Satellite Notification and Acceptance Program (SNAP)

1
Satellite Notification and Acceptance Program
(SNAP)

• Summary
• SNAP is a proposed new segment under OSHAs NRTL
  Program
• It is a voluntary program that provides
• Increased flexibility for NRTLs
• More effective monitoring of NRTLs by OSHA

2
Satellite Notification and Acceptance Program
(SNAP)

• Background on NRTL Program
• Current NRTL Program Policy
• Overview of Proposed SNAP

3
Background - NRTL Program

• Approval Requirement and NRTL Program
• 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
• There are 37 different types of products, and the
  largest of these types is electrical products and
  equipment
• The full listing of these categories is available
  at http//www.osha.gov/dts/otpca/nrtl/prodcatg.htm
  l.

4
What is a Nationally Recognized Testing
Laboratory (NRTL)?

• An independent, i.e., third-party, organization
• Capable of providing product safety testing
  must have a product safety testing program
• Capable of providing product safety certification
  services, - must operate listing and labeling
  products and following-up inspection programs.
• Program Regulation (29 CFR 1910.7) contains
  requirements and specifies general recognition
  process
• Program Directive (CPL 1-0.3) contains program
  policies, procedures, and guidelines

5
Background - NRTL Program

• Organizations interested in seeking recognition
  as an NRTL must apply to OSHAs NRTL Program.
• Part of OSHAs Directorate of Science Technology
  and Medicine.
• Seeks to prevent accidents through assuring
  safety of products used by American workers.
• OSHA established the NRTL Program in 1988.
• There are presently 18 organizations operating a
  total of 52 recognized sites. Two NRTLs are
  foreign-based.

6
Background - NRTL Program

• NRTL Scope of Recognition (3 elements)
• Types of products listing of product safety test
  standards that the NRTL may use in approving
  products.
• Recognized Sites wholly-owned by NRTL and has
  capability to perform full range of testing and
  certification activities.
• 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

• Product testing can be performed by
• NRTLs recognized site
• NRTLs SATELLITE (currently, must be wholly-owned
  unrecognized site)
• Other parties (specifically, independent labs and
  product manufacturers) if NRTL is approved by OSHA

8
Current NRTL Program Policy

• OSHA uses a program approach to allow NRTLs to
  use other-party testing
• Called March 9 programs due to date adopted.
• Each specifies category of testing and criteria
  that NRTLs must meet to receive OSHA approval to
  use.

9
Current NRTL Program Policy

• Product certification can only be performed at
  NRTLs recognized site
• NRTL Program staff only audit these NRTL sites
• Examples of product certification activities
• Perform final technical evaluation of product
• Render final decision on certification
• Authorize use of the NRTLs mark

10
Overview of Proposed SNAP

• Role of Satellites would be expanded to
  performing certification activities
• Would allow NRTLs to locate approval activities
  closer to manufacturers, which are located in
  many foreign countries
• Uses program approach to implement policy
  Satellite Notification and Acceptance Program
  (SNAP).
• 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

• SNAP describes two basic sets of criteria that
  any NRTL must meet to receive OSHA approval to
  use program
• One set focuses on the degree of ownership and
  control by NRTL, and eligible sites and
  organizations
• Other set focuses on the detailed criteria for
  NRTLs satellite qualification and audit program
  (addresses quality controls, competency, and
  increased frequency and depth of internal audits)

12
Overview of Proposed SNAP

• NRTL would qualify its own SNAP sites
• Specifies each SNAP sites testing and
  certification functions
• NRTL would need to annually audit and re-qualify
  each SNAP site
• NRTLs would need to notify OSHA of qualified SNAP
  sites
• Their qualification and functions
• Their auditing schedule

13
Overview of Proposed SNAP

• OSHA would audit SNAP sites and main satellite
  operations office.
• OSHA could drop a SNAP site or the NRTL from SNAP
  if warranted.
• NRTLs not approved for SNAP by OSHA would not be
  able to use satellites to perform certification
  activities.

14
Overview of Proposed SNAP

• If SNAP is approved, OSHA plans to publish a
  Federal Register notice to make the public aware
  of adoption of new program
• Similar to action taken when other programs
  adopted in 1995
• There would be a 12 month transition period to
  implement SNAP