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Steve Rogers
Published: Friday, February 20, 2009 - 11:58
Today’s manufacturers must develop products quickly and inexpensively to meet the demands of a competitive marketplace. Rigorous testing to meet North American product certification requirements may prove to be a time-intensive process. If not properly planned, third-party approvals can inadvertently delay product launch plans and increase overhead costs.
In one common example, a third-party testing lab finds a problem with a product, and must ship the faulty item back to the manufacturer for review and modification. Once corrected, the manufacturer ships the product to the lab again for additional testing. If another issue is found, the product returns to the manufacturer for yet another round of review and changes. This process continues until the lab approves a product that meets quality standards. With a certified in-house lab, the development team can bypass this back-and-forth process and make product adjustments accordingly and without delays.
To save weeks or even months in the product’s launch plans, manufacturers have the option of having their in-house testing labs certified by a nationally recognized testing laboratory (NRTL). With a qualified lab onsite, manufacturers can perform product testing in tandem with product development. There are many benefits to this strategy, including improved economies of scale, quick identification of product flaws, and quicker lead time to market with modified or new products.
Currently, there are more than a dozen third-party approval bodies in North America that follow the standards defined by the Occupational Safety and Health Administration (OSHA). Annually, OSHA evaluates NRTLs and approves those that continue to uphold national quality standards. NRTLs endorse the quality and consistency of a product’s performance, ensuring the buyer a reliable purchase for his or her company.
Through the NRTL certification, manufacturers can establish a certified in-house lab so long as it follows OSHA-approved quality testing procedures. Some NRTLs, such as CSA International and Underwriters Laboratories (UL), allow manufacturers to self-certify their in-house testing labs. If your product accepts those marks, then it makes sense to consider a lab certification.
To decide, manufacturers should perform some due diligence to evaluate their specific needs and the benefits of self-certification. Costs, turn-around time, and effect on employees should all be considered in the decision.
If it’s worth investigation, the manufacturer should also have a formal discussion with the NRTL to further define the program’s pros and cons. Lab certification involves numerous requirements, ranging from specific documentation to the physical environment. Outlining those requirements with the NRTL may help the business further establish the costs, time investment, and resources involved with self-certification.
This investigative phase may be eye-opening for some. At first glance, some companies may believe self-certification to be a costly investment with little monetary return. After thoroughly reviewing previous third-party lab tests, however, manufacturers may learn that some programs have incurred an inordinate amount of lab time and agency fees. Bringing the testing process in-house may eventually prove a valuable investment for the manufacturer’s future.
If you decide to move forward with the lab certification process, the following requirements for your in-house laboratory may need to be documented by the NRTL:
Altogether, these six areas assure the NRTL that you have the capability in place to properly support testing on its behalf. The process to reach that final self-certification point is intensive. If you keep the following tips in mind, you will be on the path to bringing the product certification process in-house.
NRTLs look closely at the manufacturer’s quality system to ensure consistency in procedures and processes. There are two excellent ways to immediately prove your quality system can meet the NRTL’s rigorous requirements:
ISO 9001 or similar quality management system (QMS) standards incorporate a quality system for product development and testing. As a framework, QMS standards prove consistency and repeatability in a company’s quality test results. In the applications, companies should highlight their ISO-registered quality management systems.
The quality team of the control division of Parker Fluid, a manufacturer of motion and control technologies and systems, initiates ongoing calibration procedures as part of their ISO 9001 registration. Because the quality team already directs the in-house lab to follow ISO 9001 procedures, the company is effectively adhering to the NRTL’s requirements.
NRTLs have strict guidelines about the quality of testing equipment. During onsite audits, they scrutinize the equipment’s condition, age, and suitability for product testing. In doing so, the NRTL’s project engineer can confirm that the equipment has been calibrated to produce quality results.
In the manufacturing world, not all facilities can afford to purchase or upgrade thousands of dollars in test equipment each year. NRTLs understand this and therefore focus their attention on the equipment’s maintenance and calibration records. These documents help support the company’s claim that the equipment can provide repeatable and accurate test data for quality test purposes.
When deciding to self-certify, it’s recommended to compile and review all test equipment records. While sifting through this information, identify any inconsistencies in the test data and work with your quality team to sort through the issues. Then, organize these records into a single file to further simplify the certification process for you and the NRTL. This strategy also helps avoid last-minute document searches.
NRTLs take a close look at the testing lab’s environment and make sure it doesn’t resemble a drafty garage. Overall, the parameters for a top-quality lab include physical building requirements and energy resources. Such a focus on the environment can ensure that the lab provides consistent and accurate test results. Examples of environmental parameters include calibrated temperature and humidity gauges and controls on power and pressure sources to ensure consistent levels are maintained during testing.
Out of all the certification requirements, the product testing team can make the difference in obtaining a pass or fail grade by the NRTL. It’s important to select the design engineers and lab technicians who best understand testing requirements and the equipment’s capabilities.
Ultimately, the responsibility for certification doesn’t rest with a single person but collaboratively with the design engineers and the lab team. NRTL representatives often ask individuals to test products against certain criteria and will note whether that person has done so accurately. If a team member doesn’t understand a product’s testing criteria, he or she can jeopardize the entire certification process. Overall, when selecting your team, consider each member’s expertise and ability to communicate effectively with outside agencies.
A critical team member is the NRTL liaison, the primary team representative who acts as a go-between for the company and the agency. Although the liaison may be the program’s designated administrator, his or her role encompasses far more. Typically, the liaison is an engineer who can handle technical questions about the product, its performance, characteristics, and other criteria.
During the certification process, the NRTL liaison must also demonstrate communication and organizational skills. This will ensure the agency that the company can maintain agency documentation and record-keeping requirements.
Once you have established agreements with the agency as a certified lab, you will receive your first audit. This visit allows the NRTL to establish the in-house lab’s capabilities that were outlined in the agreements. This visit should be considered a mini ISO 9001 audit of the product development phase, and product tests must be performed as part of this evaluation. By doing so, the NRTL will be assured that you, as the manufacturer, meet the design and performance standards.
In audits, the NRTL engineer initially identifies and then evaluates the standard by which the product is being tested. Significant to this process are the standards that define the product’s most critical performance characteristics. For example, products from Parker Fluid’s control division comply with electrically-operated valve standards UL 429 and CSA C22.2 No. 139.
Next, the NRTL engineer may interview your lab’s testing personnel to make sure the team understands the intent of the standards. Each team member may need to explain the company’s testing process, its construction and performance standards, as well as the capabilities of the testing equipment. Essentially, the NRTL wants to know that all gray areas have been considered and that no standard has been left open to interpretation.
Finally, the NRTL engineer checks the equipment and testing environment, as well as the calibration parameters. The goal is to make sure that your equipment can produce the most optimal results for repeatable and consistent testing. In effect, this part of the audit process evaluates the quality of your equipment.
Once a lab is certified, the NRTL engineer may visit before and after product testing but it’s important to recognize that the contact may choose to witness the actual testing as well. At this point, the third-party approval body may choose to return for a scheduled or unscheduled (surprise) audit to ensure that any and all changes have been properly documented and recorded. For example, UL has field inspectors in its follow-up services group that conduct surprise audits based on existing files. As part of its client test-data program, the agency’s project engineer can decide to have a planned audit for a testing project currently in the development process. A UL project engineer usually conducts this latter audit semiannually.
During the certification and testing process, the NRTL liaison is responsible for generating and receiving documentation. He or she takes descriptive notes of all product modifications and outcomes of follow-up tests. If an issue arises, the liaison must have a simple and accessible filing system from which to draw. An electronic filing system provides uncomplicated transmission, filing, and access; however, it’s still recommended to print key electronic documents and place them in a manual filing system. Having such a system allows the team to continually review the project’s milestones and spot missing requirements.
Additionally, the liaison should become familiar with the forms and documents the agency uses to more easily confer with the NRTL contact. Knowing the layout of the agency’s documents also increases credibility with the agency contact. It’s quite possible that if you do not know the agency’s documentation inside and out, your certification process may be placed under a microscope.
The end result of the entire certification and product evaluation process may be a group of notebooks that represent the “design fingerprint.” This is a descriptive and historical record of the product’s design changes and is an excellent resource to keep track of product adjustments and certification procedures for both the company and the NRTL.
The following are some tips to keep in mind as you begin the testing lab certification process:
Preparation is key. Prepare in advance to avoid wasting the NRTL’s time and your own. Have your questions, objectives and goals at hand.
Clean house first. In audits, first impressions do matter. Keep the lab clean and accessible. Remove clutter from the floor, tables, and machinery.
Keep maintenance and calibration records. Maintenance and calibration records prove that your equipment can provide repeatable and accurate test data for quality tests.
Know the NRTL documents inside and out. The agency’s documents are now your documents. Becoming fluent in the paperwork will simplify the process for everyone.
Maintain electronic record keeping. Stay on track by filing your documents and correspondence electronically.
Consider the agency your partner. Be prepared to guide and work closely with the agency engineer in your product or industry.
Take advantage of your ISO 9001 procedures. If you are ISO 9001-registered, use those rigorous standards to aid in your lab certification.
Be patient with the process. You cannot rush the lab certification process. Work with your agency engineer to complete the task.
The manufacturing industry requires businesses to develop products quickly and inexpensively to keep pace with the competitive arena. By building, evaluating, and testing products in-house, manufacturers can meet customers’ performance and construction specifications while maintaining the quality standards of a nationally recognized testing laboratory.
Quality Digest does not charge readers for its content. We believe that industry news is important for you to do your job, and Quality Digest supports businesses of all types. However, someone has to pay for this content. And that’s where advertising comes in. Most people consider ads a nuisance, but they do serve a useful function besides allowing media companies to stay afloat. They keep you aware of new products and services relevant to your industry. All ads in Quality Digest apply directly to products and services that most of our readers need. You won’t see automobile or health supplement ads. So please consider turning off your ad blocker for our site. Thanks, Steve RogersIn-House Lab Certification
How to have your testing lab certified by a nationally recognized testing laboratory
The decision to self certify
Keep your quality system in check
Evaluate and update your testing equipment
Consider the lab’s environment
Choose a quality team
Prepare for the auditing process
Organize your records
Final tips for testing lab self certification
Lab certification for today’s market
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Steve Rogers
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