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Technical collection

The use of conformity certification


for product validation

2007 - Conferences publications


P. Migaud
M. Vittoz
J-F. Rey

Schneider Electric 2007 - Conferences publications


THE USE OF CONFORMITY CERTIFICATION FOR PRODUCT
VALIDATION
Pierre MIGAUD, EDF R&D, (France), Pierre.migaud@edf.fr
Marc VITTOZ, AREVA T&D, (France), marc.vittoz@areva-td.com
J.-F. REY, SCHNEIDER ELECTRIC, (France), jean-francois.rey@schneider-electric.com

ABSTRACT
For MV and HV switchgear, Utilities (and generally speaking
Users) most often request a reliable demonstration of safety
and performances. The purpose of this paper is to describe
a way to adapt the concept of Product Certification to
electrical equipment for Transmission and Distribution
networks.
The main features of this certification scheme are :
o Independence based on the strong involvement of each
party : Manufacturers, End Users, Testing Laboratories
and independent experts,
o Competence based on Testing Laboratories,
o Certification scope limited to the conformity of the type of
product,
o International recognition through accreditation.
The main advantages of this system are :
o The organisation is cost effective,
o The organisation is time effective and flexible,
o Responsibilities are clearly split between
stakeholders,
o Certificates are well accepted.

the

KEYWORDS
Conformity Assessment, Testing, Laboratory, Certification,
Accreditation.

INTRODUCTION
Testing is only part of conformity assessment
Assessing the conformity of a product is part of the
relationship between the Manufacturer and the possible
Users of a product. For Medium Voltage and High Voltage
electrical equipment, assessment is based on the results of
tests in most cases. However, it is not only the result of a
single type test that allows to decide that a product fulfils all
the requirements of a specification.
Tens of type tests have to be performed, addressing various
sharp technical competences. Several samples of
equipment may be required to perform the complete list of
type tests. And when a range of products is concerned, it is
often cost effective to combine different tests with various
options of equipment in order to cover the whole range of
rated values with the minimum set of tests.
Some tests may fail (it is part of the game, otherwise testing
would be useless), leading to adjustments or improvements
of the product design. In such a case it is important to avoid

repeating the whole test series if possible, in order to


minimize costs and delays. Then technical competences
are needed to decide which tests have to be repeated
according to the necessary design adjustments.
Last but not least, identification of the product (or range of
products) is part of the conformity assessment. This is not
the less complicated task if the design has been updated in
the course of the testing process.
Consequently, assessing the conformity of a piece of
equipment is not only performing type tests, but also
defining the list of tests to be performed (or repeated),
interpreting test results with regards to the test conditions,
checking that drawings adequately represent the objects
under tests. The complexity of this activity is well described
by ISO/IEC Guide 67 (see table 1 in [1]). For the sake of
simplicity, we can split this bunch of tasks in two parts :
performing tests on one hand, and making a decision about
conformity on the other hand.

There are many


responsibilities

ways

to

split

the

As far as Testing is concerned, tests may be performed in


the Laboratories of the Manufacturer (called First Party) or
in the Laboratories of the User (called Second Party),
assuming such facilities are available. They are also often
performed by commercial Laboratories which are belonging
neither to the Manufacturer nor to the User (called Third
Party Laboratories).
As far as the decision is concerned, various situations may
be encountered :
o The Manufacturer may supervise the testing process
himself and finally attests the conformity of the object
This is First Party assessment.
o Some Utilities may demand to be involved in the
assessment process (witnessing tests, reviewing the test
results, attending the final expertise of the object after
tests, and so on). A given Utility may also rely on an
external consultant of his choice, or an assessment
panel made of several Utilities interested in the same
pieces of equipment. Those two cases are Second Party
assessment.
o Third Party Bodies may also offer services such as
supervising tests and reviewing test results. Amongst
these bodies, we may find Certification Bodies or
Inspection Bodies, as well as equivalent or alike bodies.
Some of these bodies may operate their own testing
facilities, while others may resort to separate
Laboratories to have tests performed (either Third Party
Laboratories, or Firsts or Second Party Laboratories in
some cases).

Schneider Electric 2007 - Conferences publications

Moreover, any combination of these various means of


assessment is also possible. There is no right or wrong
recipe. All is a matter of equilibrium between parameters
such as : the financial amount at stake (price per unit X
number of pieces), the possible impact of the piece of
equipment on the reliability of the network, the availability of
testing facilities, the availability of human resources and
competences of each Party, the sale strategy of the
Manufacturer, the purchase strategy of the Utility, and so
on
To the end, the responsibility always lies on the shoulders
of the Manufacturer who guarantees the rated
performances, and on the shoulders of the Utility who
intends to operate the equipment on its network for tens of
years hopefully. This is why it is often important for them to
keep an eye on the assessment process, being able to
make sure the Laboratories in charge of testing and the
Body in charge of deciding are correctly fitted to the
interests at stake.

An example of assessment system dedicated


to MV and HV products
The purpose of this paper is to describe an original solution
for conformity assessment, based on the general concepts
of certification and accreditation, involving each Party, and
tuned to fit the specific requirements of MV and HV
equipment. Such a solution that has been implemented in
France for ten years, may be chosen each time a Third
Party assessment is required.

FEW RECALLS ABOUT GENERAL CONCEPTS


The concept of Product Certification has been first
developed for mass products in order to remove technical
trade barriers. Accreditation is also intended on the same
purpose since it is a way to get international recognition.
The basis of both concepts is briefly recalled hereunder.

Product Certification
Product Certification is described by EN 45011 [2] that is
identical to ISO/IEC Guide 65 [3]. It is a broad concept that
encompasses all kinds of products (including processes
and services) and may be implemented in different ways,
including or not including : initial testing, assessment of the
suppliers quality systems, surveillance of the factory quality
system, subsequent surveillance testing of samples from
the factory, and son on (see Introduction in [2] or [3]).
It is important to keep in mind that the concept of Product
Certification ranges from certification systems based on
type testing, to certification systems including type testing
and surveillance of the manufacturing process. The choice
of a given system within this range depends of product
specificities and market needs.
It is important also to note that the scope of the standards
[2] and [3] is so broad that each Certification Body is
responsible to adapt the general requirements of the
standard to its specific domain of activity.

But in any case, all certification systems exhibit a common


feature that is to be operated by Third Party Bodies (being
both independent from the Manufacturer and from the
User).
The outcome of a Product Certification system is usually
called a certificate of conformity. It is important to avoid
confusion with look alike wordings that may be used for
designation of documents that do not result from a Product
Certification system.

Accreditation
According to the International Vocabulary [4], Accreditation
is a third-party attestation related to a conformity
assessment body conveying formal demonstration of its
competence to carry out specific conformity assessment
tasks. It is described by EN ISO/CEI 17011 [5].
According to European Regulation, Accreditation is a non
profit activity that is operated in each Member State by a
single national accreditation body (see article 4 in [6]).
Following these principles :
o a Laboratory that complies with ISO/IEC 17025 [7] may
be accredited according to this standard by an
Accreditation Body,
o a Certification Body that complies with EN 45011 [2] may
be accredited according to this standard by an
Accreditation Body.
In both cases, it is important to note the difference between
complying with and being accredited according to
that means providing an evidence of compliance with.
Only Accreditation provides a formal evidence of
compliance.
It is to be noted that Quality Requirements of ISO
9001:2000 are fully covered by ISO/IEC 17025:2005, as
stated in [8] : The management system requirements in
ISO/IEC 17025 (Section 4) [] meet the principles of ISO
9001:2000 Quality Management systems Requirements
and are aligned with its pertinent requirements. As a
consequence a Laboratory has no need for ISO 9001
certification if it is already accredited against ISO/IEC
17025.
On the contrary, it is important to mention that ISO/IEC
17025 goes further than ISO 9001, with additional
requirements for technical competence and metrology that
are specific to Laboratories.

SPECIFIC FEATURES OF MV/HV EQUIPMENT


The assessment schemes that have been tailored for mass
domestic products may not fit MV and HV network
equipment that have specific features. Amongst these
specific features, let us consider the main ones as follows :
o The ratio between the cost for testing (including the cost
of the object under tests) and the number of
manufactured products may be much higher for network
equipment than for domestic products. As a
consequence, it is more of all important to avoid useless
test repetitions.

Schneider Electric 2007 - Conferences publications

o Due to the investment amount requested for testing


facilities (especially facilities for power testing), few Third
Party Laboratories are available over the world. Apart
from the few Third Party Laboratories, the competence is
mostly available in the Manufacturers and the Utilities. As
a matter of fact, it is the case in France for instance, as
far as HV switchgear is concerned.
o Utilities are very much involved in the technical
assessment of the products for two reasons. First, some
pieces of equipment may have a strategic impact on the
energy network. Second, purchasing equipment is a long
term investment over at least 30 years and sometimes
more.
o Manufacturers of MV and HV equipment need to keep
control on their development and assessment process
and not depend on the availability of external
Laboratories.

A CERTIFICATION SYSTEM TAILORED FOR


MV AND HV EQUIPMENT
It is possible to design a certification system that takes
advantages of the general concepts as described above
(certification and accreditation) and that is tuned up to suit
the specific features of MV and HV electrical equipment.
For instance, such a solution has been implemented in
France for years in the shape of a unique combination of
partners, concepts, principles, and rules of operation. The
legal frame of the French Certification Body that comes out
of this combination is a non profit association involving
Manufacturers, Utilities and Third Party stakeholders
(Laboratories and Standardization Body).
Lets have a look at the main characteristics of the French
Certification Body :

Independence, impartiality and involvement


o Independence of the French Certification Body is
guaranteed by its constitution that grants a balanced
influence to each Party. In this case, independence
doesnt mean this Body is operated on commercial
purpose only and doesnt care about the possible
outcome of the certifications it performs. On the contrary,
Manufacturer and Utility members of the French
Certification Body, are very much concerned by the
results of the certification if they manufacture the object
under test, or if they intend to operate it for 30 years on
their network. This involvement is the guarantee that
each object under certification is thoroughly tested and
that results are deeply examined. Nevertheless the
equilibrium between the different Parties leads to a final
decision that is impartial in any case. Thus, involvement
and impartiality are the ground for independence.
o From a practical point of view, it should be noted that the
Three Party System exists at each level of this Body,
and not only on the top of the pyramid. From the
Technical Committee up to the Board of Directors, each
part of the French Certification Body has a balanced
management. Especially the Certification Committee is

composed of the three Parties : it is in charge of granting


or refusing certificates based on technical evaluation of
test results.
o There is a close relationship between this Body and the
Laboratories where the tests are performed. This
relationship is called homologation. The French
Certification Body is responsible for granting
homologation to a Laboratory for a limited period of time.
Periodical reviews are made to keep up homologation.
Accreditation according to ISO/IEC 17025 is one of the
requirements for homologation. Other requirements are
related to technical competence (for a given nature of
tests, on a given category of products), and rules of
operation that place the testing process under the control
of the French Certification Body.
o Homologated Laboratories may be Manufacturers
Laboratories or Utilitys ones. But in any case, tests are
supervised by the French Certification Body. Supervision
includes test program, test planning, witnessing,
identification of the objects under tests, and test reports.
Technical observers are selected and appointed by the
French Certification Body.

Technical competence
o Competence of the French Certification Body is made of
the competence of the members forming the Body. And
the core of the competence is located in their
Laboratories. This is the reason why technical experts
acting as observers and reviewers are chosen amongst
the teams of experienced test engineers of the
homologated Laboratories. This brings the guarantee
that competence of observers and reviewers is kept up to
date thanks to their everyday professional activity.
o Observers never come from the laboratory which is
performing the test. Observers always belong to a
separate Company.

Scope of activity in line with the needs of the


market
o The Product Certification System operated in France is
limited to the conformity of the type of product. It
corresponds to the column 1 in table 1 of ref [1]. It does
not include Surveillance. The reason for it is that MV and
HV are produced in small series (compared to domestic
mass products). Most Utilities operates themselves their
own schemes for Surveillance, taking into account their
return of experience.
o The scope of activity of the Body is not limited to IEC
standards. It includes also national standards and
specifications, not only French ones, but also German
ones or Italian ones for instance. It is a matter of fact that
large Utilities throughout Europe have their own
specification. So there is no reason to limit the scope of
activity to IEC.
o It is possible to issue a partial certificate covering only a
part of the requirements of a standard as far as the batch
of tests performed is consistent to demonstrate a given
performance (dielectric performance for instance). In

Schneider Electric 2007 - Conferences publications

such a case, the scope of the certification is clearly


mentioned on the front page of the certificate. Once
again, this answers to a requirement of the market since
Utilities are not always interested in getting the same
level of guarantee for the whole batch of tests of a
standard. Utilities may accept mere tests reports for
some tests, and focus their attention on the tests that are
the most strategic for them according to their application.

Recognition
The competence and independence of the French
Certification Body is recognized through its accreditation by
COFRAC (the French Accreditation Body) according to EN
45011 [2], [3]. It is a voluntary choice of the French
Certification Body to go through the accreditation process to
demonstrate its transparency and competence, and to enter
into a continuous improvement process.

Flexibility
Although it is made of very strict procedures, the whole
certification system that is operated by the French
Certification Body, remains flexible :
o The Body is opened to new members (Manufacturers,
Users, Laboratories) as soon as they fulfil membership
requirements,
o The French Certification Body offers services to any
client (not only members),
o The scope of accreditation may be extended to new
references, including specifications of Utilities,
o The amount of activity may be easily adjusted to the
yearly needs by calling skilled technical resources in the
Laboratories of the members,
o Personal involvement of the experts is an actual reality
since all technical experts involved in the certification
process are active in the Company members,
o The possibility to take into account the results of tests in
the Manufacturers Laboratory (assuming the whole
testing process in under control of the French
Certification Body) avoids tests repetition,
o Costs are restricted to the minimum since French
Certification Body is a non profit organisation,
o Additional cost related to supervision of tests, review of
test results, review of identification and impartial decision
process are justified by the added value of the
Conformity Certificate that is issued.

Results and experience


Such a Certification System has been existing for about ten
years in France. It runs for Low Voltage, Medium Voltage
and High Voltage equipment, but only MV and HV domains
are addressed within the scope of this paper.
Over the last ten years, the average number of issued
certificates for the sole MV and HV domains is about 25 per
year, and there is an increasing tendency up to 40
certificates some years. About 1/3 is strictly related to IEC
standards, while 2/3 are related to specifications based on
IEC. Certified products are MV switchgear, HV circuitbreakers and HV cable systems.
The End Users for these products are located both in
Europe and outside Europe. All these certificates have
always been well accepted by the Users and no reclamation
has been addressed to the Certification Body up to now.

FUTURE TENDENCIES
Although Certification is not the only way for assessing the
conformity of a product, Manufacturers and Utilities may
tend to rely more and more on Third Party assessment in
order to clarify the border lines of their responsibilities. But
the French example shows that this does not prevent them
from being involved in the process of assessment to keep
competence, impartiality and transparency at a high level.
What is important for a Utility is to get choice between
different offers in order to select the solution that fits the
best his need. This is true also for assessment schemes.
The development of Third Party assessment is a
complement to First Party assessment and Second Party
assessment. It allows the Utility to select the assessment
profile according to the stake.
As far as Certification is requested, there is not a unique
solution to erect a Third Party Certification System and the
French example is just one possibility. Other systems do
exist and may give also good results. But whatever the
organisation may be, it seems important that it fulfils the
deep needs of the market.
On that purpose, more the Utilities requirements will be
stated clearly (in terms of competence, transparency, scope
of activity), more will be the possibility to harmonize the
different existing schemes into a Mutual Recognition
Agreement. Such an Agreement is useful to avoid test
repetition and minimize cost and delay for assessment. It is
also useful to clarify the status of the various assessment
documents that are circulated on the marketplace.

REFERENCES
[1] ISO/CEI Guide 67, 2004, "Conformity assessment
Fundamentals of product certification,
[2] EN 45011, 1998, "General requirements for bodies
operating product certification systems,
[3] ISO/CEI Guide 65, 1996, "General requirements for
bodies operating product certification systems,
[4] ISO/IEC 17000, 2004, Conformity assessment
Vocabulary and general principles,
[5] EN ISO/CEI 17011, 2005, General requirements for
accreditation
bodies
accrediting
conformity
assessment bodies (cancels and replaces EN 45010,
1998).
[6] Commission of the European Communities,
2007/0029, 14/02/2007, Proposal for a regulation of
the European Parliament and of the council setting out
the requirements for accreditation and market
surveillance relating to the marketing of products
[7] ISO/CEI 17025, 2005, "General requirements for the
competence of testing and calibration laboratories.
[8] 601946.2005-08, August 2005, Joint ISO ILAC IAF
Communiqu