Clarification on testing standards: UK21/G008

Adopted EU recommendation GEN-010. UK approved recommendation on testing standards and the responsibilities of UK Approved Bodies.

Question

  • Is it acceptable to perform examinations and tests described in the Merchant Shipping (Marine Equipment) Regulations 2016 as amended, Schedule 2 paragraphs 3, 4 and 5, within the facilities of the manufacturer using his measuring equipment and personnel? If yes, under which circumstances?
  • What is the responsibility of the UK Approved Body if tests are performed in a non‐accredited laboratory or one whose accredited scope does not cover the specific tests?

Recommendation

Traditionally, certain tests have been carried out at the manufacturer’s works using his equipment and personnel under the supervision of an Approved Body. However, others can only be carried out at a qualified laboratory which possesses the necessary competent staff and test equipment.

Note: Some International Instruments specify that the testing is only to be carried out in a qualified laboratory.

In all cases, the Approved Body is required to satisfy themselves that the test facility is suitable and that the personnel have the necessary competence to undertake the proposed tests. This assessment should be fully documented by the Approved Body.

Where it is agreed to carry out the tests at the manufacturer’s works, then the testing should be witnessed independently by a competent representative of the Approved Body.

Where testing is carried out in a laboratory, it should be either approved by the national authority (for example on the IMO list) or be an accredited facility for the tests to be conducted. Where not approved by the national authority or accredited, the Approved Body is responsible for auditing the facilities to verify they are equivalent to those of an accredited laboratory and have the required tests equipment, procedures and staff competency. In such cases, the Approved Body must carry out and document their audit of the following topics, as a minimum:

  • the laboratory meets the intentions of EN ISO/IEC 17025 ‐ “General Requirements for the competence of testing and calibration laboratories” or equivalent
  • the required equipment is available and suitable for carrying out the test, for example, test range, accuracy of result, test report format, etc
  • the equipment is properly calibrated and traceable back to National or International standards
  • the staff is qualified and competent to undertake the tests to be performed

Tests are to be supervised and accepted by a competent representative of the Approved Body.

References

  • EN ISO/IEC 17025
  • MSN 1874 as amended
  • The Merchant Shipping (Marine Equipment) Regulations 2016 as amended

Items affected

  • All

More information

Maritime and Coastguard Agency
Bay 2/21
Spring Place
105 Commercial Road
Southampton
SO15 1EG

Telephone: +44 (0) 203 817 2000

Email: MEQA@mcga.gov.uk

Website: www.gov.uk/mca

Published 18 July 2023