Just yesterday we had an MCAA webinar with advocacy experts from the Goddard Institute for Public Affairs. Last year, Teresa Sebring and I had a one day workshop with them to see if we could learn how to navigate the political landscape or at least how to frame an issue so that we might be able to represent the MCAA position when necessary. As an example of an industry public policy issue, we used with them the problems that our members encounter in getting products approved through the Nationally Recognized Testing Laboratory (NRTL) system run by OSHA. For years we have expressed our concerns that there are too many standards (not all recognized by ANSI or IEC); that there is no reciprocal recognition among NRTL organizations of test data provided by other NRTLs; that users, insurers, local jurisdictions (sometimes our own salespeople) don’t understand the NRTL program so they think they need to look for a specific mark; and that post-certification audits are too frequent and not always focused on the manufacturing process. I thought, just last year, that unless we engaged some very heavy hitters to ally with our positions, the situation with the NRTL system would be unlikely to change during my tenure with MCAA. Lo! and Behold! A heavy hitter weighed in. OSHA.
In October, OSHA has scheduled a Stakeholder’s Meeting to discuss a number of proposals that they have made to change (hopefully improve) the NRTL system. Among other things they have proposed bifurcating the testing process from the certification process, requiring that certifying NRTLs accept the test data from testing NRTLs, a universal NRTL conformity mark, risk-based audit frequency and standardization of the audit process. MCAA’s Chairman, Todd Lucey, will make a presentation of MCAA’s position on the OSHA proposals at the October 22 meeting and 4 others (including me) will participate in the meeting to hear what others affected by the NRTL program think about the OSHA proposals.
Its still a long shot that the product approval process might become easier (don’t expect less expensive but if time and effort translates into money for you, then it could actually become less expensive too!). If nothing else, we will have a very clear picture of who our allies and opponents are and what the sticking points are. It won’t be a quick process, not an easy process. But it appears that OSHA itself shares with MCAA some ideas about how to make the process better. Stay tuned for more information after the Stakeholders Meeting!