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Information on Submitting an Application

Application Guidelines are available in PDF (PDF*), WordPerfect, and Word formats. Please email WordPerfect or Word requests to NRTL Program.

The Application Guidelines provides information and a format for submitting an application for initial recognition or for expansion or renewal of recognition.

Contents:

More Information on the Recognition Process

  • Application Acceptance
  • On-site Review
  • Evaluation and Approval
Overview

The NRTL Program

Occupational Safety & Health Administration (OSHA) safety standards require that specified equipment and materials (products) be tested and certified for safety by an OSHA-recognized organization. OSHA's Nationally Recognized Testing Laboratory (NRTL) Program fulfills this responsibility by recognizing the capabilities of (mainly) private sector testing organizations to test and certify such products for manufacturers. The NRTL Program, in operation since 1988, is an effective public and private partnership. Rather than performing testing and certification itself, OSHA relies on private sector organizations to accomplish it. This helps to ensure worker safety, with existing private sector systems performing the work rather than maintaining government facilities.

These organizations use generally accepted, consensus-based product safety standards issued by national standards-producing organizations such as:

  • American National Standards Institute (ANSI)
  • American Society for Testing Materials (ASTM)
  • Factory Mutual Research Corporation (FMRC)
  • Underwriters Laboratories (ul)
Product Categories

OSHA requires testing for certain products in its standards found in Part 1910 of Title 29, Code of Federal Regulations (29 CFR Part 1910) (see specific references). Thirty-seven broad categories of products are covered, including:

  • Electrical equipment
  • Fire detecting and extinguishing equipment
  • LPG gas utilization equipment
  • Equipment used in potentially hazardous locations

The Meaning of Product Certification

A product certified by a Nationally Recognized Testing Laboratory has met consensus-based standards for safety. Users of that product are thereby assured that the certifying NRTL monitors the product and the process of its manufacture for quality assurance. The NRTL Program, in turn, assures that the organizations certifying the safety of the products are qualified to do so.

Eligibility

To be recognized, an organization must meet OSHA's requirements. Initial recognition, valid for 5 years and for a specific scope of recognition, is granted if the application and an on-site review of the organization demonstrate the applicant is completely independent, has the capability (including equipment, personnel, and quality assurance), and meets other requirements to test and certify products for safety. An organization must have the necessary capability both as a testing laboratory and as a product certification body to receive OSHA recognition as an NRTL. In addition, for foreign-based applications, OSHA must consider "reciprocity" of the foreign government. Once recognized, OSHA reviews each NRTL's activities to assure it continues to comply. Also, the NRTL can request an expansion of its recognition. The initial renewal of recognition is based upon a renewal application and may require an on-site review.

Program Regulations, Policies, and Procedures

Program requirements and criteria are explained in OSHA Regulations 29 CFR 1910.7 and the NRTL Program Directive.

Confidentiality

The name of an applicant seeking recognition becomes public information at the time OSHA publicly announces its preliminary finding on an application. In addition, all documents and other information in an application become public information when submitted unless: (1) particular items are specifically designated as confidential or (2) OSHA determines particular information appears to be confidential. However, neither of these two conditions guarantees confidentiality. If either condition applies, OSHA will provide an applicant or NRTL an opportunity to object to disclosure of the information. For more information, see 29 CFR Part 70, "Production and Disclosure of Information or Materials."

Information

If you have questions about the NRTL Program or these guidelines, or would like to receive more information or guidance in completing an application, please call 202-693-2110.

Send completed applications, amendments to applications, or other correspondence to:

  • Director
  • Office of Technical Programs and Coordination Activities
  • NRTL Program
  • Occupational Safety and Health Administration
  • US Department of Labor
  • 200 Constitution Avenue NW, Room N3653
  • Washington, DC 20210
On the Web

Application and general information is available by selecting "Programs" or "Subject Index" in http://www.osha.gov.

How OSHA Processes an NRTL Application

The regulations for the NRTL Program require that organizations applying for an initial recognition by OSHA as an NRTL, or for an expansion or a renewal of its recognition provide sufficient information and detail in its application to demonstrate that it meets the requirements and criteria for recognition, expansion, or renewal. This application guidelines provides an appropriate basis for the review, determination, and evaluation of the qualifications of the organization applying for recognition under the Program. The applicant is not required, but is strongly encouraged, to submit all the information requested in the formats shown.

When an organization submits its application materials, OSHA staff thoroughly reviews those materials for completeness and adequacy. For applications from foreign-based organizations, OSHA must consider the "reciprocity" of the foreign government (as described in I.A of Appendix A in 29 CFR 1910.7). When the NRTL Program staff determines that the application is complete and adequate, the staff perform an in-depth on-site review of the applicant's organization, programs, and facilities. If certain criteria are met (see NRTL Program Directive), an on-site review may not be necessary.

Based upon the information obtained primarily through the on-site review, the staff prepares a report and recommendation. The report and the application provide the main basis for a preliminary finding on the application. OSHA publishes a notice of this finding in the Federal Register to allow for public comment. Following a 30(formerly 60)-day comment period, OSHA must publish a final decision and response to comments in the Federal Register. Publication makes the recognition official for successful applicants and officially denies the recognition for unsuccessful applicants. A formal notification from the Assistant Secretary of Labor for Occupational Safety and Health (OSH), the head of OSHA, is sent to successful applicants. The specific scope of recognition is set forth in this formal notification as well as in the final Federal Register Notice.

(See More Information on Recognition Process)

Instructions for Completing the NRTL Application

Provide information for every item contained in each part of the application, even if only to provide proper references or to note that it is not applicable. Information and documents you provide for your application must be in English unless otherwise accepted by OSHA. You may either submit hard copy of the application or complete the application on diskette, using WordPerfect, Word, or other compatible word processing programs. If the application is completed on diskette, insert the text of your information in the appropriate spaces following each item. Then submit a signed hard copy of the General Application Information, with the diskette and copies of any attachments. If submitting your application in hard copy, provide your information on a separate attachment. Then, submit the application along with any hard copies of attachments. Send application and a cover letter to the address shown in the Overview section. Contact the NRTL Program staff if you have any questions. Note: OSHA will formally accept your application, and then schedule an on-site review, only when it has determined that the application is complete and the information provided is adequate. At that time, OSHA may request, and you will need to provide, two more copies of the complete application.

General Application Information

Provide all information requested. Attachments should be numbered and labeled, referencing the numbering on the General Application Information sheet. The legal signatory must sign in the space provided.

Applicable Test Standard(s)
  • Complete one sheet for each product safety test standard for which recognition is sought. Other formats may be used if the same or equivalent information is provided. Do not submit a copy of the actual test standard. If the test standard is not readily available to OSHA, Program staff will ask you to provide a copy of the standard. You should apply for all test standards for which you may qualify at the time of application.
  • The test standard must meet the criteria for an "appropriate test standard" in 29 CFR 1910.7(c).
  • If the test standard has been issued by an organization other than ANSI, ASTM, ul, or FM, please submit documentation assuring compliance with 29 CFR 1910.7 (c)(1), (c)(2), and (c)(3).
  • The scope of the test standard must pertain to products covered under the NRTL Program.
Detailed Application Information/Evaluation Criteria

Provide information for every item under each of the categories. Each category represents a critical component, of the requirements for recognition, that OSHA must review and evaluate.

Complete Application

In order for your application to be complete, it must include the General Application Information, Applicable Test Standards and Detailed Application Information/Evaluation Criteria, or equivalent information, and the following supplements:

  • Organizational chart(s) (for overall organization and, if applicable, each major unit or location) that depicts owners, directors, and officers, and shows areas involved in the NRTL operations
  • Position descriptions/responsibilities and resumes of key personnel involved in the NRTL operations
  • Listing/labeling, qualification and follow-up inspection procedures; sample of agreement(s) for certification
  • Sample(s) of test data sheets & testing procedures, test/evaluation report procedures for NRTL operations, test and calibration equipment listing for each site
  • Calibration program manual (including samples of specific calibration procedures) or equivalent
  • Identification number or verification of registration of certification mark(s) with the US Patent and Trademark Office (USPTO), or evidence of application for registration with the USPTO
  • Quality manual (covering both test laboratory and certification organization operations); related detailed quality assurance procedures or appropriate samples
  • Detailed standard operating procedures (including work instructions) for testing and certification operations or appropriate samples
  • Certificate of Incorporation or proof of applicant's legal existence, pertinent by-laws or articles

Attach any other documents requested or that will assist the OSHA staff in better assessing your application. Any additional documents submitted should be for illustration or clarification, and not in lieu of the information requested. In addition, clearly label and reference each attachment to the application itself.

Expansion and renewal of recognition

After receiving its recognition, an NRTL may submit requests to expand its scope of recognition to include additional standards or sites, or to use the "supplemental" programs described in the March 9, 1995 Federal Register notice. Also, at the end of the initial five-year recognition period, an NRTL must request a renewal of its recognition. Please complete and submit the following documents to apply for an expansion or for a renewal. Send all information to the address shown in the Overview page.

Requesting an expansion of recognition

  • Complete any of the sections 1 through 10 of the General Application Information, if not previously submitted or to reflect major changes since the date of the most recent application, and sign section 12. Also, complete any applicable portions of the Detailed Application Information/Evaluation Criteria (DAI/EC) specifically requested below. Include a cover letter, or only submit a letter to apply if these instructions require no other information.
  • For additional test standards, complete an Applicable Test Standard sheet for each test standard unless the necessary information has been previously submitted.
  • For an additional site(s), complete the Basic Information portion of the DAI/EC to provide the necessary information or to identify information previously submitted that will apply. Do not address the "Independence" section of the DAI/EC unless information was not previously submitted or previously submitted information has changed. Also, submit an Applicable Test Standard sheet for each standard to be used for the site(s), and submit any applicable supplements listed in the "Complete Application" section above.
  • For a "supplemental" program(s), complete the applicable Optional Information of the DAI/EC to provide the necessary information.

Requesting a renewal of recognition

  • Submit a letter requesting the renewal of recognition. Complete any of the sections 1 through 10 of the General Application Information, if not previously submitted or to reflect major changes since the date of the most recent application, and sign section 12. Also, complete any applicable portions of the Detailed Application Information/Evaluation Criteria (DAI/EC) to reflect major changes since the date of the most recent application.
Amendments

You may amend the application any time prior to publication of the preliminary notice. Submit an original and 2 copies of amendments unless it is just a letter.

SUPPLEMENTAL INFORMATION:
Program Regulations, Policies, and Procedures

The application shall be prepared in compliance with all applicable requirements in the Program regulations, policies, and procedures. The Program regulations are 29 CFR 1910.7, which specifies the requirements an NRTL must meet to be recognized, and specifies the general requirements and process that OSHA will use to evaluate and recognize an NRTL. The Program policies and procedures are contained in the NRTL Program Directive, which further details how OSHA will evaluate and recognize an NRTL, monitor the NRTL's recognition, and administer aspects of the Program. Additional criteria are specified in a March 9, 1995 Federal Register notice (60 FR 12980). This notice describes the "programs," whereby the NRTL qualifies other organizations to partially test and/or certify products and to provide support services. The NRTL Program Directive modifies and clarifies portions of this notice.

Program Fees

You must pay some fees at time of application. OSHA does not process and may return an application if it does not receive the applicable fees. OSHA bills you for the remainder of the application fees. Once recognized, you generally pay fees each year. The Fee Schedule and the Fee Payment Instructions and Information documents detail the amount that you must pay and when and where to pay the fees. You may obtain these documents by contacting OSHA at the address or phone number listed below or through the program's web page, also listed below. Fees for the NRTL Program went into effect on October 1, 2000.

Legal Signatory

The legal signatory signs the application, and any amendments. The legal signatory(s) of the applicant is recognized by OSHA as the individual responsible for submitting the application, and who can legally bind the applicant to the conditions and requirements for recognition. The legal signatory is the applicant's official contact for OSHA. To change the legal signatory, the current legal signatory (or an individual that can legally bind the organization) sends a letter to OSHA regarding the change.

More Information on the Recognition Process

Application Acceptance. An applicant is given an opportunity to correct any deficiencies in its application. When the application review is completed, OSHA sends a letter to the applicant to formally accept or reject the application.

On-site Review. The on-site review typically takes two or three days but varies with the size of the applicant organization and its proposed scope of recognition. After the review, the assessor (or lead assessor, if more than one) sends a report of the findings to the applicant to obtain its written response to any corrective actions (i.e., deficiencies) noted. The applicant must respond by a mutually-agreed-upon or other appropriate deadline. After the applicant submits its response, the assessor completes the on-site review report describing the findings of the site visit and the preliminary evaluation of the application.

Evaluation and Approval. OSHA staff performs the final evaluation of whether the applicant has or has not met the requirements for recognition. The Agency then publishes the notice of the preliminary finding on the application and provides the public an opportunity to comment. OSHA makes a final decision on the recognition following resolution of any significant issues raised by timely comments and publishes the notice of final decision.


*Accessibility Assistance: Contact OSHA's Directorate of Technical Support and Emergency Management at (202) 693-2300 for assistance accessing PDF materials.

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