MCAA’s Chairman Todd Lucey (Endress + Hauser) was the voice for the industry this past week when he and 4 others from the Association attended the OSHA Stakeholder’s Meeting in Washington, DC where over 100 stakeholders talked about the product approval process. He represented our membership more than ably and presented our positions on possible changes–some that could substantially improve the current testing and certification system–in a cogent and reasoned manner with plenty of real-life examples that took away any notion of self-serving justifications. If you want an overview of the meeting (from my perspective of course), just follow this link or click into General Information/Product Approval Process.

It was hard to explain what this Stakeholder’s Meeting was all about and why MCAA was part of it. For the most part we did feel a little like outsiders–at least until representatives of GAMBICA, ZVEI and Orgalime made their presentations. They represent companies in Europe (GAMBICA in the UK, ZVEI in Germany and Orgalime in Europe) which are much like ours who try to sell into the US market and come up against the US NRTL regulations which are very different from the rest of the world! So we did have some friends in the room. Not that anyone was antagonistic toward our positions–they largely ignored them by focusing on the internal operations of the NRTL program (OSHA-to-NRTL) rather than the external operations (NRTL-Manufacturer).

One of the most important proposals that OSHA did put forward in advance of this meeting was the notion of separating the testing and the certification functions. We support this proposal because we think it will move us toward the goal of requiring Certifiers to accept the test data and results from Test Labs (similar to the CB Scheme in Europe). In fact, the changes that OSHA is planning to submit for comment next spring deal with bringing our current program into conformity with ISO/IEC 17025 and 17065 for the accreditation of test labs and certification bodies. By and large, the NRTLs and accreditation bodies in attendance endorsed the adoption of such a scheme. Ultimately, OSHA will likely have to get regulatory authority to require certifiers to accept test data and results. That certainly will be MCAA’s objective.

It was very important that MCAA made itself heard this past week and now we believe we will have a permanent seat at the table as these issues which have such an important time and monetary impact on our business are discussed and the reformation of the NRTL program takes place over the next several years. They say it could be 4-5 years–I’m retiring in 3.5 so we have to get a move on!