Jul 2020

Who’s inspecting your inspectors?

Third party oversight during PV module manufacturing is mainstream practice today. Most utility-scale developers, especially if they are not geographically close to the location of manufacturing, request the production to be supervised by a third party. That is in fact not surprising; the practice also exists in many other industries such as automotive, building and infrastructure, chemicals, food, oil & gas, consumer products, etc.

As the PV industry is slowly maturing, we expect Inspection Bodies to be present in other elements of the value chain: upstream to ensure traceability and quality of key components (e.g. solar cells, backsheets, etc.) and downstream, ensuring requirements of buyers are met during the construction of the power plants, for instance. What is surprising however, is that some of the inspectors active in the PV industry are actually not “Inspection Bodies”. Only a few inspection firms active on the PV market have the accreditation to perform the work according to the relevant international ISO standard, which is, for Inspection Bodies, ISO17020.

So why does it matter to use ISO17020-accredited Inspection Bodies?

ISO 17020 is an international standard describing a set of requirements to ensure competence, integrity, impartiality, independence, transparency, etc. There are many reasons why a developer may require the inspector to be ISO17020-accredited:

First, only an accredited Inspection Body (accredited firms can be called Inspection Bodies, while non-accredited firms cannot claim this title) can deliver ISO-compliant Reports and Certificates of Conformity. Keeping ISO-compliant records of production inspection may be critical in the future, as the industry matures and more investors, coming from other industries, may be more used to, or more demanding on the quality levels of the documentation before acquiring a project. Projects built today may change hands several decades from now. Keeping ISO-compliant records ensures future recognition across industries, regulators, and borders.

In addition, and maybe even more importantly, being compliant to ISO17020 enforces spotless independence, impartiality, and integrity. The inspectors, for instance, are required to be on the payroll of the Inspection Body; it is not allowed to subcontract inspection. It is not allowed to “pass by the local Home Depot” to pick-up the manpower for the job. Both training and work history of inspectors are regulated to make sure the inspector is well versed in the task, and has not worked for the supplier inspected for several years before performing the inspection. The Inspection Body is also not allowed to trade the goods inspected, which would create some conflict of interest. Non-accredited companies do not have these requirements.

Then why is it that some active PV module inspection companies are not ISO17020-Accredited?

First, we believe that it is just a question of time. The PV industry has been growing so fast that the developers have to face many other challenges first. Availability of components, price dynamics, technical risks, financial risks, or even simply getting “someone” to the factory during production are immediate concerns that need to be addressed under time and cost pressure. We believe that as industry and players mature, the request for ISO-accredited Inspection Bodies will come naturally as a standard request for inspection work. Most buyers (even if not yet all) already request today that the factories are IS09001-compliant. Most buyers (and similarly, not yet all either) request today that the test labs used for their own testing, or for IEC certificates are ISO17025-accredited. As the industry matures, we believe that compliance to ISO requirements will simply become mandatory for all inspection work.

Secondly, being compliant to ISO17020 is an effort which comes with some cost for the Inspection Body. Having all the inspectors on the payroll, for instance, complexifies the logistics. Remaining fully independent also requires avoiding some potentially lucrative business. For instance, for some of the established conformity assessment companies, inspection is not a business opportunity as lucrative as certification. Showing unequivocal integrity during inspection may cause tensions with their prime certification customers (the module manufacturers) and potentially jeopardize their certification business. Some companies, although active in both IEC certification and production inspection, chose to be ISO-compliant for certification, but not for inspection. ISO17020-compliance puts additional constraints on the Inspection Body; and although these constraints clearly benefit their customers, each PV conformity assessment company has to make choices, and identify their own priorities.

Finally, it is just a fact that no company likes having an inspector looking over their shoulder. It is somewhat ironic that PV inspection companies encourage their customers to send inspectors to look over the shoulder of module makers, accept to review only ISO-accredited lab reports, highlight non-compliance when the manufacturer fails to show their ISO9001 certificate, but do not impose the same level of scrutiny for themselves. After all, the inspector is just another supplier to the developer; why not requesting the same level of ISO-compliance to the inspector? 

So, ask yourself, “who is inspecting your inspectors?“, and the PV industry will take one step in the direction of a more mature and a more transparent industry!