Currents of Change:
Navigating South Africa's Conformity Assessment Controversy

The certification of a product's conformity to standards and compulsory specifications is regarded by many countries as a valuable supplement to the relationship between a buyer/seller and for regulatory proof of compliance systems. In most countries, conformity certification systems are operated under the national standards body or the regulatory authority, specifically to ensure product safety and regulation of energy efficiency of electrical products.

To understand the controversy that has arisen regarding “Proof of Compliance”, it is essential to evaluate the validity of a Type Test + LOA (Letter of Authority), Type 5 product certification and Self-compliance (SDoC).

The publications ISO/IEC 17067: 2013 – Conformity assessment — Fundamentals of product certification and guidelines for product certification schemes, and the Technical report “Certification – Principles and Practice” compiled by the CERTICO Committee and SANS 17050 – “Suppliers Declaration of Conformity” provide invaluable information.

Background

The South African Bureau of Standards was established in 1945 with the main objective to develop product standards and provide test facilities to support the industry in product development through conformity assessment services. SABS played a leading role through its Type 5 SABS product certification scheme.


SABS has seen many structural transitions with the application of standard protocols. It also pioneered many standards that have shaped the way South Africa currently operates.

The most significant impact on the SABS and industry was the formation of the regulator NRCS in 2008. This structural change severely affected industry and also the financial sustainability of the Conformity Testing Services and SABS Mark Scheme which since have experienced a dramatic decline in market coverage. The NRCS policy not to recognise the SABS certification mark as proof of compliance with the relevant compulsory product specifications resulted in cancellation of many suppliers’ SABS permits to remain competitive in this regulated market.

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Type Testing and the NRCS regulatory (LOA) Model:

According to Section 5.3.2 of ISO/TEC 17067 the NRCS LOA model can be categorised as a Type 1a scheme:

“5.3.2 Scheme type 1a

In this scheme, one or more samples of the product are subjected to the determination activities. A certificate of conformity or other statement of conformity (e.g. a letter) [LOA] is issued for the product type, the characteristics of which are detailed in the certificate or a document referred to in the certificate.

Subsequent production items are not covered by the certification body’s attestation of conformity.”

“Type testing forms the basis – an ineluctable element – of the 4 subsequent systems numbered Type 2 to Type 5 inclusively. …. Although type testing has been classified as a system, some hold that type testing is not really a system at all and oppose its inclusion in any list of systems for that reason, despite the fact some standards organizations award their mark on the basis of type testing only. It is nonetheless generally accepted that type testing as a system is often subject to conditions that have to be fulfilled either before or after the actual test itself, or by various conditions relevant to the acceptability of the results and, therefore that its inclusion as a system may be justified on this account. … The disadvantage of this system is that it does not of itself provide any first hand or reliable evidence about the normal subsequent production of other articles made to the same specification. To a greater or lesser extent, all other systems do.

One can think of occasions where it has been assumed that the conformity evidenced by the result of the type test leads to the probability of conformity of subsequent items; but on close examination one can say that either the assumption is unjustified or that there is something else – some other factor than the test itself – that has been brought into consideration in making the assumption. The type test gives evidence only about a particular item made at a particular time. It is an operation that is one of a kind, performed once-for-all.

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This is illustrated by consideration of the circumstances of a typical type test operation. Let us presume for the sake of simplicity, that the type test is to be done on a single sample by an engineer in his testing laboratory. It may be a sample of material – perhaps a piece of metal – or a complex contrivance made up of a number of components. He is provided with a document describing the requirements for the item and the method of measurement of those requirements.

He is competent and has suitable equipment to perform the job: to test the item in accordance with a described method and to report the result in terms of conformity with the requirements specified in the document. In the basic essentials of the operation, he does not need to know who made it, what its function is, or the use that will be made of his report. He is concerned only with the wholly objective matter: to report upon the product in terms of the precisely stated requirements described in the document when measured by a specified method. He is as it were, cut off as much from the circumstances – the how, the when, the where, and the why of the matter – as he is from the consequences of the result of what he will record. We are not suggesting that testing engineers are or should be robots. They may be concerned, for example with questions of liability and ethical considerations: but the narrowness of scope of the type testing system must be emphasized in order to illustrate its limitations.

Of all the certification methods described, type testing alone allows of no declaration or claim with regard to future production and it would not justify any such inferences.

Inferences of this nature can only be sustained if the system that incorporates the type testing includes some additional evidence or data which provide a credible link between the type test and the subsequent production based upon it.”

From the above it is clear that a Type 1a system as that of the NRCS without follow-up market surveillance fails to ensure continued compliance of LOA approved products.

Despite widely used conformity assessment schemes, the NRCS has been reluctant to apply/consider international best practice contained in those systems listed below;

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Type 5 Certification

According to Section 5.3.7 of ISO/TEC 17067

“Scheme type 5;

The surveillance part of this scheme allows for the choice between periodically taking samples of the production either from the point of production or from the market, or from both, and subjecting them to determination activities to check that items produced subsequent to the initial attestation fulfil the specified requirements. The surveillance includes periodic assessment of the production process, or audit of the management system, or both. The extent to which the four surveillance activities are conducted may be varied for a given situation, as defined in the scheme. If the surveillance includes audit of the management system, an initial audit of the management system will be needed.”

Self-Compliance (Type N)
Suppliers’ Declaration of Conformity (SDoC) is covered by SANS 17050: 2013

“The purpose of the declaration is to give assurance of conformity of the identified object to specified requirements to which the declaration refers, and to make clear who is responsible for that conformity and declaration. A supplier’s declaration of conformity may be used alone or in conjunction with another conformity assessment procedure for regulatory or non-regulatory purposes.

General Requirements:
The issuer (issuing organization or person) of a declaration of conformity shall be responsible for issuing, maintaining, extending, reducing, suspending or withdrawing the declaration and the conformity of the object to the specified requirements.


The declaration of conformity shall be based on results of an appropriate type of conformity assessment activity (e.g. testing, measurement, auditing, inspection, or examination) carried out by one or more first, second or third parties. Conformity assessment bodies involved, where applicable, should consult relevant International Standards, Guides and other normative documents”

 

Conclusion

In conclusion, the South African Bureau of Standards (SABS) and the National Regulator for Compulsory Specifications (NRCS) play pivotal roles in the product conformity landscape of South Africa. The NRCS’s reluctance to adopt a surveillance-based model for ongoing compliance, such as the Type 5 Certification described in ISO/IEC 17067, may hinder South Africa’s ability to maintain a consistent standard of product safety and efficiency over time. As globalization intensifies, the need for South Africa to align with international best practices becomes more urgent. The SABS has a legacy of pioneering standards and can potentially reclaim its role as a guarantor of quality by advocating for more robust surveillance measures post-Type 1a certification. This would not only enhance the credibility of the SABS mark but also instill greater consumer confidence in South African products. Adopting comprehensive surveillance and auditing systems would demonstrate a commitment to excellence and help South African industries remain competitive in the international market while ensuring the safety and reliability of electrical products for all stakeholders.