On Oct. 1, 2019, the U.S. Occupational Safety and Health Administration (OSHA) released a new directive (CPL-01-00-004) covering policies, procedures and interpretations for Nationally Recognized Testing Laboratories (NRTLs), such as FM Approvals. One of the most notable changes is the requirement for NRTLs to perform surveillance audits “without advance warning or notice to the manufacturer.”
The new requirement for unannounced audits is detailed in Annex B, which specifies Certification Minimum Performance Policies. The new requirement for unannounced surveillance visits can be found in section 7.9, subsection E.
“As an NRTL, we are subject to OSHA directives with respect to FM Approved products that fall under the OSHA purview, such as some electrical equipment, automatic sprinkler systems, fixed fire suppression systems, smoke and fire detection systems, and fire doors,” notes Bob Lovell, FM Approvals vice president of auditing and quality assurance.
He adds, “Until now, we have worked with our customers to schedule audits for courtesy and logistical reasons. The OSHA requirement for unannounced audits is supposed to take effect on Oct. 1 of this year; however, we are asking them to extend the deadline to Jan. 1, 2021. We believe it will be easier for everyone to start this new program at the beginning of the year. We will notify our customers who are affected by this, by letter this fall when we know the start date and other program details.” It is the intention of FM Approvals to perform unannounced audits only for products that are within the OSHA scope of accreditation.
FM Approvals conducts thousands of product and quality audits throughout the world to validate the production of FM Approved products. These products can be manufactured for the North America market, the European market (ATEX Directive, the Construction Products Regulation and International Schemes) and other regions.
FM Approvals auditors work in partnership with each manufacturing location to independently examine the manufacturing, inspection and test procedures, processes, systems and records that have been established by the manufacturer to ensure that the FM Approved product conforms to specified requirements. The auditor provides an independent perspective that can help identify opportunities to enhance existing activities, improve system efficiency and effectiveness, and optimize a location’s ability to demonstrate the conformity of the manufactured products.
A complete list of FM Approvals standards that fall under OSHA’s NRTL Program may be found at this link.