To close this one also – UKAS have accepted our portal submission, they didn’t however provide any feedback to us for what we submitted:
The analyst estimated the visual inspection as 45 minutes, however, it only took 20 minutes. The analyst appeared to be confused regarding the estimate and assumed this would be for the whole of Stage 2 i.e. collecting photos etc after the visual was complete etc.
Clause: ISO17025 para 7.5.1
We have reviewed the clause sited by UKAS and found in bold below the requirement for recording information at the time you perform the task. Additionally, we reviewed Lab30 and HSG248 and could find no further clear guidance on whether the time for the visual inspection included documenting findings or not.
ISO 17025 7.5.1 The laboratory shall ensure that technical records for each laboratory activity contain the results, report and sufficient information to facilitate, if possible, identification of factors affecting the measurement result and its associated measurement uncertainty and enable the repetition of the laboratory activity under conditions as close as possible to the original. The technical records shall include the date and the identity of personnel responsible for each laboratory activity and for checking data and results. Original observations, data and calculations shall be recorded at the time they are made and shall be identifiable with the specific task.
At the time of the audit our analyst recorded his data at the end rather than during the course of the inspection. Normally our analysts would record as they go a long, especially for larger enclosures.
We have interpreted the estimated time for stage 2 to also include recording of the stage 2 findings, specifically the contextual information of what you have inspected as well as the date and time stamped photographic evidence to support the written findings.
We believe that if you leave the recording of information to the end of stage 2 you are less likely to accurately record the required detail (particularly in larger enclosure where stage 2 takes several days), the same is true for the photographs – we want to avoid going back at the end of a stage 2 visual to photograph previously inspected areas e.g. ceilings, high level beams and ledges etc., it is more efficient to photograph these while doing the visual than it is to have a scaffold either rebuild or moved into the locations to allow access.
Root cause is Other.
This will affect all analysts as all of our staff are working to the same system.
Minimal – as stated above we class the recording of the stage 2 as part of stage 2. It still allows us to review and detect any instances where an over or under estimation has been made, such that we can try to mitigate inaccurate estimations in the future.
Hopefully, this will be of use to others. And thanks once again to those who responded with their views.