April 21, 2008
To: All NRTLs1
In March 2004, my office requested your informal comments on a draft description of the proposed Satellite Notification and Acceptance Program (SNAP), which you may know is a voluntary program intended for use by Nationally Recognized Testing Laboratories (NRTLs). A year earlier, we requested your initial feedback on a preliminary outline of the program. If you provided comments on either request, we thank you and have incorporated many of them into the SNAP Program Description. You are receiving this letter concurrently with the publication of OSHA’s Federal Register notice formally requesting public comments on SNAP. We refer in that notice to the current version of the program description, which is attached for your convenience.
In general, we did not incorporate the informal comments received if we believed the program description was adequate. However, a few comments indicated the need to provide clarification on our use of the term “sites,” on audits that need to be performed, and on the quality assurance system of a SNAP site. The purpose of this letter is to provide that clarification (Appendix A) and to describe our proposed implementation process for SNAP (Appendix B).
If you wish to suggest any change to the description or other comment, please submit them following the instructions in the published notice. After implementing SNAP, we will write to provide instructions on submitting applications for it. At that time, additional topics regarding implementation will also be addressed.
Thank you for your continuing interest in OSHA’s NRTL Program. If you have any questions about this letter, you may contact Bernard Pasquet at (202) 693-2110, or by e-mail at pasquet.bernard@dol.gov. If you have technical questions about SNAP, you may contact him or John Linkletter at (801) 233-4926 or by e-mail at linkletter.john@dol.gov.
Sincerely,
MaryAnn Garrahan
Director
Office of Technical Programs and Coordination Activities
Attachments
1 Note: OSHA is sending this letter to each NRTL in order to provide clarifications pertaining to the description of the proposed Satellite Notification and Acceptance Program (SNAP).
Appendix A
Clarification of Satellite Notification and Acceptance Program (SNAP)
Program Description
SITES - One area that appeared to create some confusion is the various terms we used in the NRTL Program to describe sites and the functions they could perform.
A recognized site is part of the NRTL’s scope of recognition and is listed under the OSHA Web site for the NRTL Program. Such a site must have the capability to perform the full range of testing and certification activities necessary in certifying products.
A satellite not under SNAP (a regular “satellite”) is an unrecognized site that is qualified by the NRTL to provide only testing and evaluation data to a recognized site. The NRTL must wholly own such sites, which cannot qualify any other location to provide test data; must audit such sites annually; and must operate the site following the NRTL’s “quality assurance program.”
A satellite under SNAP (“SNAP site”) is an unrecognized site qualified by the NRTL to perform any of the “SNAP functions” (as described in the SNAP Program Description) that the NRTL is recognized to perform under its NRTL scope of recognition. Such a site must meet the definition of “SNAP site” in the SNAP Program Description. As is the case for a regular “satellite,” this definition requires that the NRTL operate the site following the NRTL’s “quality assurance program.”
AUDITS - An explanation was requested on the differences between technical and program audits and on the audit functions required to be performed on a SNAP site.
A technical audit evaluates the SNAP site’s test equipment availability, and the ability of site personnel to test, evaluate, and review test reports. The NRTL must qualify any technical auditor as technically knowledgeable about the testing and evaluation specified by the test standards for which the site itself is to be qualified. This is similar to what NRTLs do to qualify a regular satellite (i.e., one not under SNAP) to provide test and evaluation data to a recognized site; a person located at a recognized site performs the technical audit of the satellite. However, one difference to SNAP is that the technical auditor under SNAP does not have to be located at a recognized site. The SNAP Program Description has added controls in the auditing and quality assurance areas for ensuring sufficient monitoring of SNAP site activities, which permits this flexibility in auditor location.
A program audit primarily evaluates the satellite’s process, and implementation of the NRTL’s requirements, for the (1) generation or acceptance of test data from outside sources, (2) issuance of certifications, and (3) control of necessary support functions. The program auditor must be knowledgeable in the NRTL’s processes and requirements and have a quality auditing background.
The NRTL must perform three audits of each SNAP site during a calendar year: two program audits, at approximately six-month intervals, and one technical audit. A program auditor “located” at the SNAP Headquarters’ office must perform the initial qualification audit and one of the two yearly re-qualification program audits. If qualified as both a program auditor and technical auditor, an auditor may perform both a technical and a program audit during one visit to a SNAP site. As clarified in the SNAP Program Description, 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. If qualified, an auditor may also evaluate an expansion or other change to the SNAP site’s scope during a technical or program audit.
The SNAP Program Description specifies that both technical and program audits must be performed “on-site.” A SNAP site will have some of the same capabilities as a recognized site, and the NRTL audits of SNAP sites will parallel OSHA audits of recognized sites. Our normal practice under the OSHA NRTL Program is to perform on-site audits of recognized sites by OSHA auditing personnel. The on-site audits are critical and necessary to a proper evaluation of the NRTL’s activities and to identification of non-conformances that in all practical respects could only be identified through on-site review. Therefore, OSHA’s experience indicates that on-site auditing by the NRTL and a headquarters’ presence is crucial to the NRTL maintaining adequate control of SNAP site facilities.
QUALITY ASSURANCE – Comments indicated the need to explain OSHA’s expectation in the quality assurance area.
In the “Definition of a Satellite Under SNAP (SNAP site)”, which is in the SNAP Program Description, OSHA had required that the SNAP site be “maintained under” the quality assurance program of the NRTL. We revised the phrase in quotes to “operated following” to clarify how the assurance program affects a site’s operations. Each NRTL’s quality assurance program must have the policies, procedures, and elements meeting the OSHA NRTL Program requirements and the controls necessary for a credible program. The basic policies of the program are usually contained in the NRTL’s quality manual and related broad level documents. Quality assurance programs are dynamic in that they are modified to address changes in operations, but we review and continually monitor the program and any modifications during OSHA audits of NRTLs. OSHA recognizes that work instructions and procedures may be tailored for a particular SNAP site to address local conditions in areas such as test equipment, product handling, security, records, and labeling. However, a SNAP site 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.
Appendix B
Implementation Process for Satellite Notification and Acceptance Program (SNAP)
OSHA plans to accept applications for the SNAP starting 60 days after the date of publication of the Federal Register notice that implements SNAP. Prior to the end of the 60-day period, we will invite existing NRTLs and current initial applicants to apply for use of SNAP. The documentation to submit for application is identified under Initial Application Procedure in the SNAP Program Description.
Under the SNAP process, if an NRTL applies and receives approval to use the program, it may then perform “SNAP functions” (as identified in the SNAP Program Description) at its qualified SNAP sites and/or at its recognized site(s). If an NRTL does not apply to use the program, or if it is not approved for use of the program, it may only perform the “SNAP functions” at a recognized site(s). Once OSHA makes its determination about an NRTL’s participation in SNAP, OSHA will audit the NRTL’s sites accordingly and cite as non-conformances any findings that show the NRTL is operating inconsistently with the applicable OSHA requirements and policies. For all NRTLs, OSHA will utilize a 12-month transition period, which begins 60 days after the date of publication of the Federal Register notice that implements SNAP. During this transition period, unrecognized sites that are performing SNAP functions, but are not satellites under SNAP (i.e., not SNAP sites), will be identified in audit reports. At the end of the transition period, NRTLs not approved for SNAP must cease performing any SNAP functions at any unrecognized sites. If OSHA finds that such activities have not ceased, this will constitute a violation of the NRTL’s terms of recognition, which would justify commencing the process to revoke the NRTL’s recognition. The only exception to the application of the 12-month transition deadline just described is any delays caused by OSHA.
Approval of any initial NRTL applicant for use of SNAP would be determined as part of OSHA’s regular NRTL application approval process.
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