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NRTL Updates - NRTL Update #4 (January 8, 1999) |
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NRTL Update #4 (January 8, 1999)
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Happy New Year! It's time for another of our periodic updates on activities related to the NRTL Program.
- Trip to Brussels
On December 3rd, Steve Witt, Dorothy Dougherty, and I met with staff from DG III of the Commission of the European Union, as well as representatives from member states and a number of European labs that may apply to be recognized as NRTLs. We were accompanied by Deputy Assistant Secretary of Commerce Charles Ludolph. Representatives from 6 NRTLs also participated. The MRA became effective on December 1st.
The primary purpose of the meeting was to conduct a workshop on the requirements of the NRTL Program. In discussions with various parties in the months prior to the workshop, including NRTL representatives, it became clear that there were considerable misunderstandings in Europe about the NRTL Program and the terms of the MRA. As OSHA has stated on many occasions, the electrical safety annex addresses the issue of reciprocity under current OSHA requirements. In other words, the MRA has established reciprocity for the countries in the European Union, so that step of the application process for a foreign lab has been accomplished. Beyond that step, European labs must go through the same process as a US-based lab would for NRTL recognition.
It was clear from our workshop discussions that we were correct in assuming there were misunderstandings in Europe in the Commission, member states and prospective labs. We believe that our presentation and subsequent question and answer period were very instructive in this regard, and that the requirements of the program, the application process, and OSHA's review process, have been clarified. It was also very helpful to have the NRTL representatives participate in the discussion, and provide their perspective on the issues.
I am attaching an electronic copy of our presentation in PowerPoint for those who may be interested.
(Note: click here for presentation)
In addition, I am also attaching the latest version of the application guidelines, and a summary of policies that we distributed to the workshop. These policies are in draft form, and will be included in the directive establishing standard operating procedures for the program that is nearing completion within OSHA. The draft policies address areas such as independence and follow-up inspection frequency. If you have any feedback on these draft policies, I would appreciate receiving it by January 20th. Have also attached draft Appendix F to the directive which provides information about the derivation of evaluation criteria for the requirements for the NRTL Program. This document was also made available to the participants in the Brussels workshop. (These documents are all in Word Perfect 8.0.)
(Note: click here to access current Application Guidelines and Program Directive, which contain the policies and the appendix mentioned in the preceding paragraph)
In addition to the workshop, OSHA and Commission officials met informally to discuss implementation plans and possible procedures for the Joint Sectoral Committee. A formal Joint Sectoral Committee meeting will be held in Washington, DC at some time after the initial applications are filed for European labs. At present, we expect to receive those applications in February. The total number of applications is still uncertain. Meeting participants indicated that they believed the number would be smaller than originally anticipated given the clearer understanding of program requirements such as the need to be able to both test and certify.
- Expansion of Recognition to Include Additional Standards
Please note that you must apply for an expansion of your recognition to add standards to your NRTL program. As you know, we are putting the standards you are recognized for on the web site. We have had some inquiries lately from people who believe the web site is out-of-date because they have been told by an NRTL that they can test for a standard that is not on the web. We make every effort to keep the Internet information up-to-date, and in this case, the lab was not recognized by OSHA for the standard in question. It should also be noted that the approval process cannot be circumvented for a "quick" approval. It may be shortened if the standard is similar to others you are recognized for, and we do not need to conduct an on-site assessment to verify capabilities, but we still have to follow the public notice process.
- Changes in Ownership
Please note that your recognition includes a condition that you notify us "as soon as possible, in writing, of any changes in ownership or key personnel, including details." The notification should be sent to my attention.
- Marks
We now have copies of all of your marks for use in the training modules for our compliance officers. In addition to using them for this purpose, we are planning to add them to our web site so the public can access them as well.
- Certificates of Recognition
As you know, we currently send you a letter from the head of OSHA as your NRTL recognition. We have recently designed a certificate of recognition to accompany this letter with a logo for the NRTL Program. All of the labs currently recognized will receive this certificate in the near future. The 4 labs that are in the renewal process will not receive them until their renewal is granted.
- Fees Notice
We hope to have the fees proposal through our legal and administrative review process sometime in the near future. The current proposal has a different approach than had been contemplated in the past, and is generally based on fees for the specific services provided to each NRTL. We will let you know the details of the proposed approach as soon as we are cleared in the review process. The proposal will be published in the Federal Register with an opportunity for public comment on the record. The proposal will then be modified based on the public input, and published in the Federal Register in final form.
As always, please feel free to contact us if you have any questions, comments, or issues of concern. Thanks.
Jennifer Silk
Director
Office of Technical Programs and Coordination Activities
Occupational Safety and Health Administration
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