NRTL Directive – Frequently Asked Questions
OSHA is updating the NRTL Directive to align the NRTL Program Policies and Procedures with International standards on accreditation. With the new Directive, an NRTL or applicant will meet the performance-based testing and certification requirements by complying with NRTL Program-specific regulations, as well as the testing and certification requirements found within ISO/IEC 17025: 2005 and ISO/IEC 17065: 2012.
To provide comments on the NRTL Directive during the 60-day comment period, please email your comments to email@example.com. Please title your submissions as "NRTL Directive Comment". Please note, comments sent via U.S. Mail may take an additional ten days to be received due to security screening procedures.
To submit in hard copy, please use the following address:
- NRTL Program
- Office of Technical Programs and Coordination Activities
- 200 Constitution Avenue NW, Room 3653
- Washington, DC 20210
To submit comments via fax, please send comments to 202-693-1644.
Comments on the draft NRTL Directive are due to OSHA’s Office of Technical Programs by COB Monday, August 8th, 2016.
Significant changes in the new Directive include:
- Proposed Revision to Existing Policy on Independence. OSHA is proposing to revise its policy on how NRTLs can comply with the requirement in the NRTL Program regulation that NRTLs be "completely independent" of employers subject to the tested equipment requirements and of any manufacturers or vendors of equipment or materials being tested for these purposes, 29 CFR 1910.7(b)(3). The revised policy would focus on the NRTL's ability to effectively identify, eliminate and control any risk to its impartiality.
- Proposed Revision to the NRTL Policy on Supplemental Programs and Addition of Procedures for NRTLs to use the IECEx Scheme. OSHA is also proposing to revise its policies and procedures on supplemental programs. OSHA would no longer refer to procedures and criteria for specific programs as "supplemental programs" and would no longer include them within an NRTL’s scope of recognition. OSHA would also eliminate the Satellite Notification and Acceptance Program (SNAP). Under the revised policy, NRTLs could apply to make existing SNAP sites recognized sites. Additionally, OSHA is proposing new procedures for the acceptance of inspections and test data from organizations that function as part of the IECEx Certified Equipment Scheme (IECEx Scheme).
- Proposed Revision to Existing Policy on Sites and Elimination of Satellite Notification and Acceptance Program (SNAP). OSHA is proposing a new definition for the term recognized site. Under this new definition, sites that were formerly "SNAP sites" could become recognized sites if they are administratively and operationally controlled by an NRTL and perform testing and inspection (and/or accept test data or inspections), perform reviews, and make certification decisions with the NRTL management system. OSHA would thus eliminate the policy that, to be a recognized site, an NRTL must wholly-own (directly or indirectly), or organizationally encompass the site.
- Proposed Revision to the NRTL Policy on Calibration. OSHA is proposing to revise its policy on calibration to include new policies for external and internal calibration laboratories used by NRTLs or applicants.
- Chapter 1 of the NRTL Directive (Introduction) describes general information about the NRTL Program and this Directive.
- Chapter 2 describes NRTL Program administrative procedures, associated with the recognition of organizations as NRTLs, which supplement the administrative procedures contained in Appendix A to the NRTL Program Regulations, 29 CFR 1910.7.
- Annexes A and B describe NRTL Program specific-testing and certification policies, which supplement Clauses 4 and 5 of ISO/IEC 17025: 2005 and Clauses 4 thru 8 of ISO/IEC 17065: 2012.
- Annex C presents terms and definitions.
- Annex D presents NRTL program forms.
- Annex E presents NRTL program fees.
The NRTL Directive will become effective, when it is formally issued by the Assistant Secretary of Labor for OSHA. This final notice will be published within the Federal Register. All new applicants and NRTLs will be required to adhere to the new Directive at the time it is issued.
For existing applicants (NRTL applications received before the final Directive was issued) and NRTLs recognized before the new NRTL Directive was issued, there will be a phase-in period of 1 year (which will allow the NRTLs and applicants to update their policies and procedures to meet the new requirements within the new Directive). At the end of that 1 year phase-in period, NRTL Audits will be conducted against the policies and procedures of the new NRTL Directive.
OSHA will allow a 1-year phase-in period to allow existing NRTLs to update their policies and procedures to meet the requirements of the new NRTL Directive. After this phase-in period, NRTL Audits will be conducted against the requirements of the new NRTL Directive. At that time, any nonconformances observed will be documented against the terms of the new NRTL Directive.
Applications for NRTL Recognition received before the final Directive is issued will be evaluated under the current Directive, although any recognition decisions will include language requiring that NRTL to update their procedures based on the updates provided within the new NRTL Directive. Applications for NRTL recognition received after the new NRTL Directive is issued will be evaluated against the requirements within the new Directive.
OSHA will outline procedures to describe the transfer of SNAP sites to recognized sites when the NRTL Directive is issued in final.
The requirements of the supplemental programs will now be included in the main body of the new NRTL Directive. These supplemental programs dealt with accepting evaluations, test data and services from 3rd parties. Under the new Directive, NRTL’s are now required to have procedures addressing how (or if) they will accept this type of data and services. The option remains to not accept outside data and services but that must now be indicated in the NRTL’s procedures.