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Workshop on OSHA’s Nationally Recognized Testing Laboratory Program (NRTLP)

Workshop on OSHA’s Nationally Recognized Testing Laboratory Program (NRTLP). Workshop on Nationally Recognized Testing Laboratory Program (NRTLP). Agenda. Place: Brussels, Belgium Date: December 3, 1998 Program: Opening EU/US MRA Electrical Safety Annex

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Workshop on OSHA’s Nationally Recognized Testing Laboratory Program (NRTLP)

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  1. Workshop on OSHA’s Nationally Recognized Testing Laboratory Program (NRTLP)

  2. Workshop on Nationally Recognized Testing Laboratory Program (NRTLP) Agenda • Place: Brussels, Belgium • Date: December 3, 1998 Program: • Opening • EU/US MRA Electrical Safety Annex • Overview of U.S. Requirements • Application Process

  3. List of Documents for Workshop • Selected provisions of 29 CFR 1910 Subpart S • 29 CFR Section 1910.7 • Federal Register notice of March 9, 1995 • Draft Application Guidelines - completed sample • Draft Application Guidelines • Summary of Key Policies • Appendix F from draft NRTL Program Directive

  4. Introduction on EU/US MRA Electrical Safety Annex Overview - MRA • Composed of two parts: • Umbrella (or master) Agreement. • Sectoral Annexes, which contain requirements of specific industry sectors. • Umbrella: acceptance or recognition of the results of conformity assessment procedures. • Sectoral: Electrical Safety Annex relates to OSHA NRTLP.

  5. Introduction on EU/US MRA Electrical Safety Annex Overview - Electrical Safety (ES) Annex • EC access to US market for electrical safety requirements of products falling under the scope of 29 CFR 1910 Subpart S. • Coverage also includes electrical aspects for workplace safety of medical and telecommunications equipment.

  6. Introduction on EU/US MRA Electrical Safety Annex Overview - Electrical Safety (ES) Annex • Includes the process to use in the designation of conformity assessment bodies. • Does notsupercede or replace U.S. laws or regulations. • Designation processdoes not replace OSHA’s current NRTL application process.

  7. Overview of U.S. Requirements Outline of Topics • Nationally Recognized Testing Laboratory Program (NRTLP) • Product Coverage of NRTLP • Eligibility and Requirements for NRTL Applicants • Appropriate Test Standards • Post Recognition and Key Issues

  8. Overview of U.S. Requirements -Nationally Recognized Testing Laboratory Program (NRTLP) 1. General • Recognizes a private sector testing organization's capability to test and certify specific types of products for workplace safety. • Part of OSHA’s Directorate of Technical Support. • Seeks to prevent accidents through assuring safety of products used by American workers. • Commonly called the NRTL Program.

  9. Overview of U.S. Requirements -Nationally Recognized Testing Laboratory Program (NRTLP) 2. History and Current Facts • OSHA Safety Standards contain provisions requiring that certain equipment be "approved" by an NRTL. • When first adopted, the provisions either required or implied that the equipment approvals be performed only by Underwriters Laboratories (UL) and Factory Mutual Research Corporation (FMRC).

  10. Overview of U.S. Requirements -Nationally Recognized Testing Laboratory Program (NRTLP) 2. History and Current Facts • In 1983, OSHA ordered by a court to remove the specific references to UL and FMRC in a lawsuit brought by a private lab. • In 1988, OSHA revised its regulations to remove the references, and established the NRTL Program to recognize other organizations as NRTLs.

  11. Overview of U.S. Requirements -Nationally Recognized Testing Laboratory Program (NRTLP) 2. History and Current Facts • Currently, 15 laboratories are recognized in more than 35 locations, and pending applications could result in a total of 21 laboratories in over 50 locations. • NRTLs have collectively been recognized to test and certify to over 600 product safety test standards.

  12. Overview of U.S. Requirements -Nationally Recognized Testing Laboratory Program (NRTLP) 3. Scope and Applicability • Requirements for NRTL approval of equipment apply to the great majority of private employers in the U.S. and its territories. • Requirements apply to most Federal Government places of employment.

  13. Overview of U.S. Requirements -Nationally Recognized Testing Laboratory Program (NRTLP) 3. Scope and Applicability • Requirements also apply to state and local government places of employment, in states that are approved to operate an OSHA program. • Requirements apply only to workplaces and not to the marketplace.

  14. Overview of U.S. Requirements -Nationally Recognized Testing Laboratory Program (NRTLP) 3. Scope and Applicability • Requirements do not apply to state or local code enforcement authorities, although many accept or require certifications by an NRTL for purposes of their enforcement. • Legal authority to impose requirements on employers is given by the Occupational Safety and Health Act of 1970.

  15. Overview of U.S. Requirements -Nationally Recognized Testing Laboratory Program (NRTLP) 4. Significance of OSHA Recognition • Means the organization has met the legal requirements for recognition in 29 CFR Section 1910.7, i.e., the organization has the capability, control programs, complete independence, and reporting and complaint procedures to test and certify specific types of products for workplace safety.

  16. Overview of U.S. Requirements -Nationally Recognized Testing Laboratory Program (NRTLP) 4. Significance of OSHA Recognition • Means OSHA will accept products certified by the NRTL as meeting the “approval” requirements with which employers must comply. • Does not mean a government position, a transfer of government authority, or a government license.

  17. Overview of U.S. Requirements -Product Coverage 1. Types of Products Requiring NRTL Approval • Product types within the scope of the NRTL Program are generally those for which NRTL approval requirements are found in 29 CFR Part 1910. A table of these types of products is available on the Internet. The main types for which NRTLs are recognized are: • Electrical equipment (Subpart S) • Fire detecting and extinguishing equipment • Liquefied Petroleum Gas (LPG) utilization equipment

  18. Overview of U.S. Requirements -Product Coverage 1. Types of Products Requiring NRTL Approval • The scope of recognition of EU NRTLs is limited to test standards for products falling under the scope of Subpart S, i.e, electrical conductors and equipment.

  19. Overview of U.S. Requirements -Product Coverage 1. Types of Products Requiring NRTL Approval • 29 CFR 1910 Subpart S • Refers to Subpart S of Part 1910 of Title 29, Code of Federal Regulations (CFR). • The CFR contains the official regulations of US Government Agencies.

  20. Overview of U.S. Requirements -Product Coverage 1. Types of Products Requiring NRTL Approval • 29 CFR 1910 Subpart S • Part 1910 contains OSHA’s General Industry Safety Standards • Subpart S - Electrical: consists of sections 1910.301 through 1910.399

  21. Overview of U.S. Requirements -Product Coverage 1. Types of Products Requiring NRTL Approval • Scope of Subpart S, see 1910.302(a) • Includes virtually all electrical equipment “installed or used within or on buildings, structures, and other premises including:” • Mobile homes • Recreational Vehicles • Industrial Substations

  22. Overview of U.S. Requirements -Product Coverage 1. Types of Products Requiring NRTL Approval • Scope of Subpart S (continued) • Includes equipment used in hazardous (classified) locations (1910.307); use of zone classification is not permitted at this time. • Excludes electrical equipment installations on ships, aircraft, most vehicles, and underground mines.

  23. Overview of U.S. Requirements -Product Coverage 1. Types of Products Requiring NRTL Approval • Scope of Subpart S (continued) • Excludes electrical equipment installations of utilities or railway companies used for communications, or for power generation, distribution, and other power related functions.

  24. Overview of U.S. Requirements -Product Coverage 1. Types of Products Requiring NRTL Approval • Content of Subpart S: • Contains safety requirements with which employers must comply. • The technical safety requirements for equipment are found in appropriate test standards.

  25. Overview of U.S. Requirements -Product Coverage 2. Example of Specific References (see selected provisions) • Section 1910.303(a), and applicable definitions, are the main reference to NRTL approval in Subpart S: • The conductors and equipment required or permitted by this part shall be acceptable only if tested and certified by an NRTL, although there are minor exceptions.

  26. Overview of U.S. Requirements -Product Coverage 2. Example of Specific References • Definition of “acceptable” is key (see section 1910.399) - A product is acceptable to OSHA if: • It is tested and certified by an NRTL, or • It is tested by a Federal, state or local authority and is of a kind that no NRTL tests and certifies, or • It is custom-made equipment designed for a particular customer and determined to be safe by its manufacturer.

  27. Overview of U.S. Requirements -Eligibility and Requirements 1. Eligibility • Any testing organization may apply for NRTL Program recognition • May be U.S.-based or otherwise. • May be owned by a U.S. or foreign organization, but if foreign, OSHA must make a determination about equal treatment by the foreign country. • An applicant must have the capability to be both a testing laboratory and certification body.

  28. Overview of U.S. Requirements -Eligibility and Requirements 2. Requirements for Recognition • 29 CFR Section 1910.7 contains the legal requirements that an organization must meet to obtain and retain its recognition as an NRTL. • Appendix A to this section contains the requirements that OSHA follows in approving or denying the recognition (see 29 CFR 1910.7).

  29. Overview of U.S. Requirements -Eligibility and Requirements 2. Requirements for Recognition • There are four basic requirements that an organization must meet: • It must have the capability (including proper testing equipment and facilities, trained staff, written testing procedures, and calibration and quality control programs) to perform testing for each item to be certified.

  30. Overview of U.S. Requirements -Eligibility and Requirements 2. Requirements for Recognition • Four basic requirements (continued) • It must have adequate controls for: • Listing and labeling the items it certifies. • Conducting follow-up inspections of the actual production of items to evaluate conformance with test standards. • Conducting field inspections to assure proper use of its marks or labels.

  31. Overview of U.S. Requirements -Eligibility and Requirements 2. Requirements for Recognition • Four basic requirements (continued) • It must be completely independent of employers (i.e., users), manufacturers, and vendors of the items it tests and certifies. • It must have effective procedures for producing its findings and reports, and for handling complaints and disputes fairly.

  32. Overview of U.S. Requirements -Eligibility and Requirements 3. Evaluation Criteria • In evaluating whether an NRTL meets the requirements for recognition, OSHA uses the specific criteria shown in the Detailed Application Information/Evaluation Criteria section of the Applications Guidelines (see Guidelines). • Criteria are partly based on modified portions of specific ISO Guides.

  33. Overview of U.S. Requirements -Eligibility and Requirements 3. Evaluation Criteria • Criteria are also based on specific OSHA policies, which take precedence where there are differences with any provisions of the specific ISO Guides. • Requirements in 1910.7 are broad, not as detailed as the ISO Guides, and in the case of the requirement on complete independence, exceed the general provisions on independence in the appropriate ISO Guides.

  34. Overview of U.S. Requirements -Eligibility and Requirements 3. Evaluation Criteria • Requirements in 1910.7 are only similar to, and not the same as, the “provisions” of the ISO Guides. • The general basis for the criteria is explained in Appendix F of the Directive.

  35. Overview of U.S. Requirements -Eligibility and Requirements 4. Key Policies (see summary) • Follow-up Inspection Program and Frequency • Independence of an NRTL • Sites • Quality Assurance and Internal Audits • Allowable and Withdrawn Test Standards • Certification Marks and Listing Programs

  36. Overview of U.S. Requirements -Eligibility and Requirements 5. Supplemental Programs (see March 9, 1995 notice) • An NRTL may be recognized to use outside parties to do part of its testing or certification activities. • OSHA has broadly grouped the testing and certification activities that an NRTL may undertake under nine (9) programs. • The first, or basic, program requires the NRTL to perform all activities itself without use of outside parties.

  37. Overview of U.S. Requirements -Eligibility and Requirements 5. Supplemental Programs (see March 9, 1995 notice) • The remaining 8, or supplemental, programs involve the NRTL’s use and control of outside parties to perform specific types of activities. • The program descriptions and criteria for each program were first publicly issued on March 9, 1995 in the US Federal Register.

  38. Overview of U.S. Requirements -Eligibility and Requirements 5. Supplemental Programs (March 9, 1995 notice) • The description of the supplemental programs and a brief explanation of each follows. In practice, an NRTL’s use of outside parties may be a combination of different aspects of various programs. • The NRTL must meet the criteria for the first program, and certain minimum criteria, to use any of the supplemental programs.

  39. Overview of U.S. Requirements -Eligibility and Requirements 5. Supplemental Programs (March 9, 1995 notice) • Programs 2 and 3: Acceptance of testing data (#2) or product evaluations (#3) from independent organizations • The NRTL must: • Have a program to qualify independent organizations • Ensure the organization does not subcontract the activity • Meet the criteria for #2 to use #3

  40. Overview of U.S. Requirements -Eligibility and Requirements 5. Supplemental Programs (March 9, 1995 notice) • Program 4: Acceptance of Witnessed testing data • The NRTL, using its own qualified personnel, may witness tests for outside parties. • The outside party may or may not be independent of users, manufacturers, and vendors.

  41. Overview of U.S. Requirements -Eligibility and Requirements 5. Supplemental Programs (March 9, 1995 notice) • Programs 5 and 6: Acceptance of testing data (#5) or product evaluations (#6) from non-independent organizations (including manufacturers) • The NRTL must have established a long term relationship with the manufacturer, and meet the criteria for #2 to use #5, and #3 and #5 to use #6.

  42. Overview of U.S. Requirements -Eligibility and Requirements 5. Supplemental Programs (March 9, 1995 notice) • Program 7: Continued certification following minor product modifications by the client • The NRTL must clearly define what constitutes a minor modification, and meet the criteria for #6.

  43. Overview of U.S. Requirements -Eligibility and Requirements 5. Supplemental Programs (March 9, 1995 notice) • Program 8: Acceptance of product evaluations from organizations that function as part of the International Electrotechnical Commission Certification Body (IEC-CB) scheme • The NRTL must have proper procedures to review testing data, evaluations, national deviations, and components.

  44. Overview of U.S. Requirements -Eligibility and Requirements 5. Supplemental Programs (March 9, 1995 notice) • Program 9: Acceptance of services, other than testing or evaluation, performed by subcontractors or agents • The NRTL must have procedures to properly qualify the organization. • Services may include calibrations and follow-up inspections.

  45. Overview of U.S. Requirements -Appropriate Test Standards 1. Requirements and Guidelines • Approval requirements and guidelines - A test standard may be approved for recognition if it is: • Within the scope of the NRTL Program based on the products it covers. • A "document that specifies the safety [not primarily installation or maintenance] requirements" for a specific type of product, contains or references testing methods, and does not conflict with OSHA standards.

  46. Overview of U.S. Requirements -Appropriate Test Standards 1. Requirements and Guidelines • Approval requirements and guidelines (continued): • Issued by a US-based standards organization (e.g., ANSI) and provides an adequate level of safety. • Developed under a method providing for input by a broad spectrum of those experienced in the safety field involved and that is consistent with an ANSI approved method. • Maintained current with revisions of applicable codes and installation standards, as demonstrated by proper policies and procedures.

  47. Overview of U.S. Requirements -Appropriate Test Standards 1. Requirements and Guidelines • Standards of the following organizations have been approved for NRTLs: • American National Standards Institute (ANSI) • American Society for Testing and Materials (ASTM) • Underwriters Laboratories (UL) • Factory Mutual Research Corporation (FMRC)

  48. Overview of U.S. Requirements -Appropriate Test Standards 1. Requirements and Guidelines • ANSI and ASTM standards are acceptable in accordance with section 1910.7. • Not all test standards from these four organizations are necessarily appropriate.

  49. Overview of U.S. Requirements -Appropriate Test Standards 2. Examples of appropriate test standards • Over 600 individual product safety standards have been recognized and a complete list is available through the Internet. • Examples of standards recognized: • ANSI/UL 50 Enclosures for Electrical Equipment • ANSI/IEEE C37.21 Control Switchboards. • ANSI/UL 696 Electric Toys • ANSI/UL 1082 Household Electric Coffee Makers • ANSI/UL 1950 Information Technology Equipment Including Electrical Business Equipment

  50. Overview of U.S. Requirements -Post Recognition Activities and Issues 1. OSHA Audits • An on-site audit of each NRTL is scheduled annually to verify that the laboratory's capability and quality of operation has been maintained. • In some cases, an office audit may be performed in place of the on-site audit, or more than one on-site audit may be done in a year if warranted. • Audits are conducted by OSHA staff.

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