The NRTL determined that the product met the requirements of an appropriate consensus-based product safety standard either by successfully testing the product itself, or by verifying that a contract laboratory has done so; and
The NRTL has certified that the product met the requirements of the product safety standard
The manufacturer can indicate that the NRTL has certified the product and that the product has met specified product safety standards by placing the NRTL's certification mark on the manufactured product
Following the product certification, the NRTL monitors the manufacturer, the product, the marketplace, and the use of the NRTL's certification mark
Many product "approval" requirements are found in OSHA's standards (29 CFR Parts 1910, 1915, 1918, and 1926). Approval, i.e., NRTL testing and certification, is required for many types of products, including
Electrical equipment
Fire detecting and extinguishing equipment
Liquefied Petroleum Gas (LPG) utilization equipment
When first adopted, OSHA regulations gave two examples of approval organizations: Underwriters Laboratories (UL) and Factory Mutual Research Corporation (FMRC)
In 1983, OSHA was ordered by a court to remove the specific references to UL and FMRC in a successful lawsuit brought by a private lab
In 1988, OSHA revised its regulations to remove the references, and established the NRTL Program to recognize other organizations as NRTLs
Any testing organization may apply for NRTL Program recognition
- May be US-based or otherwise
- May be owned by a US or foreign organization, but if foreign, the US Trade Representative must make a determination about equal treatment by the foreign country
- Must meet OSHA's criteria for recognition
An applicant must have the capability to be both a testing laboratory and certifying body
An organization must meet 4 basic criteria to be recognized: a) The capability (including proper testing equipment and facilities, trained staff, written testing procedures, and calibration and quality control programs) to perform testing for each item to be certified b) Adequate controls for
Identifying the items it certifies
Conducting follow-up inspections of the actual production of items to evaluate conformance with test standards
Conducting field inspections to assure proper use of its marks or labels c) Complete independence from employers (i.e., users), manufacturers, and vendors of the items it tests and certifies (generally interpreted as not owned or controlled by) d) Effective procedures for producing its findings and reports, and for handling complaints and disputes
Specific scope for each recognition includes
- Specific product safety standards (e.g., ANSI/UL 1313 - Nonmetallic Safety Cans for Petroleum Products)
- Specific locations (geographical facilities)
- Specific programs (e.g., will do own testing; will accept witnessed testing data; etc.)
Expansion requests may involve any of the 3 areas of scope
Continuation after initial 5-year recognition period requires application for renewal
State Plans have the option of establishing their own program for recognizing testing laboratories
Any such program
- Must accept product certification by OSHA-recognized NRTLs where State safety requirements are the same as the Federal
-Applies only within that State
-Must be at least as effective as the Federal program