Overview

On March 27th, 2020, the president of the National Institute of Metrology, Quality, and Technology - INMETRO announced actions in response to the coronavirus pandemic, aiming to ensure the continuity of conformity assessment activities for regulated products.

Key Resolutions

Based on SEI process No. 0052600.001384 / 2020-74, the following provisions are established:

Article 1: Alternative Conditions for OCPs

Alternative conditions are set for Product Certification Bodies (OCP) to conduct conformity assessments in manufacturing plants in countries affected by the coronavirus, including Brazil.

Article 2: Risk Analysis Requirement

1. The OCP must perform a risk analysis based on:

   • Records of the latest internal audits
   • Critical analyses from top management
   • Complaints handling procedures
   • History of non-conformities in testing

2. The OCP may choose to postpone maintenance or recertification audits under certain conditions:

   • I - Audit postponement by documented OCP decision does not impede the issuance of maintenance confirmation or recertification certificates within the specific RAC deadlines.
   • II - If postponed, the audit must occur within 6 months from the decision date, possibly requiring two in-person audits in the same evaluation stage.
   • III - Depending on the risk analysis, the OCP may decide to conduct a remote audit.
   • IV - During remote auditing, which may include “Complaints Handling” activities, the maintenance or recertification audit may be recognized as conducted, potentially bypassing the requirement for an in-person audit in item II.
   • V - If the risk analysis does not support postponement of the audit, or if conditions do not allow for remote auditing, the certificate must be suspended.

3. Tests can be executed by the manufacturer in accredited 1st or 3rd party laboratories in Brazil or abroad, under the ILAC Mutual Recognition Arrangement (ILAC MRA).

4. If justified, the DCO may issue the “Certification Maintenance Document” or a new “Certificate” without conducting the required tests, but must complete those tests within 6 months of the decision, which may require two rounds of testing in the same evaluation stage.

5. The same conditions apply to certifications of new families or new models.

6. Conformity assessment schemes published by INMETRO involving OCPs and Forest Audit Bodies under INMETRO Ordinance No. 235 are also encompassed by these established conditions.

Article 3: Compliance with PEFC Guidelines

The Chain of Custody Certification Bodies accredited under INMETRO Ordinance No. 512 must follow the guidelines in the PEFC document, “COVID-19: Guidance for certification bodies and certified companies,” to align the Brazilian Forest Certification Program - Cerflor with the PEFC standards it endorses.

Article 4: Additional Guidelines for Forest Management Certification

Forest Management Certification Bodies accredited under INMETRO Ordinance No. 547 must adhere to the provisions of Circular Letter No. 5/2020 / Dicor / Cgcre-INMETRO.

Article 5: Exceptional Conditions for Initial Certification

1. For initial certifications, the OCP may conduct a remote audit and decide the necessity of a subsequent in-person audit.
2. Testing may be performed in accredited laboratories as previously outlined.
3. If justified, the OCP may issue certificates based on tests not older than 6 months from the start of certification, provided relevant reports are equivalent as stated.
4. All initial certifications must comply with specific RAC tests within 6 months post-granting of the certificate, maintaining the testing requirement for the first maintenance assessment.

Article 6: Record Keeping

Records of all activities, analyses, and decisions per this Ordinance must be retained for INMETRO’s review upon request.

Article 7: Postponement of Test Reports

For Product Supplier's Declaration mechanisms, test report submissions are postponed for 6 months during maintenance or renewal, conditional on adherence to timelines previously established.

Article 8: Initial Registration Concession Waiver

Initial registration concessions under Product Supplier Declaration may waive certain test report submissions, with specified compliance within six months post-registration.

Article 9: Ordinance Validity

This Ordinance is effective from January 1, 2020, to June 30, 2020.

Article 10: Compliance with Technical Requirements

All technical requirements in INMETRO regulations remain mandatory for suppliers.

Article 11: Revocation of Previous Ordinance

INMETRO Ordinance No. 79, dated March 4th, 2020, is revoked upon publication of this Ordinance in the Federal Official Gazette.

Article 12: Effectiveness

This Ordinance is effective from the publication date in the Federal Official Gazette.

For more information, please contact info@orbiscompliance.com - mailto:info@orbiscompliance.com or (408) 465-7331.

Based on the Grupo Ibrace website.