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NRTL Updates - NRTL Update #6 (December 1, 1999) |
Printing Instructions
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NRTL Update #6 (December 1, 1999)
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Hello Everybody:
It's been a busy time for the NRTL Program, with a number of activities and issues underway or under discussion. Here are a few updates you may be interested in:
- The Directive/Web Site
We have at long last gotten clearance to release the directive detailing the procedures and policies of the NRTL Program. This information has been circulated to you in draft in the past, but it has now been reorganized, formatted, put in plain language as much as possible, and cleared through OSHA and the Solicitor's Office. It may be found on OSHA's web site under "Directives". It is supposed to be posted tomorrow, December 2, 1999. (A cautionary note: We are experiencing very heavy usage of our web site at the moment due to the interest in our new proposed ergonomics standard so it may be difficult to get through.) We will be posting a link to the directive from the NRTL page as soon as possible.
We want to emphasize particularly the independence policy in the directive. This was circulated for comment earlier this year. There continue to be issues regarding independence as many laboratories have new business relationships that test the policy. Please be advised that we will be reviewing these issues very carefully, both in the initial application process and when an existing NRTL is applying for a renewal of recognition.
The training program for our compliance staff is also now available on the NRTL web page.
- Mutual Recognition Agreements
OSHA recently participated in a Joint Committee meeting on implementation of the US/EU MRA. At this time, we have not received any complete applications from Europe, but understand that we will be receiving some new submissions soon.
The US/EU MRA is the only MRA process that OSHA is participating in. We are not taking part in any discussions regarding agreements in the Asia-Pacific area, and maintain that our program has no barrier to participation from labs in any country as long as reciprocity has been established. Once it is agreed there is reciprocity, the existing NRTL procedures will be implemented by OSHA for any foreign lab application for recognition.
- Relationship of the NRTL Program to State/Local Electrical Authorities
Based on conversations we have had recently with some of you, there appear to be some misunderstandings about the NRTL Program and its relationship to state and local electrical authorities. The NRTL Program deals strictly with workplace safety. Enforcement of our requirements is through our own compliance staff, and in OSHA state programs, through their enforcement staff. State and local electrical inspectors who are not part of a state OSHA program are NOT enforcing OSHA requirements, nor do we have any relationship with them or with their programs. Their purpose is public safety, and while that may overlap with our workplace safety issues since workers are part of the public, they do not enforce our requirements.
- Audit Results
Our annual audits of NRTL sites continue to be instructive. As a result of things we found during the past year's audit activities, our auditors will be giving particular emphasis to 3 areas of concern for this year's audits:
- An NRTL's use of another NRTL's follow-up audit in place of doing a follow-up audit of their own.
- Checking that the NRTL has requirements for client manufacturers to use calibrated instruments when the applicable test standard requires on-line testing.
- Review of the NRTL's use of the programs in the March 9, 1995 notice to ensure all requirements are met.
We will continue to review other areas on the audits as well, but you can expect a new focus on these issues.
- Fees Notice
We received 4 comments on the notice of proposed rulemaking on fees for the NRTL Program and shortening the comment periods for NRTL Federal Register notices. We are in the process of reviewing the proposal and preparing a final rule.
- Withdrawn Test Standards
Just a reminder that when a standards organization withdraws a standard, an NRTL can no longer be recognized for that standard. In the past, we changed the recognition at the time of renewal to address the withdrawn standard issue. This is a piecemeal approach that is not very efficient or effective. In the future, we will be removing recognition across-the-board for all NRTLs that had been recognized for the withdrawn standard.
As always, if you have any questions or comments, please contact the OSHA NRTL staff. We would like to wish each of you a happy holiday season, and a great Y2K.
Jennifer Silk
Director
Office of Technical Programs and Coordination Activities
Occupational Safety and Health Adminstration
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