Hi Brian, You are correct that the NRTL Directive is 17025/17065 with "national differences". I am glad that was obvious in the first read as that was the approach that we were trying to take.
I should have stated that the draft version of the NRTL directive is the latest iteration of a document that was published almost 20 years ago (loosely based off of Guide 25 & Guide 65). The goal with this revision was to "translate" existing OSHA policy into the common ISO 17025/17065 language that most of us speak as well as to add some clarity to some areas that were previously ambiguous. Our goal was not to make too many significant changes. More significant changes will be introduced in future updates over the next several years The Directive establishes the minimum performance standards that an NRTL must meet in a given area, I would say that all of the current NRTLs exceed these minimum standards in one or more areas. Having worked for an NRTL, and now working for the NRTL Program at OSHA I can say that the assessments we conduct are probably one of the most technical assessments that a laboratory will likely ever undergo, and I suspect that is the reason for the high level of scrutiny that the NRTLs give to manufacturers and other 3rd party test labs. I would say that we would lean more towards the "authoritative source" rather that meeting only the basic ISO requirements. If we don't have a lot of clarity in certain areas, we are likely working on the text for a future update (Staff training and qualification is one of those areas that we are looking hard at for future updates). "Recognition" is going to be roughly equivalent to "Accreditation" throughout the document. Looks like we have another definition to write. Kevin if you (or anyone) has any questions, feel free to contact me through my "Official" channels: Kevin Robinson Director - Office of Technical Programs and Coordination Activities NRTL Program 202-693-1911 robinson.ke...@dol.gov or nrtlprog...@dol.gov On Thu, Jun 9, 2016 at 7:50 PM, Brian O'Connell <oconne...@tamuracorp.com> wrote: > Nothing that follows necessarily represents the opinions or policies of my > employer or my dog; and certainly not my cat. Did a quick browse (ok, not > so quick - took several hours for the transformer temp to stabilize). But > will have to clear with senior management before more of my > thought-provoking, insightful (?) comments are formally submitted. But need > to understand some things before these deep and meaningful thoughts are > forwarded for the entertainment of the U.S. OSHA. > > Appears that intent is to adopt/harmonize with ISO17025 and 17065 but with > 'national differences'. This is a good base-line for writing administrative > law, but is effectively less demanding in both personnel competence and > test equipment traceability and control (annex A) than that of some NRTLs > that have audited my humble company lab. > > Does OSHA want an NRTL to be an authoritative source, or only > representative of the basic requirements per IEC/ISO? > > The term "Recognized" is defined per the physical site, but the text also > uses 'recognition' in the general sense for the company's personnel and > labs. Is this intended to be same or something other than the "Accredited" > definition in annex C? > > R/S, > Brian > > From: Kevin Robinson [mailto:kevinrobinso...@gmail.com] > Sent: Thursday, June 09, 2016 2:10 PM > To: EMC-PSTC@LISTSERV.IEEE.ORG > Subject: [PSES] For Your Information NRTL Directive Draft and Comment > > Hello All, > > I wanted to advise you that the Draft NRTL Program Directive has been > published on the OSHA website for public comment. We encourage you all to > review the draft directive and to submit any questions, comments, revisions > or concerns you may have to OSHA. > > In previous communications OSHA indicated that the Directive would be > published in the Federal Register for comments. Due to some complications > in that process, and in the interest in sharing the draft Directive with > you as soon as possible, we will not be publishing the Directive in or > seeking comments through the Federal Register. > > Please submit your comments no later than 11:59pm Eastern Time Tuesday > August 9, 2016 > > To submit via email, send comments to nrtlprog...@dol.gov Please title > your submissions as “NRTL Directive Comment” . > > To submit in hard copy, please use the following address: > > OSHA > NRTL Program > Office of Technical Programs and Coordination Activities > 200 Constitution Avenue NW, Room N3653 > Washington, DC 20210 > > *** Please note, comments sent via U.S. Mail may take an additional ten > days to be received due to security screening procedures.*** > > To submit comments via fax, please send comments to 202-693-1644. > > Draft NRTL Directive: > http://www.osha.gov/dts/otpca/nrtl/nrtl_draftdirective_public_comment.pdf > > Additional information, including a list of Frequently Asked Questions may > be found at: http://www.osha.gov/dts/otpca/nrtl/nrtlnews.html > > - > ---------------------------------------------------------------- > This message is from the IEEE Product Safety Engineering Society emc-pstc > discussion list. To post a message to the list, send your e-mail to < > emc-p...@ieee.org> > > All emc-pstc postings are archived and searchable on the web at: > http://www.ieee-pses.org/emc-pstc.html > > Attachments are not permitted but the IEEE PSES Online Communities site at > http://product-compliance.oc.ieee.org/ can be used for graphics (in > well-used formats), large files, etc. > > Website: http://www.ieee-pses.org/ > Instructions: http://www.ieee-pses.org/list.html (including how to > unsubscribe) > List rules: http://www.ieee-pses.org/listrules.html > > For help, send mail to the list administrators: > Scott Douglas <sdoug...@ieee.org> > Mike Cantwell <mcantw...@ieee.org> > > For policy questions, send mail to: > Jim Bacher: <j.bac...@ieee.org> > David Heald: <dhe...@gmail.com> > - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <sdoug...@ieee.org> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
