For seated operations, we use wrist strap as the designated personnel grounding method in our ESD control program (Program).
We have historically purchased ESD control chairs but chairs/seating are not included in our Program Plan as a chosen ESD control item. Currently they are only used as regular chairs.
Recently during an audit, a non-conformance was issued by the auditor because what appear to be ESD control chairs are used inside the EPA, yet they are not managed as ESD control items.
The explanation that chairs are not part of the Program and wrist strap is the chosen personnel grounding method was rejected.
What is your suggestion for resolution of this matter?
Chairs are one of the optional ESD control items that can be implmented in an ESD control program. If the chairs are part of the ESD control plan, then the qualification and compliance verification requirements must be meet.
If there are chairs (no matter if they are ESD control chairs or not) and they are not part of the ESD control program, they are not subject to the qualificaiton and compliance verification program.
In this particular care, since the chairs are not part of the ESD control program a non-conformance should not have been written. A question that could be asked at this point would be if the chair was considered a threat, as if they are insulators.
At most, the assessor could write an observation for the ESD control chairs should be considered as part of the ESD control plan but a non-conformance should not be written.
So, if there are records to show the chairs have been assessed for threats on a regular schedule, i.e. field induction threats of >2kV within 30cm from where the ESDS items are handled, is the observation still necessary?
Assuming of course we are still limiting the application to the scope of S20.20.
An observation is either something that that assessor has seen that could lead to a non-conformance. While not necessary, it is information given to the client for information. This does not require a reply or a change to the ESD control program.