|<< Nationally Recognized Testing Laboratories (NRTL)
Under the NRTL Program policy on Sites, NRTLs can perform the functions listed below only at a recognized site. Each such site is listed under the 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, as a result, OSHA does not consider their capability in any determination regarding an NRTL's recognition. In fact, a SNAP site 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) 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.
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:
In addition, under SNAP, a SNAP site that is wholly owned by the NRTL may authorize the use of the NRTL's mark.
Description of SNAP
- Qualify 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).
- Accept data under Programs 2 through 8, which are described in the March 9, 1995, Federal Register notice (60 FR 12980).
- Maintain or provide the only access to primary product test and evaluation files or records for any of the Programs.
- Perform the final technical review or make the final decision on certification of a product.
Audit and other controls by OSHA
Definition of a SNAP site: A testing and/or certification facility that is:
- Operated following the quality assurance program of the NRTL1;
- Not a recognized site, i.e., not included under the NRTL's scope of recognition2; and
- Locally3 administered and controlled by the NRTL (the legal entity recognized by OSHA), and owned or leased by either the NRTL or an organization that the NRTL owns by more than 50%; or
- Locally administered and controlled, and owned or leased, by an organization that the NRTL:
- controls administratively and operationally,
- operates following the quality assurance program of the NRTL, and
- owns by more than 50%.
Terms for Use: To use SNAP, the NRTL must meet the conditions in paragraphs A and B below and the criteria in paragraphs C and D below.
- 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:
- OSHA has not withdrawn that approval, and
- The NRTL continues to meet OSHA policies related to SNAP, which includes the provisions of this description.
- The NRTL may designate and use a site as a "SNAP site" provided that:
- The site meets the definition of a "SNAP site" in this description,
- The NRTL properly qualifies and audits the site in accordance with the criteria in paragraphs C and D below4,
- OSHA has not terminated the NRTL's or the site's participation in SNAP, and
- 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.
- The NRTL has and follows a written "site qualification program," which includes detailed criteria and procedures for qualifying (i.e., initially approving) and re-qualifying (i.e., renewing the qualification of) a site and that has the following elements:
- 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.
- Detailed criteria to grant a site's qualification, addressing both its capability to 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).
- Detailed criteria to renew a site's qualification.
- Detailed criteria to modify or revoke a site's qualification.
- A listing of NRTL personnel responsible for the site qualification program.
- 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 the site is qualified to perform (program scope) and the test standards for which the site is qualified to perform testing or evaluation activities (technical scope).
- The NRTL has and follows a written "site audit program," which contains the following elements:
- Detailed audit procedures for evaluating, with respect to the site's proposed or actual scope of qualification, a site's program capability (i.e., capability to perform the applicable SNAP functions) and technical capability (i.e., capability to evaluate a product with respect to the requirements of applicable test standard), as applicable.
- An on-site audit of a site to initially qualify its program and technical scopes (initial qualification), as applicable, and to qualify an expansion or modification of its scope.
- An on-site re qualification audit of each existing site, twice each calendar year (approximately every six months) after the initial qualification, that confirms the site still possesses the program capability for its existing program scope (program audit).
- An on-site re qualification audit of each existing site, yearly after the initial qualification, that confirms the site still possesses the technical capability for its existing technical scope (technical audit).
- All audit documentation must be maintained at the audited site, and maintained or available at one recognized site designated by the NRTL, normally the NRTL's headquarters facility. The "one recognized site designated by the NRTL" is referred to as the "SNAP headquarters facility" for purposes of this policy.
- A documented program for training and qualifying auditors in the SNAP functions they will be auditing.
- Program auditors, i.e., staff performing program audits, must be in an organizational unit that is separate from the organizational unit for operations. These two units must directly report only to the top executive of the NRTL. The initial qualification program audit and one of the two yearly re qualification program audits must be performed by auditors of the NRTL that are "located" at the SNAP headquarters facility. For purposes of this policy, an individual is "located" at a site or office if s/he has a dedicated office space there that s/he occupies more than 50% of her or his regular work schedule exclusive of any travel time.
- Technical auditors, i.e., staff performing technical audits, must audit each site yearly and forward their audit results to the NRTL's SNAP headquarters facility and to appropriate SNAP and quality assurance personnel. Technical auditors are not required to be located at the SNAP headquarters facility or at a recognized site. Technical auditors cannot carry out the duties of program auditors, unless they have appropriate training.
- Detailed program and technical audit forms (with space for narrative comments) for auditing each SNAP function and each test standard to ensure that audits are comprehensive and cover all quality functions and operations and technical areas.
- Auditing of a sample(s) of the end product of each SNAP function to ensure that all the required steps have been adequately performed.
- An auditor monitoring, rotation, and oversight program.
- A root cause analysis of the adverse findings of any audit that ensures corrective action eliminates the recurrence of the problem(s) identified.
- A tracking system to ensure that problems are corrected in a timely manner.
- Monitoring of corrective actions to ensure that they are being implemented and that they are achieving the desired results.
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):
- 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.
- 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.
- As scheduling permits, OSHA may travel with the NRTL's program or technical auditors to a SNAP site.
- OSHA audits the NRTL's SNAP headquarters facility 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.
- OSHA identifies on its NRTL Program Web site whether the NRTL is approved to use SNAP and the SNAP functions it is approved to perform. OSHA may also list the NRTL's SNAP sites and their SNAP functions on that Web site, but the NRTL must do so on its site.
- 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.
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.
- 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;
- If applicable, a listing of sites that already meet the criteria and that shows the technical areas and the SNAP functions each of these sites is qualified to perform;
- 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 technical areas and the SNAP functions a site would be qualified to perform;
- Schedule for auditing the sites already qualified for the program during an 18-month period starting from the date of the application; and
- One or more documents demonstrating the site(s) meet the "Definition of a SNAP Site".
OSHA reviews an application and notifies the NRTL whether or not it is approved to use SNAP, providing the reason(s) for non-approval. 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 the 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 any of their 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: name of deleted sites; name of new sites, including its 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.
OSHA fees are based upon the time that is required to perform specific tasks. OSHA will be charging an application fee to cover processing time for the review and acceptance of application documentation under SNAP. At that time, the applicable fee will be identified in OSHA's NRTL Program Fee Schedule, and OSHA will notify NRTLs once the schedule goes in 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 following 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 site to address local conditions in areas such as test equipment, product handling, security, records, and labeling.
2 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.
3 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.
4 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.