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Background

According to the NRTL Program policy on Sites, NRTLs may perform certain functions (listed below) only at a recognized site. Recognized sites are listed under each NRTL’s scope of recognition, as shown on our informational Web page for each NRTL. OSHA limits these functions to recognized sites because it initially evaluates the NRTL’s resources and capabilities to perform those functions only at those specific sites. In addition, the NRTL Program staff then monitors the NRTL’s performance of these critical functions during its audits of only those sites. However, the Satellite Notification and Acceptance Program (SNAP) contains a series of controls and safeguards that permit NRTLs to expand the utilization of certain unrecognized sites. Under SNAP, a particular NRTL, if it meets the criteria and conditions in this SNAP Description, may qualify a special unrecognized site, called a “SNAP site”, to perform some of the functions normally reserved for a recognized site. SNAP sites are not recognized sites under the OSHA NRTL Program and must be under the control of a recognized site. NRTLs can always apply to OSHA to “convert” any of their satellites or SNAP sites to a recognized site. OSHA would process this application as a regular scope expansion, and thus grant it if the site meets the necessary requirements.

In order to perform any of the functions listed below at a SNAP site, OSHA must approve the NRTL to use SNAP. NRTLs, in turn, must qualify their SNAP sites(s), using the procedures specified in this Description, to perform any of the noted functions. NRTLs not approved to use SNAP must perform the functions below only at their recognized site(s). SNAP sites also may perform product testing, if so qualified by the NRTL.

The functions that may be performed at a SNAP site (hereafter, SNAP functions) and that are otherwise restricted to be performed only at recognized sites are:
  1. Qualifying sites under Programs 2 through 7, or parties under Program 9, which are all described in a March 9, 1995, Federal Register notice (60 FR 12980).
  2. Accepting data under Programs 2 through 8, which are described in the March 9, 1995, Federal Register notice (60 FR 12980).
  3. Performing the final technical review or making the decision on certification of a product.
  4. Authorizing the use of the NRTL’s mark.
  5. Maintaining or providing access to original product test and evaluation files or records for any of the Programs.
An additional or sole activity that may be performed at a SNAP site (hereafter, SNAP product testing):
    Conduct testing of products falling within the scope of recognition of the NRTL.


Description of SNAP
  1. Definition of a SNAP site: A facility that performs any SNAP function and/or SNAP product testing activities, where:
    1. The activities are performed in accordance with the quality assurance program of the NRTL1;
    2. The activities are locally2 administered and controlled by:
      1. The NRTL (the legal entity recognized by OSHA), or
      2. An organization that the NRTL owns by more than 50%, and controls administratively and operationally;
    3. The facility is wholly owned3 or leased (including subleased or rented) by an:
      1. Organization described in I.B.1 or I.B.2, or
      2. Organization that wholly owns the NRTL; and
    4. The facility is not a recognized site, i.e., not included under the NRTL’s scope of recognition.4
  2. Terms for Use: To use SNAP, the NRTL must meet all the conditions and criteria in paragraphs A through D, below.
    1. Any NRTL seeking approval to use SNAP must submit an application to OSHA following the Initial Application Procedure in this description. The NRTL must receive OSHA approval prior to using SNAP and may continue such use provided that:
      1. OSHA has not withdrawn that approval, and
      2. The NRTL continues to meet OSHA policies related to SNAP, which includes the provisions of this description.
    2. The NRTL may designate and use a site as a “SNAP site” provided that:
      1. The site meets the definition of a “SNAP site” in this description,
      2. The NRTL properly qualifies and audits the site in accordance with the criteria in paragraphs C and D, below5,
      3. OSHA has not terminated the NRTL’s or the site’s participation in SNAP, and
      4. Products tested and/or certified and programs used at the site fall within the NRTL’s scope of recognition, as shown on OSHA’s Web site.
    3. The NRTL must have and follow a written “site qualification program,” which includes all of the following elements:
      1. Detailed procedures that cover the overall process for granting (i.e., initially approving), renewing, modifying, or revoking a site’s qualification; and a description or flowchart of the overall decision making process.
      2. Detailed criteria to grant a site’s qualification, addressing both its capability (including proper equipment, written procedures, and qualified staff) to test and/or evaluate a product with respect to the requirements in a standard (i.e., technical capability) and its capability to perform any of the proposed SNAP functions (i.e., program capability).
      3. Detailed criteria to renew a site’s qualification.
      4. Detailed criteria to modify or revoke a site’s qualification.
      5. A listing of NRTL personnel responsible for the site qualification program.
      6. Detailed procedure for notifying OSHA of the initial qualification of a site, including its location and scope of qualification, of any changes in the site’s location or scope, and of any changes to the site’s qualification status (e.g., renewal of qualification). The scope of qualification comprises the SNAP functions which the site is qualified to perform (program scope) and the test standards for which the site is qualified to perform testing and/or evaluation activities (technical scope).
    4. The NRTL must have and follow a written “site audit program,” which contains the following elements:
      1. Detailed audit procedures for evaluating, with respect to the site’s proposed or actual scope of qualification, a site’s program capability and technical capability, as applicable.
      2. An on-site audit at a potential SNAP site to pre-qualify it for its program and technical scopes (“initial qualification”), as applicable, and to pre-qualify it for an expansion or modification of its scope.
      3. For each existing SNAP site performing SNAP functions or product testing, a minimum of two on-site requalification audits by the NRTL, every 12-month period. During each audit, the NRTL must review all aspects of the site’s SNAP operations and confirm that the site still possesses the capabilities for its existing program scope and technical scope at the time of the audit.
      4. For each existing SNAP site performing only SNAP product testing, a minimum of one on-site requalification audit by the NRTL, every 12-month period. During this audit, the NRTL must review all aspects of the site’s SNAP operations and confirm that the site still possesses the capabilities for its existing technical scope at the time of the audit.
      5. All audit documentation must be maintained or available at the audited site, at the one recognized site designated by the NRTL as its “SNAP headquarters,” and, at the site where the auditor is located, if not the SNAP headquarters. The overall auditing function of the NRTL’s SNAP operations must be administered from the NRTL’s SNAP headquarters.
      6. A documented program for training and qualifying auditors to audit the program capability, the technical capability, or both of these capabilities of a site’s SNAP operations (“SNAP auditor”).
      7. SNAP auditors must be independent of the site audited. The auditor cannot be under the control or direction of any SNAP site and may only be located at a recognized site.
      8. Detailed audit forms (with space for narrative comments) for auditing the program and the technical capability of a site’s SNAP operations and for demonstrating that all technical, program, and quality functions that are applicable at a site were reviewed comprehensively.
      9. Auditing of a sample(s) of the final records or documents (if applicable) generated when performing each SNAP function to ensure that all the required steps have been adequately performed.
      10. An auditor monitoring, rotation, and oversight program.
      11. A root cause analysis of the adverse findings of any audit that ensures that corrective action eliminates the recurrence of the problem(s) identified.
      12. A tracking system to ensure that problems are corrected in a timely manner.
      13. Monitoring of corrective actions to ensure that they are being implemented and that they are achieving the desired results.

Audit and other controls by OSHA
  1. Each year, OSHA selects sites to be audited from the list of all of the NRTL’s SNAP sites, in part based upon previous audit results. Prior to finalizing its audit plans, OSHA confirms the list with the NRTL. The number of these SNAP sites that OSHA audits in any year will not usually exceed 50% of the total number of SNAP sites. OSHA also audits all of the NRTL’s recognized sites. OSHA will coordinate its audits of the NRTL’s sites (recognized or SNAP sites) to try to minimize travel time and expenses. OSHA bills the NRTL for all audits under the Fee Schedule in effect at the time of the audit.
  2. OSHA may audit more than 50% of the SNAP sites or may audit a SNAP site more than once if the NRTL appears to be in violation of any NRTL Program requirements or policies. OSHA will explain to the NRTL the need for such audits and bill the NRTL for such audits.
  3. As scheduling permits, OSHA auditors may travel with the NRTL’s SNAP auditors on an audit of the SNAP site, and conduct an audit of the site and the NRTL’s auditing process.
  4. OSHA audits the NRTL’s SNAP headquarters facility, or other recognized sites where SNAP auditors are located, at least once a year, if necessary with additional personnel, to ensure that the audit and quality assurance functions are adequate. It is estimated that an additional day of auditing will be required at the headquarters facility for every two SNAP sites.
  5. OSHA identifies on its NRTL Program website whether the NRTL is approved to use SNAP and the SNAP functions it is approved to perform. OSHA will also list the NRTL’s SNAP sites and their SNAP functions on that website.
  6. If OSHA determines that the NRTL is not fulfilling its obligations under SNAP, OSHA, at its own discretion, and after discussion with the NRTL, may reduce the number of SNAP sites or functions, or terminate the NRTL’s participation in SNAP.

Initial Application Procedure

Any NRTL or applicant desiring to participate in SNAP must apply to the OSHA NRTL Program by submitting (either hard copy or electronically):
  1. Documentation demonstrating that the NRTL meets the criteria in paragraphs II.C and II.D, above, i.e., documenting site qualification and site audit programs;
  2. If applicable, a listing of sites already meeting the criteria that shows the product testing activities and the SNAP functions each of these sites is qualified to perform;
  3. Evaluation reports for up to 3 sites already identified above in #2 as qualified for the program; or, if none have been qualified, a typical evaluation report that shows the product testing and the SNAP functions a site would be qualified to perform;
  4. Schedule for auditing the sites already qualified for the program during an 18-month period starting from the date of the application; and
  5. One or more documents demonstrating that the site(s) meet(s) the “Definition of a SNAP Site”.
If the application is submitted in hard copy, it should be mailed to: NRTL Program, Office of Technical Programs and Coordination Activities, Occupational Safety and Health Administration, Room N-3655, 200 Constitution Avenue, NW, Washington, D.C. 20210.

OSHA reviews an application and notifies the NRTL whether or not it is approved to use SNAP, providing the reason(s) for nonapproval. OSHA will request additional information from the NRTL as needed to render its decision on the application. When OSHA approves the NRTL to use SNAP, OSHA will review and modify its audit schedule for the NRTL. This modification will be in accordance with the application and the history of the NRTL’s performance in past audits.


Modifications after Initial Approval

Once the NRTL has been accepted into SNAP, it must submit to OSHA any changes to the NRTL’s site qualification program or site audit program. OSHA must accept such changes prior to implementation by the NRTL. The NRTL must also notify OSHA in writing within 30 days of any changes to its SNAP sites. Changes that must be provided are: names of deleted sites; names of new sites; new sites’ address, key personnel, audit schedule, and SNAP functions; and, for existing sites, any changes to the SNAP functions or technical ability that a site has been qualified to perform. For a new site and for existing sites that have changes in their legal structure or ownership, the NRTL must also submit documentary proof that the site meets the SNAP site definition as well as a copy of the audit report that adequately address the site’s capabilities and functions under the SNAP.

Fees

OSHA will charge an application fee to cover processing time for the review and acceptance of application documentation under SNAP. The applicable fee will be identified in OSHA’s NRTL Program Fee Schedule, and OSHA will notify NRTLs once the schedule goes into effect. OSHA will not charge the application fee at the time of implementation of SNAP if the fee has not yet been included in the Fee Schedule. However, OSHA will charge fees for the auditing it performs concerning this program using the fee schedule (for auditing functions at regular sites) in effect at the time of the audit


1 For purposes of this description, “operated in accordance with the quality assurance program of the NRTL” means that a site or an organization must comply with the NRTL’s basic quality policies that broadly address all areas of the testing or certification operations. Such areas include security planning, product handling and control, test equipment calibration and handling, or records review and storage. The basic policies of the program are contained in the NRTL’s quality manual and related broad-level documents that OSHA reviews during its audits of the NRTL’s recognized sites. Detailed-level documentation, such as work instructions and procedures, may be tailored for a particular site in areas such as test equipment, product handling, security, records, and labeling.
2 For purposes of this description, “locally” as it modifies “administer and control” means that the person having overall authority to administer and control a site’s operations, normally, is physically located at that site.
3 For purposes of NRTL Program policy, a wholly-owned site includes a site that is “organizationally encompassed,” which means that an office or other facility is part of an entity’s organizational structure and is subject solely to that entity’s control. This term applies to situations where the entity does business in a state or region under its legal name, and has an office or facility for this purpose, without the need to establish a subsidiary or other similar entity.
4 The NRTL’s scope of recognition is determined by OSHA and is based upon the technical and administrative personnel, the equipment, the control programs, and other resources that are available at the NRTL’s recognized sites.
5 For purposes of participating in SNAP and complying with the criteria in II.C and II.D of this description, any NRTL may use policies and procedures applicable to other aspects of its operations provided they meet or are tailored to meet the relevant criteria. Under such conditions, the NRTL would not need to develop separate policies and procedures for its participation in SNAP.