Presentation on theme: "1 Satellite Notification and Acceptance Program (SNAP) Summary u SNAP is a proposed new segment under OSHA’s NRTL Program u It is a voluntary program that."— Presentation transcript:
1 Satellite Notification and Acceptance Program (SNAP) Summary u SNAP is a proposed new segment under OSHA’s NRTL Program u It is a voluntary program that provides: u Increased flexibility for NRTLs u More effective monitoring of NRTLs by OSHA
2 Satellite Notification and Acceptance Program (SNAP) u Background on NRTL Program u Current NRTL Program Policy u Overview of Proposed SNAP
3 Background - NRTL Program u Approval Requirement and NRTL Program u OSHA requires that NRTLs approve (i.e., test and certify) certain categories or types of products to ensure they can be used safely in the workplace u There are 37 different types of products, and the largest of these types is electrical products and equipment u The full listing of these categories is available at http://www.osha.gov/dts/otpca/nrtl/prodcatg.html.
4 What is a Nationally Recognized Testing Laboratory (NRTL)? u An independent, i.e., third-party, organization u Capable of providing product safety testing – must have a product safety testing program u Capable of providing product safety certification services, - must operate listing and labeling products and following-up inspection programs. u Program Regulation (29 CFR 1910.7) contains requirements and specifies general recognition process u Program Directive (CPL 1-0.3) contains program policies, procedures, and guidelines
5 Background - NRTL Program u Organizations interested in seeking recognition as an NRTL must apply to OSHA’s NRTL Program. u Part of OSHA’s Directorate of Science Technology and Medicine. u Seeks to prevent accidents through assuring safety of products used by American workers. u OSHA established the NRTL Program in 1988. u There are presently 18 organizations operating a total of 52 recognized sites. Two NRTLs are foreign-based.
6 Background - NRTL Program u NRTL Scope of Recognition (3 elements) u Types of products: listing of product safety test standards that the NRTL may use in approving products. u Recognized Sites: wholly-owned by NRTL and has capability to perform full range of testing and certification activities. SNAP would be one of these programs, but it serves other purposes u “Programs”: mainly allows use of other-party testing if NRTL meets certain criteria. SNAP would be one of these programs, but it serves other purposes.
7 Current NRTL Program Policy u Product testing – can be performed by: u NRTL’s recognized site unrecognized u NRTL’s SATELLITE (currently, must be wholly-owned unrecognized site) u Other parties (specifically, independent labs and product manufacturers) if NRTL is approved by OSHA
8 Current NRTL Program Policy u OSHA uses a “program” approach to allow NRTLs to use other-party testing u Called March 9 programs due to date adopted. u Each specifies category of testing and criteria that NRTLs must meet to receive OSHA approval to use.
9 Current NRTL Program Policy u Product certification – can only be performed at NRTL’s recognized site u NRTL Program staff only audit these NRTL sites u Examples of product certification activities u Perform final technical evaluation of product u Render final decision on certification u Authorize use of the NRTL’s mark
10 Overview of Proposed SNAP u Role of Satellites would be expanded to performing certification activities u Would allow NRTLs to locate approval activities closer to manufacturers, which are located in many foreign countries u Uses “program” approach to implement policy: Satellite Notification and Acceptance Program (SNAP). u Satellites under SNAP (“SNAP sites”): NRTL would generally need to have majority ownership and would need to locally administer and control.
11 Overview of Proposed SNAP u SNAP describes two basic sets of criteria that any NRTL must meet to receive OSHA approval to use program u One set focuses on the degree of ownership and control by NRTL, and eligible sites and organizations u Other set focuses on the detailed criteria for NRTL’s satellite qualification and audit program (addresses quality controls, competency, and increased frequency and depth of internal audits)
12 Overview of Proposed SNAP Overview of Proposed SNAP u NRTL would qualify its own SNAP sites u Specifies each SNAP site’s testing and certification functions u NRTL would need to annually audit and re-qualify each SNAP site u NRTLs would need to notify OSHA of qualified SNAP sites u Their qualification and functions u Their auditing schedule
13 Overview of Proposed SNAP u OSHA would audit SNAP sites and main satellite operation’s office. u OSHA could drop a SNAP site or the NRTL from SNAP if warranted. u NRTLs not approved for SNAP by OSHA would not be able to use satellites to perform certification activities.
14 Overview of Proposed SNAP u If SNAP is approved, OSHA plans to publish a Federal Register notice to make the public aware of adoption of new program u Similar to action taken when other “programs” adopted in 1995 u There would be a 12 month transition period to implement SNAP