S20.20 Table 2 Specifies to utilize TR53 Footwear Section for Verification Requirements
TR53 Section 8.3 Footwear section lists (2) test methods for footwear verification.
- Integrated Test System
At no point within TR53 does it state that either test is acceptable as proof of verification. But rather it details “required equipment” of both an integrated checker and a Meter. Then guides the user to conduct each test method.
As written, there is not a choice of which test method to use but rather both would be required to fulfill footwear verification. I am concerned that within an audit we may be asked why we do not complete both test methods. Should there not be a clear statement either in TR53 or S20.20 that states to use one of the verification test methods within TR53 or are both truly required to be compliant?
Let’s look at the requirements first. ANSI/ESD S20.20 states that the ESD control program include a compliance verification program that defines the test procedure, limits, frequency of the verification. Further, ANSI/ESD S20.20 gives limits and test methods that need to be considered. The user then must select the appropriate test method for compliance verification from ESDA TR53. In some cases, there are multiple test methods. Most of the time, the alternate method is depending on the type of equipment the user had to make the test. The outcome of the tests should be the same provided the correct equipment is used.
Let’s go back to the requirement. ANSI/ESD S20.20 basically says to use TR53 and the stated limits to construct a compliance verification plan. An audit or assessment can ask and should how do you verify footwear. If you state that you use an integrated tester and the limit is set by ANSI/ESD S20.20, that fulfills the requirements of ANSI/ESD S20.20.
Although not quite the same, let’s take personnel grounding. The requirement is to ground people but there are two methods that are acceptable in ANSI/ESD S20.20. Only one is required, not both, even though both are listed.
In this case, you need to define a compliance verification test that meets the requirements in ANSI/ESD S20.20. TR53 gives you a choice on how this is implemented.
Thank you John for your response. Although I do completely understand what you are saying, I am reading these documents as written and not the intent. Which is typically the same as how an auditor would read it. During our S20.20 audit, the auditor will read a statement and then expect us to show evidence of meeting that statement.
Example: S20-20-2021 sect 7.4 Compliance verification states “A compliance verification plan shall be established to ensure the ESD control items used by the organization meet the requirements identified in Tables 2, 3, and 4 of this standard. This includes the use of the test methods and test limits identified in these tables.” And as such to me is clear that “all” items in tables 2,3 and 4 must be met. This statement is followed by “If the test methods or test limits used by the Organization differ from any of the test methods referenced in Tables 2, 3, or 4 of this standard, a tailoring statement shall be developed”. So this seems to confirm that all items must be met unless a tailoring statement must be used. Tables 2,3 and 4 do not indicate that we may select which test method or required limits we chose to use.
As stated previously, I do not see any place within TR53 or S20.20 where it documents there is a choice. As such, if does not state there is a choice than that implies all items must be met. If I am missing something “written” that states these are choices, can you please point them out so I can reference them?
Thank you again
I appreciate the interpretation but don’t read to much into the standard. The requirement for a compliance verification plan is to present objective evidence that indicates that the ESD control item meets the limits in ANSI/ESD S20.20 but using the test methods in TR53. While I understand your question, the alternate test methods in TR53 yield the same results. The assessors are trained (and I know the training modules) not to require testing to all the methods in TR53 but to verify the the objective evidence and the test method can be found in TR53.
When writing a test method, the requirements are general as there are many ways to satisfy a requirement. It is up to the user to determine the compliance verification plan using TR53.
If there is ever a conflict, you can ask for resolution all the way to the ESD Associaiton.