Discuss MCS Quality Management System in the Solar PV Forum | Solar Panels Forum area at ElectriciansForums.net

L

Loyd

I have submitted my application to the NICEIC for MCS.

I have a Health and Safety Handbook and appropriate method satements and risk assessments. What I do not have is a Quality Management System. I don't want to write this myself from scratch and so need a template to work from.

I am sure many of you were in the same boat. Did you buy/beg/steal/borrow a QMS template? If so where from and would you recommend it?

Loyd
 
Hi Loyd,

Your not going to be able to buy this as it is bespoke to your company and methods of work. No one can tell you how to do your processes.

The QCS is best described as a manual to hand to a complete stranger on how to run your business while you go on holiday! Outrageous I know but that was how it was described to me.

Think about how you are going to or do handle every item from first customer contact to hand over and registering. What controls you have in place for customer care, complaints. Product checks and delivery. What source of information are available and how to check and source sub contractors etc. Think about every step of the works, what information you need and need to give. Where to find this information and detail where it is kept (in crate under bed for example!) How you will review the information and how often. Detail date and version number on it also to identify updates etc.

Having done ours some 12 months ago we review every 3 months but in practice its reviewed every time we add or change suppliers or products etc. It doesn't take much if saved on a PC.

Its not as hard as you may think and it doesn't have to be war and peace!

PM me if you need guidance or even to review one you have written, I'd be happy to do so but having written ours I'm not going to pass it out or write one for someone else, Sorry! Not that it would be relevant to how YOU do things.

Mark
 
Hi Mark

I'm know I'm sticking my neck out here I know because I haven't been through MCS but .....

My reasoning runs like this. There have to be many common processes and standard documents used by all Domestic PV Installers. Currently, like most prospective MCS Installers, I have little experience of installing Solar PV. If 10 of us started from scratch in producing those processess and documents we would come up with 10 different versions, some parts of which would be brilliant, other parts would be total tosh.:confused:

If we were to pull all the best bits together we would get close to Best Practice processes that we could adapt to our own busineses.

It's that Best Practice starting point that i'm looking for.

I may be wasting my money but I have booked myself on to the National Energy Foundation / Solar Trade Association course. More info here NEF | MCS - Microgeneration Certification Scheme Made Easy Course. I wouldn't use their Quality Management System unchanged, but it looks like it is a good model.

The course is next Wednesday in Manchester - I'll let you know after the course whether I have wasted my time and money.
 
Good luck with the course. Let us know how you get on. Would be interseting to know.

I understand your reasoning regarding the QCS. Pulling all the best bits together may still not be how you will do things and unless your QCM resembles what you do then it will be of no relevance. We had only done two installations when we formed our first QCM but what we produced was relevant to our use at that time. Once we increased installations we updated the QCM as required by adding bits in and changing others. If you show a fully loaded QCM on first inspection you may be asked to demonstrate how you implement it. As I was told the QCM for British Gas would be no use to our two man band company.

I have seen companies advertising manuals made bespoke for you but I don't know the cost and when amendments need to be made whether they have to do them as well or if they let you have a digital draft copy.
 
The National Energy Foundation/Solar Trade Association 'MCS Made Easy' course is very good.

The course was delivered by a MCS Assessor - an external contractor to BRE. She had been involved in the renewable energy business for 20 years and knew the ropes. She overcome any conflict of interest by being outside the BRE organisation and by making sure that she did not assess any company that had been on one of her courses.

The course provided just what I was looking for - it took us through a best practice quality management process manual containing document templates to address the basic requirements of MCS. NEF claim is that without their template, creating an MCS Quality Management System will take ~20 man days. Tailoring the 'MCS Made Easy' templates to the requirements of your business they claim will take ~ 1 day. As they provide CD containing templates in word format with your company name and other key data already merged, this is a fair claim.

The added bonus is that we can adapt the processes and templates to improve the management of our existing business.

I'm just waiting for the final CD with our personalised templates. I will keep you informed of progress.
 
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I've not used the software yet. I'm going to do the QMS course to make sure I'm as well prepared for the visit as possible. After that, I will reassess whether making a purchase is a good idea or not.
 
Hi Mark,

I am just looking at getting my MCS in place for PV but do not have the time or knowledge to create a QMS, I have heard of a company called easymcs Cost & Pain Free MCS Installer Accreditation & Certification

they seem to produce a QMS bespoke for your company and mentor you through the process. I have spoken to a few people and these guys seem to be the biggest in the market at the moment, do you know much if anything about them? they have said the cost is £495 which when you consider a course is generally £150 and then a day not installing is another £250 + i would still have to build it with most of these seminars i think it is a good deal?

They have also offered a £50 discount to mcs assessment with NIC EIC do you know if this is legitimate?
 
I have submitted my application to the NICEIC for MCS.

I have a Health and Safety Handbook and appropriate method satements and risk assessments. What I do not have is a Quality Management System. I don't want to write this myself from scratch and so need a template to work from.

I am sure many of you were in the same boat. Did you buy/beg/steal/borrow a QMS template? If so where from and would you recommend it?

Loyd

The problem with stealing, begging, or borrowing other QMS's, as stated, is that it isn't specific to your business, and will force you into doing things in ways you don't work.

Far, far better to document the processes you currently follow, keeping it as simple as you can, while covering everything.

Draw flowchart diagrams to start with, and take it from there.

I've stuck up a link to another conversation about this, only a week or so ago.
 
Hi Bill,

that link is great thanks , apparently easy mcs will build your qms for you what are your thoughts on this?

There's a few companies out there with offers along these lines - one I recall offering a complete QMS in 30 days.....at only a grand. On closer inspection, it was, kind of.

The real problem with a lot of QMS consultancies, and especially ones which offer "standard" QMS systems is that they generally either only offer a "starter" system which misses half of what you actually do, or it forces a load of stuff on you that you don't need to do.

There is a myth that QMS is hard to understand. It isn't. In essence, all any QMS is, is a system which contains documentation of how your business operates. It needn't be any more complicated than that.

The Easy MCS scheme seems to offer the right service - not sure on pricing, but definitely worth investigation as to cost, and precise involvement. It likely won't be cheap though, especially given the strap saying 0% loans for Welsh Installers (time for a Welsh branch location?).....

One key thing I will say is that the more you can document what you already do, and design basic processes for, the easier the process becomes, the better your understanding of things, and the more likely you are to be consistent in things in any case.

You probably already have most of what you need, just never written it down at all.

For example - do you deal with all installations in the same way? Many of the processes for testing, inspection, even install practice are already there.

The single biggest thing most people have difficulty getting their head around is mapping the processes - i.e. every document has to have a unique number, so it can be referred to unambiguously.

The other thing of note is that is is ALWAYS worth speaking to your scheme admin to see if they have any guides as to what they expect from you in terms of the QMS. They should have some kind of overview document, and may even let you have a copy of the assessment form.

After all, it's as much in their interest as yours that your application is successful.
 
Bill,

I received my QMS manual from Easy MCS today and have been in contact with Pete one of the mentors over the last few days to get myself set-up to implement it over the x mas break. I am really impressed with the package they have provided but the mentoring they have given me over the last few days has given me full confidence in going for my accreditation. The package they provide cost me £495 and includes all the relevant procedures for mcs for heat pumps the only bit I have to get is the TR/30 guide.

They have given me a list of 10 things to do over the x-mas break such as creating a non conforming product area and a few example customer complaints and using the info in the folder i need to create a project pack and hand over but everything is in the pack.

They have advised either NIC or Corgi for my assessment does anybody know of any others ?
 
Bill,

I received my QMS manual from Easy MCS today and have been in contact with Pete one of the mentors over the last few days to get myself set-up to implement it over the x mas break. I am really impressed with the package they have provided but the mentoring they have given me over the last few days has given me full confidence in going for my accreditation. The package they provide cost me £495 and includes all the relevant procedures for mcs for heat pumps the only bit I have to get is the TR/30 guide.

They have given me a list of 10 things to do over the x-mas break such as creating a non conforming product area and a few example customer complaints and using the info in the folder i need to create a project pack and hand over but everything is in the pack.

They have advised either NIC or Corgi for my assessment does anybody know of any others ?

That's quite impressive then.

It seems you're well on the way, too.

I'd have said either NIC or Corgi for the assessment too.

Happy Christmas!
 
I have recently received my quality management system, mentoring service & advice on inspection from a company called easy mcs i am now looking to book my assessment. does anybody have any advice on who to use for my inspection i have been advised either NIC or Corgi ?
 
hi all, just joined the site. we all seem to be in the same boat, im looking into booking myself on a quality management seminar too get assistence with the criteria of passing the pv assesment, can anyone one give me further advice and if the have experienced it and if they belive it has been worth it, many thanks
 
hi all, just joined the site. we all seem to be in the same boat, im looking into booking myself on a quality management seminar too get assistence with the criteria of passing the pv assesment, can anyone one give me further advice and if the have experienced it and if they belive it has been worth it, many thanks

Hi there, this mcs stuff is certainly a bit of a task to say the least. Well I went on a seminar that cost £75 (+ a day not working as I am self employed) it did give me a knoledge of what mcs is and a stack of templates for my qms but when I sat down to but the bespoke qms together I was still miles from the standard required. I eventually called a company called easy mcs in Chester and they produced my qms for me and mentored me through the standard all for £495. When you take into consideration that I would of failed my assesment with the pack I started putting together + a re-assesment fee i started thinking this should of Been my first route instead of the seminar. Well worth giving them a bell.
 
Hi, just to say we're with NAPIT and they have an MCS / QMS template that we're just working through now - it includes things like templated Excel sheets for document registers etc etc. We're looking to customise it to our way of working ready for our MCS assessment mid Jan
 
To be honest when I started putting mine together I worked out it would take me about two / three weeks and it may still fail. I just liked the thought that for £495 I could have someone do it for me that knows the standards and guarrantees an office based pass. It meant I could get on with installing and making money. If I missed three days work because I was working on my qms then I would of lost the same amount of income as the cost of the pack.
 
just to go off the subject how ae you guys going to to be assesed, what i mean is you first job that you will be assesed on. its not a good selling point to a customer that there house will be the first one you do etc, or you going to install on a friends or family house, cheers
 
You don't have to actually do an installation yourself, if you know of someone who has done an installation you could use this as an example to show the assesor. You build your project pack and hand over pack around this installation as if you have completed it from initial enquiry to calcs to commissioning. The assesor will be able to see that you understand the installation process and audit you in 12 months to ensure you are doing it correctly.
 
cheers treadwarm, do you have any info i.e paperwork you fill in on commisioning etc, my pv course is in 2 weeks just want to get the best understanding i can before the course starts. i always feel they rush these courses. if you have anythinbg that you may feel will benifit me could you send me them to [email protected]. diolch..
 
If I am honest mate I am still in the early stages myself and will be looking to get my training course booked in jan myself . If I can give any advice it would be to speak to your certification body or easy mcs before you book your course I went on one that cost me £300 and I had no practical training what so ever. Like with anything u have good and bad courses but easy mcs reccomended me on to one just need to get it booked.
 
You don't have to actually do an installation yourself, if you know of someone who has done an installation you could use this as an example to show the assesor. You build your project pack and hand over pack around this installation as if you have completed it from initial enquiry to calcs to commissioning. The assesor will be able to see that you understand the installation process and audit you in 12 months to ensure you are doing it correctly.

Who told you this? It is my understanding that the installation has to be completed entirely by the applicant.
 
You don't have to actually do an installation yourself, if you know of someone who has done an installation you could use this as an example to show the assesor. You build your project pack and hand over pack around this installation as if you have completed it from initial enquiry to calcs to commissioning. The assesor will be able to see that you understand the installation process and audit you in 12 months to ensure you are doing it correctly.

I think I would be very sceptical of this. Who is the accreditation body offering this, i.e, NIC, Napit, Corgi etc? How can they asses YOU for your installation if YOU haven't done it? Can you clarify this?
 
I have worked closely with corgi and NIC EIC and have been the nominee for three companies who have hired myself as the MCS quality representative to gain MCS. The MCS standard does not specifically state that you physically need to do the installation even to the point that you can use a sub contractor to complete the work ( as long as the complete a sub contractor agreement form, outlining that they will work the relevant technology standard). MCS covers the knowledge and capability of an individual or company to both calculate and document all sections of a project and company procedure to ensure they work to the standards required. During your assessment 80% of the day will be spent on your QMS a collection is specific procedures documenting the procedures of your business and the capabilities you have to design / specify the equipment you are looking to supply / install. During this time they will also ask to see a project pack specific to the installation you will be showing them. Finally they will visit the site with you and ask questions relevant to the MCS product standard to ensure you are aware of the specific points on the installation. Trust me I have done this three times and passed first time each time. I also have worked closely with easy MCS the largest MCS preparation inspection company in the UK.

Any questions please feel free to ask I am here to help
 
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I have to say if this is true then I am totally staggered.

A firm can gain MCS accreditation, which is effectively a sign that a firm excels at installing PV systems, even if a firm has NEVER even installed a single system?!

What next? A driving license issued to someone that has never driven?
 
Hi Biggs, this is a common mistake with MCS, it does not stand for excellence of installation of renewable technologies. It actually covers the fact that you are compotent to design and specify correctly and record the information in a professional manner. Also this leads into the competent person scheme to sign of your own work . But don't think that anybody could gain MCS as you must be able to prove that you are competent to install your chosen equipment, ensuring you have the knowledge and capability to design / specify the kit, taking into account wind loads etc. If all these elements are covered then you can be sure that as long as the correct kit turns up then any roofer or part p spark can screw some panels to the roof.
 
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As unbelieveable as it sounds I think Treadwarm maybe right, technically. The MCS is more about assessing the buisness and procedures, very much like ISO9001. I worked for 4 years for in a ISO9001 (and other high quality systems) business and have had more quality assements than hot dinners, in all those years and inspections, not once did the assesor want to see actual work carried out or even equipment on the bench. The nearest he got to the workshops was checking calibration stickers on multimeters and complaining we had resistors stored next to capcitors.

I suppose you could well pass the MCS if you had a sub-contractor round to do the install - after all the subby is there on behalf of the company and any problems the solar company is ultimately resonsible as prime contractor.

Shame if the MCS is only a paperwork exercise, i'd be worried about new firms springing up with at least the experience of one proven and assesed install. I'm sure alot of people could desgin and specify a suitable system after going on a course, but it's a different ball game installing some one elses desgin.
 
The MCS is supposed to give consumers the assurance that a company meets a certain set of strict standards. I'd have thought the actual installation of the equipment is a pretty vital aspect of these standards. Otherwise I'd argue pretty strongly that the whole MCS scheme is as much use as a chocolate saucepan.

I don't mean to get all 'Daily Mail' here but this country fills me with despair at times, it really does.
 
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So along these lines and as a MCS company would it be correct to say the REAL (or alike) scheme would expect the MCS company to state to the proposed customer that they, as the MCS company, do not install the system and they use sub contractors to do the installation?

I have to say I'm with Biggs here! What a mockery it makes of the entire procedures! When I achieved MCS though the NIC I had to of had TWO systems installed. No where in the NIC literature does it state that these can be installed by others. When we were assessed our two installations where checked (Not as toughly as I was expecting) but nether the less still inspected. Labels, cable routes, gen meter location etc. If this was installed by others how can it be assessed against a company who hasn't installed it?
 
I have deleted my last post as I hope the explanation below gives a better account of the situation

I hope I have not mislead anybody via my posts above, Morgan123 is perfectly correct and the MCS scheme does require you to operate in a manner similar to ISO9001 ( which I think we all agree is a good thing???). in addition to this the company must show that a senior member of staff e.g Technical director has the ability to install the products ( this covers mounting the panels correctly) and design the electrical feeds & inverter section of the system ( this is nearly impossible without 17th edition and experience on site) in addition the technical representative must be able to show they can calculate wind loads etc. (basically give a good understanding of a working PV system).

If you have all this in place then you are capable of not only completing the installation to mcs standard but also of ensuring a system is installed to these standards which bring in the sub contractor section.

So for instance you are an M&E consultant looking to gain MCS to be able to check and ensure installation are to MCS standard and that your customers are eligible for MCS. so you gain your MCS by ensuring you have the following.

A high understanding of a Quality Management System which includes similar standards to ISO9001 but in addition have specific procedures for the product(s) you are working with. ( I got mine from easy mcs in chester)

Technical ability to complete the installation : ability to design, install and commission the system.

PROBLEM: Your technical director iS 50 years old and can't bend like he use to, what do you do????

You sub-contract in a fully qualified electrician carrying 17th etc and ask him to sign a sub contractor agreement form, this form must state that the installer will work to the standards set out in the relevant mcs standard (e.g MIS3002 ). Once he has completed the installation you as the MCS accredited company would asses the installation to ensure all the standards have been met. Once you are confident with that all the paperwork, design & installation are up to the standard you can apply for your assessment. they will check as you have that all the sections are up to standard.

Yes at this point you as the MCS accredited company have not physically screw a panel to the roof but doing this is not rocket science and you / the customer is safe in the knowledge that the system has been designed by an MCS approved installer which is specific to the technology they are having. and in addition to this a fully qualified spark has fitted the system into the grid so once again everybody feels alot more confident.

I don't want you to think just anybody could gain MCS, I can assure you that if you do not have the technical ability to do the installation then you will not gain MCS. But you can use sub contractors to en-sure work is done quickly and professionally but you as the technical rep will have to asses the installation for compliance and commission prior to logging onto the mcs list.

Ok, so with all this in mind we go back to using someone else's installation to gain your MCS, this covers the same rules as above you must have all the technical ability and professionalism to both complete the installation and document it correctly. you must prove this during your assessment by showing your calculations / certificates of training and competency etc. Once you can prove to the assessor you can cover all these sections and trust me you will be tested on it then you will be granted MCS. f they come back in twelve months time to audit you and you are not working to these standards you will have your MCS taken from you (I have seen this happen).

in conclusion yes you can gain MCS without actually fitting the equipment but you must prove you are capable of fitting the equipment if required.

sorry if this is not what you wanted to hear but I hope this helps people looking to get into mcs and doesn't rattler the cages of to many of you who are already MCS ( i am only stating the facts )
 
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Your last post does now make more sense. It's not how I first thought that you can use an existing system. It is still up to the assessed company to provide proof from first contact to completion that they were the installing company, all be it via sub contracted labour on certain aspects. So on that first job it would be a case of not only ensuring faith from the client to the contractor that they will achieve MCS but also fund sub contracted labour for the installation.

If however it isn't the case I don't understand how you can possibly use someone else's installation to gain MCS like you said in an earlier post? Am I correct is assuming if you know of an installer who is MCS you could contact them to ask if you can use their installation as an example of works for you to achieve MCS rather than having the expense of installing a system yourself? If that is correct it is that, that sticks in the throat a bit.

Thanks for the last post Treadwarm
 
Don't worry, I won't shoot the messenger :)

I don't agree that the QMS equals customer satisfaction. I don't agree that it helps small businesses in any way either.

So if the MCS scheme does not consider technical ability (it cannot, unless it judges an installation) then it is useless.

For example, I have worked with plenty of sparks who are 17th Edition but does this mean they are good sparks? Of course not. If it did then we could do away with the NICEIC, ECA and NAPIT.
 
The question is how would the assesor know if you have used somebody elses installation ??? Impossible for them to check, but they can asses that you understand all the areas of the standard and test you on this during your assesment.

In reality if you adopt an mcs standard qms then your company will operate to a high standard for documentation ( see easy mcs in Chester ) and the procedures will en-sure you know how to work.

Only during your annual audit when they pick your installations at random to asses could they check if you are installing to the correct standard. Furthur more if a client feels your installation is poor they can report you to REAL who could arrange an audit.

Put it this way you could be the best spark in the world with the highest standard qms but you don't have the cash to pay for the products to put them on your own house, or find anybody to take a punt on someone who is not mcs accredited.

Sorry to say it guys but yes, you can get mcs from an existing installation I know because I have done it myself.

U do need a good quality management system and easy mcs seem to be the best for this!!
 
Hi Treadwarm, Is it PV you have achieved MCS on for the three companies you mentioned earlier? The reason for asking is, is there an avenue for someone with a PV system to recoup some of the cost by "letting out" their own system? As they say if you can't beat them join them!
 
The question is how would the assesor know if you have used somebody elses installation ??? Impossible for them to check, but they can asses that you understand all the areas of the standard and test you on this during your assesment.

Could this not be said about a lot of assessments? If you use someone elses work as your own to achieve NICEIC accreditation then you are guilty of fraud.

In reality if you adopt an mcs standard qms then your company will operate to a high standard for documentation ( see easy mcs in Chester ) and the procedures will en-sure you know how to work.

It seems to me, and I could well be wrong, that companies are being led by the hand through the QMS process. They may well end up with a high standard document at the end but there is nothing stopping cowboy outfits from getting involved if what you say is correct. That cannot possibly be right.
 
Passing off someone elses work as your own would be fraud, using a sub contractor to install for you would be 'technically' fine. I think it depends how your business is setup, some companies will have employees, some will use CIS labour as required, others will be what I term "salesman with an MCS umbrella".
Pretty sure we'll see a lot of salesmen selling systems this coming year.

No offence to you Treadwarm but you do seem to be very vocal about easy mcs, imo you can never really fully understand a complex quality management system unless you write it yourself. I'd certainly not want a company fitting panels on my roof that have never installed a system for accreditation, no matter what the MCS assesor approves.
 
Hi Treadwarm, Is it PV you have achieved MCS on for the three companies you mentioned earlier? The reason for asking is, is there an avenue for someone with a PV system to recoup some of the cost by "letting out" their own system? As they say if you can't beat them join them!

I passed with Heat pumps for a company in Doncaster, and for my current company (Treadwarm) then PV and Solar thermal for a company in North Wales.

Not heard of anybody doing this but it may be an option.
 
I passed with Heat pumps for a company in Doncaster, and for my current company (Treadwarm) then PV and Solar thermal for a company in North Wales.

Yet one week ago........

I am just looking at getting my MCS in place for PV but do not have the time or knowledge to create a QMS, I have heard of a company called easymcs Cost & Pain Free MCS Installer Accreditation & Certification

they seem to produce a QMS bespoke for your company and mentor you through the process. I have spoken to a few people and these guys seem to be the biggest in the market at the moment, do you know much if anything about them? they have said the cost is £495 which when you consider a course is generally £150 and then a day not installing is another £250 + i would still have to build it with most of these seminars i think it is a good deal?

They have also offered a £50 discount to mcs assessment with NIC EIC do you know if this is legitimate?

I'm trully sorry Threadwarm but I think it may be time to come clean. A very cunning marketing scheme you have in place there. Easy MCS will be pleased. I like the plan and I have been following the posts with interest.

With the greatest if respect Mark C.
 
to be honest I was simple asked how did you get around needing to show and installation without anybody letting you on the roof without MCS.

If you can prove you have the knowledge and been on the necessary training, your assessment is then a test of your capability via a series of questions for you to answer (do we agree on this) . before you answer ask yourself how you can gain part p ( 3 day course, £300) this includes a practical exam on a training rig. how do you gain 17th edition (5 day course £500 - £700) including a practical on a training rig and written exam. both come with annual assessments.

MCS is no different but everyone seems to want to make it more difficult, your mcs assessment is more in-depth than the other you have been on because they want to en-sure you are not only capable of designing the system but also dealing with the customer correclty from a document point of view.

I think that in this forum MCS is being confused, it seems that it is thought of as a mark on your quality of INSTALLATION capability, if so then why would you require the other electrical certification ??? Answer you have part p ,17th and working at heights for for this, MCS is to ensure you run your business correctly if you then want to do PV you must have 17th or heat pump G3 etc. you will be assessed on these separately in some cases by the same CB (certification body)

This is why the majority of MCS assessors are ex-ISO assessors and the reason your QMS must be of a high standard, and include proof of your capabilities as an electrical engineer to carry out your work.

Also the reason why I recommend Easy MCS other than the fact I have had my QMS from them and worked with them to understand the needs of the installer, is due to the fact that they actually mentor you through the introduction of your QMS as well as supplying you with the pack. Some companies do just supply you with a bundle of docs and say crack on, Easy MCS definitely do not.

Once again guys this is not meant as a cheat for MCS but as assistance in understanding the true meaning behind MCS. Trust me I do know the standards, and also people on the MCS steering group so please any help I can be just ask.
 
Yet one week ago........



I'm trully sorry Threadwarm but I think it may be time to come clean. A very cunning marketing scheme you have in place there. Easy MCS will be pleased. I like the plan and I have been following the posts with interest.

With the greatest if respect Mark C.

Yes Mark fair point I did advise i would recommend them on the forum to gain some interest for them, in all fairness they did do me a deal on my QMS but I would not be on here promoting them if the service was crap. I do know some of the people at easy MCS but i can assure you they are well worth speaking to when looking to gain mcs.

I hope i am not being seen as a cheats way to gain mcs as i only came on here to give help rather and advise people on gaining mcs and that it is not as difficult or costly as everybody makes out.
 

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