United Kingdom Accreditation Service – Written evidence

Executive summary

• UKAS supports the introduction of a duty on regulators to promote economic growth.
   
• UKAS believes that accreditation can help regulators meet this duty by providing a business friendly alternative to regulation or by supporting the use of co-regulatory and ‘earned recognition’ models to reduce and target inspections.
   
• UKAS accreditation is used effectively by some regulators but greater use could be made to increase the potential for economic growth.

Detail

The United Kingdom Accreditation Service (UKAS) is the national accreditation body for the UK. UKAS is recognised by government to assess, against internationally agreed standards, organisations that provide certification, testing, inspection and calibration services. UKAS is independent of government but is appointed as the national accreditation body by the Accreditation Regulations 2009 (SI No 3155/2009) and operates under a Memorandum of Understanding (MoU) with the Department of Business, Innovation and Skills, on behalf of government as a whole.

As the national accreditation body, UKAS has a particular interest in the provisions of the draft Bill relating to the introduction of a duty on regulators to ‘have regard to the desirability of promoting economic growth’. UKAS supports the introduction of this duty and agrees that, as set out in s58(2) of the draft Bill, regulatory action should be taken only when it is needed and that any action taken should be proportionate. UKAS believes that the main non-economic regulators, such as the Environment Agency, the Health and Safety Executive  and the Food Standards Agency, do have regard to these principles but also considers that they could do more in this respect.

UKAS accredited certification, inspection and testing provide the policy maker with alternative tools to regulation that can reduce the need for direct intervention by the regulatory authorities. They are used across a wide range of policy areas including forensic science, gas safety, drinking water quality and medical laboratories. However, in the context of the draft Bill, UKAS considers that the accredited certification of businesses against recognised management systems standards provides the best opportunities for regulators to focus their regulatory and inspection activities on those businesses that need it most and therefore help to promote economic growth in those that do not.

The use of accredited certification of management systems is already well established with some regulators. For example, the Environment Agency has a published policy of recognising accredited certification to BS EN ISO 14001:2004 (the international standards for environmental management systems) in their approach to enforcement. They use it to inform their Operator and Pollution Risk Appraisal (OPRA) scheme under which businesses are graded according to the level of risk they present to the environment. Certification of a business’ management system by an independent certification body provides confidence that the standard has been implemented correctly and will provide the benefits required. UKAS accreditation ensures that the certification bodies are competent to carry out this activity.

Businesses that have accredited certification to ISO 14001 receive credit for this in the OPRA assessment process. The OPRA gradings are used in the inspection planning process and also feed into the calculation of the environmental levies paid by businesses. In this way, the Environment Agency benefits in being able to target its inspection activities on higher risk businesses. Businesses benefit from a risk based inspection regime and reduced levies.  Information on EA’s use of accredited certification to ISO 14001 can be found at http://www.environment-agency.gov.uk/business/142627.aspx.

UKAS strongly believes that this approach could be used by other regulators.

In particular, BS OHSAS 18001:2007 provides a specification for Occupational Health and Safety Management Systems. By complying with BS OHSAS 18001, businesses can ensure that they have good processes in place to manage the risks to health and safety within their own specific business environment. Accredited certification acts in the same way as for environmental management systems to provide assurance that the standards have been met.

Accredited certification to BS OHSAS 18001 therefore provides businesses with a market led and delivered solution to health and safety management that has sufficient authority and trust to be accepted by the enforcement authorities as evidence of compliance with regulation.

BS OHSAS 18001 is a relatively new standard but UKAS believes that, with greater recognition from the Health and Safety Executive, it could play a major part within a co-regulatory framework and provide a basis for businesses to ‘earn recognition’ for their efforts to manage their own health and safety risks. This in turn could lead to a reduction in the level of inspections carried out by enforcement agencies at national and local level without weakening the levels of health and safety maintained in the workplace.

Similar considerations also apply to ISO 22000, the international standard for food safety management systems. This standard provides a framework to help businesses to manage food safety hazards in order to ensure that the food chain is safe. It can be used by any business regardless of its size or position in the food chain.

Accredited certification to ISO 22000 is used, to a certain extent by the Food Standards Agency, in assessing risk and targeting inspections, particularly in relation to large food processing businesses. However, UKAS believes that this approach could be given greater prominence and could equally be applied to smaller business, perhaps in support of the Food Hygiene Ratings schemes.

The greater recognition by regulators of accredited certification to voluntary standards would allow businesses to use market-led management tools to demonstrate compliance with regulation and could reduce the likelihood of compliant businesses being inspected by the regulators. This in turn could help businesses work more effectively and efficiently and would thus encourage growth.

A recent research study indicated that accreditation now contributes at least a billion pounds towards UK GDP each year in terms of improving productivity, growth and public safety (see http://www.ukas.com/media-centre/news/news-archive/2013/Economic_Benefits_Of_Accreditation.asp for further details). UKAS has a strong track record of working with regulators to ensure that the accreditation process is properly focused on their needs and would welcome the opportunity to continue this work to investigate further how the use of accreditation by regulators can promote economic growth.

September 2013