method using new technology. In case
of (partly) replacement of an existing inspection method, it should be investigated
whether the inspection outcome is equally (or more) reliable than the outcome of the
existing method;
- The applicable legal and safety requirements (like permits), legal limitations and
legal conditions;
- The applicable limitations and conditions for the inspection method when new
technology is used;
- Whether the use of new technology should be mentioned in the inspection report;

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- Whether the use of new technology should be mentioned on the inspection and/or
accreditation scope.

7.1.5 n1 Where appropriate the contract or work order control system shall also ensure that;

- contract conditions are agreed

- personnel competence is adequate
- any statutory requirements are identified
- safety requirements are identified
- the extent of any subcontracting arrangements required is identified

For routine or repeat work requests the review may be limited to considerations of time
and human resources. An acceptable record in such cases would be an acceptance of
the contract signed by an appropriately authorised person.

7.1.5 n2 In situations where verbal work orders are acceptable, the inspection body shall keep a
record of all requests and instructions received verbally. Where appropriate, the
relevant dates and the identity of the client’s representative should be recorded.

7.1.5 n3 The contract or work order control system should ensure that there is a clear and
demonstrable understanding between the inspection body and its client of the scope of
the inspection work to be undertaken by the inspection body.

7.1.6 n1 The information referred to in this clause is not information provided by a sub-
contractor, but information received from other parties, e.g. a regulating authority or the
client of the inspection body. The information may include background data for the
inspection activity, but not results of the inspection activity.

7.2 Handling inspection items and sample

7.2.1 n1 The Inspection Body shall ensure that the requirements of PER regulation 9 and SANS
10227 clauses 9 and 10 are implemented.

Note: The Inspection Body shall stamp their approval number on the nameplate i.e. PER 007.

7.3 Inspection Records

7.3.1 n1 The records should indicate which particular item of equipment, having a significant
influence on the result of the inspection, has been used for each inspection activity.

7.3.1 n2 The Inspection Body shall retain records of original observations, derived data and
sufficient information to establish an audit trail, calibration records, staff records and a
copy of each inspection report or inspection certificate issued, for a minimum period of
eight (08) years.

7.4 Assessment Reports and Assessment Certificates

7.4.2 n1 ILAC P8 provides requirements for the use of accreditation symbols and for claims of
Accreditation status.

7.4.4 n1 It may be useful to identify the inspection method in the inspection report/certificate
when this information supports an appropriate interpretation of the inspection results.

7.5 Complaints and Appeals

No interpretations of the requirements of ISO/IEC 17020 are required for this clause.

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7.6 Complaints and Appeals process

No interpretations of the requirements of ISO/IEC 17020 are required for this clause.

8. Management system requirements

8.1 Options

8.1.1 General

8.1.1 n1 It is the responsibility of the Inspection Body to select, define and maintain
a management system based on Option A or Option B. SANAS shall
assess the appropriateness of the management system defined in
accordance with the requirements of ISO/IEC 17020 and not the
requirements of ISO 9001.

8.1.2 Option A

No interpretations of the requirements of ISO/IEC 17020 are required for this clause.

8.1.3 Option B

8.1.3 n1 The expression “this International Standard” is a reference to ISO/IEC 17020.

8.1.3 n2 Option B does not require that the inspection body's management is certified to
ISO 9001. However, when determining the extent of required assessment, the
accreditation body should take into consideration whether the inspection body
has been certified against ISO 9001 by a certification body accredited by an
accreditation body which is a signatory to the IAF MLA, or to a regional MLA, for
the certification of management systems.

8.2 Management system documentation (Option A)

8.2.1 n1 The policies and objectives shall address the competence, impartiality and consistent
operation of the inspection body.

8.2.1 n2 Policy statements are intended to demonstrate senior management commitment to the
quality system. Objectives shall include measurable targets, which are reviewed at
least annually. Policies and objectives shall be reviewed at management review, see
clause 8.5. Training records shall show that all staff is familiar with the quality system.

8.2.3 n1 In cases where an Inspection Body has a number of offices at different locations,
responsibility for the practical maintenance of the quality system in each office should
be assigned to a named, local, individual.

8.2.4 n1 For easy reference, it is recommended that the inspection body indicates where the
requirements of ISO/IEC 17020 are addressed, e.g. by means of a cross reference
table.

8.3 Control of documents (Option A)

No interpretations of the requirements of ISO/IEC 17020 are required for this clause.

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8.4 Control of records (Option A)

8.4.1 n1 This requirement means that all records needed to demonstrate compliance with the
requirements of the standard shall be established and retained.

8.4.1 n1 In cases where electronic seals or authorizations are used for approvals, access to the
electronic media or seal should be secure and controlled.

8.5 Management review (Option A)

No interpretations of the requirements of ISO/IEC 17020 are required for this clause.

8.5.2 Review inputs

8.5.2 n1 A review of the impartiality risk identification process and its conclusions (clauses
4.1.3/4.1.4) shall be part of the annual management review.

8.5.2 n2 The management review shall take into account information on the adequacy of
current human and equipment resources, projected workloads and the need for
training of both new and existing staff.

8.5.2 n3 The management review shall include a review of the effectiveness of systems
established to ensure adequate competence of the personnel.

8.5.3 Review outputs

No interpretations of the requirements of ISO/IEC 17020 are required for this clause.

8.6 Internal audit (Option A)

8.6.1 n1 Inspection Bodies with more than one operational site clause all aspects of the
management system and all the sites shall have a full internal audit during an
accreditation cycle.

8.6.4 n1 The inspection body shall ensure that all requirements of ISO 17020 are covered by the
internal audit program within the accreditation re-assessment cycle. The requirements
to be covered shall be considered for all fields of inspection and for all premises where
key activities are performed.

The inspection body shall justify the choice of audit frequency for different types of
requirements, fields of inspection and premises where key activities are performed.
The justification may be based on considerations such as;

- criticality,
- maturity,
- previous performance,
- organisational changes,
- procedural changes, and
- efficiency of the system for transfer of experience between different operational sites
and between different fields of operation.

8.6.4 n2 The internal audit is an essential tool the inspection body should apply with a frequency
short enough to monitor its capacity to consistently fulfil the requirements in ISO/IEC
17020. When an inspection body detects problems that affect the fulfilment of any
ISO/IEC 17020 requirement (e.g. a rise in complaints and appeals; unsatisfactory
results at external audits; issues with personnel qualification, etc.), it should consider
increasing the frequency and depth of its internal audits, and/or to extend their coverage
to include other locations and fields of inspection.

8.6.5 n1 Competent externally contracted personnel may carry out internal audits.
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8.7 Corrective action (Option A)

No interpretations of the requirements of ISO/IEC 17020 are required for this clause.

8.8 Preventive action (Option A)

8.8.1 n1 Preventive actions are taken in a pro-active process of identifying potential non-
conformities and opportunities for improvement rather than as a reaction to the
identification of non-conformities, problems or complaints.

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Annex A Independence requirements for inspection bodies

A n1 Annex A.1 and A.2 of ISO/IEC 17020 refer to the phrase “items inspected” with respect to Type A
and Type B inspection bodies (4.1.6 n1 clarifies the cases where an inspection body may have
different types of independence). In Annex A.1 b it is stated that “In particular they shall not be
engaged in the design, manufacture, supply, installation, purchase, ownership, use or maintenance
of the items inspected”. In Annex A.2 c it is stated that “In particular they shall not be engaged in
the design, manufacture, supply, installation, use or maintenance of the items inspected”. The
reference to “they” in the above sentences is a reference to the inspection body concerned and its
personnel. The items in this case are those items that are specified in the accreditation body’s
certificate/annex with respect to the accredited scope of the inspection body (e.g. pressure
vessels).

A n2 It is also considered as a conflicting activity the provision of consultancy in the design,

manufacture, supply, installation, purchase, use or maintenance of the items inspected.

A n3 A ‘regulatory requirement’ means that the exception has been written into relevant legislation
and/or where a Regulator provides publicly available guidance stating that this exception is
permissible when undertaken as part of the regulated inspection activity.

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Annex 1: Possible format for an impartiality risk analysis (Informative)

Clause 4.1.3 requires the inspection body to identify risks to impartiality on an ongoing basis and clause
4.1.4 requires the inspection body to demonstrate how it eliminates or minimizes such risks. In practice the
combination of these two clauses indicates that “an impartiality risk analysis” is required. Although this term
“impartiality risk analysis” is not mentioned in ISO/IEC 17020, in this application note it is used as a widely
spread term through which the requirements of clauses 4.1.3 and 4.1.4 may be addressed by the inspection
body.

The actions through which the inspection body demonstrates how it eliminates or minimizes the identified
impartiality risks in practice are often called “control measures”. Also this term is not mentioned in ISO/IEC
17020.

A possible format for an impartiality risk analysis is shown in the table below.

Situation Impartiality risk Control measure and Where in the

its monitoring management system
is control measure
embedded
(procedure,
instruction, form,
statement)?

1. Activities of the inspection body

2. Relationships of the inspection body

3. Relationships of personnel

Figure 1. Possible format for a impartiality risk analysis

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Annex 2 Relationship between impartiality and Type A independence requirements

(Informative)

- Impartiality (defined as presence of objectivity) is the leading requirement;

- Impartiality of an inspector is present when the inspector in all cases demonstrates objectivity in
his/ her judgement;

1- Risks Eliminated by complying to Type A independence requirements

- Complying with the Type A independence requirements eliminates the impartiality risks related to
engaging in activities that may conflict with the independence of judgment and integrity in relation
to inspection activities;
- The Type A independence requirements are meant to increase confidence in impartiality and
exclude only certain impartiality risks. Hence, complying with these Type A independence
requirements does not eliminate all impartiality risks;
- The remaining impartiality risks have to be identified (4.1.3) and minimized or eliminated (4.1.4);

2- Impartiality Risk Analysis and Control Measures

- In practice, the identification of the potential risks to impartiality is often called “impartiality risk
analysis”; the minimization or elimination of impartiality risks according to 4.1.4 in practice is often
called “control measures”;
- An impartiality risk analysis is required for all three types of independence (Type A, Type B and
Type C);
- Complying with the Type A independence requirements A.1b and A.1.c is binary (yes or no)
meaning that partly complying with these Type A independence requirements is not possible.
This also means that a risk analysis resulting in control measures to minimize the impartiality
risks of a situation where there is no compliance with these Type A requirements is not possible.
Hence, only elimination of the situation that is not compliant with these Type A
requirements is possible;
- The Type A independence requirements A.1d could be addressed through control measures
resulting from the risk analysis;
- The assessment whether an inspection body complies with the Type A independence
requirements A.1b and A.1c can be complex in some specific situations (depending on the items
inspected at hand and market characteristics), but the outcome must be yes or no;

3- Items Inspected

- The term “items inspected” is mentioned in the Type A independence requirements of Annex
A.1b/c of ISO/IEC 17020 and is clarified in this document ILAC-P15 under A n1.
- The reasoning behind the ILAC-P15 clarification is that possible influence on the market or
possible influence from the market should be prevented, thus also preventing
commercial/financial pressures on the inspection body and/ or its personnel (e.g. inspectors);
- Inspection bodies may operate in markets with different characteristics in terms of the number of
suppliers/ producers:
• Markets where there is a limited number of suppliers/ producers. For instance, elevators,
cars, pressure equipment;
• Markets where there is a very large number of suppliers/ producers. For instance, in the
agro/ food sector.
This kind of difference in the market situation has no influence on the interpretation of ILAC-P15 A n1:,
Inspection Bodies and its inspectors shall not be engaged with the items inspected as mentioned on
the scope of accreditation, thus in general and not restricted to only the specific/ unique/ individual
items that are subject of an inspection by the Inspection Body;

4- Type A / Type C

- It may be difficult to comply with the Type A independence requirements A.1b and A.1c in some
sectors of economic activity where potential external inspectors in those sectors are, in most
cases, engaged with the items inspected; In such cases Type C is an alternative for Type A.
- It should be noted that the impartiality and competence requirements for Type A and Type C are
the same; only the independence requirements are different.

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9. List of Approved Inspection Authorities

A list of approved inspection authorities will be maintained by the chief inspector and distributed to all
provincial offices and labour centre offices of the Department of Labour. Copies of this list will reflect
the name and address, contact details, services approved, initial date of approval and the approval
number of each Inspection Body.

Regulations www.labour.gov.za
SANS 10227 & SANS 347 https://www.sabs.co.za/
SANS/ISO/IEC 17020: 2012 https://www.sabs.co.za/
SANAS R & TR-documents www.sanas.co.za

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APPENDIX 1: Scope of Accreditation

ANNEXURE A – Manufacturing Inspection

S COPE O F A C C R E D I T A T I O N

Inspection Body Accreditation Number: LVUP00X

TYPE A

Permanent Address: Postal Address:

Tel: Issue No.: 01

Cell: Date of Issue: 01 September 2020
E-mail: Expiry Date: 31 August 2024

Nominated Representative: Design Verification Engineers: Technical Signatory:

AAA Mr VVVV Pr. Eng 8606 Manufacturing
& Pre-Commissioning
Mr BBB IPE 3, PV 1 &
SG 3
Technical Manager:
BBB
Pre-Commissioning only:
Inspector:
Mr KKK - PV 8 & SG 1
Quality Manager: Mr CCC IPE
AAA

Field of Inspection Type and Range of Inspection Standards and Specifications

Regulatory:
The supply of services as an Inspection Design Verification and New ASME 1, VIII Div 1 & 2; PCC-2, B
Authority for Inspection of Pressure Manufacture 31.3 & B 31.4
Equipment as defined in the Pressure Inspection TEMA
Equipment Regulation, Government
API 580, 581, 661 & 1104
Notice No. R734 of 15 July 2009 Pre-Commissioning Inspection Sastech/Sasol/Natref Specifications

Re-Certification Inspection

ISSUED BY THE SOUTH AFRICAN NATIONAL ACCREDITATION SYSTEM

Accreditation Manager

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ANNEXURE B – In-Service Inspection

S C OP E OF ACCREDITATION

Inspection Body Accreditation Number: LVUP00X

TYPE A

Permanent Address: Postal Address:

Tel: Issue No.: 1

Cell: Date of Issue: 01 September 2020
E-mail: Expiry Date: 31 August 2024

Nominated Representative: Technical Manager: (CP-PV) Technical Manager: (CP-SG)

Mr AAA Mr BBB Mr BBB

Quality Manager: Technical Signatories: (CP-PV) Technical Signatories: (CP-SG)

Mr AAA Mr AAA PV 7 Mr H SG 3
Mr KKK PV 081 Mr RA SG 1

Inspectors:
Mr ML PV 6
Mr MJ PV 2
Mr S PV 5
Mr PA PV9

Field of Inspection Type and Range of Inspection Standards and Specifications

Regulatory:
The supply of services as an Inspection In-service Inspection of Pressure In-service inspection procedures
Authority for Inspection of Pressure Equipment generally, in accordance with:
Equipment as defined in the Pressure ANSI/NB23
Equipment Regulation, Government API 510, 570, 571, 573, 574, 576 &
Notice No. R734 of 15 July 2009
579

ISSUED BY THE SOUTH AFRICAN NATIONAL ACCREDITATION SYSTEM

Accreditation Manager

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ADDENDUM 1: Amendment Record

Proposed Section Change

By:
AM All Aligned with ILAC P15: 05/2020

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