Regulation for the accreditation of Verification Bodies verifying GHG (greenhouse gases) emissions

Title Regulation for the accreditation of Verification Bodies verifying GHG (greenhouse gases) emissions Reference RG-15 Revision 01 Date 2012-...
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Regulation for the accreditation of Verification Bodies verifying GHG (greenhouse gases) emissions









Authorization of issue

Application date

Director of Dept. of Certification & Inspection

Directive Council

The President



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CONTENTS 0.1 INTRODUCTION ..................................................................................................................... 3 0.2 SCOPE AND FIELD OF APPLICATION................................................................................... 3 0.3 REFERENCE STANDARDS .................................................................................................... 4 0.4 TERMS AND DEFINITIONS .................................................................................................... 5 0.5 ACRONYMS ............................................................................................................................ 7 1

REQUIREMENTS AND INFORMATION FOR ACCREDITATION ............................................ 8

1.1 GENERAL INFORMATION ...................................................................................................... 8 1.2 PRESENTATION OF THE APPLICATION FOR ACCREDITATION ......................................... 9 1.3 PROCESS OF ACCREDITATION.......................................................................................... 10 1.4 DECISION PROCESS AND GRANTING OF ACCREDITATION............................................ 11 1.5 RENEWAL AND SURVEILLANCE OF ACCREDITATION ..................................................... 12 1.6 EXTENSION OF ACCREDITATION ...................................................................................... 16 1.7 SUSPENSION AND WITHDRAWAL OF ACCREDITATION .................................................. 16 1.8 COMPLAINTS AND APPEALS .............................................................................................. 18 1.9 OBLIGATIONS OF THE VB ................................................................................................... 19 1.10 ACCREDIA’s OBLIGATIONS ............................................................................................... 19 PART 2 – REGULATIONS FOR VBs OF GHG INVENTORIES IN ACCORDANCE WITH UNI EN ISO 14064-1 ................................................................................................................................. 20 ANNEX 1 ...................................................................................................................................... 31 ANNEX 2 ...................................................................................................................................... 33 ANNEX 3 ...................................................................................................................................... 35 ANNEX 4 ...................................................................................................................................... 36 ANNEX 5 ...................................................................................................................................... 37 ANNEX 6 ...................................................................................................................................... 39 ANNEX 7 ...................................................................................................................................... 41 PART 3 – PROVISIONS REGARDING VBs OF GHG EMISSIONS IN THE MANDATORY SECTOR – EMISSION TRADING SCHEME (ETS) ...................................................................... 42 PART 4 – ACCEPTANCE CLAUSE .............................................................................................. 43 ANNEX A ...................................................................................................................................... 44


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FOREWORD The objective of ACCREDIA’s Department of Certification and Inspection is to make a contribution towards the creation of trust in the conformity assessment system, whose task is to assess and issue declarations of conformity for products, processes, management systems and personnel, in accordance with the requirements of the applicable national and international technical standards, with the objective of ensuring a consistent and effective approach by the operators of systems, promoting growth in competitiveness and productivity in Italy and greater well-being among its citizens. In order to achieve this, ACCREDIA’s Dept. of Certification and Inspection accredits Certification, Inspection and Verification Bodies (CBs, IBs, and VBs), verifying that they possess and continue to possess the necessary organizational, procedural, technical and professional requirements, so as to foster throughout the community and especially among consumers and end-users, a high level of trust in the value of the declarations of conformity which they issue. Along with these aims and in conformity with the policies of its statutory bodies – in order to ensure the effectiveness of the accreditation process and to guarantee behavioral consistency among accredited Bodies – ACCREDIA’s Dept. of Certification and Inspection has drawn up regulations and criteria for the application of general requirements for the applicable reference standards which are formalized by means of the present Regulation (as well as other documentation which is to be used together with the present Regulation).

0.1 INTRODUCTION To promote the effectiveness and credibility of the accreditation process it is necessary to introduce specific criteria which, without overlooking the spirit and the letter of the standards, function in favor of their thorough application by accredited Bodies, simultaneously constituting unequivocal, objective and impartial references for the assessments which ACCREDIA performs on them. This aim can be carried out thanks to the proper application of the present Regulation which was drawn up on the basis of the findings of a Working Group which represented a full range of those involved in accreditation and certification, and also the state-of-the-art of sector knowledge and experience.

0.2 SCOPE AND FIELD OF APPLICATION The present Regulation is applicable to the accreditation of VBs of GHG emissions. - in the voluntary field: for activities concerning the verification of declarations regarding the quantification and reporting of GHG emissions and of their removal, in accordance with UNI EN ISO 14064-1; - in the mandatory field: Emission Trading Scheme or ETS. Any additional prescriptions or prescriptions which are different from the present Regulation may be formalized for the VB in the form of a specific contract. This Regulation establishes the conditions and procedures for the granting, surveillance, suspension, withdrawal and renewal of accreditation of VBs, in accordance with the applicable standards and guides, with details and specifications in cases where the existing reference standards do not provide precise requirements.


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The present Regulation effectively constitutes a contractual agreement between ACCREDIA and the accredited Bodies whereby:


ACCREDIA undertakes, with objectivity, diligence, impartiality and professional integrity, the conformity assessment of VBs to the requirements of the reference standards and documents and, when the result is positive, to issue accreditation with the subsequent maintenance and renewal and also to place the Body on the register of accredited Bodies. The Body shall comply with the present Regulation and shall maintain conformity throughout the period of accreditation.


ACCREDIA has no obligations with regard to a positive output of assessments and therefore with regard to the issue, maintenance or renewal of accreditation. ACCREDIA has the responsibility to verify – within the limits of what is generally an assessment by sampling – that the VB possesses the necessary competences in terms of organization, procedures and other operative, human resources and instrumental documents, and that it is effective in the matter of audits and similar activities, for the proper fulfillment of its duties in accordance with the present Regulation and with any other relevant regulatory document. The VB is responsible to ensure full and systematic conformity with the above prescriptions at all times and in all its activities. The present Regulation consists of 4 related and complementary parts and one Annex, as follows: -

Part 1: the general conditions regulating the process of accreditation and related obligations; Part 2: the general regulations regarding the functioning of the VB against the standard UNI EN ISO 14065 for the audit of GHG emissions in accordance with UNI EN ISO 14064-1 (voluntary field); Part 3: the general references regarding the functioning of the VB for the audit of GHG emissions in the mandatory field: Emission Trading Scheme; Part 4: acceptance clause; Annex A: criteria for the imposition of sanctions.

The term “verifier” is used for personnel of the VB verifying GHG emissions. For ACCREDIA personnel the term “assessor” is used, abbreviated to AVI for a single assessor, RGVI for the Lead Assessor and GVI for the audit team or group. The present document is submitted to the Directive Council for approval under article 14 of the ACCREDIA Statute after being approved by the Committee for Accreditation Activity and it is issued with the authority of the ACCREDIA President.

0.3 REFERENCE STANDARDS The reference standards for the application of the present document are contained in ACCREDIA document LS-12 “Standards and documents for the accreditation of Verification Bodies”, in the current revision. Ongoing dispositions issued by ACCREDIA which are not contained in the present document or in the documents for the schemes must also be taken into consideration.


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The present Regulation, where applicable, also refers to the following ACCREDIA statutory standards and regulations, in their current version: -

The ACCREDIA Statute (ST); Regulation for the application of the Statute (ST-01); Regulation for the functioning of the Committee for Accreditation (RG-04); Regulation for the functioning of the Sector Accreditation Committees (RG-04-DC); Regulation for the functioning of the Sector Sub-committees for accreditation (RG-04-01); Regulation for the functioning of the Steering and Guarantee Committee (RG-05); Regulation for the functioning of the Appeals Commission (RG-06); Regulation for the use of the ACCREDIA accreditation Mark (RG-09); ACCREDIA pricelist (TA-00); Accreditation contractual agreement (CO-00) Application for accreditation (DA-00); Application for accreditation for Verification Bodies (DA-07); Applicable ACCREDIA Technical Regulations; Mandatory standards, where applicable; EA, IAF Documents and other schemes applicable to Verification Bodies.

For all ACCREDIA documents only the version currently in force is valid. All documents can be downloaded from the area of documents or of the Certification and Inspection Bodies from ACCREDIA’s website.


Accreditation: an attestation or declaration by a national accreditation body (AB) certifying that a conformity assessment body (CAB) fulfils the criteria set out in the harmonized standards and, where appropriate, any other supplementary requirement, including those defined in the relevant sector programs, to undertake a specific conformity assessment activity (Reg. CE 765/2008 Chapter 1, Art. 2, section 10).


National Accreditation Body: the sole Body in a Member State which is authorized by the Government to undertake accreditation activity (Reg. CE 765/2008 Chapter 1, Art. 2, section 11).


Conformity Assessment Body (CAB): a body which performs conformity assessment activities, including calibration, laboratory tests, certifications and inspections (Reg. CE 765/2008 Chapter 1, Art. 2, section 13). For the purposes of the present document a CAB is a Verification Body.


Verification Body: a body which carries out validations or verifications regarding GHG in conformity with the International standard (UNI EN ISO 14065 point 3.3.3).


Declaration of verification: a formal, written declaration for specific use, providing a guarantee concerning GHG on the part of the party which is responsible (UNI EN ISO 14065 point 3.3.5).


Audits: for the purposes of the present Regulation, as defined in standard ISO/IEC 17011 – “on-site audit”, referring to the various types of audit carried out by ACCREDIA (initial, supplementary, surveillance, renewal, planned or extraordinary) which are part of the process for the granting, maintenance and renewal of accreditation.


Witness audits: with regard to the present Regulation, as defined in ISO/IEC 17011, this means an on-site audit of the assessed entity conducted by the CAB’s inspectors in the presence of ACCREDIA assessors and, where necessary, experts.


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Findings: with regard to the present Regulation, the term “findings” is used for findings raised by ACCREDIA during audits performed at the VB and formalized in the subsequent audit report. A finding raised by ACCREDIA at a VB may derive from two situations: a) Failure to satisfy an applicable requirement resulting in a Nonconformity or in a Concern. b) The identification of an activity of the VB which is “weak or potentially a failure”, possibly resulting in a Nonconformity or in a Concern or the suggestion of ways of improvement. Such situations result in the raising of a Comment.


Nonconformities (NCs): a finding revealing the presence of a failure which: a) jeopardizes the reliability of results, activities, or services undertaken by the VB and/or, b) influences the capacity of the QMS of the VB to maintain the level of quality of conformity assessment activities, or indicates an interruption of the proper functioning of the QMS and/or, c) threatens the credibility of the accreditation procedure or the integrity of ACCREDIA and/or, d) highlights a failure to respect mandatory requirements. A nonconformity always requires corrective actions and subsequent evidence of the verification of the closure of such corrective actions before the decision regarding the issue or renewal of accreditation is taken by the Sector Accreditation Committee. The Committee may take a positive decision, depending upon the proper conclusion of the corrective actions. With regard to maintenance and renewal, the NC shall be closed within the fixed timeframe (see next paragraph below). An on-site visit may be necessary to verify the completion of the corrective actions or to establish if it is necessary to impose sanctions as described in § 1.7. Concern: a finding which does not affect or is not likely to affect, either directly or immediately, the quality of the performances and results of the VB. A Concern which is not resolved at the next due audit becomes a NC. This type of finding requires the opening of a treatment or corrective action within the given timeframe and verification during the next due visit, or else verification by means of documentary evidence undertaken by ACCREDIA when necessary.


Comment: a finding raised by ACCREDIA against a VB is classified as a Comment if the situation in question is not a failure to satisfy a requirement but it is intended to avoid this happening in the future (when this is a real possibility), and/or to give suggestions for the improvement of the documents or of the operative modalities of the VB. This kind of finding can be managed by the opening of a preventive action or an improvement or it may not be accepted and in this case the reasons have to be given and recorded.


Management of the findings by the VB: activities which are carried out by the VB in the case of findings raised and formalized by ACCREDIA. All NCs and Concerns raised by ACCREDIA, according to the above criteria, require treatment and/or corrective actions by the VB using the correct applicable actions on a case-by-case basis and approved by ACCREDIA. It is not necessary to respond immediately and formally to findings which are classified as comments, however the relevance of the indications provided by ACCREDIA can be verified by ACCREDIA during the first due audit. If such indications are not adequately verified, the Comment may become a Concern, with the application of the conditions as given above. As further clarified below in this Regulation, it is confirmed that when a NC exists, accreditation or the extension of accreditation are not granted, until there is confirmation of the implementation of the necessary corrections, the corresponding corrective actions have been closed and the relative checks have been performed by ACCREDIA to verify their effectiveness.


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Where NCs are identified during surveillance activities, the procedures specified in the pertinent paragraphs of the present Regulation apply. *

Accreditation scheme: set of rules, defined procedures and activities performed by ACCREDIA to grant, extend and maintain the accreditations relating to the various categories of certification activities covered by ACCREDIA accreditation and distinguished by significant differentiations for the purposes of the accreditation procedures: The present Regulation refers exclusively to the scheme regarding the accreditation of VBs.


Increased surveillance: minor sanction caused by negative evidence on the part of the VB consisting of supplementary or anticipated audit with respect to the regular surveillance, payable by the VB, to assess the effective implementation of treatments and corrective actions required within the established timeframe, in relation to a certain accreditation scheme or sector.


Termination of extensions of accreditation or granting new accreditations: minor sanction measure involving the termination of granting extensions of accreditation for a defined period of time, in relation to one or more accreditation schemes and/or sectors, as well as the termination of granting accreditation for new schemes.


Suspension of accreditation: sanction measure suspending accreditation of a VB for a complete accreditation scheme for a fixed period of time.


Withdrawal of accreditation: definitive provision for the withdrawal of accreditation for an entire accreditation scheme.


Implementation time: period between the date of issue (1st issue or revision) of any document of ACCREDIA regulations and the application date of such regulations.


GHG consultancy services: GHG quantification services for a specific organization or project; monitoring and recording of GHG data, information system regarding GHG or internal audit services or training with regard to GHG (UNI EN ISO point 3.1.3).


Technical (Compliance) Officer: person tasked by ACCREDIA to manage the various phases of appraisal for the purposes of accreditation, surveillance maintenance, renewal, extension, reduction, suspension or withdrawal of accreditation, coordinating the activities of the assessors.


Assessor: person tasked by ACCREDIA to perform, individually or as a member of a group, the assessment of a VB’s management system.


Technical expert: person tasked by ACCREDIA to supply specific knowledge/experience with regard to scheme assessment.

0.5 ACRONYMS - ACCREDIA–DC: Dept. of Certification and Inspection; - CSA: Sector Accreditation Committee; - DDC: Director of Dept. of Certification and Inspection Bodies; - VB: Verification Body; - FT: Technical Officer.


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Accreditation and subsequent listing on the Register are granted to Bodies that perform certification of conformity in accordance with the standards and documents applicable to them and detailed in the document ACCREDIA LS-03. Accreditation for audits of GHG inventories against standard UNI EN ISO 14064-1 is not issued on a sector basis.


The required conditions enabling a given VB to be accredited are as follows: •

that the VB conforms with the applicable requirements as defined in this Regulation, and with the standards and with the reference documents detailed in ACCREDIA document LS-03 and constantly maintains conduct based on correctness, transparency and collaboration with ACCREDIA;

that at the moment of the initial on-site audit, the VB: a) has been operative in the voluntary field, having issued declarations regarding GHG inventory verifications for at least 12 months. This is not applicable for VBs whose operations have already been recognized in the mandatory field of ETS (recognition issued by the national committee for the management and implementation of Directive 2003/87/CE and for support in the management of Tokyo Protocol activities.) b) that in the ETS mandatory field it has a contract for ETS verification activities.

The VB is obliged to have issued: in the voluntary field, at least 3 declarations of verification of GHG inventories. For recognized VBs in the ETS mandatory field, it is sufficient to have issued just one audit declaration of GHG inventories. Any exemptions, regarding special cases, shall be submitted to the CSA for deliberation.

The VB is also obliged to have transferred to its clients all the applicable obligations, by means of a contractual or similar document, including the acknowledgement of the right of ACCREDIA assessors to access the premises of the clients in question (in a witness visit at the VB), also at short notice. If this is not done the issue of the audit declaration will not be made or suspension or, in cases of persistent failure to fulfill these obligations, suspension or withdrawal sanctions will be imposed.

At the moment of the initial on-site audit at its location, the VB shall have completed at least one internal audit of its entire management system and have defined, when necessary, a plan for corrective actions. It shall also have undertaken at least one system review and, when necessary, planned the relative corrective and preventive actions. 1.1.3

The Body shall demonstrate, by means of an appropriate accounts document, (balance sheet or equivalent document with additional notes and management report) that it possesses or can obtain the necessary financial resources to undertake audit activities of GHG inventories for, at least, the


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next period of accreditation. Any sources of finance not deriving from audit activities shall be specified and shall not compromise the Body’s independence and impartiality. If the balance sheet does not provide this information, it shall be provided by means of other documents requested by the ACCREDIA management or assessors. All income not deriving from accreditation activities shall be detailed and presented. The Body shall also communicate to ACCREDIA by the end of June of every year, the following data regarding accredited activities in the voluntary sector, using the module available in the area for Bodies of ACCREDIA’s website: -

annual revenue for audit activities of GHG inventories; staff numbers involved in internal GHG inventories; number of GHG inventories audited; number of audit days per year for GHG inventory audits; number of T CO2s audited (GHG inventories).

Communications in the mandatory sector are covered by Reg. 600/2012/CE. ACCREDIA may extend these requests to other data such as invoices for training activities. Data concerning the calculation of the above parameters shall be kept available to ACCREDIA and to its assessors. 1.1.4

No member of the Body’s personnel shall provide or carry out consultancy activities, as defined in § 0.4. In the case of breaches of the above rules (see also Annex A, § A.5), sanctions are applicable as per § 1.7.


If the Body outsources activities concerning the accreditation scheme, it shall ensure that it can demonstrate that the provider of such services is competent and that, where applicable, is in conformity with UNI EN ISO 14065. The names of persons involved shall be communicated to ACCREDIA beforehand, with the application.




The application for accreditation of a Body shall be presented to ACCREDIA-DC using the modules DA-00 and DA-07, which are available on the website, together with the necessary documentation.. The application shall be complete and clear, providing all the information and data requested and giving reasons for any omissions which may result in the application not being accepted.


If all the attached documents are properly completed, within 30 solar days from the date of formal receipt, the FT, tasked by the DDC, formalizes acceptance and prepares a quotation for accreditation activity to be approved by the DDC and sent to the VB. If the application is incomplete or unclear or not all the conditions are fulfilled, within 30 days of receipt, the application is refused and, also within 30 days, the FT asks for the outstanding documentation to be sent. Any additional documentation shall be sent within two months, otherwise the application lapses. If the additional documentation is alright the application is accepted and the quotation is prepared.


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1.3.1 EXAMINATION OF DOCUMENTS Following acceptance of the quotation by the applicant Body, the accreditation procedure is sent with a detailed description of the documentation involved. The documentary examination takes place within 60 days of the date of acceptance of the quotation. If the outcome of the verification of the documents sent to the Body is positive, the performance of audits can begin. If the outcome is negative ACCREDIA-DC informs the applicant of the necessity to make the relevant changes to the documentation in the light of the findings raised. If the Body has not carried out the modifications after 3 months, the application lapses and a new one has to made, along with all the related costs and obligations. If, in order to reach a satisfactory situation, it is necessary to make more than two modifications after the initial documentary examination, the provisions contained in point become applicable. If it is evident from the documentation presented, or from direct contacts with the applicant Body, that the Body does not possess an adequate level of preparedness, ACCREDIA-DC sets out a minimum timeframe before a new application can be presented, given that the first one is deemed to have lapsed.

1.3.2 AUDITS Following a positive outcome of the documentary examination as above, the DDC prepares for the initial audit at the Body’s premises. The audit team shall include at least two ACCREDIA assessors. The objective is to verify that the operative activities of the VB conform with the present Regulation and every other general and sector or legal reference standard, as well as the regulations and procedures established by the VB itself and set out in its management system documentation (quality manual, regulations, procedures, instructions, control lists, personnel qualifications and so forth.) If one or more NCs are raised and formalized (as defined in § 0.4), the provisions contained in § become applicable. If the findings raised consist of Concerns or Comments, the process of accreditation continues by means of one, or more than one, witness audit/s. The sampling of activities for audit is performed in the voluntary sector taking into consideration the number and complexity of GHG inventories audited by the VB, and in the mandatory sector (ETS) taking into consideration the sectors given in Annex 1 of Reg. 600/2012/CE. The witness audit consists of the observation of the VB’s audit group during audit activities for GHG emissions (GHG inventories, or ETS in the mandatory sector) at the location of the audited or applicant organization. Witness audits have the following objectives:  

to verify the effectiveness of the VB’s procedures with particular regard to the use of inspectors with the necessary experience and competence; to observe the inspectors and their conformity with the Body’s procedures and with all other applicable reference standards.


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The witness visit permits an assessment of whether the Body has, in previous audits at the same organization, formulated a correct judgment of the assertion regarding the GHG inventory. In this way ACCREDIA can assess not only the performance quality shown by the VB, but also previous actions and, therefore, the capacity of the VB to consistently provide an audit service of the GHG inventories from an adequate level (quality of results.) Witness audits are conducted by at least one ACCREDIA assessor who may be assisted by an expert chosen from the list as per §, if necessary, to complete the competence of the audit team. In exceptional cases, justified by objective difficulties in the organization of witness audits, the DDC may authorize such audits in advance of the initial audit at the VB’s location. In these cases the accreditation process is suspended until the conclusion of the on-site audit phase at the VB. The names of the ACCREDIA assessors and experts, qualified according to ACCREDIA procedures, are given in the appropriate list. The names of the assessors and experts designated for inspection activities are communicated in advance to the VB; the VB has the right to object, subject to the terms specified in the communication, giving reasons for such objection in written form. The VB shall allow the ACCREDIA audit team members to gain access to its premises and to its documentation and shall give them the maximum co-operation. Likewise, the VB shall put in place measures which allow access by the ACCREDIA audit team members to the locations of the audited or applicant organizations. If, during the ACCREDIA audits (on-site or witness) one or more than one NCs are raised, the accreditation process is suspended. Suspension remains in place until confirmation is obtained of the implementation of the necessary corrections, completion of the corresponding corrective actions and the related evaluation to check their effectiveness is performed by ACCREDIA-DC. These actions are verified by ACCREDIA-DC by means of supplementary audits. The end-date for the implementation of the corrective actions and for the relative demonstration of effectiveness shall not exceed six months, otherwise the accreditation procedure will be deemed invalid. Supplementary visits may also be arranged after accreditation has been granted, if a significant number of findings classified as Concerns have been identified.




Following the performance of the above ACCREDIA audits and with positive results, the FT, in accordance with the procedures and using the modules in force, prepares a document summarizing the evaluations carried out (accreditation schedule). This is then submitted – with the proposal of the DDC – to ACCREDIA’s CSA, for the approval and implementation of the decisions taken. The above audits shall be conducted less than 15 working days from the date of the next due CSA meeting in order to allow a correct and complete preparation of the relevant documentation. The granting of accreditation is exclusively the task of the CSA which decides after examining the outcome of the inspection activities conducted by the Body. If the decision is negative, the CSA shall give reasons for its decision as it shall also do when it decides that supplementary audits are required or if other conditions are imposed.


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Accreditation can be granted only when payment to ACCREDIA-DC is made in accordance with the ACCREDIA quotation and with the ACCREDIA price-list. 1.4.2.

In the voluntary sector (GHG inventories) accreditation is to be understood as granted only and exclusively for each specific scheme and sector stated in the decision made by the CSA, without the identification of specific operative sectors. In the mandatory sector (ETS) accreditation is issued with regard to sectors as stated in Annex 1 of Reg. 600/2012/CE.


Accreditation is formally granted via a contractual agreement (CO-00) between ACCREDIA-DC and the Body, with the issue of the relative Certificate of Accreditation and the corresponding Annex containing the description of the scope of accreditation and with the placing of the VB on the Register of Accredited Verifiers and publication on the ACCREDIA website. Accreditation and the relative contractual agreement are valid for four years. The contract outlines all the provisions which concern the granting and use of accreditation, including the terms and conditions for the use of the ACCREDIA Mark, which are described in the relevant Regulation.


By signing the contractual agreement and registering as an accredited Body, the VB commits itself to retain its organizational structure and operative activities in conformity with the requirements of the present Regulation and with the applicable standards and reference standards.


With regard to reference to accreditation and, in particular, use of the ACCREDIA Mark, the VB shall comply with the applicable Regulation.


If accreditation is not granted the DDC informs the applicant Body within 15 days of the decision, giving reasons and conditions for continuing or for the resumption of the application process.



1.5.1 SURVEILLANCE OF ACCREDITATION GENERAL During the period of accreditation, ACCREDIA-DC, through the use of audits, carries out continuous surveillance activities of the accredited VB, by means of programmed audits (formally communicated as an annual surveillance program), and also by performing extraordinary audits (also at short notice), so as to ensure compliance with the present Regulation, with the international standards and guides and all other applicable reference standards. For the purposes of these audits, all the operative locations of the VB – such as the locations of organizations possessing audit declarations issued by the VB – shall be made accessible to the ACCREDIA audit teams. The VB shall communicate to ACCREDIA-DC the details of any updates made to its organization and to its documentation, with regard to the information and the data provided with the initial accreditation application, which entail significant changes in the resources and the procedures used for audit activities of the GHG inventories and for ETS audits. In particular, the VB is under an obligation to transmit the updated editions of the Quality Manual, the audit regulations of the GHG inventories and ETS audits, the controlled lists of


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qualified verifiers and the persons who are members of internal committees inspectors qualified for the various inspection activities and the names of members of internal committees. This documentation can be forwarded, either in hardcopy format or in electronic format. Alternatively, the documentation can be made available on a relative Internet website that can be consulted by ACCREDIA. Such documentation may be sent either in hardcopy format or electronically. Alternatively, the documentation can be made available on a relative Internet website that can be consulted by ACCREDIADC. Maintenance of accreditation depends upon due payment of sums owed to ACCREDIA-DC and in the ACCREDIA pricelist. PROGRAMMED SURVEILLANCE OF ACCREDITATION With regard to the audits programmed by ACCREDIA, in agreement with the VB by means of the technical/economic quotation sent by ACCREDIA by the end of January, the first surveillance activity consists of an audit at the VB’s location six months after the issue of accreditation. In exceptional cases the first surveillance may be postponed until 12 months after the issue of accreditation, if the VB has no new clients. The subsequent audits are carried out on an annual basis starting from the date of the first surveillance and this includes both on-site and witness audits. The on-site and witness audits are planned in such a way as to permit full coverage of the scope of accreditation over the four-year period of the accreditation agreement, and the type of audit (extent and duration) is fixed according to a number of factors such as: -

operative sectors in the ETS mandatory sector (sectors given in Annex 1 or Reg. 600/2012/CE); quality progress of the VB in the previous period; geographical area of operations; number and complexity of declarations/attestations issued and related increase; considerations regarding the relationship between revenue and the number of declarations/attestations issued; knowledge on the part of ACCREDIA of the VB’s inspectors; complaints or remarks received by ACCREDIA.

In order to perform more effective surveillance witnesses, ACCREDIA-DC reserves the right to choose the VB’s audit group as well as the organization to be audited. ACCREDIA-DC will carry out the same number of audit days at the location of the VB as the number of unplanned audits. Other types of audit at the location of the organizations may be decided by ACCREDIA-DC, (e.g. post GHG verification review). UNPROGRAMMED SURVEILLANCE OF ACCREDITATION Starting with the annual program as above, surveillance activity (on-site and witness visits, control and market surveillance visits) may be increased according to the behavior of the VB with regard to the above factors. Supplementary and/or special audits, also performed as witnesses, may be deemed necessary by ACCREDIA-DC after the granting or extension of accreditation following the signaling of an inadequacy by ACCREDIA or following written and objectively justified communication received by ACCREDIA. Such situations are communicated instantly to the VB which is required to deal with the findings and to eliminate their causes and, if necessary, to communicate that it will carry out a specific audit.


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For such audits, which are to all intents and purposes special (or extraordinary) audits, minimum notice of 7 working days is given, during which time the VB may exercise its right to raise an objection to the choice of ACCREDIA’s audit team members. Another form of special surveillance visits are those (both on-site and witness) performed in the context of the annual program set out by the DDC and submitted to the CSA for approval. The cost of special audits (on-site, witness, control or market surveillance) is met by the VB only in cases where NCs or a significant number of Concerns are raised. In other cases the cost is met by ACCREDIA as part of the approved annual budget.


The results of the above surveillance activities are analyzed by the FT, drawn up in a report by the ACCREDIA assessors and analyzed by the ACCREDIA management. After this, the procedure is as follows: a)

If there are no NCs the maintenance of accreditation is confirmed by the recording of the results together with the related request for treatment and corrective actions for any Concerns raised.


If there is one, or more than one, NC it is examined and confirmed to the VB by the DDC. In critical cases the matter is submitted to the CSA as a critical case for consideration. In other cases treatment and corrective actions shall be implemented by the VB, usually within 2 months. If the corrective actions have not been properly implemented, the case is submitted to the attention of the CSA. In cases of NCs as described in the present Regulation and further described in Annex A, the ACCREDIA management, in agreement with the President, imposes sanctions of a minor nature in accordance with § 1.7 below. c) If a particularly critical NC is raised due to a high number of infringements and breaches which reflect improper and/or unprofessional behavior on the part of the VB, the file is submitted directly to the CSA for the imposition of major sanctions: reduction, suspension or withdrawal of accreditation.


Reference should be made, in all cases, to Annex A with regard to the imposition of major sanction provisions.

In case b), the treatments and corrective actions requested shall be implemented, normally within 2 months, otherwise the measure will be converted from a “minor” to a “major” sanction measure. In the case of suspension of accreditation (c), such implementations shall be put into place within the timeframe described in § 1.7.2. VARIATIONS TO THE FIELD OF ACCREDITATION If the reference standards used by the VB for GHG inspection activity, as given in the certificate of accreditation, are updated or changed in any way, ACCREDIA verifies such modifications in compliance with the regulations issued by the appropriate Bodies (ISO, IAF, EA etc.) or in compliance with those issued by ACCREDIA itself. The results of such verifications are submitted to the CSA for deliberation.


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1.5.2 RENEWAL OF ACCREDITATION PROCESS OF RENEWAL OF ACCREDITATION At least six months prior to the expiry of the four-year accreditation period, ACCREDIA-DC enacts the procedure for renewal (in agreement with the VB through the technical-economic quotation) which takes place with a full document review (with costs met by the VB) and with an on-site and a witness audit where necessary. The outcome of the renewal audit is analyzed by the FT together with a review of the operative activities of the VB in general during the four-year period, including the data regarding the monitoring activities of the VB conducted by ACCREDIA (client complaints, market complaints and suchlike.)


The FT, in accordance with the procedures and modalities in force, prepares the document summarizing all the inspections carried out in the period of accreditation (accreditation schedules – renewal) and this document, with the proposal of the Department Director, is submitted to the CSA for the approval of the decisions taken. The above audits shall be concluded not more than 15 working days before the next due CSA meeting so that the documentation can be fully prepared. The issue of renewal is exclusively the task of the CSA, which deliberates after examining the output of the analyses carried out. If the outcome of such examination is negative, accreditation is withdrawn and the contents of § become applicable. The CSA shall record the reasons for such decision, as it shall also do when it requests additional supplementary audits or imposes other conditions. If renewal cannot be granted, the DDC communicates as such to the VB within 15 days of the decision, giving reasons and conditions required for the resumption of the renewal of accreditation process. If the renewal audit is conducted too near in time to the CSA meeting, the validity of the accreditation may be extended by the Department Director or by the CSA beyond the expiry date as far as the subsequent CSA meeting after expiry. Renewal, however, shall not be granted over 5 years after the initial date of accreditation. Following the granting of renewal, the accreditation certificate is updated, a new contractual agreement is signed and the register of accredited Bodies is updated. Renewal of accreditation is granted subject to payment to ACCREDIA in accordance with economic conditions presented by ACCREDIA-DC and agreed on the basis of the ACCREDIA price-list.


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1.6.1 GENERAL INFORMATION In the voluntary sector (GHG inventories): The extension of accreditation to other sectors is not provided for: accreditation is issued only for the scheme, as long as the VB uses competent verifiers for all sectors of activity in which it operates (e.g. issuing quotations for GHG verification activities.) In the mandatory sector (ETS): Extension of accreditation is issued with reference to the sectors given in Annex 1 of Reg. 600/2012/CE.



1.7.1 MINOR SANCTIONS MEASURES If the on-site or witness audits – undertaken as part of surveillance activities or extension procedures of the scope of accreditation – provide clear evidence of situations which may compromise the reliability of the inspection activity results issued by the Body, together with the supplementary activities related to the verification of adequacy and effectiveness of the corrective actions, the ACCREDIA management, in accordance with the President, can impose minor sanctions as described below: -

increasing the assessment activity performed by ACCREDIA; termination of requests for accreditation to other schemes for a fixed period of time; obligation of suspension or withdrawal of declarations of audits unduly issued (with re-issue in the light of the necessary implementations required).

These minor sanctions are communicated to the AB by letter, signed by the ACCREDIA President and subsequently published on the ACCREDIA website (without further details). They are communicated to the CSA (which may review the case) and also brought to the attention of ACCREDIA's statutory Bodies (Directive Council and the Control and Guarantee Committee) with all the relevant information.

1.7.2 MAJOR SANCTIONS MEASURES If critical situations emerge following surveillance, supplementary, special or renewal audits, or from other controls and appraisal activities – either of a technical or of a professional nature – ACCREDIA, depending on the gravity of the case, imposes the reduction (temporary or permanent) or the suspension or the withdrawal of accreditation. The following situations are among those regarded as particularly critical: * * * * *

failure to remove the causes of the imposition of minor sanctions and failure to related obligations; failure to resolve NCs in accordance with ACCREDIA procedures; failure to manage complaints; improper use of the ACCREDIA Mark; cases in which the VB does not permit ACCREDIA to carry out audits, as set out in the present Regulation.


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In conformity with the statutory and regulatory standards, the imposition of major sanctions takes place after a decision by the CSA. Where necessary the President or the General Director of ACCREDIA may convene extraordinary meetings of the CSA to decide with regard to the suspension or withdrawal of accreditation of a VB. Decisions taken by the CSA are communicated to the VB by recorded delivery post and signed by the President. The duration of the measures for the temporary reduction and suspension of accreditation is established by the CSA (in accordance with the constraints detailed below), concurrently with the decision relating to the measure. The suspension of accreditation does not mean that the contractual obligations towards ACCREDIA also terminate. Suspension is revoked when the VB has shown that it has removed the causes leading to the imposition of sanctions. If this is not done the sanction automatically becomes a withdrawal of accreditation. During the period of suspension, the VB shall not issue new declarations of audits under ACCREDIA accreditation and it shall conform with the ACCREDIA Regulation RG-09 concerning use of the ACCREDIA Mark. Suspension of accreditation may be applied automatically by the ACCREDIA management if payment owed to ACCREDIA is delayed by more than 60 days from the date specified in the contract (payment date specified in the invoice) and also after a reminder has been sent by ACCREDIA after 45 days. Exception is made if an agreement for deferred payment has been reached and approved by the ACCREDIA management. The suspension measures are published on the ACCREDIA website and an entry is made in the Register of accredited Bodies and anywhere else applicable. Accreditation is withdrawn in the following circumstances: * * * *

failure to remove the causes which of the suspension sanction, within the foreseen timeframes; damaging or seriously unprofessional conduct in terms of professional ethics; failure to make obligatory contractual payments leading, if the VB fails to pay after 6 months from the communication, to the automatic suspension sanction; use of accreditation such as to cause serious damage and discredit to ACCREDIA and/or to the accreditation system and verification of GHG emissions.

Accreditation also lapses in the event that the VB terminates its activity, due to winding up or bankruptcy, and in the case of renunciation of accreditation on the part of the VB. Following withdrawal or expiry of accreditation the VB shall immediately stop issuing audit declarations with references to ACCREDIA accreditation and it shall return to ACCREDIA the original certificate, refrain from using any copies or reproductions of the certificate in question, and it shall comply with the provisions detailed in the Regulation relating to the use of the ACCREDIA Mark. Withdrawal or expiry of accreditation are published on ACCREDIA’s website. The name of the VB is cancelled from the register of accredited Bodies and anywhere else applicable. In the event of withdrawal of accreditation the Body cannot submit a new accreditation application before twelve months have passed from the date the withdrawal was imposed. The sanction measures as detailed in § 1.7.1 and § 1.7.2 above, can be cancelled before the established end-date (if applicable) and only after the VB has demonstrated that it has removed the


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causes of the NCs which resulted in the imposition of the sanction and after approval of the Body which imposed the sanction. Withdrawal of accreditation does not result in the forfeiture of contractual commitments with ACCREDIA which has the right to carry out forcible collection and recovery of expenses, with interest, in accordance with the law.

1.7.3 SUSPENSION REQUESTED BY THE VERIFICATION BODY If the VB considers itself to be, for whatever reasons, in a situation of nonconformity against the reference standards and regulations for accreditation, it may make a request to the ACCREDIA management for selfsuspension for a period of time sufficient to return to conformity and not greater than 12 months, otherwise self-suspension will automatically become withdrawal. The reasons and duration of the self-suspension are evaluated by the Department Director who may modify the conditions and timeframe for the return to conformity, conducting the necessary appraisals for such return to conformity at the end of the period of self-suspension. The CSA is informed regarding the self-suspension, as well as the other statutory Bodies in accordance with the applicable procedures and the information is published on the ACCREDIA website and on the register of accredited Bodies.

1.7.4 RENUNCIATION OF ACCREDITATION An accredited VB may renounce accreditation at any moment in time and for any reason, such as non-acceptance of changes to the price-list or modifications to the regulations governing accreditation etc.. Accreditation lapses along with the relative obligations 60 days after the communication of renunciation. During this period the VB shall fulfill its obligations by safeguarding the rights and interests of its client organizations, the transfer of certifications to another accredited Body. Renunciation of accreditation does not result in the forfeiture of contractual commitments with ACCREDIA which has the right to carry out forcible collection and recovery of expenses, with interest, in accordance with the law.



1.8.1 COMPLAINTS Complaints relating to ACCREDIA-DC operational activities (for example: the conduct of assessors, procedures for managing files, alleged unfair treatment, etc.) are to be formally submitted in writing and are to be addressed to the ACCREDIA DDC who will manage the complaint in accordance with the applicable procedures, always replying to the complainant within one month.

1.8.2 APPEALS If the accredited or applicant VB wants ACCREDIA to reconsider measures taken against it, it may present an appeal using the modalities described in the ACCREDIA general regulation RG-06.


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The VB shall pay the annual accreditation maintenance fee in accordance with the price-list.


The VB shall permit audits to be carried out by ACCREDIA’s audit teams on-site and at the locations where inspection activity takes place.


The VBs shall communicate to ACCREDIA any significant changes in their set-up, transfer of ownership of accreditation to a new legal person or entity, any change to the legal status or ceding of activities to another VB. In such cases ACCREDIA has the possibility of carrying out all necessary evaluations to ensure permanence of the conditions of accreditation, including the examination of statutory or any other applicable documentation concerning the following: - statutory norms and regulations; - organizational set-up; - human resources (in terms of quantities and competences); - any other applicable condition.

1.9.4 Everything which is not specifically covered by the present Regulation, the contents of article 4 of the contractual agreement, CO-00 are to be considered applicable and valid.



1.10.1 In cases of variations to the conditions of accreditation such as modifications to reference standards or regulations or standards concerning certified entities, ACCREDIA-DC communicates as such to the VB which may retain accreditation, adapting accordingly its organization and operative functions within the timeframe set by ACCREDIA, or else it may renounce its accreditation. It is ACCREDIA’s task to renew the contractual agreement with the VB. 1.10.2 If accreditation is retained the ACCREDIA-DC can carry out audits to ascertain the proper implementation of the actions requested. 1.10.3 In cases of modifications to the price-list, even if the quotation has been accepted, services will be invoiced at the cost as it stands when the activities are performed. If costs are changed, immediately after approval by the Inter-ministerial Surveillance Commission, the VB is promptly informed of such, bearing in mind that the updated price-list will be published on ACCREDIA’s website. The VB has the right to renounce accreditation within six months of the receipt of such communication. During the six-month period of notice of the VB, the price-list applied is the one which was valid before the modifications, solely for the activities undertaken until the moment of renunciation. 1.10.4 ACCREDIA-DC shall periodically update the register of accredited Bodies and make sure that it is available to the public on ACCREDIA’s website. 1.10.5 In the case of owner schemes ACCREDIA-DC shall load on specific databases all the necessary information concerning accredited VBs. 1.10.6 Everything which is not specifically covered by the present Regulation, the contents of article 3 of the contractual agreement, CO-00 are to be considered applicable and valid.


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PART 2 – REGULATIONS FOR VBs OF GHG INVENTORIES IN ACCORDANCE WITH UNI EN ISO 14064-1 Part 2 contains a series of requirements regarding the organization and operation of VBs, with which the Bodies are under obligation to conform in the framework of conformity with the applicable standard references. To help to understand the references and indications contained in the text below, reference is made to the numbering used in UNI EN ISO 14065, in which the title are printed in bold. Title and subtitles relating to UNI EN ISO 14064-3, in bold italics are numbered adding a progressive number after the point number of the standard UNI EN ISO 14065 to which it refers. The original number of UNI EN ISO 14064-3 is given in brackets. The provisions of IAF MD-6 are not given in this Regulation. The new parts of this Regulation are in normal characters, preceded by the letter R, and followed by the main section number of UNI EN ISO 14065 (or of UNI EN ISO 14064-3) and by a further progressive number. In addition to UNI EN ISO 14065 the present Regulation is based on the standard UNI EN ISO 14064-3 and on the IAF Guidance MD-6 which is a general interpretation of ISO 14065. Considering the similarity with the audit activities of European emission trading (ETS), the content of the mandatory document EA-6/03:2010 has been taken into account for the recognition of verifiers in accordance with the EU ETS Directive, published by EA. Note regarding the text The word “shall” is used with reference to the requirements of standards and normative documents to mean an obligation; “should” is used for an action by the VB which provides a further assurance regarding the conduct of activities and, specifically in this Regulation, for GHG inventory audits. Departures from these rules are permitted only after an explicit acceptance by ACCREDIA of alternative modalities with which the VB demonstrates its conformity with the requirements of the relative sections of UNI EN ISO 14065 and the approach given in the corresponding Guidances. Where an individual section contains the wording ”no particular rule of accreditation”, it means that only the requirements of UNI EN ISO 14065 are applicable. In the case of translation from the original English standard or document, the original version is to be considered the definitive one.


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3 – DEFINITIONS GHG related program:

voluntary or obligatory system or scheme - international national or sub-national - which records, accounts or manages emissions, removal, reduction of emissions, or increases of GHG removal outside the organization. (ISO 14064-3:2006, point 2.16] Note: an example of a GHG program is the Directive 2003/87/EC of the European Parliament and Council, also known as the EU ETS (Emission Trading Scheme)

Nonconformities (NCs):

failure to meet one, or more than one, requirement of the GHG program, of the GHG monitoring program, of other requirements regarding the GHG inventory; documentation failure regarding data and information related to the inventory involving single errors, omissions, untruthful statements or the aggregation of such in the assertion regarding GHG which, in the opinion of the verifier, could influence the decisions of users. NCs shall be documented in the audit report.

Monitoring program:

management procedures for information related to GHG in accordance with point 6.1 of UNI EN ISO 14064-1

Elements of calculation:

input data used for the quantification of GHG emissions and removal, e.g. 0% carbon, emission factors, oxidation, lower calorific power


group, company, enterprise, body or institution, part or combination of such, public or private association, possessing a functioning structure and administration (UNI EN ISO 14064-1, point 2.22) Note: in the present document the term “organization” includes the manager and operator used for the EU ETS.


single plants, set of plants or productive processes (fixed or mobile) which are within a single geographical area, an organizational unit or a productive process (UNI EN ISO 14064-1 point 2.21).

4 - PRINCIPLES No particular rule of accreditation.


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5 - GENERAL REGUIREMENTS 5.1. – Legal status R.5.1.1 In conformity with the present Regulation, only organizations can be considered to be VBs, and therefore single verifiers cannot be included.

5.2. – Legal and contractual matters R.5.2.1. The VB shall clearly indicate in its contractual documents the request for authorization with regard to an organization to have access to all the operator’s plant area/s and to information relevant to the audit. Any exclusion from area/s due to safety provisions shall be clearly indicated in the contractual documentation.

5.3. – Government and management commitments No particular rule of accreditation. 5.4. – Impartiality 5.4.1 – Commitment to impartiality R. The impartiality and independence of the VB shall be guaranteed on three levels: a – strategy and policy; b – audit activities; c – the certification decision.

5.4.2 – Avoiding conflicts of interest R. A VB or another party belonging to the same legal entity, is not allowed to offer or carry out the following services: Consultancy services aimed at the development or maintenance of methods and systems for monitoring GHG emissions in voluntary schemes or in the ETS mandatory sector; b) Other consultancy services or technical assistance where economic dependence on specific audit activities could compromise the independence of the VB. a)

R. The VB shall show how it conducts its activities in such a way as to eliminate all conflicts of interests and to reduce as much as possible the risks to impartiality. Such measures include both internal activities and activities of associated bodies, sub-contractors and experts/verifiers. R. Personnel who have been engaged in consultancy activities shall not undertake activities under accreditation if the consultancy activities in question were performed less than two years previously. The VB is obliged to evaluate situations of potential conflicts of interests and to guarantee impartiality. R. The VB shall explain the Concerns and NCs and the requirements but it may not suggest solutions or consultancy as a part of the audit. R. Training courses carried out by the VB are not considered as consultancy activities.


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5.4.3 – Mechanisms for the monitoring of impartiality R. If an independent committee is chosen as an independent method for safeguarding impartiality it must include all the parties with an important interest in the system. It is essential that all the parties can take part and that a balance of interests is created so that no particular prevalence prevails.

5.5. – Responsibilities and financial resources No particular rule of accreditation.

6 – COMPETENCES 6.1. – Management and personnel R.6.1.1. The VB shall create and implement procedures concerning the responsibilities for the various levels and members of the staff, including the qualification criteria of the verifier, the Lead Auditor, the experts (the technical competences and the specific experience) and for the issue of audit declarations, as well as for other personnel needing different levels and competences. R.6.1.2. The procedures shall include an analysis of the training needs to maintain an adequate level of competence.

6.2. – Competences of personnel R.6.2.1 The verifier shall demonstrate that the following requirements are met: 1) Reference standard Knowledge of the standards: a) UNI EN ISO 14064-1; b) UNI EN ISO 14064-3; c) UNI EN ISO 14065; d) IAF MD 6; e) Other applicable GHG programs. 2) Audit methodologies Training and experience in GHG audits: a) successful participation in a GHG verification course (Annex 7); b) participation at not fewer than three audits related to GHG emission quantities (UNI EN ISO 14064-1, GHG protocol, ETS and CDM). 3) Data and information audit: a) extensive knowledge of the principles of monitoring and reporting of data, of the verification of uncertainties, of the concept of relevance (Annex 1), of the principles of the calculation of data, of the use of electronic systems for processing data, of the quality guarantee in the processing of data and of possible errors; b) the ability to understand the range of measurement and calibration processes; c) the ability to prepare an audit pan, to identify errors in reported data and to decide if they are correct; d) the ability to identify the effectiveness of the control system as an input for strategic and risk analysis;


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4) Emission elements - general: Basic knowledge of technical, environmental and energy factors regarding emissions. R.6.2.2 Audit team leader The RGVI must possess all the competences of the verifier as given in the above point as well as the ability to manage an audit team. S/he must also have participated in at least one of the three audits (point 6.2.1) related to the quantification of GHG emissions (UNI EN ISO 14064-1, GHG protocol, ETS and CDM) and as RGVI under the supervision of a qualified RGVI. R.6.2.3. Expert The expert must show competence in areas specifically related to monitoring GHG emissions. Within the specific technical sector process or activity, the expert must also show as follows: a) thorough and updated knowledge of the equipment for Energy conversion and of measurement activities including the risk of accidents and undesired emissions; b) knowledge of the audited processes especially with regard to energy conversion or GHG emissions related to production processes and the calculation of CO 2 emissions or other GHGs. c) knowledge of the background of all the information concerning individual sources of emissions related to organizational activities, especially regarding the gathering, measuring (including the calibration), calculation and presentation of data; d) knowledge of raw materials, intermediate products and production where CO 2 or other GHG emissions are relevant; e) knowledge of the mapping and the instruments of analysis related to emissions.

R.6.2.4 Officer in charge of the issue of the audit declaration Person/s who, based on the reports of the RGVI and other documents, take decisions regarding the issue of an audit declaration with a positive result (reasonable or limited) or not, must show adequate knowledge of: a. the standard involved (UNI EN ISO 14064-1); b. the audit procedures of the VB; c.

basic technical sector competences (it is possible to resort to other experts when necessary).

The level of competence of a RGVI is normally considered sufficient with regard to decisions for the issue of the audit declaration.

6.3. - Personnel R.6.3.1 The GVI shall consist of at least one RGVI.

6.4. – Use of contracted verifiers No particular rule of accreditation. 6.5. – Registration of personnel No particular rule of accreditation.


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6.6. - Outsourcing No particular rule of accreditation.

7 – COMUNICATIONS AND RECORDS 7.1. – Information given to the client or to the party in question No particular rule of accreditation. 7.2. – Communication of responsibilities to the client or to the parties in question No particular rule of accreditation. 7.3. – Confidentiality No particular rule of accreditation.

7.4. – Information which is publicly accessible No particular rule of accreditation.

7.5. – Records No particular rule of accreditation.

8 – AUDIT PROCESS 8.1. - General No particular rule of accreditation.

8.2 – Preliminary obligations 8.2.1 – Impartiality No particular rule of accreditation.

8.2.2 – Competence No particular rule of accreditation.

8.2.3 – Agreement R. In order to make a quotation the VB shall obtain, at the minimum, information as follows: a. b. c. d. e.

a description of the organization; activities, emission sources and typologies; a description of the processes and technologies used; the location/s where information concerning the emissions is kept; the extent of the inventory in terms of other indirect GHG emissions (Scope 3).

R. Quotations shall be approved by qualified staff before issue.


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R. The VB’s contract with the organization shall include requirements whereby the organization: a. makes the necessary preparations for the on-site audit, allows access to documents, areas, records and audit personnel; b. does not use the audit report in a misleading way; c. gives a written confirmation that all the data and information are available as they should be. R. The contract shall foresee the possibility to increase the duration of the audit if necessary after a strategic or risk analysis and if a critical NC is raised due to insufficient data or errors in the database. R. The VB shall review the contracts for each audit request. The review shall include as follows: a) the definition of the scope of the audit, taking into consideration any accreditation of the VB; b) a verification of the risk related to the audit (see Annex 1); c) documentation guaranteeing that the VB shall conduct the audit taking into consideration such risks. d) analysis of competences for the appointment of the GVI; e) definition of the timeframe and documentation. The review shall contain evidence of approval on the part of an appointed and qualified member of the VB’s personnel before the organization has been informed of the acceptance for the conduct of the audit. R. in setting out the timeframe the VB shall consider also factors regarding the complexity of the organization and its plants, the agreed level of guarantee and the complexity of the processing of data in accordance with Annex 3. R. The VB shall keep records regarding the above.

8.2.4 – Appointment of the RGVI No particular rule of accreditation. 8.3 - Approach 8.3.1 – Choice of the audit team No particular rule of accreditation. 8.3.2 – Communication with the client R. The VB shall communicate the names of the GVI to the client with a margin of time sufficient to allow for any substitutions following a reasoned objection by the client. R. Apposite procedures shall be available to indicate how the requests of communication by the parties in question or the Accreditation Body.

8.3.3 – Planning (4.4.1) - General R. The audit is based on a strategic analysis of the organization’s activities and their importance with regard to emissions.


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R. The strategic analysis includes a review of the documents and, where necessary, interviews or visits with regard to the organization to clarify the scope and complexity of the audit activities.. R. The strategic analysis shall be done by competent personnel and shall consider the following factors:

a) the organization’s control system for the identification and control of risks in the processing of data which could result in data errors in the GHG assertion;

b) any changes at the plant during the year (personnel structure of the organization, changes to products or to production or processes) if the organization’s inventory had been audited on a previous occasion;

c) any management system which the organization adopts concerning the management or processing of emission data;

d) typology, scope and complexity of equipment and processes used to generate emissions, including methods of calculation;

e) the level of importance defined by the organization. R. The result of the strategic analysis shall be filed and recorded together with other information obtained by strategic analysis in the records of the VB. R. On the basis of the results of the strategic analysis the VB shall perform a risk analysis (identification and verification of uncertainties/errors in the emission base of the organization and their importance regarding the result in the quantification of emissions) which, as a minimum, shall include as follows: a) total emission with regard to individual emission sources; b) complexity of the processes of the organization and of the plants; c) adequacy of the management system, of the data processing system and of the control system; d) information regarding previous evaluations at the organization’s location. The risk analysis constitutes an information input for the preparation of the audit plan. R. The VB shall keep the documents related to the risk analysis. (4.4.2) – Audit plan R. The audit plan must be based on the risk analysis undertaken beforehand by the VB. R. The VB shall include the following activities in the audit plan: a) audits of the organization’s locations and of the emission sources; b) interviews with personnel; c) review of documents and data; d) sampling plan of emission data, giving priority to the output of the strategic analysis; e) verification of the complexity of activities undertaken at the location/s of the organization. The audit plan shall clearly define the activities which will be performed at the organization.


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R. The audit plan shall be sent to the organization sufficiently in advance to permit the sending of any remarks or comments by the organization. R. The audit plan shall be in keeping with the sampling plan which remains a document for internal use by the VB.

8.4 – Audit R. 8.4.1. General R. Visits to locations of the organization (plants and/or other places where data are managed) serve to establish the precision of calculations, if the data were produced in acceptable conditions, if the calculation methods are suitable and also if the subsequent activities, calculations, measurements and calibrations etc. are carried out as set out in the monitoring program. The audit shall be performed at the location/s of the organization unless other modalities can be justified in special cases. R. If, during the document review carried out by the GVI, it has been decided not to undertake an on-site visit, doubts emerge or problems which cannot be resolved without an on-site visit, the GVI shall nevertheless carry out the visit at the organization to clarify the situation.

R. The audit is performed on the basis of an adequate sampling to verify the reliability of both data and information. R. The audit shall also evaluate as follows:

a) that the monitoring system of the organization is adequate for the conditions of the organization, and that:


It includes all the GHG sources (including, for example, emergency units);


It includes all types of GHG emissions;


It includes Scope 3 activities (together with the sources and correlated GHG) which the organization has decided to include in the GHG inventory.

b) If the methodology adopted for the measuring, including the positioning of the energy and fuel meters, is able to give an accurate picture of the GHG emissions of the organization. R. If the RGVI raises a NC, the times and methods of the follow-up shall be agreed with the officer in charge of corrective actions at the organization. R. The resulting follow-up is documented in the audit report. R. The purpose of the audit is to evaluate the reliability of the information system on GHG and its controls and of the data and information on the GHG.

R.8.4.2. (4.5) Evaluation of the information system on GHG and on their controls R. The evaluation of the information system on GHG and on their controls can be made at the same time as the evaluation of data and information or preliminary to this. The VB’s procedures shall describe how the various possibilities are managed.


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R. That the level of guarantee set out in the monitoring program, including the procedures for the calibration of the meters and the management of documents regarding the measurement and recording of GHG data, is respected by the organization.

R.8.4.3. (4.6) Evaluation of GHG data and information R. During the audit the reliability, credibility and precision of the monitoring system and of the related data are evaluated, as well as the information concerning emissions, including as follows: a) the choice and use of measurement methodologies; b) calculations for defining total emissions; c) modalities of use of measuring instruments, including calibration; d) data which was modified owing to the performance of the audit and the cause of such modifications.

R.8.4.4. (4.9) Audit declarations Following all audit activities the verifier prepares a report related to the GHG inventory of the organization as well as an audit declaration. Both documents shall contain a conclusion regarding conformity to the audit requirements, a description of any NCs and the verified assertion in terms of quantities of GHG emissions of the inventory expressed in T CO2s. These documents may refer to a number of plants.

8.5 – Review and issue of the audit declaration R.8.5.1 The officer in charge of the decision regarding the audit and the issue of the audit declaration must not have had audit responsibilities connected to the audit in question. R.8.5.2. The decisions taken during the audit process should be sufficient to permit the VB to reach a well-founded decision for a positive or negative declaration, and to guarantee the traceability of the documents in case of complaints or in order to program the next audit. R.8.5.3. With regard to the decision concerning the audit, special attention must be given to the following factors: a) the designation of the GVI and the verification of competences; b) the decision to accept the appointed task; c) the timeframe for the audit; d) the strategic analysis; e) the risk analysis; f)

the audit and sampling plan;

g) the proposal of the result of the audit; h) the adequacy of the internal evaluation documentation; i)

the elements highlighted by the GVI if they have led to a negative evaluation;


any wrong information or errors which were corrected during the audit;

k) any NCs raised.


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8.6 - Records R.8.6.1 The internal audit documents of the VB shall include the strategic analysis, the risk analysis, the audit plan and the basis for the decisions regarding incorrect and noncompliant information. Following the audit the documentation shall be filed and made available to ACCREDIA or to any other third parties involved.

8.7 – Facts which came to light after the validation or audit declaration No particular rule of accreditation. 9/10 – COMPLAINTS AND APPEALS R.9.1. Personnel, including the VB management, who, in the last three years, have collaborated in any way with the organization in question, shall not manage complaints or appeals. R.9.2. When a complaint is received the VB shall deal with it as quickly and efficiently as possible. R.9.3 Appeals and complaints may result in internal NCs at the VB. R.9.4. The procedures of the VB for the management of complaints should be such as to:  limit the consequences of any emerging internal NC;

restore conformity to the audit requirements as quickly as possible;

make sure that the NC is not repeated;

evaluate the effectiveness of preventive and corrective actions.

R.9.5. The documents regarding complaints and appeals shall be appropriately archived and made available for audits by the Accreditation Body.

11 – SPECIAL AUDITS No particular rule of accreditation.

12 – MANAGEMENT SYSTEM No particular rule of accreditation.

ANNEXES Annex 1: Guidance to audit activities Annex 2: Audit plan Annex 3: Factors involved in deciding times and when to decide samplings Annex 4: Content of the internal audit documentation of the GVI Annex 5: Module proposed for the audit report Annex 6: Audit declaration Annex 7: Minimum requirements for the GHG verifier course


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1.1 Role of the VB The judgment of the RGVI can be based on a “reasonable” or “limited” level of guarantee, meaning that the VB shall verify in full that the applicable criteria are respected. This does not constitute a “total” guarantee, but it means that the certainty requirements ensure that the declaration of the emissions does not contain major errors, while a negative audit declaration indicates that the information is not in conformity with the requirements.

1.2 Sufficient information for the audit The VB shall gather enough information to be able to present a complete report by means of a systematic procedure, including the following: 

to understand the activities of the plant, the monitoring system, the methodologies based on measurements, the acquisition and management of data;

to understand the activities of the plant, the sources of emission, the measurement equipment, the factors of emission and oxidation used and other data used for determining emissions;

to understand the activities of the control environment and of the control system to ensure conformity of the GHG emissions with the assertion;

to evaluate the risk that the audit declaration and the data it contains may be misleading;

to ensure that any further audit activities are clearly related to the risks identified by activities of inspection, observation, confirmation, calculation, repetition and analysis of procedures. Such audit activities may also contain procedures carried out independently of the organization and also include control measures;

to verify the adequacy and relevance of information.

1.3 Relevance/importance Relevance is defined in single errors, omissions, untruthful statements or the aggregation of such which can influence the assertion regarding GHG and the decisions of users. The VB shall consider as relevant any information of the total emission which is incorrect due to omissions, incorrect information or other errors in the emission data. The relevance is significant when the VB decides the form, time and procedure scope for the acquisition of data and when an audit is performed to establish if the assertion of emissions of the organization is without errors, omissions or incorrect information. In considering the relevance the VB shall evaluate which factors nay influence the decisions of the users. The level of relevance is considered and documented during the planning of the internal audit of the VB which subsequently communicates the presence or absence of significant errors in the audit declaration of


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emissions. The verification of the level of relevance has an impact on the verification of the risk of errors, omissions and other errors in the emissions data. A conclusion on the relevance includes all the results of the risk analysis, on the strategic analysis and the analysis of processes.

1.4 Risk analysis in the audit It is the risk that the VB may present a conclusion which contains incorrect information regarding emissions at the organization. The VB may attempt to reduce the risk by creating a process permitting an easy identification of NCs. The risk analysis must be directed towards the control system, the management and other personnel and functions which could raise the risk level, including as follows:  

Risk of NCs: the VB shall take into consideration the risks regarding the monitoring and control methodologies used by the organization in such a way as to lend support, bearing in mind that there will always be risks owing to the limitations of the measurements of internal controls. Risk of findings: the VB does not identify a significant NC and so there will be no corrective actions.


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ANNEX 2 AUDIT PLAN (DA EA-6/03 Rev. 03 - Annex C) (INFORMATIVE) The following two factors may have a significant influence on the audit plan:

IT communication systems When the audit of data is performed using IT methods the GVI should take the following factors into consideration: 1. all the risks for the operator regarding the congruence, reliability and precision of the data in case of malfunctioning of the IT system and resulting problems; 2. software problems which could result in erroneous emission data or the conversion factor of emissions; 3. human error in use of the IT system; 4. if the software is not standard the presence of a software expert in the GVI may become necessary; 5. the security system of the management and archiving of data as well as the lack of back-up; 6. proper use of the formulae of calculation and control of access, the possibility to recover data and IT security.

The organization’s control environment The verifier should be competent in the control environment and in the control system in order to evaluate the knowledge and activities of the management with regard to internal controls and their importance in generating and reporting emissions and with the requirements of the monitoring program. The verifier should deepen his/her knowledge of the following factors: 1. the analysis of risks, errors in the assertion of emissions or NCs raised against the monitoring program; 2. the account activities and management of the internal control system as well as control activities carried out by the organization in order to face risks; 3. competence in the management of internal and control accounts systems and other control activities for the prevention and identification of errors; 4. the discovery of errors of communication or NCs. By means of techniques such as investigation, observation, inspection, analytical procedures, and using his or her own experience, the verifier reaches a good knowledge of the plant or of the operator’s control environment in order to implement the monitoring system. The verifier should also obtain a good level of knowledge of the following aspects of the organization: 1. its organizational structure; 2. its operative procedures; 3. its HR policies; 4. the communication of information. 5. its IT system.


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The verifier should evaluate the control system at the plant or at the organization and verify that the control systems and related activities set out in the monitoring system have been properly implemented and are working well with regard to the data and to the generation of emissions. The organization and the verifier should be aware that the implementation of such systems is not sufficient to minimize the risks associated with the audit of a GHG inventory. However if the organization is certified against standards such as ISO 14001, EMAS etc., this can make the gathering of material for auditing the GHG inventory more easier, granted that all associated elements of the data system and information foreseen for the GHG inventory are included. The implementation of a management system can improve the general management of the inventory. The verifier should verify the necessary procedures to monitor the GHG as well as the application of such procedures.


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ANNEX 3 ASPECTS TO BE CONSIDERED IN DECIDING TIMES AND SAMPLING DEFINITION TIMES (EA-6/03, Rev. 03, Annex E) (NORMATIVE) In deciding the audit times and the extent of the sampling, the verifier shall take the following into consideration:

1. the complexity of the activities of the organization and of its plants; 2. the type and quantity of GHG and the source fluxes; 3. the methods applied to determine the GHG (such as measurement or calculation); 4. that the inventory includes Scope 3 and the extent of this; 5. quantities of data to be controlled; 6. the accuracy of the procedures for archiving and managing data; 7. competence of the GVI and audit tasks; 8. that the GHG inventory of the same organization has been audited in the past. The following additional elements may be considered for a better definition of the complexity of the monitoring and reporting system of GHG emissions and removal on the part of the organization: 1. the counting system of the emissions and their complexity; 2. the accuracy and thoroughness of the activities of gathering and treating data; 3. the consistency between the GHG inventory control activities and the general control system of the organization for reducing risks in the risk analysis conducted by the operator; 4. the culture of the organization in management supported by updated internal procedures; 5. the transparency of the system of control and management of data with regard to personnel; 6. validation of the IT interface; 7. records and archives file; 8. internal audit (horizontal and vertical controls); 9. whether the specific aspects of the activities (emissions, calorific values, oxidation etc.) are determined by the operator, by third parties (suppliers, external accredited or not accredited labs) or if they are based on standard factors); 10. the sampling quality based on significance, the level of guarantee adopted, the inherent risk and the identification risk of errors; 11. 12. 13. 14.

the validity of the sampling units and any lack of emission data due to malfunctioning of equipment; the application of a calculation or measuring method for determining GHG emissions; the types and numbers of emission sources where continuous methods of measuring are applied; the way in which the quantity of the flux of sources is determined – the measurement of the organization or the level of trust with regard to data of the suppliers.


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The audit document should cover, at least, the following aspects: 1

information regarding the GVI in question: a. names of the RGVI and the GVI; b. tasks of each team member; c. audit times for each member.


the scope of the audit shall correspond to the audit plan unless changes are introduced while the audit is underway;


conclusions concerning independence and impartiality controls with regard to the inspectors in order to start the audit;


conclusions concerning the follow-up of previous audits;


the audit plan;


the client’s GHG assertion, expressed in T CO2s, verified by the VB;


the audit criteria of the assertion to be submitted to the verifier, to the competent authority, to the Accreditation Body and to other interested parties;


a description, where necessary, of any limitations to the audit of the GHG assertion;


full conclusions of the strategic analysis, of the risks and of the processes;


the audit activities undertaken. These shall respect the plan unless changes are introduced while the audit is underway;


any unless changes introduced while the audit is underway;


reasons for increasing or reducing the sampling and the resolution of all factors of further evaluation with the relative outputs, criteria and evidence of modalities used in reaching conclusions with regard to the conformity of the GHG assertion;


conclusions with regard to the data quality of the GHG assertion with the applicable threshold;


NCs raised by the GVI and possible solutions;


audit conclusion of the GHG assertion.

ACCREDIA shall have access to the internal audit documentation.


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ANNEX 5 AUDIT REPORT (NORMATIVE) The following information shall be contained in the VB’s audit report:

Audit conducted at: name of the organization: [ ] address: [ ] references of the plant/s: [ ]

Base: 

Audit report [date and number of version]

Audit of: 

The organization’s GHG assertion expressed in tons of CO2s: [ ]

Audit criteria: 

UNI EN ISO 14064-1: [Scope and field of application of the GHG inventory]

Type of audit:  Base year or subsequent GHG inventory: [ ]

Dates of visits and audits: [the dates and references to audit programs; clear indications of the performance or otherwise of such visits, giving reasons for missed visits.]

Names and tasks of GVI members: Names and tasks of the organization’s personnel during the audit: Documents used for the audit: [material received by the organization or viewed during the audit]

Procedures and scope of the audit: Identify the scope of the sampling, the interviews and the assessment activities for auditing as follows:    

[the plant], [the management system and the procedures]; [the documents], [the databank].


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Description of the impact of uncertainties on the accuracy of the emission or removal data of GHG. Summary and conclusions: [results of the audit]

NCs and criteria for their closure: [indicate in this space]

Remarks and reservations: [remarks and reservations regarding suggestions]

Suggestion: [positive/negative audit declaration]

Signatures: [signature of the RGVI with date]


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ANNEX 6 AUDIT DECLARATION (INFORMATIVE) The audit declaration of the VB shall contain the following information:

Audit declaration (year……) for the organization name of the organization: [ ] address: [ ] references of the plant/s: [ ]

Base The audit of GHG emissions was performed on the basis of: 

GHG assertion: [date and number of version.]

Declaration The audit was undertaken against UNI EN ISO 14064-3, and UNI EN ISO 14065, and the ACCREDIA accreditation regulation for the accreditation of audits regarding GHG emissions. All GHG emission sources were audited for data reliability for each source which contributes to the organization’s total GHG emissions.

Positive declaration On the basis of the above and of an examination of the organization’s GHG assertion, its database and generation, with reservations concerning any subsequent remarks or observations, it is declared that: in the case of a reasonable level of guarantee, on the basis of the process and procedures carried out, the GHG assertion is substantially correct and is a correct representation of the GHG data and information; the assertion was prepared in accordance with the applicable international standards for the qualification, monitoring and reporting of GHG or against the applicable national standards and procedures. The inventory was created in accordance with UNI EN ISO 14064-1. In the case of a limited level of guarantee: On the basis of the process and procedures carried out, there is no evidence that the GHG assertion is not substantially correct and is a correct representation of the GHG data and information; the assertion was prepared in accordance with the applicable international standards for the qualification, monitoring and reporting of GHG or against the applicable national standards and procedures. The inventory was created in accordance with UNI EN ISO 14064-1.


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Given the above and on the basis of the audit report (date:…..), it is concluded that the data presented in the GHG assertion have no omissions, NCs, errors of any type at all which could lead to incorrect declaration with regard to the total volume of emissions. The GHG emissions for the year ….. is ….. (T CO2s), also indicating if it includes Scope 3 emissions and, if it does, which ones. The following observations/remarks are attached to the declaration as above: (declaration of the noted circumstances regarding the declaration, preferably referring to the audit report). The positive declaration is based on the assumption that the remarks indicated above have no relevant influence on the calculation of GHG emissions. Address of the verifier, accreditation and registration number [ ] Stamp of the verifier [ ] Mark of the AB [ ] Date and signature of the verifier [ ]

Negative declaration Given the above it is declared that it is not possible to issue a positive audit, the reasons for this being: [text with references to the audit report] Address of the verifier, accreditation and registration number [ ] Stamp of the verifier [ ] Mark of the AB [ ] Date and signature of the verifier [ ]


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ANNEX 7 MINIMUM REQUIREMENTS FOR THE COURSE OF GHG VERIFIER (NORMATIVE) Duration 24 hours of lessons and practice on successive full days of at least 8 hours. No end-of-course test. The daily total cannot exceed 8 hours in the calculation of the course total. For ETS auditors the course may be reduced to 8 hours.

Aims and objectives • thorough knowledge of the applicable standards (UNI EN ISO 14064, UNI EN ISO 14065); • knowledge of the methods for monitoring GHG emissions; • knowledge of the methods for verifying data and the control of communications.

Minimum content of the course Introductory part • climate change and the GHG effect • the Kyoto protocol and flexibility mechanisms • the Emissions Trading Scheme Applicable standards • UNI EN ISO 14064-1, UNI EN ISO 14064-3, UNI EN ISO 14065, IAF MD6 Techniques and modalities for the quantification of GHG emissions Identification of the source of emission • GWP • element of calculation such as emission factors, lower calorific value • measurement and dispositions used for monitoring activities • measurement methodologies for the calculation of GHG emissions • quality control and assurance for data and information regarding GHG emissions • uncertainty evaluation • management and control of documentation Conduct of audits • the documentation to be audited • strategic and risk analysis, audit and sampling programs • audit report and declaration • minimum requirements for audit reports and declarations • behavioural modalities


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PART 3 – PROVISIONS REGARDING VBs OF GHG EMISSIONS IN THE MANDATORY SECTOR – EMISSION TRADING SCHEME (ETS) The mandatory ETS scheme is one of the main policy instruments of the EU for the reduction of GHG emissions in the industrial sector. The origins lie in the Directive 2003/87/EC and subsequent updates and, in order to create a consistent approach in the EU, it has been systematically standardized also in terms with regard to audit and accreditation activities. The publication of Reg. 600/2012 effectively harmonized such activities. With the aim of aligning activities in Italy with the Regulation and the other European documents for its implementation, ACCREDIA has not introduced any additional requirements and sets out below the main standards and regulations which are applicable to the mandatory ETS scheme for audit activities: - Reg. EU 600/2012 of 21.06.2012 (and relative guidelines and modules issued by the European Commission for the support of the application of such regulation). - UNI EN ISO 14065 - EA 6/03 - IAF MD/6 The above technical documents referred to shall be applied in their current version.


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PART 4 – ACCEPTANCE CLAUSE The present Regulation constitutes an integral part of the agreement between ACCREDIA and the Body (contractual agreement of accreditation). By signing this agreement the Body declares that it accepts all the clauses in the present Regulation, as well as the standards, guides and reference documents contained in the Regulation.

Date ……………………

Stamp of the Inspection Body and signature of the legal representative or empowered attorney.

In accordance with article 1341 of the Civil Code the following clauses of the present Regulation and relative Annex are approved: 1.1.2 1.1.4 1.4.3 1.7 1.10.3 A.0

“Conditions of accreditation” “Communications to ACCREDIA” “Minimum period of time for re-presenting the application for accreditation” “ACCREDIA’s rights of access” “Undersigning of the accreditation agreement with ACCREDIA” “Outcome of surveillance activities – imposition of sanctions” “Imposition of sanctions” (all sub-clauses) “Pricelist” “General criteria for the imposition of sanctions”

Stamp of the Inspection Body and signature of the legal representative or empowered attorney.


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General criteria

The imposition of sanctions in accordance with § 1.7 of Regulation RG-15 occurs in cases in which failure to respect a requirement is such as to compromise the reliability of the results of inspections undertaken by the Body (a nonconformity as defined in § 0.4) The criteria given below (which do not constitute a complete list) regard the imposition of sanctions, with reference to cases which are identifiable under the present Regulation and which have been further examined.


Requirements and criteria of impartiality

In accordance with the contents of standard UNI EN ISO 14065 (§ 5.4) regarding impartiality, the following activities cannot be undertaken: - participation in the planning, implementation or maintenance of a GHG inventory involving the following activities: - the processing or production of monitoring programs, the giving of specific advice, instructions or solutions for the development, implementation and management of a GHG inventory; (1) - the delivery of training which offers specific company solutions rather than general information which lies within the public domain. The Body can only offer certain limited training courses; - offering or supplying internal audit services for GHG inventories to its own audited clients. (1)

It is possible only to deliver trainings which are in no way connected to consultancy activities. A training may be offered to physical persons belonging to an entity or to single juridical persons. In the latter case, irrespective of the training location, the VB shall thoroughly analyze the risks deriving from excessive familiarity. Explanatory trainings regarding standards of a general nature and duration are always permissible. It is not permitted that, for audit activities at the location of an organization, personnel are tasked who have already carried out training activities at the company’s location, or exclusively for the organization’s personnel, also if the objective of the training is not strictly relevant to the activity for which the inspection personnel of the VB has been tasked.


Audit times

If, during the audit, the VB’s audit team finds significant differences with respect to the conditions of the quotation, such as the number of operators being different from the number included in the audit plan, the team shall contact the VB to establish which of the two lines of action to follow: - not to issue the audit declaration; - to perform a supplementary audit within 60 days.


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Competence of the audit team and of the inspection personnel in general

The VB shall provide support, with clear and objective evidence, for the qualifications of its inspectors. Such evidence shall also underscore the possession of qualifications in other pertinent schemes. Failure to respect the above requirements will lead to the imposition of sanctions by ACCREDIA.


Competence of technical personnel concerning certification decisions with regard to audits

The personnel (individual or committee) who re-examine files and decide with regard to audit declarations, shall possess the competences described in §, regarding every single file examined. Evidence of such competences shall be provided – either singly or collectively – by means of CVs or other appropriate documents. Failure to respect the above requirements will lead to the imposition of sanctions by ACCREDIA.


Separation of audit activities from consultancy activities with regard to GHG

Granted that, in accordance with the applicable standards, the VB shall not undertake consultancy activities or trainings which could be interpreted as consultancy, the VB shall ensure the separation (technical, commercial, administrative and logistical) between the audit activities performed and consultancy activities provided by persons (physical and juridical) who have a formal relationship with the VB of any nature. It is not possible, in this document, to give a complete case-list of situations in which there is a potential conflict of interests. Some examples are, therefore, presented, in which the automatic imposition of sanctions takes place as described at the start of this Annex: -


a manager or other staff of the VB carries out tasks at organizations which perform consultancy activities; logistical or administrative activities undertaken by the VB and consultancy organizations, such as offices or administration in common. In addition, if a situation occurs as follows: there is a high percentage of audit declarations issued to organizations which are all assisted by the same consultancy company or consultants,

ACCREDIA will undertake the appropriate investigations and impose sanctions if such are deemed necessary.


Improper use of the accreditation Mark.

ACCREDIA Regulation RG-09 sets out the rules covering use of the Mark. Improper use of the Mark can lead to the immediate imposition of major sanctions, notwithstanding the specifications at the start of this Annex.


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