Proposed Updates to the Nationally Recognized Testing Laboratory Program
OSHA is proposing significant updates to the Nationally Recognized Testing Laboratory (NRTL) Program by aligning it with ISO standards, revising independence policies, and making major proposals to enhance the program. These changes aim to ensure stakeholders' views are considered and to improve the certification and testing processes. The proposed updates include aligning with ISO 17025 & 17065, revising policies on independence, supplemental programs, equipment calibration, and more. Stakeholders' feedback is vital in this process as OSHA works towards updating the NRTL Program to meet modern standards.
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Presentation Transcript
Nationally Recognized Testing Laboratory Program Proposed Directive Update October 22, 2014
Legal OSHA is not looking for consensus. OSHA Is looking for individual stakeholder views on the issues presented. Documents distributed or posted online are for informational purposes only. Actions will be announced through the Federal Register.
History The NRTL Program established in 1988 NRTL Directive published 1999 Only minor updates in 15 years NRTL Application Guidelines GAO Study 2012
Improvement steps Stakeholder meeting March 2013 Initial Plan to make a few changes to fix major problem areas. Later decided to update and rewrite the entire directive.
Major Proposals Align requirements with ISO 17025 & ISO 17065 Revise OSHA policies on Independence Revise OSHA policies on Supplemental Programs Revise OSHA policies on the use of the IECEX Scheme Revise OSHA policies on equipment calibration Revise the definition of a Recognized Site and eliminate SNAP Sites
Alignment with ISO Standards OSHA is proposing to align its requirements with ISO 17025 and ISO 17065 and adding NRTL Specific requirements and interpretations. Change NRTL specific terminology to align with ISO Standards where possible.
Independence OSHA requires that NRTLs and applicants be completely independent of employers subject to [OSHA s] tested equipment requirements, and of any manufacturers or vendors of equipment or materials being tested for these purposes (29 CFR 1910.7(b)(3)) NRTLs must be free from commercial, financial and other pressures that could compromise the results of its testing and certification processes
Independence OSHA proposes to align its existing independence policy with Section 4.1 of ISO/IEC 17025:2005 and Section 4.2 of ISO/IEC 17065: 2012. NRTL Program-specific requirements to supplement and clarify Section 4.2 of ISO/IEC 17065: 2012.
Supplemental Programs 9 Supplemental programs that allow NRTLs to accept data from outside organizations Independent Laboratories Manufacturers CB Scheme SNAP Sites NRTLs apply for recognition
Supplemental Programs Supplemental programs will disappear NRTLs must demonstrate capability to accept data from outside sources OR must state that the NRTL will not accept data from outside sources.
IECEx Acceptance With OSHA recognition of IEC harmonized Hazardous Location standards, it sets the stage for acceptance of IECEx reports and certificates. NRTL Specific guidance provided in the NRTL specific requirements for ISO 17065 Section 7.4H
Equipment Calibration NRTL must have an adequate "calibration program" in order to meet the capability requirements of 29 CFR 1910.7 (NRTL Program Directive, Appendix C.XVII).
Equipment Calibration OSHA is proposing to include new requirements that require the NRTL or applicant to use an accredited calibration laboratory for the calibration of its test equipment. Additionally, if calibrations are conducted by the NRTL s internal calibration laboratory, then the internal calibration laboratory must be accredited for the scope of calibrations it conducts with certain exceptions. (NRTL Requirements 17025 Section 4.6)
Definition of Recognized Site The legal entity recognized by OSHA as the NRTL must wholly-own (directly or indirectly) or organizationally encompass the NRTL's laboratory and certification sites, and have administrative and operational control over these sites
Proposed definition of a Recognized Site A site administratively and operationally controlled by the NRTL that performs testing, inspection, certification decisions and/or accepts test data or inspections in accordance with the NRTL management system.
