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 7, replaces REC-LAB, Procedure for the Recognition of Foreign Testing Laboratories, issue 6, dated March 2018. 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. This procedure has been streamlined to simplify the process for those testing laboratories (whether Canadian or foreign) seeking recognition to test/assess to Canadian requirements.
2. Radio Standards Specification RSS-102 (localized power density above 6 GHz) has been added as a new partial scope for recognition.
3. A distinction between “measurement” and “computational” for RSS-102 has been included, and these are now separate scopes for recognition.
4. Broadcasting Equipment Technical Standards (BETS) (with the exception of BETS-3 and BETS-7) have been clarified under the scope of recognition.
5. Testing laboratories must indicate which information and documents provided in support of an application for recognition are confidential (if any), given that the provisions of the Access to Information Act apply.
6. The Testing Laboratory Technical Assessment Checklist has been updated.
7. A transition period of six (6) months has been provided between issue 6 and issue 7.

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 be in force upon publication on ISED’s website. However, a transition period of six (6) months following its publication will be provided, within which compliance with REC-LAB, issue 6, or REC-LAB, issue 7, will be accepted.

The same applies to the Testing Laboratory Technical Assessment Checklist.

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.

Broadcasting equipment

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

Category I equipment

Equipment 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 process by which ISED accepts a designated testing laboratory as competent to test/assess to Canadian requirements.

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.

Testing laboratory

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

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:

Category I equipment standards list

Testing Laboratory Technical Assessment Checklist (2021 version)

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 is deemed competent to test products subject to DoC or Certification.

Step 1: Laboratory accreditation

1. Seek accreditation:
   1. Canada: Seek accreditation from an accreditation body such as the Standards Council of Canada (SCC) or as per the list of appointed accreditation bodies for Phase I.
   2. MRA country: Seek accreditation from one of the accreditation bodies recognized by your designating authority (DA).
   3. Non-MRA country: Seek accreditation from 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 ISED’s Testing Laboratory Technical Assessment Checklist.

Step 2: Online application (new, renewal or scope amendment)

1. In Canada, once the Canadian testing laboratory ensures it meets ISED’s requirements for recognition, it submits to ISED the online Application for the Recognition of a Testing Laboratory.
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 to ISED a request for recognition 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 to ISED a request for recognition through the online Application for the Recognition of a Testing Laboratory.

The respective applicant should include a signed and dated covering letter with a statement that the testing laboratory complies with all provisions of this procedure.

Notes:

• For renewal purposes, the latest Testing Laboratory Technical Assessment Checklist must be submitted.
• The DA or the AB may alternatively submit a statement to the effect that the testing laboratory is in continued compliance with the previously submitted checklist in cases where the answers to the Testing Laboratory Technical Assessment Checklist remain the same.
• It is important that the information submitted by the applicant matches the ISO/IEC 17025 Certificate and Scope of Accreditation and that the accreditation is valid at the time of application.

Step 3: ISED recognition

1. ISED will assess the recognition application on a first-come, first-served basis.
2. 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).
3. 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.
4. The testing laboratory will be added to the list of recognized Conformity Assessment Bodies.

Testing laboratories can be recognized to test to the following scopes of accreditation:

• Radio Standards Specification RSS-Gen and any RSS, where RSS-247, Digital Transmission Systems (DTSs), Frequency Hopping Systems (FHSs) and Licence-Exempt Local Area Network (LE-LAN) Devices, can be recognized with or without dynamic frequency selection (DFS).
• The scope for RSS-102, Radio Frequency (RF) Exposure Compliance of Radiocommunication Apparatus (All Frequency Bands) is divided into two main categories: i) measurement and ii) computational. Under each of these categories, a further division of scopes is made to better differentiate testing laboratories performing nerve stimulation (NS), specific absorption rate (SAR), localized power density (LPD) and/or radio frequency exposure (RF Exp.) evaluation tests as illustrated below:
  1. Measurement: RSS-102 (NS), RSS-102 (SAR), RSS-102 (LPD), and/or RSS-102 (RF Exp.)
  2. Computational: RSS-102 (NS), RSS-102 (SAR), RSS-102 (LPD), and/or RSS-102 (RF Exp.)
     • Note: For RSS-102, the scope of accreditation shall list the applicable component (NS, SAR, LPD, and/or RF Exp.) and specify whether it is measurement or computational-based or both. For example, a testing laboratory seeking recognition for RSS-102 (SAR), RSS-102 (RF Exp.) measurements and RSS-102 (SAR) computational shall list on the scope of accreditation:
       • Measurement: RSS-102 (SAR), RSS-102 (RF Exp.)
       • Computational: RSS-102 (SAR)

• Compliance Specification CS-03, Parts I-VIII (except Part III and Part IV)
• Broadcasting Equipment Technical Standards (BETS) (except BETS-3 and BETS-7).

Testing laboratories may 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.

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 wishes to subcontract part of the testing to another laboratory, the subcontracted laboratory must also be recognized by ISED.

It is not acceptable for an ISED-recognized testing laboratory to simply 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 must 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 a listed AB.

Recognized testing laboratories shall only advertise testing services that are within the scope of their ISED recognition.

When a recognized testing laboratory is the subject of an investigation for non-compliance with this procedure, a recognition suspension may be issued. 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. Such action will, however, take place only after consultation between ISED and the Canadian laboratory or the DA, as applicable. For testing laboratories recognized in non-MRA countries, the suspension or withdrawal of recognition can be immediate.

If a testing laboratory’s designation is suspended or withdrawn, the recognition will also be suspended or withdrawn and removed from the list of ISED-recognized testing laboratories.

A testing laboratory whose recognition has been suspended or withdrawn shall cease advertising its recognition.

A testing laboratory whose recognition has been suspended or withdrawn may reapply for recognition once the causes leading to the suspension or withdrawal have been eliminated to the satisfaction of ISED and of its designating authority.