DNDO GRaDER Guidance Notice

The U.S. Department of Homeland Security Domestic Nuclear Detection Office (DNDO) is mandated by Congress to set Technical Capability Standards, and implement a Test and Evaluation program, to provide performance, suitability, and survivability information, and related testing, for preventive radiological/nuclear (rad/nuc) detection equipment in the United States. DNDO intends to meet these responsibilities by establishing the Graduated Rad/Nuc Detector Evaluation and Reporting (GRaDER^SM) Program.

Background

Sec. 121(f) of the Security and Accountability For Every Security and Accountability For Every (SAFE) Port Act, Pub. L. No. 109-347, directs the Secretary of the United States Department of Homeland Security, "acting through the Director for Domestic Nuclear Detection and in collaboration with the National Institute of Standards and Technology [NIST], to publish technical capability standards and recommended standard operating procedures for the use of nonintrusive imaging and radiation detection equipment in the United States."

Sec. 1902 of the Homeland Security Act of 2002, Pub. L. No. 107-296, added by Sec. 501 of the SAFE Port Act, and amended by Pub. L. No. 110-53 (codified at 6 U.S.C. §592), directs the Department of Homeland Security Domestic Nuclear Detection Office to "carry out a program to test and evaluate technology for detecting a nuclear explosive device and fissile or radiological material..."

The GRaDER Program incorporates the initial technical capability standards, and establishes the program to test and evaluate this technology. The Department has adopted the published American National Standards Institute (ANSI) N42 consensus standards as the initial benchmark against which Commercial Off-the-Shelf (COTS) rad/nuc detectors will be tested. Government-unique technical capability standards are being developed, and will be published at a later time. It is our expectation that the Government-unique technical capability standards will be published over a period of several years starting in 2009, and DNDO will subsequently initiate an additional government testing phase that will incorporate these new standards.

The initial technical capability standards will be revised as capabilities increase, and requirements evolve. Rad/nuc detectors will be periodically retested as a result of consensus and technical capability standard revisions, and as instrument design and firmware changes.

Manufacturers may have their products tested against these initial standards through a fee-for-service transaction at laboratories that have been accredited under the NIST National Voluntary Laboratory Accreditation Program (NVLAP) or other DNDO accepted laboratories. DNDO may accept test results from laboratories that have self-declared conformity to the NVLAP accreditation criteria, and submitted accreditation applications to NIST.

Manufacturers that choose to have their product(s) tested under the GRaDER Program may elect to have those test results included in a Department-published list. When published, this list will be publicly available online, with links from www.dhs.gov, Homeland Security Components, Domestic Nuclear Detection Office. While there is no requirement for a manufacturer either to have its product tested against the technical capability standards, or to have its test results published, federal, state, local, or tribal agencies may use the published test results in making procurement decisions. Test results will be confidential, and will not be disclosed without the consent of the manufacturer.

Comments will be considered in making any changes to the initial technical capability standards, or testing portion of this guidance. Comments may be submitted to the DNDO contact.

This guidance has been coordinated with the Office of the Under Secretary for Science and Technology, Federal Emergency Management Agency, and NIST.

Scope and Standards

The scope of the equipment evaluated and standards employed by the GRaDER Program continues to evolve. A listing of GRaDER equipment categories and the applicable ANSI/IEEE N42 standards may be found on the GRaDER Equipment Categories page.

Publishing Results

Manufacturers or vendors whose products have been tested and conformed to at least Level 1 may elect to have those test results included in a Department-maintained list. This list will be available online, with links from the www.dhs.gov, Homeland Security Components, Domestic Nuclear Detection Office. Publishing test results in this list is not mandatory, and a vendor may elect to have the test results included or excluded from the equipment list. Results that are not included in the list will be considered proprietary.

Quality Assurance

Equipment conformity to Compliance Levels will be verified periodically through unannounced, random surveillance by the NIST. Equipment that fails to demonstrate a consistent performance through such verification may require full retesting and/or additional information in order to have its performance results retained on the list. Evidence of significant deviation between the units submitted for testing and the commercially-marketed units will result in removal from the list.

Testing to Consensus Standards

A manufacturer or vendor may have its product tested at DNDO-accepted or NVLAP-accredited laboratories. Testing laboratories must be DNDO-accepted or NVLAP-accredited in accordance with NIST Handbooks 150:2006, NVLAP Procedures and General Requirements and 150-23:2007 (DRAFT) NVLAP Radiation Detection Instruments, and the specific ANSI/IEEE N42 standards. In order for DNDO to accept a test facility without NVLAP accreditation, laboratories must have already applied for NVLAP accreditation and self-declare their conformity with these requirements to DNDO. Labs also must conform to International Organization for Standardization (ISO)/ International Electrotechnical Commission (IEC) 17025:2005, General Requirements for the Competence of Testing and Calibration Laboratories.

DNDO will review laboratories capabilities for acceptance with NIST's assistance. DNDO will determine if test results from these facilities will be accepted pending completion of the accreditation process within the required period of time. NIST will inform DNDO when laboratories have been awarded accreditation. Only test results from DNDO-accepted or appropriately accredited NVLAP facilities will be considered for evaluation.

Testing to Government-Unique Standards

Vendors may initiate testing against the ANSI consensus standards at any time. However, rad/nuc detectors must first pass at least the GRaDER Level 1 requirements against ANSI consensus standards before submission to be scheduled for GRaDER Level 3 testing against government-unique technical capability standards, and to have DNDO evaluations posted to the GRaDER Program Evaluated Equipment List.

Manufacturers apply to DNDO for consideration of designated radiation detectors under the GRaDER Program by submitting the required information under company letterhead. Criteria for entry into the GRaDER Program include satisfactory demonstration of compliance with applicable subsets of the ANSI N42 Standards' requirements as outlined above in the "Compliance Levels" section. Demonstration of compliance with the consensus standards may be achieved in either of two methods. The first method is with an original independent test report from a NVLAP-accredited facility for testing against the ANSI N42 Standards. The second method is with an original independent test report from a DNDO-accepted testing laboratory. The conformity requirements outlined below in the "Test and Evaluation Interest Areas" section must also be satisfied.

Test and Evaluation Areas

A complete and independently verifiable detector configuration description must be provided with the application, to include software and firmware version identification and instructions. Applications must include manufacturer or vendor points of contact names, mailing address, telephone number, and electronic mail addresses.

DNDO requires that vendors provide information relating to conformance to other industry and government standards, including those identified below. The GRaDER Program examines certifications from recognized organizations and agencies, and original signed declarations of conformity to these standards. GRaDER verification may include audit and/or testing at the government's discretion, and as part of the GRaDER post-market surveillance program.

• Training Capabilities. DNDO assesses the vendor provided training capabilities and materials as part of the government unique technical capability standards phase of GRaDER testing, using portions of ANSI N42.37-2006 American National Standard for Training Requirements for Homeland Security Purposes Using Radiation Detection Instrumentation for Interdiction and Prevention to be identified at a later date.
• Electrical Safety. Electrical equipment that is intended to be used in a regulated workplace will be "certified" to the appropriate safety requirements by an Occupational Safety & Health Administration (OSHA)-accredited Nationally Recognized Testing Laboratory (NRTL), under the General Industry Standards (Part 1910 of Title 29, Code of Federal Regulations - 29 CFR Part 1910). Please visit OSHA for a listing of NRTL facilities:

http://www.osha.gov/dts/otpca/nrtl/index.html

Cost and Labs

A manufacturer or vendor is responsible for paying the laboratory directly for testing its own equipment. The NVLAP-accredited and the DNDO-accepted laboratories will set their own rates for testing, and the transaction will not result in a transfer of funds to DNDO. Cost will vary by the type of equipment tested, and the individual laboratory performing the test. Cost shall not exceed the amount necessary for the laboratory to recoup the direct and indirect costs incurred in performing the testing.

The following laboratories may perform the Consensus Standards testing: To Be Published.

Questions and Comments

To submit questions, comments and self-declarations of conformity, please visit DNDO GRaDER Contact Information.