Records Retention Schedule for ema
ema names this requirement as "Registros de competencia del personal inspector — competence criteria per activity, authorisation records, training and ongoing monitoring". The QA manager owns it, and a contracted Level III can author and sign it.
The finding auditors record against this document is: Competence criteria for inspectors written generically rather than per inspection activity and method, with no authorisation records tying a named inspector to a specific scope. ema is the accreditation body that turns a Mexican inspection firm into one whose dictámenes a regulator will recognise. It accredits unidades de inspección against NMX-EC-17020-IMNC-2014, the Mexican adoption of ISO/IEC 17020:2012, applying ILAC P15 as guidance. Two things routinely trip up foreign firms. First, accreditation alone is not sufficient for regulated work: issuing a dictamen under a NOM also requires aprobación by the relevant dependency, and STPS publishes the directory of accredited and approved units. Second, since the Ley de Infraestructura de la Calidad took effect the statutory term changed from unidad de verificación to unidad de inspección — the activity is unchanged, and ema's own procedures still carry both names.
Source: ema, 'Manual de Procedimientos — Evaluación y Acreditación de Unidades de Verificación (Organismos de Inspección) con base en la norma NMX-EC-17020-IMNC-2014 / ISO/IEC 17020:2012', extracted and read directly, including its definitions of renovación (4.33), testificación (4.44) and vigilancia (4.46) and its surveillance, reevaluation and witnessing intervals; the procedure cites ILAC P15, 'Guía de aplicación de la ISO/IEC 17020 para unidades de Verificación'. Types A, B and C and the accredited-plus-approved requirement from ema's application guides for the same standard and from NOM-020-STPS-2011 clauses 4.41 to 4.43 and 19. Terminology change from unidad de verificación to unidad de inspección under the Ley de Infraestructura de la Calidad, published in the DOF on 1 July 2020; cancellation grounds from Article 59 of that law. Limitation: ema's own website returned HTTP 403 from this environment on 21 August 2026, so the public accredited-body directory at catalogo.consultaema.mx was not consulted and no counts or named accredited firms are stated. Verified 21 August 2026.
| Item | What applies | Why it matters |
|---|---|---|
| Regime | Entidad Mexicana de Acreditación, A.C. | Enforced by ema, operating as an Entidad de Acreditación under the Ley de Infraestructura de la Calidad; sectoral aprobación is granted separately by the regulating dependency — for pressure equipment under NOM-020, the Secretaría del Trabajo y Previsión Social |
| Document | Records Retention Schedule | how long each record is kept, where, and who can retrieve it during an audit |
| Owner | the QA manager | The signature an auditor traces back |
| Where it is checked | Dictamen — the relevant evaluation committee or technical opinion commission decides to grant, deny, reduce, suspend or cancel. | Usually against a sampled job, not in isolation |
| Common failure | Type declared as A while the unit also inspects for a related party, breaching the independence conditions that type requires | The gap between the manual and the job file |
What must a records retention schedule contain under ema?
It has to satisfy ema as ema, operating as an Entidad de Acreditación under the Ley de Infraestructura de la Calidad; sectoral aprobación is granted separately by the regulating dependency — for pressure equipment under NOM-020, the Secretaría del Trabajo y Previsión Social enforces it: how long each record is kept, where, and who can retrieve it during an audit. The test is not completeness on paper but traceability — an auditor picks a finished job and works backwards to this document, so anything it claims must be demonstrable on that job.
Who signs the records retention schedule for ema?
The QA manager. Because this regime accepts employer-based certification, that role can be filled by a contracted Level III rather than a staff appointment, provided they are qualified in the methods they sign for.
How does a ema auditor test this document?
By sampling. They take a completed job, find the technicians and equipment used, and trace each back through this document to the evidence behind it. A document that reads well but cannot survive that trace is the most common finding across every regime, not just this one.
How long must ema records be kept?
ema's procedure sets surveillance (vigilancia) at 12-month intervals, which may be conducted in the two months before or after the due date. The first surveillance evaluation is performed on site and preferably before 12 months from the accreditation date, with an outer limit of 18 months measured from that date for initial accreditations. Reevaluación must be carried out before the four-year cycle completes, counted from the last reevaluation decided by the relevant evaluation committee or technical opinion commission. Testificación must be repeated within no more than four years of the last witnessing. Renovación — a full re-evaluation against an expiry date — applies where a dependency requires the accreditation to carry one. Under Article 59 of the Ley de Infraestructura de la Calidad, accreditation or approval can be cancelled for issuing documents with false or erroneous information, repeatedly refusing requested services, express renunciation, serious breaches of obligations, or altering issued documents. Retention is set by the regime and by the client contract above it, and the longer of the two governs. Firms that set one retention period for everything and document it fare better at audit than firms tracking different periods per record type and losing track.
Does a generic template satisfy ema?
No. A downloaded template describes a generic firm, and the first question an auditor asks is whether the document describes THIS firm — its methods, its equipment, its people, its actual workflow. Templates are a starting structure; the content has to be the firm's own or the trace fails immediately.
What happens if this document is missing at a ema audit?
It is a finding, and depending on the regime it can suspend the certificate rather than merely generate a corrective action. The related finding auditors record most often is: Type declared as A while the unit also inspects for a related party, breaching the independence conditions that type requires
Where this sits in the ema evidence pack
- Solicitud de acreditación filed through ema's SAEMA system, naming a representante autorizado who accepts the accreditation requirements on the body's behalf
- Alcance de acreditación — the requested scope stating inspection activities, methods, and the NOMs or standards to be inspected against
- Documented management system meeting NMX-EC-17020-IMNC-2014, including the impartiality and independence declaration that establishes Type A, B or C
- Procedimientos técnicos de inspección for every method and activity in the requested scope
- Registros de competencia del personal inspector — competence criteria per activity, authorisation records, training and ongoing monitoring
- Registros de equipos y trazabilidad metrológica — calibration certificates and traceability evidence
- Formatos de dictamen and reporting templates carrying the accreditation number and the required dates
- A real inspection made available for ema to witness (testificación) before initial accreditation is granted
- Solicitud de aprobación to the regulating dependency, such as STPS for NOM-020, once accredited
Personnel certification context
ISO/IEC 17020 does not require an inspection body's inspectors to hold third-party certification. The body itself defines, documents and verifies competence criteria for each inspection activity, and ema evaluates that system — verifying personnel competence by demonstration during the on-site evaluation and by witnessing real inspections (testificación). That makes an employer-operated competence scheme backed by an outsourced Level III genuinely workable in Mexico, provided it is documented, applied and evidenced. Separately, ema accredits personnel certification bodies against NMX-EC-17024-IMNC, which is how centrally certified NDT personnel exist in Mexico at all. Where a NOM or a client contract names a personnel standard, that sits on top of, not instead of, the 17020 competence system.
Related: the ema overview, outsourced ASNT Level III cover, written practice development, NDT procedure development, a programme gap assessment, interim Level III cover.