Reply To: LAB30 and RG8 NORAC Consultation

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    Type of comment (GE = general, TE = technical, ED = editorial)
    Comment (justification for change)
    Proposed change




    RG8 [TE] Section 2.1 (d)

    Comment: What happens when there are no management surveys left (either for all companies or for particular customers) – how can we do reinspection if they are “tied” to management survey authorisations?

    Comment [GE]: Long overdue. Anything other than the inspection of known or presumed ACM’s should be a management survey. Consideration of the use of previous information collected would be useful. The use of plans and liability. Does a new reinspection use the plans from the previous report or is it adequate to draw new plans and risk changing original info?

    RG8 [TE] Section 6.2

    Comment: under the “duty to manage” – does that suggest we only need to monitor/audit for non-domestic premises?

    Comment: the paragraph appears to be incomplete “…and are suitably”…what?? Is suspect it should say “…and are suitably independent to carry out the witnessed surveys objectively” as that is what current RG8 says.

    RG8 [TE] Section 3.4:

    Comment: Where organisations exist that have relationships, UKAS should seek from that organisation conduct procedures that can be measured to ensure impartiality.

    RG8 [TE] Section 10.3

    Comment: How do UKAS propose we can demonstrate why a resurvey has not been conducted? Is this for every single survey? The 4% number if this is an arbitrary – can we move away from a defined number and do it on a risk based approach e.g. higher risk work (refurb/demo) would have a stronger weighting compared to a basic management survey. (for example if we were to survey 500 bus stops that were all made from concrete, what would be the point of resurveying 20 bus stops?).

    RG8 [TE and GE] Section 10.4

    Comment: bullet point 2 – why does it not state an independent comparison e.g. the re-surveyor may not “highlight” their own failings?

    Comment: bullet point 2 – why do blind resurveys have to be undertaken during each planned audit schedule/programme? Does that mean we cannot resurvey if there wasn’t planned audit? It would most likely then be the auditor who did the resurvey – how can they do it “blind” if they have audited someone on it already?

    RG8 [TE and GE] Section 10.6

    In the current RG8 it states “Information obtained from the client, and particularly from third party sources, should be verified during the contract review stage and/or by the surveyor before the survey commences on site. If Priority Risk Assessment is required by the client this data shall also be verified.” Has this been deliberately left out?

    RG8 [ED] Section 15.2

    The 29th word in the paragraph should be “a” instead of “an”.