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ISO Publishes New Edition of ISO 17712

16 Jul 2013

The 2013 Edition replaces 2010

The International Standards Organisation (ISO) published the new version of ISO 17712 on 15 May 2013. The new version is a further evolution of ISO's standard for Mechanical Seals, first issued as a Publicly Available Specification (PAS) in 2003.

ISMA is providing this information to help inform other stakeholders about the new edition. Several ISMA members are among the volunteers who drafted each iteration of ISO 17712; the volunteers participated as National Experts in Working Group 8 (WG8), Mechanical Seals, of ISO's Technical Committee (TC) 104, Freight Containers.

The major changes in the new edition concern Clause 6, Evidence of Tampering. Changes were required due to the demonstrated impracticality of tamper-related tests in 17712's 2010 edition.

What is new in ISO 17712:2013?

Evidence of tampering remains an important area in the new edition, but there is a significant change in approach. The new edition addresses tampering via third party process inspections as part of the manufacturer's ISO 9001 quality operational procedures.

ISO 17712 no longer requires certification of successful third party laboratory testing against specific tamper-related criteria. Instead, the requirement for tamper-related quality procedures include internally generated and managed tests of tamper evidence as part of the manufacturer's documented quality program.

A manufacturer may choose to employ a third party laboratory, but such testing would be against the manufacturer's test protocol or specification. The third party lab in such a situation simply provides a lab report to its customer. Since Clause 6 has neither tamper-evident test procedures nor a requirement for accredited testing, an outside lab cannot certify conformance with ISO 17712 Clause 6.

Manufacturers that wish to offer 17712-compliant seals in the future must establish tamper-mitigation procedures for the design and manufacturing process. Auditable processes must assure explicit attention is given to tamper issues in design and manufacturing.

New Clause 6 will be effective May 15, 2014.

The new Clause 6 requirements become effective 15 May 2014; a 12 month transition period is essential to enable manufacturers to draft, refine, and apply their tamper-mitigation processes and to be audited accordingly.

Effective May 15, 2014, compliance with the tamper-evident aspects of the new edition requires documnetation such as a certifying report or letter from auditors accredited in accordance with ISO 17020, Conformity assessment - Requirements for the operation of various types of bodies performing inspection. ISO 17020 applies to accreditation for ISO 9001 quality inspections and, since ISO 17712 Annex A continues to specify ISO 9001 certification, most seal manufacturers will find it convenient to have their quality and tamper-mitigation programs inspected at the same time.

The 2013 edition requires such certification of compliance only for High Security ("H") barrier seals; certification is voluntary for Indicative ("I") and Security ("S") grades. In other words, manufacturers may choose to offer Clause 6-compliant "I" or "S" seals for business reasons; and a user or group of users may choose to request or require such compliance for its own reasons.

What does 17712 require prior to May, 15, 2014?

ISO's "recommendation to users for interim application of ISO 17712" remain in force between now and mid-May 2014. The recommendation, provided to regulatory bodies and to the World Customs Organization (WCO), essentially reiterates the active features of 17712 conformance.

Certification of successful physical testing for proper seal classification.

Certification of successful inspection of the seal manufacturer's security-related processes.

More detail is in the paragraph ISO TC 104's "recommendation to users for interim application of ISO 17712" below.

ISMA's recommendations to seal users:

Seal buyers should specify purchase of 2013 Clause 6 compliant seals for delivery in March 2014; this should provide sufficient time to deploy the compliant seals to the field before the May 15 transition date.

No manufacturer, to ISMA's knowledge at the time this is written, has had time to develop and document its tamper migration and management programs, apply them, and be successfully inspected for compliance. ISMA recommends that buyers treat near-term claims to the contrary with skepticism.

Finally, ISMA recommends that buyers acquire security seals from quality manufacturers - and the easiest way to do that is to specify suppliers that are members of ISMA.

ISO TC 104's

"recommendation to users for interim application of ISO 17712"

"Consider a seal as compliant with ISO 17712: 2010 if the manufacturer or distributor can produce upon request:

A current Certificate of Conformance for Freight Container Mechanical Seal Testing or an equivalent letter from an ISO 17025 accredited independent testing laboratory with ISO 17025 in its scope of accreditation. For High Security "H" seals, the certificate or letter should indicate only classification ratings of "High Security" and the seal should be marked with an "H". For bolt seals, the certificate or letter must also show "Pass" for the minimum diameter test.

A timely audit report or equivalent letter of conformance with ISO 17712: 2010 Annex A, Seal manufacturers' security-related practices, completed by an independent process certification provider specifically accredited to audit conformance with ISO 17712.

Although not required by the standard, best practise among testing laboratories and auditors is to provide digitally authenticated documents.

Consider a seal as non-compliant with ISO 17712 only if the manufacturer or distributor cannot provide documentation and marking as described above."

This material has been taken verbatim from the Chairman of TC 104's letter to the WCO Director of Compliance, dated February 23, 2012.

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