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Comments and Documents
Date/Time Commenter Comments Supporting Document
09/28/2017 12:51PM  Carol Tillman  Clarification is need for the following section of the proposed AR: Proposed AR Section 4 "Per IAF MD 2, section 2.4.2, “The issuing certification body shall not suspend or withdraw the organization’s certification following the notification that the organization is transferring to the accepting certification body if the client continues to satisfy the requirements of certification.” When extenuating circumstances (e.g., nonconformance, lack of payment, or client request) require suspension or withdrawal, the issuing CB shall follow its suspension or withdrawal process." Section 17021-1:2015 " Surveillance audits shall be conducted at least once a calendar year, except in recertification years. The date of the first surveillance audit following initial certification shall not be more than 12 months from the certification decision date." Therefore if a surveillance audit has not been held in a calendar year prior to the requested transfer - would the withdrawal date be 12/31/XXXX or something beyond the calendar year. If the CB has not conducted an audit in the 12 months - they are not meeting 17021-1:2015 requirements, but may be withdrawing a certificate before an effective transfer can be made.   
09/28/2017 2:31PM  Martin O'Connell  ABS Quality Evaluations has concern with the following text in the proposed rule: "it is recommended that the documentation be obtained from the issuing CB" due to non disclosure clauses in our legally enforceable agreement with the client. Depending the CB agreement with their certified client, it would require another complex agreement to release this type of information. To avoid this situation, ABS QE requests wording be change to: " the issuing CB will acknowledge that all certification documentation presented from the accepting certification body is complete and the certification is valid and eligible for transfer. This verification and acknowledgement shall occur in a timely manner." This acknowledgement will not violate non disclosure requirements contained in ISO 17021-1   
10/30/2017 2:35PM  Che Masters  The levels of accreditation and their significance could be better explained.