REC-LAB — Procedure for the Recognition of Testing Laboratories to Test/Assess to Canadian Requirements

This document, REC-LAB, Procedure for the Recognition of Testing Laboratories to Test/Assess to Canadian Requirements, issue 8, replaces REC-LAB, Procedure for the Recognition of Testing Laboratories to Test/Assess to Canadian Requirements, issue 7, dated October 2021. It describes the criteria and procedure for recognition by Innovation, Science and Economic Development Canada (ISED) of testing laboratories to test/assess to Canadian requirements for telecommunications terminal equipment, radio apparatus and broadcasting equipment standards.

The following are the main changes:

1. Issued a transition period of six (6) months between issue 7 and issue 8 (section 2)
2. Revised the Testing Laboratory Technical Assessment Checklist. A transition period of six (6) months has been provided, after which ISED will no longer accept any previous versions (section 2)
3. Added requirement that the Testing Laboratory Technical Assessment Checklist be provided with every application
4. Clarified that a separate Testing Laboratory Technical Assessment Checklist is required for each testing location listed on the scope of accreditation (section 6)
5. Added requirement that the assessment date of the Testing Laboratory Technical Assessment Checklist shall not be older than 12 months (section 6)
6. Added requirement that the testing Laboratory Ownership documents (Official Government Document or Certificate of ownership) be provided with an initial application and when renewing, if revised (section 6)
7. Added requirement that a list of the names of employees responsible for testing, reviewing and signing, including the physical address (city/country) where work will be performed be provided with an initial application and when renewing, if revised (section 6)
8. Moved the list of standards available for recognition to an online webpage
9. Added new requirements in the suspension or withdrawal of recognition section

Issued under the authority
of the Minister of Innovation, Science and Industry

Martin Proulx
Director General
Engineering, Planning and Standards Branch

This document specifies the criteria and procedure for recognition by Innovation, Science and Economic Development Canada (ISED) of testing laboratories, whether Canadian or foreign, to test/assess to Canadian requirements for telecommunications terminal equipment, radio apparatus and broadcasting equipment standards.

This document will come into force upon its publication on ISED’s website. Once published, ISED will grant a transition period until January 1st, 2025, during which compliance with either REC-LAB issue 7 or issue 8 will be accepted. After January 1st, 2025, compliance with REC-LAB issue 8 only, will be accepted.

Additionally, after January 1st, 2025, the lab must use the latest version of the Testing Laboratory Technical Assessment Checklist if seeking recognition or a change to its existing recognition. Previous versions of the checklist will no longer be accepted.

Accreditation

A procedure by which an authoritative body gives formal recognition that a body or person is competent to carry out specific tasks.

Accreditation body (AB)

An authoritative body that performs accreditation of conformity assessment bodies by assessing them against international voluntary standards.

Assessment Date

The date the Testing Laboratory Technical Assessment Checklist was completed and signed by the assessor.

Broadcasting equipment

A radio apparatus in which the transmissions are intended for direct reception by the general public.

Category I equipment

All equipment that is listed and classified as Category I equipment in the Category I equipment standards list (canada.ca), as amended from time to time, published by(ISED), and that is classified as Category I equipment in the applicable standard. Category I equipment is subject to technical regulations for which certification is required.

Certification

The conformity assessment scheme used for Category I equipment.

Certification body (CB)

A recognized independent organization that conducts certification of radiocommunication equipment to Canadian regulatory requirements.

Conformity assessment

A systematic examination to determine the extent to which a product, process or service fulfills specified requirements.

Conformity assessment body (CAB)

A body engaged in the performance of procedures for determining whether the relevant requirements in technical regulations or standards are fulfilled.

Declaration of Conformity (DoC)

The conformity assessment scheme used for telecommunications apparatus defined in the Telecommunications Act.

Designating authority (DA)

A body with authority to designate, monitor, suspend designation or withdraw designation of conformity assessment bodies under its jurisdiction.

Designation

The nomination by a designating authority of a domestic conformity assessment body as competent to perform conformity assessment activities under the terms of an agreement or arrangement to the requirements of foreign regulatory authorities.

Mutual Recognition Agreement/Arrangement (MRA)

An agreement between countries to mutually recognize the other’s regulatory testing and/or certification, including any other equivalent agreement, such as, but not limited to, free trade agreements.

Radio apparatus

A device or combination of devices intended for, or capable of being used for, radiocommunication.

Recognition

The acceptance of a designated conformity assessment body by a regulatory authority.

Recognized accreditation organizations

Accreditation organizations that have been appointed by ISED or by a Mutual Recognition Agreement/Arrangement (MRA) partner as competent to perform accreditation.

Regulatory authority

A government agency or other entity with the power to regulate products within its jurisdiction.

Suspension

When a recognized testing laboratory is the subject of an investigation for non-compliance with the requirements of this procedure, the recognition may be temporarily suspended at the discretion of ISED.

Testing laboratory

A body responsible for determining the applicable test procedures and for properly testing to those requirements.

Withdrawal

When a recognized testing laboratory does not comply with the requirements of this procedure, the recognition may be withdrawn. The terms of recognition after being withdrawn will be at the discretion of ISED.

All spectrum-related documents referred to in this paper are available on ISED’s Spectrum Management and Telecommunications website. Refer to the following documents as needed:

Testing Laboratory Technical Assessment Checklist

In order to be recognized by ISED, all testing laboratories subject to Declaration of Conformity (DoC) or Certification must:

1. be accredited to ISO/IEC 17025:2017 General requirements for the competence of testing and calibration laboratories by an accreditation body (AB) located in a Mutual Recognition Agreement/Arrangement (MRA) country, or by ABs appointed by Canada for MRAs, or by a recognized AB for non-MRA countries listed on the List of Recognized Accreditation Bodies for Non-MRA Countries
2. be a Canadian testing laboratory or be designated by an MRA partner for testing laboratories located in MRA countries or be designated by a recognized accreditation body for non-MRA countries
3. include in their application a list of Canadian standards, specifications, or parts thereof, for which recognition is sought (this list shall be included in the scope of accreditation of the testing laboratory)

The following procedure is used for all testing laboratories to be recognized by ISED as an accredited testing laboratory and thus deemed competent to test products subject to DoC or Certification.

Recognized testing laboratories must follow the same procedure to renew or amend their recognition.

Step 1: Laboratory accreditation

1. Testing laboratories must be accredited in:
   1. Canada: by the Standards Council of Canada (SCC) or an ISED-appointed accreditation body for Phase I
   2. MRA country: by one of the accreditation bodies recognized by your designating authority (DA)
   3. Non-MRA country: by one of the recognized ABs that lists your country on the List of Recognized Accreditation Bodies for Non-MRA Countries
2. Obtain a copy of the certificate and scope of accreditation proving that the testing laboratory has been accredited to ISO/IEC 17025:2017 General requirements for the competence of testing and calibration laboratories
3. Have the accreditation body’s assessor complete and sign the latest version of ISED’s Testing Laboratory Technical Assessment Checklist
   1. A separate checklist is required for each testing location listed on the Scope of Accreditation
   2. On-site assessments are required for initial recognition and scope amendments that include RSS-102 elements
   3. The assessment date of the checklist shall not be older than 12 months, except for laboratories that are accredited by an AB that conducts biennial assessments, but issues accreditations annually. For these laboratories, in the years where no assessment is performed, applications that do not include an updated checklist shall include a statement from the AB confirming that the laboratory remains in compliance with the previously submitted checklist

Step 2: Application (initial, renewal or scope amendment)

Online application:

1. In Canada, once the Canadian testing laboratory ensures it meets ISED’s requirements for recognition/renewal/scope amendment, it submits the online Application for the Recognition of a Testing Laboratory to ISED
2. In MRA countries, the DA reviews the accreditation information and determines whether the foreign testing laboratory meets the requirements for designation/renewal. Once the DA determines that the requirements have been met, it submits a request for recognition/renewal/scope amendment to ISED through the online Application for the Recognition of a Testing Laboratory
3. In non-MRA countries, the AB reviews the accreditation information and determines whether the foreign testing laboratory meets the requirements for designation/renewal. Once the AB determines that the requirements have been met, it submits a request for recognition/renewal/scope amendment to ISED through the online Application for the Recognition of a Testing Laboratory

Accompanying documentation:

1. ISO/IEC 17025:2017 certificate and scope of accreditation
2. The completed and signed Testing Laboratory Technical Assessment Checklist for each site
3. Testing Laboratory Ownership documents (Official Government Document or Certificate of ownership)
4. List of the names of employees responsible for testing, reviewing and signing, including the physical address (city/country) where work will be performed
5. Items c. and d. shall be submitted with an initial application and when renewing if revised
6. A signed and dated cover letter that includes a statement that the testing laboratory complies with all provisions of this procedure

Step 3: ISED recognition (initial, renewal or scope amendment)

1. ISED will assess the recognition application on a first-come, first-served basis. If ISED requires more information to make a decision, it will contact the Canadian testing laboratory, the foreign DA (MRA countries) or the recognized AB (non-MRA countries)
2. ISED will notify the Canadian testing laboratory, the DA for laboratories located in MRA countries, or the AB for laboratories located in non-MRA countries of its decision on the request for recognition for laboratories
3. The testing laboratory’s scope of recognition will be added to the Conformity Assessment Bodies page

Testing laboratories can be recognized to test to Canadian requirements as per the List of standards available for recognition.

Testing laboratories must submit a request for ISED to consider recognition for part of a technical standard by using the General Inquiry form. The request must include a justification as to why the technical standard needs to be split. ISED will respond to the testing laboratory after it completes its review.

When ISED publishes a new standard or an updated issue of a standard and the testing laboratory chooses to include/maintain the standard on its scope of recognition, the testing laboratory is responsible to work with its accreditation body to ensure the new standard or updated standard is added to its scope of accreditation when accreditation renewal assessment occurs. Failure to add the new/revised standard to the laboratories scope of accreditation will result in removal of the standard from the scope of recognition upon renewal.

ISED will only accept a test report from a testing laboratory if the standard is included under the lab's scope of recognition on ISED's website.

The Testing Laboratory Technical Assessment Checklist identifies specific items to be evaluated during the technical assessment of a testing laboratory in order to determine the capability and competence of that laboratory to perform testing needed to show compliance with ISED regulatory requirements.

The checklist is intended to serve as a guide, and provides a minimum list of items to be included in the technical evaluation of the testing laboratory as part of the complete ISO/IEC 17025 assessment. The checklist is not intended to replace the thorough evaluation of the facility. As such, other related items not shown on the checklist may be evaluated by the assessor(s). The accreditation body shall attest that all responses on this checklist are complete and accurate.

All test reports shall be generated by the testing laboratory that tested the device. Testing is required to be performed by ISED-recognized testing laboratories. If a testing laboratory subcontracts part of the testing to another laboratory, the subcontracted laboratory shall also be recognized by ISED.

It is not acceptable for an ISED-recognized testing laboratory to review a test report based on a non-recognized testing laboratory assessment; all testing must be completed at the recognized test facility.

Any confidential information submitted through the application process shall be identified. The provisions of the Access to Information Act apply.

ISED will not disclose the status of recognition applications to any third party until the assessment process is completed.

The recognition of a testing laboratory by ISED does not imply or otherwise suggest approval of a product or that the recognized testing laboratory is an agent or representative of ISED.

ISED does not accept any responsibility for the effects or consequences of services provided by the recognized testing laboratory for users of such services.

Canadian testing laboratories shall notify ISED, in writing, of any changes that may affect their continued ability to carry out the activities for which they were recognized.

For a recognized testing laboratory located in an MRA country, the DAs shall notify ISED accordingly.

For recognized testing laboratories located in non-MRA countries, the recognized accreditation body shall notify ISED of any changes that may affect the continued ability of the testing laboratory to carry out the activities for which they were recognized.

The changes for all testing laboratories include:

1. contact information, including business address
2. accreditation scope (amendments) and/or status
3. recognized accreditation body’s assessment of the testing laboratory

A recognized testing laboratory shall continue to meet the requirements of this procedure and shall maintain its accreditation status. The testing laboratory shall provide evidence of its accreditation status and scope upon request to ISED.

The testing laboratory will be recognized for the duration of its accreditation or two years from ISED’s recognition date. For Canadian labs, renewal can be sought through the online Application for the Recognition of a Testing Laboratory. Foreign labs must apply through their DA, or, if in a country without an MRA, through an ISED-recognized AB.

When a recognized testing laboratory is the subject of an investigation for non-compliance with this procedure, the recognition may be suspended. The testing laboratory is required to take immediate corrective action to ISED’s satisfaction. Where it is found after review that a recognized testing laboratory does not comply with the requirements of this procedure, the recognition may be withdrawn.

A recognized testing laboratory or a DA (in the case of testing laboratories located in MRA countries) or an AB (in case of testing laboratories located in non-MRA countries) may request that ISED withdraws its recognition at any time by notifying ISED.

If a foreign testing laboratory’s designation is suspended or withdrawn by its DA (in MRA countries) or AB (in non-MRA countries) for any reason, ISED will similarly suspend or withdraw the foreign testing laboratory’s recognition.

14.1 Suspension/Withdrawal process

The suspension/withdrawal process consists of the following steps:

1. Testing laboratory will be notified by ISED in the event of non-compliance(s) with ISED’s requirements.
2. An acknowledgment of receipt of notification by the testing laboratory shall be provided to ISED within 7 calendar days.
3. A corrective action plan shall be provided to ISED within 15 calendar days (from the date of the notification).
4. The testing laboratory shall take corrective action(s) to ISED’s satisfaction within the timeframe specified by ISED. ISED may, at their discretion, inform the DA (in MRA countries) and/or AB (in non-MRA countries) regarding the non-compliance of the foreign testing laboratory, depending on the severity of the non-compliance.
5. Failure by the testing laboratory to take corrective action(s) within the specified timeframe, may result in suspension or withdrawal of testing laboratory recognition by ISED and ISED will inform the DA (in MRA countries) and/or AB (in non-MRA countries) of this action. For testing laboratories recognized in non-MRA countries, the suspension or withdrawal of recognition can be immediate.
6. Testing laboratories whose recognition has been suspended or withdrawn will be removed from the recognized list of testing laboratories on ISED’s website and CBs will not be able to submit certification applications to ISED that include test reports issued by the de-recognised testing laboratories.
7. Testing laboratories whose recognition has been suspended or withdrawn shall immediately cease advertising their recognition.

If fraudulent activity is suspected, the testing laboratory would be subject to an investigation and their recognition could be suspended or withdrawn.

A testing laboratory whose recognition has been suspended or withdrawn may reapply for recognition once the issues leading to the suspension or withdrawal have successfully been addressed to ISED’s satisfaction and, if applicable, its designating authority.

14.2 Suspension or Modification of the Scope of Recognition

ISED may at any point in time suspend or modify the scope of recognition of a laboratory if the work being performed by the laboratory is deemed by ISED to be unsatisfactory and the laboratory has failed to implement appropriate corrective measures after having been notified by ISED.