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National Type Evaluation Program An Overview Don Onwiler Executive Director. First… A Disclaimer. The following is an excerpt from the NCWM Annual Report of 1908 It is merely presented as an illustration of the challenges that can exist in the marketplace
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National Type Evaluation ProgramAn OverviewDon OnwilerExecutive Director
First… A Disclaimer • The following is an excerpt from the NCWM Annual Report of 1908 • It is merely presented as an illustration of the challenges that can exist in the marketplace • The presentation of this passage is in no way meant to demean any particular ethnic culture
1908 NCWM Annual Report Mr. REICHMANN. The truth is that when there is no inspection the Dealers, especially the small dealers, are always looking to get the cheapest thing they can get, and of course unscrupulous manufacturers are encouraging them. They will take a scale of a certain make and use it as a pattern to cast something that looks like a scale. Iknow that they are selling in New York a certain type of scale at $9a dozen. Youtake any standard make of scale of this type, you can buy none of them at that price. And what is the result?
Continued It is just as I saw illustrated in the city of Rochester last summer, where they take a casting and merely dip it into paint. It is just like watered stock. Aman was selling a scale at $1.65, one of the bearings of which had broken off because the iron had chilled. The dealer said, “That is all right; it acts just as well with three bearings as it does with four." Now, the innocent buyer could find no difference as far as the appearance of the scale was concerned; the buyer does not know anything about it. The average dealer in groceries has no technical knowledge of scales.
Continued Mr. PETTIS. You will not find that situation in American groceries; you will always find that among foreigners-the _______s. It is particularly the _______s who buy these cheap scales. They pay only 90 cents for a scale.
How it Began • By 1915 we had model standards for weighing and measuring devices • By1967 there were various type evaluation regulations in place, including; • 14 states • 2 cities • 1 county
Why programs created type evaluation requirements • Type Evaluation was to provide assurance of; • Handbook 44 compliance • Permanence • Certification served as a revocable “permit” to access the market within a jurisdiction (play by the rules or your out)
A Better Way NBS Test Reports: One evaluation to allow state or local agencies to issue their own type approval certificates NTEP: One evaluation and one certificate that could be recognized by all jurisdictions
Proliferation of NTEP • An NTEP Certificate has no legal value on its own merit • States hold the regulatory authority • Their recognition of NTEP gives the program its value • 46 States have voluntarily adopted requirements for NTEP certification • Largely fueled by industry support
Benefitting the Marketplace • Device Manufacturers • Regulatory Officials • Sales and Service Companies • End-Users
For the Manufacturer Easier and less expensive access to the entire U.S. market Fair competition: Integrity within an industry Marketing tool: Earned competitive advantage
1967: 17 jurisdictional type evaluations in the U.S. Today: NTEP in the U.S. U.S./Canada Mutual Recognition Agreement (MRA) OIML Mutual Acceptance Arrangement (MAA) for load cells Access to the U.S. Market
It costs money to play by the rules Costs are passed on to consumers Availability of cheap, substandard scales can put the manufacturers of quality devices at a competitive disadvantage NTEP keeps unscrupulous manufacturers out of the market Confidence can extend to the global market if NTEP is thorough Fair competition: Integrity within an industry
Manufacturers are able to make claims Customers are learning to look for the NTEP logo Provides an earned competitive advantage Marketing Tool
For the End-User A standard of quality to look for when purchasing a new device Assurance the device will withstand time and use Assurance the device maintains accuracy under influence factors Fewer repairs and longer life of operation
For the Regulatory Official Confidence of H44 compliance Is the manufacturer knowledgeable of H44? Has the manufacturer demonstrated an ability to meet the design and performance requirements prior to entering the market? Does the device perform under influence factors such as temperature change?
For the Regulatory Official Improved efficiency of inspection programs • Less time on rejections and reinspections • Less time in confrontation with business owners • More time for other important activities of the Department
For the Regulatory Official A standard to reference There may be good designs that aren’t certified, but there should not be bad designs that are certified NTEP provides easy answers when business owners ask officials for guidance A method of recourse exists if production fails to meet type
Administrative Policy Content is developed by NTEP Committee and Board of Directors Technical Policy, Checklists, and Test Procedures Content developed by NTEP Sectors and approved by NTEP Committee Weighing Devices Measuring Devices Grain Analyzers NCWM Publication 14
Active Certificate holder has paid the Annual Maintenance Fees Ongoing production will continue to comply with most recent version of Handbook 44 Certificate Status
Inactive Certificate holder is not paying Annual Maintenance Fees Traceability to an Active Certificate: A device is traceable to an active CC if: (a) it is of the same type identified on the Certificate, and (b) it was manufactured during the period that the Certificate was maintained in active status. Devices manufactured after the status change are not traceable to an Active Certificate and might not conform to type Certificate Status
Withdrawn An action taken by NCWM against the Certificate Production not according to type Deficiencies in type Misuse of the NTEP logo Devices of that type are not considered traceable to an Active Certificate, regardless of date of manufacture. Certificate Status
Expired Only applies to Grain Analyzers Not participating in ongoing calibration program Each jurisdiction must determine how to deal with devices in service prior to status change Certificate Status
A (non-NTEP) device designed to meet unique demands for a specific installation and of a specific design which is not commercially available elsewhere (one such device per manufacturer). If a device manufactured for sale by a company has been categorized and tested as a “one-of-a-kind” device and the manufacturer then decides to manufacture an additional device or devices of that same type, the device will no longer be considered a “one-of-a-kind.” 2.6. One-of-a-Kind Device
This also applies to a device that has been determined to be a “one-of-a-kind” device by a weights and measures jurisdiction in one state and the manufacturer decides to manufacture and install another device of that same type in another state. In this case, the manufacturer of the device must request an NTEP evaluation on the device through the normal application process unless NTEP has already deemed that such evaluation will not be conducted. One-of-a-Kind Device (continued)
Maintenance Fee Process Support the daily operations of NTEP including cost of Sector Meetings, salaries, infrastructure • Payable each fall • Non payment results in Inactive Certificate on January 1 • Certificate may be reactivated after January 1 Manufacturers may intentionally allow some certificates to become Inactive because they are no longer in production for use in commerce.
Vehicle Sale Example: Discrimination near zero and near capacity Section tests to at least 90% of CLC Strain load tests to at least 80% of scale capacity Repeat all tests (repeatability) Verify scales errors to .1 division (if d = 20 lb, verify scale errors to nearest 2 lb What does a NTEP Evaluation Entail?
Performance Tests forVehicle Scales 65.a2. Section Tests
Vehicle Scale – Modular Design SECTION TEST 200,000 x 20 lb CLC = 100,000 lb Test Load Section Test 00 lb = 5000 lb
Vehicle Scale – Modular Design SECTION TEST 200,000 x 20 lb CLC = 100,000 lb Test Load Section Test 10 000 lb = 5000 lb
Vehicle Scale – Modular Design SECTION TEST 200,000 x 20 lb CLC = 100,000 lb Test Load Section Test 10 000 lb = 5000 lb
Vehicle Scale – Modular Design SECTION TEST 200,000 x 20 lb CLC = 100,000 lb Test Load Section Test 10 000 lb = 5000 lb
Vehicle Scale – Modular Design SECTION TEST 200,000 x 20 lb CLC = 100,000 lb Test Load Section Test 10 000 lb = 5000 lb
Vehicle Scale – Modular Design SECTION TEST 200,000 x 20 lb CLC = 100,000 lb Test Load Section Test 30 000 lb = 5000 lb
Vehicle Scale – Modular Design SECTION TEST 200,000 x 20 lb CLC = 100,000 lb Test Load Section Test 30 000 lb = 5000 lb
Vehicle Scale – Modular Design SECTION TEST 200,000 x 20 lb CLC = 100,000 lb Test Load Section Test 30 000 lb = 5000 lb
Vehicle Scale – Modular Design SECTION TEST 200,000 x 20 lb CLC = 100,000 lb Test Load Section Test 30 000 lb = 5000 lb
Vehicle Scale – Modular Design SECTION TEST 200,000 x 20 lb CLC = 100,000 lb Test Load Section Test 50 000 lb = 5000 lb
Vehicle Scale – Modular Design SECTION TEST 200,000 x 20 lb CLC = 100,000 lb Test Load Section Test 50 000 lb = 5000 lb
Vehicle Scale – Modular Design SECTION TEST 200,000 x 20 lb CLC = 100,000 lb Test Load Section Test 50 000 lb = 5000 lb
Vehicle Scale – Modular Design SECTION TEST 200,000 x 20 lb CLC = 100,000 lb Test Load Section Test 50 000 lb = 5000 lb
Vehicle Scale – Modular Design SECTION TEST 200,000 x 20 lb CLC = 100,000 lb Test Load Section Test 70 000 lb = 5000 lb
Vehicle Scale – Modular Design SECTION TEST 200,000 x 20 lb CLC = 100,000 lb Test Load Section Test 70 000 lb = 5000 lb
Vehicle Scale – Modular Design SECTION TEST 200,000 x 20 lb CLC = 100,000 lb Test Load Section Test 70 000 lb = 5000 lb
Vehicle Scale – Modular Design SECTION TEST 200,000 x 20 lb CLC = 100,000 lb Test Load Section Test 70 000 lb = 5000 lb
Vehicle Scale – Modular Design SECTION TEST 200,000 x 20 lb CLC = 100,000 lb Test Load Section Test 90 000 lb = 5000 lb