June 10, 2021 | Feature Article

Unannounced audits delayed by pandemic

Deadline extended to October 2021

OSHA has delayed implementation of its requirement that Nationally Recognized Testing Laboratories conduct unannounced surveillance audits.

Prior to the COVID-19 outbreak in early 2020, the U.S. Occupational Safety and Health Administration (OSHA) announced that all Nationally Recognized Testing Laboratories (NRTLs), such as FM Approvals, were to begin to perform unannounced surveillance audits by October 2020. FM Approvals has traditionally worked with its customers to schedule audits for courtesy and logistical reasons.

However, by mid-May of 2020, OSHA issued a temporary revision to its new policy, allowing remote audits to be used in lieu of in-person surveillance inspections. While the agency has not communicated when the remote audits will no longer be accepted, it has extended the deadline for implementing the latest revision of the NRTL Directive to October 1, 2021. This directive includes the requirement for in-person unannounced surveillance audits.

"Obviously, the plan to require unannounced audits was initiated by OSHA prior to the pandemic," notes Bob Lovell, FM Approvals vice president of auditing and quality assurance. "We plan to comply with the OSHA directive, although we would like to see an additional extension, at least until January of 2022 because we believe it would be easier for everyone to start this at the beginning of the year."

According to Lovell, the shift to unannounced audits only impacts those customers whose products are within the OSHA scope of accreditation. This includes, for example, some electrical equipment, automatic sprinkler systems, fixed fire suppression systems, smoke and fire detection systems. A complete list of impacted products can be found at this link.

"Companies are still reluctant to allow visitors within their facilities," Lovell says. "Most of our customers have embraced remote auditing and remote product sampling. We expect that to continue for now. OSHA is referring to this as a temporary allowance of remote auditing so we expect them to revert back to the requirement for in-person audits."

FM Approvals will continue to maintain close contact with impacted manufacturers and will notify those manufacturers by email or letter when a final start date is determined for the introduction of unannounced audits.