MCAA tells OSHA what to do

  • December 15, 2014
  • News

December 15, 2014 - On October 22, 2014, representatives of MCAA, along with some 100 attendees from 50 organizations, attended the Occupational Safety and Health Administration’s (OSHA) Stakeholder Meeting at the Department of Labor in Washington, DC. The meeting had been proposed in May 2014 to discuss questions and options for changes to OSHA’s Nationally Recognized Testing Laboratory (NRTL) program. Presenters from 10 organizations, including MCAA’s chairman Todd Lucey of Endress + Hauser, gave their reactions to the OSHA proposals and interacted with audience attendees on ways to improve the program. MCAA’s comments repeatedly stressed safety and how the current system sometimes pushes customers to make less safe choices. OSHA heard that it should adopt a plan to use private sector accreditors to perform application reviews and on-site assessments of NRTLs. While MCAA offered no opinion about the use of independent accreditors, the Association did comment specifically about a proposal to separate the testing and certification functions; this change would likely require a Rulemaking activity, which is a long and complex process. MCAA suggested that this should require eliminating use of proprietary standards and coalescing around ANSI or IEC standards and requiring that NRTL-approved certifying bodies accept the test data from NRTL-approved test laboratories. With regard to Certification Marks, MCAA believes that the difficulty lies in the customer perception of what mark they need to look for and that a single NRTL-approval mark might eliminate the confusion. For hazardous location products, a mark indicating conformity to IECEx would go a long way towards eliminating confusion. OSHA has already indicated its intention to accept IECEx testing and certification protocols. OSHA is considering allowing NRTLs to adopt risk-based approaches to the determination of the frequency of factory inspections. There is general support for this proposal provided it includes a floor and guidelines. Most of the current proposals for changes to the NRTL program focus on existing policies and would not address the more systemic changes MCAA sees as necessary but those would likely require regulatory changes. Therefore MCAA believes our best efforts are in providing support and encouraging the rule change process. MCAA exists to help the management teams of process and factory automation product and solution providers run and grow successful businesses by offering timely, unique and highly specialized resources acquired from shared management benchmarks where proprietary company information is secure—including speaking on behalf of the industry on issues of specific concern, such as the product approval process managed by OSHA.

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