progress has been made in this regard. In 1994, both DoD and the General Services Administration (GSA) adopted policies permitting procurement officers to accept ISO 9000 registration in lieu of equivalent military and federal quality system standards.61 It is not yet clear, however, whether procurement officers will be required to accept such registration in every instance. In addition, federal regulatory agencies have not responded with similar changes in policy.
The growth of ISO 9000 and other quality system registration services worldwide has added substantial new cost and complexity to the conformity assessment framework illustrated in Figure 3-1. Work is now in progress to develop a set of international standards that have the potential, if similarly overused, to impose even greater waste and expense on U.S. firms. The ISO Technical Committee 207 is now developing environmental management system standards. U.S. industrial and government participants in the process are promoting the position that the committee should avoid a key flaw in the ISO 9000 standards—failure to include, within the standards, strict guidance to restrain inappropriate, excessive reliance on third-party registration by government and private parties.62
As this chapter has outlined, the U.S. conformity assessment system has expanded from declaration of conformity by the manufacturer to include third-party testing, certification, and quality system registration. These activities are illustrated in the first level of Figure 3-1. The system has grown, however, not only in the range of activities included, but also through the addition of new layers of assessment. The second level of the system framework is accreditation.
Accreditation is a procedure by which an independent party, the accreditor, evaluates and formally acknowledges the competence of a first-level conformity assessment body, such as a testing laboratory, product certifier, or quality system registrar. Accreditation activities arose in the United States in response to both private and public demands for assurance that conformity assessment organizations were competent.63 Just as the cost of third-party activities such as certification must be weighed against the need for formal product assessment, the cost of accreditation systems must be weighed against their particular benefits.
The need for accreditation is greatest when the user—a purchaser or regulator—of a conformity assessment service is not able to assess for itself the competence of that service's provider. A trusted accreditor can assist users in selecting testing laboratories, certifiers, and registrars. This removes the need for manufacturers, for example, to conduct their own costly and time-consuming evaluations of independent laboratories.64 Many large manufacturers require their suppliers' testing laboratories to be accredited as a condition for accepting suppliers'