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Satellite Notification and Acceptance Program (SNAP)

Summary SNAP is a proposed new segment under OSHA’s

NRTL Program

It is a voluntary program that provides: Increased flexibility for NRTLs More effective monitoring of NRTLs by OSHA

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Satellite Notification and Satellite Notification and Acceptance Program (SNAP) Acceptance Program (SNAP)

Background on NRTL Program

Current NRTL Program Policy

Overview of Proposed SNAP

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Background - NRTL ProgramBackground - 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.html.

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

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Background - NRTL ProgramBackground - NRTL Program Organizations interested in seeking recognition as

an NRTL must apply to OSHA’s NRTL Program. Part of OSHA’s 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.

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Background - NRTL ProgramBackground - 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 SNAP would be one of these programs, but it serves would be one of these programs, but it serves other purposesother purposes.

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Current NRTL Program Current NRTL Program PolicyPolicy

Product testing – can be performed by: NRTL’s recognized site NRTL’s SATELLITE (currently, must be

wholly-owned unrecognizedunrecognized site) Other parties (specifically, independent labs

and product manufacturers) if NRTL is approved by OSHA

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Current NRTL Program Current NRTL Program PolicyPolicy

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.

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Current NRTL Program Current NRTL Program PolicyPolicy

Product certification – can only be performed at NRTL’s 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 NRTL’s mark

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Overview of Proposed SNAPOverview 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.

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Overview of Proposed SNAPOverview 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 NRTL’s satellite qualification and audit program (addresses quality controls, competency, and increased frequency and depth of internal audits)

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Overview of Proposed SNAPOverview of Proposed SNAP

NRTL would qualify its own SNAP sites Specifies each SNAP site’s 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

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Overview of Proposed SNAPOverview of Proposed SNAP

OSHA would audit SNAP sites and main satellite operation’s 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.

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Overview of Proposed SNAPOverview 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