Nonfood Compounds and Proprietary Substances Registration Policies

1
Nonfood Compounds and Proprietary
SubstancesRegistration Policies

• Steering Committee Meeting
• October 24, 2006
• Jane M. Wilson

2
Agenda

• What are NSF policies
• How policies are developed
• What the new Registration Policies will address
• Next steps in Registration Policy development

3
What are NSF Policies?

• NSF Standards, Protocols, Guidelines, other
  national standards, and regulations provide the
  requirements for products or services to be
  Certified or Registered by NSF.
• NSF Policies define the operational requirements
  for companies related to achieving and
  maintaining NSF Certification or Registration.
• NSF Policies define the responsibilities of both
  NSF and the Certified or Registered company.
• NSF Policies help NSF to maintain compliance with
  ISO Guide 65 General requirements for bodies
  operating product certification systems.

4
How NSF Policies are Developed

• NSF Certification Council
• Balanced group of NSFs traditional stakeholders
  industry, public health, and users
• Set of policies defines the organizational
  structure and functions of the Cert Council,
  including balloting requirements for approval of
  policies
• Membership elected to 3 year terms from
  nominations provided by NSF or Cert Council
  members

5
Certification Policy Development
Council of Public Health Consultants, Joint
Committees
Industry Forums, other external stakeholders
NSF Staff
Internal NSF Staff Review, legal review
External Review (Industry Forums, CPHC)
Certification Council Ballot
Implementation by NSF Program
6
Authorization for Registration

• Application for Registration
• Contract for NSF Registration
• Written Authorization for use of the NSF Mark
• Transfer of Authorization for Use of the NSF Mark
  
• Requirements for Trade Designations
• Product modification
• Implementation of revisions to Registration
  criteria

7
Testing

• Acceptable locations for the conduct of testing
• Provision of Test Report
• Disposal of test samples

8
Confidentiality

• Restrictions on disclosure of confidential
  business information
• Availability of Confidential Disclosure Agreement
• Subpoena of Confidential Business Information

9
Advertising

• Use of the NSF Mark on sales literature,
  technical publications, promotions, product
  packaging, catalogs, and advertising of
  Registered products

10
Appeals

• Three tiered process for administrative
  assessment of NSF Registration decisions
• Administrative Review
• Appeal through an Appeal Officer
• Appeal through an Appeal Panel

11
Responsibility for Fees

• Registration fee
• Reinstatement fee
• Charges by government agencies

12
Special Policies

• Intentional Use of Lead in Registered Products
• Use of NSF Mark with Accreditation Marks
• Reference to WHO Collaborating Centre status in
  relation to Registered products

13
Nonfoods Specific Policies

• Marking requirements for Registered products
• Requirements for Registered products regulated
  under FIFRA
• Registration format
• Submittal of formulation information
• Product name changes

14
Next Steps

• NSF will further refine the Draft Registration
  Policies for internal review
• NSF will work with a stakeholder group to satisfy
  external review requirements
• Identify stakeholder to serve on Certification
  Council
• Present the draft Registration Policies to the
  NSF Certification Council for adoption
• Implementation of the policies by the Nonfoods
  Program Office

15
Questions?

• Jane Wilson
• Director of Standards
• wilson_at_nsf.org
• 734-827-6835