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This document presents an interpretation that was issued by the OSHA Directorate of Technical Support and Emergency Management (DTSEM), which is the OSHA unit that contains the Office of Technical Programs and Coordination Activities (OTPCA). This office administers the NRTL Program.
Interpretation Request by: NRTL
Date(s) of Incoming Correspondence: January 26, and March 13, 2009
Subject: Satellite Notification and Acceptance Program (an option available under the NRTL Program)
Date of Interpretation: April 23, 2009
Regarding the SNAP functions identified as paragraphs A, B, D, and E1 on pages 926 to 927 of OSHA’s January 9, 2009, Federal Register notice on SNAP (74 FR 923):
If an NRTL provides access to original product-testing and evaluation records via an intranet that is accessible to its corporate sites, must the NRTL identify each of these sites as a SNAP site if the sites are not performing evaluations, testing, or product certifications associated with the NRTL Program?
No, because OSHA is not requiring that facilities with only electronic access to such records be qualified as SNAP sites. (Note: Whether the records are physical or electronic, OSHA must have access to all NRTL-related testing and certification records.)
In the NRTL Program Policies, Procedures and Guidelines, paragraph X of Appendix C (“Sites”) permits testing at unrecognized sites when the sites are either wholly owned (directly or indirectly) or organizationally encompassed by the NRTL, provided the NRTL maintains proper control over the sites. If unrecognized sites are brought into the NRTL’s SNAP operations, must the NRTL conduct audits of each of these sites twice per year?
Yes, because, as stated in the SNAP Description, for each existing SNAP site performing only SNAP product testing, the NRTL must perform a minimum of one onsite requalification audit every 12 months. With the adoption of SNAP, NRTLs may also accept product testing from their qualified SNAP sites. However, if a SNAP site conducts both testing activities and SNAP functions, the NRTL must perform a minimum of two requalification audits at that site during any 12-month period.
A two-part question as follows:
May the SNAP site audits be conducted electronically, or must each audit be conducted onsite?
Yes; if the sole capability of a SNAP site resides in the individual’s qualification for particular work under SNAP functions A through D, and the site’s records are available electronically, then electronic auditing methods are acceptable and would meet the onsite-audit requirements of the SNAP provided the site is not physically testing products. In this situation, OSHA may choose to travel to the individual’s location or meet with the individual as part of its audit of the SNAP site.
If a SNAP site performs physical testing, then the NRTL must conduct an onsite visit at the SNAP site a minimum of once a year to meet the onsite-audit requirements of the SNAP. Physical testing and testing activities consist of conformity assessment of a product sample that involves the use of any testing equipment or a hands-on technical evaluation or observation. When such testing is a SNAP function, as is the case in acceptance of testing performed under program 8 (SNAP function B), the NRTL must conduct two audits of the SNAP site each year. In its SNAP application, the NRTL must provide, under procedures, clarification on what testing activities the SNAP site will perform, and the type (i.e., onsite or electronic) and frequency of audits the NRTL will conduct at the SNAP site.
If an NRTL posts an electronic database describing a SNAP site’s scope of qualification, and makes this database available to OSHA, will this procedure properly notify OSHA of changes to the site’s scope of qualification?
No because the SNAP Description specifies that an NRTL must notify OSHA of the initial qualification of a SNAP site, including its location and scope of qualification, and of any changes in the site’s location, scope, and qualification status (e.g., renewal of qualification). The NRTL may store this information on a public or private website to which OSHA has access, provided that the NRTL also notifies OSHA about these changes through appropriate channels (i.e., letter, e-mail or similar notification).
I hope this letter addresses your questions. Should you have any other questions, or need additional clarification of these replies, please contact Kevin Robinson or Bernard Pasquet at 202-693-2110.
Directorate of Technical Support and Emergency Management