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NRTL Updates - NRTL Update #7 (May 15, 2002) |
Printing Instructions
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NRTL Update #7 (May 15, 2002)
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Hello Everybody:
It has been a while since we have sent one of these updates to you. We would appreciate it if you would distribute this update within your organization to all with a need for the information it contains. Here are some items that may be of interest to you. Many of them relate to findings discovered during our audit of NRTLs, and we present them as friendly reminders of our policies and requirements.
Jennifer Silk sent the previous updates, but she has assumed the position of Acting Deputy Director of Safety Standards and is no longer director of the office that administers the NRTL Program. Under her leadership, we made a number of key improvements to the program. She will be sorely missed, and we wish her the best. She can still be reached at her e-mail address: jennifer.silk@osha.gov. OSHA is in the process of selecting a new director for our office.
- Acceptance of manufacturer's test data for hazardous locations equipment
As covered in the March 9, 1995 Federal Register notice, our policy prohibits the acceptance of test data from manufacturers for certification of products intended for use in hazardous locations. However, the policy does not prohibit acceptance of manufacturers' data for such products if the data is witnessed by the NRTL or if it is for certification of "products meant for use only in ordinary locations." When a product must meet both ordinary location requirements and hazardous location requirements, manufacturers test data can be used for determining compliance with the ordinary location requirements.
- Utilizing tests required under an international (IEC) standard
As many of you know, IEC standards are not developed in accordance with NRTL Program requirements, and therefore we cannot recognize them under the NRTL Program. NRTLs are reminded that any testing being done for products to be sold in the US must be based on or specified in the provisions of the appropriate US test standard. A test under the IEC standard does not necessarily replace or satisfy the related test specified in the comparable US test standard.
- Listing of products that have been previously listed with another NRTL
Some manufacturers may be changing from one NRTL to another NRTL to try to avoid correcting non-conformances found by the previous NRTL, usually during the follow-up audits at the manufacturing site. A review of the original NRTL's follow up audits would reveal any such non-conformances. NRTLs are required to ensure that all products they certify continue to meet the requirements of the test standards. We will continue to look for transferred listings during our audits.
- Using another NRTL's follow-up audit report of a manufacturing facility
As stated in our policy, in determining the areas to review during a follow-up inspection, NRTLs can "take into consideration inspections performed" by other NRTLs. However, merely accepting another NRTL's report does not fulfill the NRTL's responsibilities for performing the required inspections or audits. A review of the other NRTL's follow-up inspection or audit report should, for example, establish that it addresses the same product(s) as the one(s) certified by the NRTL. Also, the NRTL should track non-conformances found in the report to determine their resolution. Under our policy, NRTLs must have adequate written procedures regarding the use of another NRTL's follow-up report in place before acceptance of such reports.
- Withdrawn or replaced test standards
As noted in an earlier update, OSHA can no longer recognize an NRTL for standards that are replaced by other standards or that are withdrawn. Under our policy, if you are recognized for those standards, you can obtain recognition for "comparable" test standards, at no cost to you. To make the necessary changes to each NRTL's recognition, we must publish a notice in the Federal Register. We in the process of preparing such a notice and will be contacting you if you are affected. A special note about UL 60950. We have received a number of requests for recognition of UL 60950 and will be adding it soon to the web page for any NRTL recognized for UL 1950.
- Changes in Policies and Procedures
We are in the process of formally modifying our policies and procedures to address certain issues that we have encountered. The issues pertain to NRTLs qualifying testing sites from non-OSHA recognized sites, issuing temporary product certifications from non-OSHA recognized sites, owning sites located in certain foreign countries, and seeking to add test standards to their recognition that do not qualify as an expansion. Also, we will be addressing an issue concerning witness testing. As we did previously, once we have completed the draft revisions, we will share them with you.
- MRA
There has not been much progress in implementing the MRA due to continued disagreements between the U.S. and the European Union about interpretations of certain provisions of the MRA. To date, OSHA has recognized one laboratory that applied under the MRA: TUV Product Services (TUVPS) GmbH in Munich, Germany.
The NRTL Program Policies, Procedures, and Guidelines can be accessed by selecting the "NRTL Program Directive" from the OSHA NRTL web site. You may wish to review them if you have not done so already, especially Appendix C of the directive, which contains our major policies. The March 9, 1995 Federal Register notice is also available from our web site. We encourage you to refer your (existing or potential) clients and other interested parties to our web pages.
As always, if you have any questions, please contact the OSHA NRTL Program staff. If you have suggestions for topics to cover, etc., please feel free to send them to us.
Bernard Pasquet
Office of Technical Programs and Coordination Activities
Occupational Safety and Health Administration
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