The CFP SA is outlined in the Annex C of the ISO 14067:2018. The section C.3.4 “Validation of the CFP systematic approach”, specifies that organizations shall conduct “internal CFP systematic approach assessments at planned intervals, to ensure its continuous suitability, adequacy and effectiveness”.
The goal of this is clearly that, through an internal control, the organisation can guarantee that the systematic approach (CFP SA) keeps being able to ensure the expected outcomes.
The internal audit can thus be considered to be a possible strategy to perform such evaluation, but it cannot be considered the only one.
Nevertheless, the interpretation that sees the internal audit as compulsory before the realization of the third-party verification is not by any means acceptable. This interpretation is to be justified through the experience of verification bodies in the environmental management system. In fact, in accordance to the ISO 17021-1, they include as objective of Stage 1 “to evaluate if the internal audits and management reviews are being planned and performed” (section 126.96.36.199.2 g); in addition, it is specified that during Stage 2 the internal audit and management review have to be revised (section 188.8.131.52 e).
Such requirements are not mentioned in the standards that are currently in force for the accreditation of GHG validation/verification activities (ISO 14064-3 e ISO 14065), nor in the generic standard for validation/verification activity as conformity assessment (ISO 17029), nor in the future revision of the ISO 14065. This is due to the fact that all the mentioned activities are intrinsically different from the certification of environmental management systems.
Therefore, in the GHG accreditation system of verification there is no instruction requiring the realization of an internal audit before the third-party verification.