OSHA’s Safety Certification Program is Still Confusing for Some Manufacturers
Established by the U.S. Occupational Safety and Health Administration (OSHA) in 1988, the Nationally Recognized Testing Laboratory (NRTL) program provides manufacturers and distributors with a mechanism to demonstrate that their electrical and electronic equipment and materials meet U.S. government regulations regarding worker safety. However, there is still widespread confusion and misunderstanding among manufacturers, distributors and retailers alike about what NRTL certification means, and which laboratories are authorized to perform testing and grant certification under the NRTL program.
In this article, we’ll answer 10 of the most frequently asked questions about OSHA’s NRTL program and address the certification options that are available to manufacturers.
What is OSHA’s NRTL program?
OSHA’s NRTL program facilitates compliance with the agency’s rules and regulations regarding the safety of equipment and materials used in the federally-regulated workplace in the U.S. It does so by giving manufacturers and distributors a choice in the selection of a recognized testing laboratory to evaluate and certify their products for compliance with applicable product safety standards. In this way, manufacturers and distributors can work with any OSHA-recognized testing laboratory that best meets their needs for location, timeliness, quality of service and cost.
Why was the NRTL program created?
The NRTL program was created in part to help give industry greater flexibility in the testing and certification of their products. Prior to the NRTL program, only two organizations, UL and Factory Mutual, were expressly identified as testing entities approved by OSHA for required testing. This created a virtual monopoly for testing services, eliminating other highly qualified testing laboratories from consideration. With the creation of the NRTL program in 1988, testing laboratories were now able to apply for OSHA recognition, and provide equipment and material manufacturers and distributors with a broader range of testing and certification services and options.
What products require NRTL certification?
Under Part 1910 of Title 29 Code of Federal Regulations (29 CFR Part 1910), NRTL certification is required for 37 different categories of products. The categories include a wide range of equipment and materials used in the construction or operation of workplace environments, such as self-closing fire doors, fire detection and sprinkler systems, as well as equipment frequently found in industrial workplaces.
However, perhaps the biggest single category of products requiring NRTL certification are “electrical conductors or equipment,” as detailed under Parts 1910.303 and 1910.307. Specifically, Part 1910.303 stipulates that all electrical equipment used in the workplace “shall be free from recognized hazards that are likely to cause death or serious harm to employees,” and specifies an extensive list of considerations to fully assess the safety of a given product. Part 1910.303 addresses additional requirements for electrical equipment and wiring used in hazardous work locations, such as those where flammable vapors, liquids or gases, or combustible dust may be present.[i]
How can I determine whether a product has received NRTL certification?
Manufacturers and distributors of products that have been tested and certified by an NRTL are authorized to apply the NRTL’s registered certification mark to their product. This mark signifies that the product has been tested and found compliant with the requirements of one or more of product safety standards applicable to that product and is safe to use in the workplace.
There is no one standard NRTL mark required by OSHA for use on NRTL-certified products. Instead, individual NRTLs typically grant use of their own proprietary certification marks, some of which may include the NRTL acronym. Therefore, the best way to verify the applicability of an NTRL mark is to check the OSHA website to determine whether the testing laboratory identified by the certification mark has been recognized by OSHA under the NRTL program for testing to the standards required for that product.[ii]
How many testing organizations are currently “recognized” under the NRTL program?
In 1989, there were just two OSHA-recognized NRTLs, operating five different testing locations. Today, there are 18 OSHA-recognized NRTLs, encompassing more than 125 individual sites on four continents around the world. In recent years, OSHA has noted that the agency has experienced a surge in new applications for NRTL recognition. So the number of NRTLs and available testing locations is likely to increase in the future.
What is the process for obtaining NRTL “recognition”?
Testing organizations seeking OSHA recognition under the NRTL program first submit a comprehensive application to the agency. OSHA staff then reviews the application for completeness and to evaluate whether the applicant testing organization meets the general requirements for recognition. As part of its evaluation, OSHA also conducts an extensive on-site assessment of the organization’s facilities, equipment and programs.
Based on its analysis of the testing organization’s application and the findings of the on-site assessment, OSHA staff then makes its recommendation regarding approval of the NRTL application to the Assistant Secretary of Labor. The recommendation details the scope of NRTL recognition, including the specific testing sites and testing standards for which the testing organization is being recognized. Notice of the recommendation is published in the Federal Register, and a final Notice is published following a 30-day public comment period.[iii] NRTL recognition is renewable every five years.
OSHA has recently adopted changes to its NRTL Program Directive to bring the program’s recognition requirements in line with those found in international standards, including ISO/IEC 17025 and ISO 17065. This move is expected to harmonize OSHA’s NRTL program with other testing accreditation programs, and eventually ease the qualification pathway for many testing organizations.
How does OSHA define the scope of a testing organization’s recognition?
As previously noted, the scope of an NRTL recognition details the specific product safety standards for which an individual testing organization has been recognized. Each testing organization identifies the standards for which it is seeking recognition as part of the application process, and OSHA’s evaluation of the applicant is based on their assessment of the organization’s ability to conduct testing consistent with the requirements of the stated standards. Therefore, the scope of a testing organization’s NRTL recognition is limited to only those standards for which it has been approved.
Can the scope of an initial NRTL recognition be modified?
Yes. Testing entities can request that OSHA evaluate their organization for the incorporation of additional product safety standards under the scope of its recognition. Similarly, NRTLs can also seek to add additional testing sites to their scope of recognition. These options give NRTLs the potential to expand their geographic reach as well as the breadth of their testing and certification services under the NRTL program.
What products is an NRTL authorized to test and certify under its recognition?
The specific products which an organization is authorized to test under its NRTL recognition is limited to those products covered by the standards for which the testing organization has been recognized. Although a testing laboratory may possess the competence to test products in accordance with the requirements of other standards, it may not certify those products under the NRTL program.
Are all NRTL-recognized testing organizations “equal”?
The scope of each NRTL-recognized testing organization is based on an individual assessment by OSHA of that organization’s ability to competently conduct testing in accordance with the requirements of a specified product safety standard or standards. The scope of NRTL recognition for some testing organizations may be limited to a small number of standards, while the scope of others might encompass more than 100 different standards. And while multiple NRTLs may be recognized by OSHA to test for the same standards, other issues such as location, cost and quality of service can be critical factors in deciding between seemingly comparable NRTLs.
In its 30-year existence, OSHA’s NRTL program has helped to expand the competitive market for testing and certification services in the U.S. and has provided manufacturers and distributors with the flexibility of partnering with an NRTL-recognized testing organization that best meets their needs. In turn, this has resulted in greater compliance with federal workplace safety requirements and helped to reduce the incidence of workplace injuries and fatalities.
TÜV SÜD America has been an NRTL-recognized testing laboratory for more than 12 years and is currently recognized to test and certify products in accordance with more than 150 individual product safety standards under the NRTL program. With four recognized testing lab locations across North America, TÜV SÜD America is also positioned to provide manufacturers and distributions with convenient access to NRTL testing and certification services, regardless of their location.
For more information about TÜV SÜD America’s NRTL testing and certification services, contact Sean Clifford at Sean.Clifford@tuvsud.com.
About the author
Sean Clifford, North American Sales Manager, Lighting
Sean Clifford joined TÜV SÜD in July of 2017 as the North American Sales Manager of Lighting. He operates out of the Atlanta based laboratory, and covers all areas of lighting from product safety to energy efficiency to FCC testing and more. Previous to TÜV SÜD, Sean spent nine years with CSA Group, managing the strategic account portfolio. As a former collegiate athlete, Sean now enjoys coaching youth soccer in his free time.
[i] For more detailed information, see “Specific References to OSHA Standards Requiring NRTL Approval,” website of the Occupational Safety and Health Administration, U.S. Department of Labor. Available at https://www.osha.gov/dts/otpca/nrtl/1910refs.html#1910_303-307 (as of 8 April 2017).
[ii] A current list of OSHA-recognized NRTLs and the standards for which each NRTL has been recognized is available at https://www.osha.gov/dts/otpca/nrtl/nrtllist.html (as of 8 April 2018)
[iii] For further information on the requirements for obtaining NRTL recognition, see “Information on Submitting an Application,” website of the Occupational Safety and Health Administration, U.S. Department of Labor. Available at https://www.osha.gov/dts/otpca/nrtl/appinfo.html (as of 8 April 2018).