ABSTRACT - 1 
                        
       U.S. DEPARTMENT OF LABOR                  Occupational Safety and Health Administration  
DIRECTIVE  NUMBER:  CPL 1 -00.XXX  EFFECTIVE DATE: TBD  
SUBJECT:   NRTL Program Policies, Procedures, and Guidelines   
 
ABSTRACT  
 
Purpose:  This Directive  sets forth policies, procedures and interpretations  that 
supplement and clarify the Nationally Recognized Testing Laboratory 
(NRTL) Program reg ulation, 29 CFR 1910.7 and Appendix A to that 
section.  
 Scope:  All OSHA offices engaged in or supporting the operations of the OSHA 
NRTL Program.  
 
Ref er ences:  29 CFR 1910.7; Federal Register notices 53 FR 12102 (4/12/1988), 65 FR 
46798 (7/31/2000), 76 FR 10500 (2/25/2011); and OSHA Directive  CSP-
01-01-022 (formerly STP 2-1.147A) – Safety Testing or Certification of 
Certain Workplace Equipment and Materials, 8/7/ 1989.  
 Cancella tions:  OSHA Directive  CPL 01-00-003, NRTL Program Policies, Procedures 
and Guidelines ( 12/2/1999); Application Guidelines for the OSHA NRTL 
Program, (10/1/2000)  and; all policies, procedures and interpretations 
contained in Federal Register notices 60 FR 1 2980 (3/9/199 5), and 74 FR 
923 (1/9/2009)  are hereby rescinded.  
 
Regional and  
State Impact : Regional Administrators (RAs) and Area Directors (ADs) will ensure that 
this Instruction is forwarded to appropriate administrative and compliance 
staff to review for changes pertinent to their areas of responsibility.  RAs will also ensure that this Instr uction is forwarded to each State Designee.  
As detailed in CSP 01-01-022 (formerly STP 2 -1.147A ), State Plan States 
are encouraged to adopt standards that rely on Nationally Recognized Testing Laboratories recognized by Federal OSHA, but State Plan States  
 
ABSTRACT - 2 
 choosing to establish their own program for recognizing testing 
laboratories may do so as long as they:  
 
A. Accept certifications of NRTLs recognized by OSHA for testing of 
equipment and materials where State safety requirements are the same 
as the Federal.  
B. Ensure that organizations receiving State recognition understand that it 
applies only within that State.  
C. Establish a program which is at least as effective as the OSHA NRTL 
Program.  
 
Action Office s :  National, Regional and Area Offices, OSHA Training Institute, and State 
Plan States  
 Originating Office:  Office of Technical Programs and Coordination Activities  
 
Contact: Director, Office of Technical Programs and Coordination Activities  
 N3655, Frances Perkins Building 
 200 Constitution Avenue NW  
 Washin gton, DC 20210 
 
 Phone:   (202) 693-2110 
 Fax:  (202) 693-1644 
 
By and Under the Authority of  
 
 
 
 
David Michaels, PhD, MPH  
Assistant Secretary    
ABSTRACT - 3 
 Executive Summary  
 
This Directive  provides policies, procedures and instructions that supplement and clarify the 
NRTL Program regulation, 29 CFR 1910.7 and Appendix A to that Section . 
 
Significant Changes  
 
In this Directive, OSHA has revised its existing policies regarding compliance with meeting the  
criteria in the NRTL Program regulation, 29 CFR 1910.7, for recognition as an NRTL.  Under 
the revised policy, OSHA deems compliance with ISO/IEC 17025: 2005, General R equirements 
for the C ompetence of T esting and C alibration Laboratories ISO/IEC 17065:2012, Conformity 
Assessment – Requirement for B odies C ertifying Products, P rocesses and Services , and the 
Testing and Certification P olicies in this Directive , as compliance with the requirements for 
recognition under the NRTL Program regulation.  This revis ion impacts several OSHA policies 
and creates several new policies.  Significant revisions include:  
 
1. A revision to OSHA’s policy on how NRTLs can comply with the requirement in the 
NRTL Program regulation that NRTLs be “completely independent” of employers  
subject to the tested equipment requirements and of any manufacturers or vendors of 
equipment or materials being tested for these purposes, 29 CFR 1910.7(b)(3) .  The 
revised policy focuse s on the NRTL’s ability to effectively identify, eliminate and contr ol 
any risk to its impartiality.  
 
2. A revision to OSHA’s policies and procedures on supplemental programs and the 
Satellite Notification and Acceptance Program (SNAP).   OSHA no longer refers to 
procedures and criteria for specific programs as “supplemental p rograms” and no longer 
includes them within an NRTL’s scope of recognition.  OSHA has also eliminated 
SNAP.   Under the revised policy, NRTLs may apply to make existing  SNAP sites 
recognized sites . 
 
3. OSHA has included new procedures for the acceptance of ins pections and test data from 
organizations that function as part of the IECEx Certified Equipment Scheme (IECEx 
Scheme).  
 
4. A revised definition for the term “recognized site”.  Under this new definition, sites that were form erly “SNAP sites” may become recog nized sites .  OSHA’s revised definition 
provides that, to be recognized, a site must be administratively and operationally controlled by the NRTL and must perform testing and inspection (and/or accept test data or inspections), perform reviews, and make ce rtification decisions with the NRTL  
ABSTRACT - 4 
 management system.  As such, OSHA eliminated ownership requirements contained in 
the prior definition. 
 
5. A revision to OSHA’s policy on calibration to include new policies for external and internal calibration laboratorie s used by NRTLs or applicants.  
   
i  
Table of Contents  
Chapter 1 – Introduction  ............................................................................................................................ 1 
I. Purpose  .............................................................................................................................................. 1 
II. Organization of Directive .................................................................................................................. 1 
III. Scope  ................................................................................................................................................. 2 
IV. References  ......................................................................................................................................... 2 
V. Cancellations  ..................................................................................................................................... 2 
VI. Responsibility  ................................................................................................................................... 2 
A. Director of the Office of Technical Programs and Coordination Activitie s (OTPCA)  ................... 3 
B. Director of the Directorate of Technical Support and Emergency Management (DTSEM) ……. 3 
C. Office of the Solicitor (SOL) ................................ .............................................................................................. 3 
D. Assistant Secretar y (AS)  ................................ ................................ ................................ ................................ ...... 3 
VII. Action Offices  ................................................................................................................................... 3 
A. Responsible Offices  ............................................................................................................................................... 3 
B. Action Offices  ......................................................................................................................................................... 3 
C. Information Offices.  .............................................................................................................................................. 4 
VIII.     Federal Program Change.  ............................................................................................................... 4 
IX. Significant Changes.  ......................................................................................................................... 4 
Chapter 2 – NRTL Program Administrative Procedures  ....................................................................... 6 
Summary of the NRTL Program Regulation, 29 CFR 1910.7.  ................................................................. 6 
Confidentiality  .......................................................................................................................................... 7 
Complaints  ................................................................................................................................................ 7 
Supplemental Procedures for Processing Applications for Initial Recognition  ........................................ 9 
Supplemental Procedures for Applicants Located Outside the United States  ........................................ 12 
Supplemental Procedures for Review of Application and Supporti ng Documentation .......................... 12 
Supplemental Procedures for Review of Test Standards  ....................................................................... 15 
Supplemental Procedures for On- site Assessment  .................................................................................. 18 
Supplemental Procedures for Report of Findings  ................................................................................... 20 
Supplemental Procedures for Making Positive or Negative Finding s  ................................................... 21 
Supplemental Procedures for Preliminary F indings and Final Decisions by the Asst . Secretary.  .......... 23 
Post-Recognition Assessments/Monitoring Visits  .................................................................................. 24 
Supplemental Procedures for Post -Recognition Assessments/Monitoring Visits  ................................. 25  
ii Supplemental Procedures for Processing Applications for Expansion of Scope of Recognition  ........... 25 
Supplemental Procedures for Processing Applications for Renewal of Recognition  ............................. 27 
Revocation of Recognition  ..................................................................................................................... 29 
Voluntary Termination of Recognition  ................................................................................................... 30 
Annex A – Testing Minimum Performance Policies  ............................................................................ A-1 
4. Management Requirements ........................................................................................................... A-1 
4.1 Organization  ................................ ................................ ................................................................................. A-12 
4.2   Management system  ................................ ................................ ................................ ................................ ..........  A-2 
4.3   Document control  ............................................................................................................................................... A-2 
4.4   Review of requests, tenders and contracts ................................ .................................................................. A-2 
4.5   Subcontracting of tests and calibrations ...................................................................................................... A-2 
4.6   Purchasing services and supplies  ................................ ................................ .................................................. A-3 
4.7   Service to the customer  .................................................................................................................................... A-3 
4.8   Complaints  ........................................................................................................................................................... A-4 
4.9   Control of nonconforming testing and/or calibration work  ................................ ................................ .. A-4 
4.10  Improvem ent ................................ ................................ ................................ ................................ ...................... A-4 
4.11  Corrective action  ............................................................................................................................................... A-4 
4.12  Preventive action  ............................................................................................................................................... A-4 
4.13  Control of records  ................................ ............................................................................................................. A-4 
4.14  Internal audits  ..................................................................................................................................................... A-4 
4.15  Management reviews  ................................ ....................................................................................................... A-4 
5. Technical Requirements  ................................................................................................................ A-4 
5.1   General  ................................................................................................................................................................ .. A-4 
5.2   Personnel  ................................ ............................................................................................................................... A-4 
5.3   Accommodation and environmental conditions  ....................................................................................... A-5 
5.4   Test and calibration methods and method validation ............................................................................. A-5 
5.5   Equipment  ................................ ................................ ................................ ................................ ............................ A-7 
5.6   Measurement traceability  ................................................................................................................................ A-8 
5.7   Sampling  ................................ ................................ ................................ ................................ ............................... A-8 
5.8   Handling of test and calibration items  ................................ ................................ ................................ ......... A-8 
5.9   Assuring the quality of test and calibration results  ................................ ................................ ..................  A-8 
5.10   Repor ting the results  ....................................................................................................................................... A-8 
Annex B – Certification Minimum Performance Policies  ................................................................... B-1  
iii 4. General Requirements  ................................................................................................................... B-1 
4.1   Legal and contractual policies  ................................ ................................ ................................................ B-1 
4.2   Management of impartiality  ............................................................................................................................ B-2 
4.3 Liability  and financing  .................................................................................................................................  B-3 
4.4 Non-discriminatory conditions  ................................ ................................ ................................................. B-3 
4.5 Confidentiality  ................................ ................................................................................................................  B-3 
4.6 Publicly available information  ................................ ................................ .................................................. B-3 
5. Structural Requirements  ................................................................................................................ B-3 
5.1 Organizational structure and top managemen t .....................................................................................  B-3 
5.2 Mechanisms for safeguarding impartiality  ................................ ............................................................ B-3 
6. Resource Requirements ................................................................................................................. B-3 
6.1   Certification body personnel  ................................ .......................................................................................... B-3 
6.2   Resources for evaluation ................................ ................................ ................................ ................................ .. B-4 
7. Process Requirements  ................................................................................................................... B-4 
7.1 General  ................................ ..............................................................................................................................  B-4 
7.2  Application  ................................ ................................ ................................ ................................ ............................ B-4 
7.3 Application review  ................................ ........................................................................................................ B-5 
7.4 Evaluation  ................................ ........................................................................................................................ B-5 
7.5 Review  ................................ ........................................................................................................................... B-10 
7.6 Certification decision  ................................ ................................ ................................ ................................ B-10 
7.7   Certification documentation  ................................ ........................................................................................ B-10 
7.8   Directory of certified products  ................................ ................................ ................................ .................... B-11 
7.9   Surveillance ................................ ................................ ................................ ....................................................... B-11 
7.10   Changes affecting certification  ................................ ................................ ................................................. B-14 
7.11  Termination, reduction, suspension or withdrawal of cer tification  ................................ ............... B-14 
7.12  Records  ..........................................................................................................................................................  B-14 
7.13  Complaints and appeals  ................................ ................................ ................................ ............................... B-14 
8. Management System Policies  ..................................................................................................... B-14 
8.1  Options  ................................................................................................................................................................ . B-14 
8.2 General management system documentation (Option A)  .............................................................. B-14 
8.3   Control of documents (Option A)  ................................ ................................ .............................................. B-14 
8.4   Control of records (Option A)  ................................ .....................................................................................  B-14 
8.5  Management review (Option A)  ................................ .................................................................................. B-14  
iv 8.6 Internal audits (Option A)  ................................ ................................ ................................ ............................... B-15 
8.7   Corrective actions (Option A)  ................................ .....................................................................................  B-15 
8.8 Preventive Actions (Option A)  ................................ ...................................................................................... B-15 
Annex C – Terms and Definitions  ......................................................................................................... C-1 
 
Anne x D- NRTL Forms  .............................................................................................................. Annex D -1 
NRTL Initial Application, Expansion and/or Scope Reduction Request  .................................. Annex D -2 
NRTL Initial Application an d Expansion Test Standard Worksheet  ...................................... Annex D -10 
Request for Renewal/NRTL Certification of Continued Compliance  .................................... Annex D -22 
Annex E – NRTL Program Fees  ............................................................................................................ E-1 
   
 
 
1 Chapter 1 – Introduction  
 
I. Purpose  
 
Many of OSHA’s safety standards for Construction and General Industry (e.g., 29 CFR 
1910, Subpart S) require that equipment and products be tested and certified to help ensure their safe use i n the workplace.  To implement these requirements, OSHA 
established the NRTL Program and the Agency generally requires NRTLs to perform this testing and certification.  
 This Directive  sets forth procedures and policies under which OSHA recognizes private 
organizations to perform product testing and certification required by OSHA standards .    
The guidelines s pecified within the Directive  are policies and procedures that 
supplement : (1) procedures addressing recognition of organizations under the OSHA 
NRTL P rogram in 29 CFR 1910.7 Appendix A; and (2) the general requirements found 
in ISO/IEC 17025:2005, General Requirements for the Competence of Testing and Calibration Laboratories, and ISO/IEC 17065:2012, Conformity Assessment – 
Requirements for Bodies Certi fying Products, Processes and Services.   
 
OSHA deems compliance with ISO/IEC 17025:2005 and ISO/IEC 17065:2012 and the 
testing and certification policies in this  Directive  as compliance with the requirements for 
recognition under NRTL Program regulation 29 CFR 1910.7.   
  
II. Organization of Directive  
 
• Chapter 1 of this Directive  (Introduction) describes general information about the 
NRTL P rogram and this Directive .   
• Chapter 2 describes NRTL Program administrative procedures, associated with the 
recognition of  organizations as NRTLs, which supplement the administrative 
procedures contained in Appendix A to the NRTL Program Regulations, 29 CFR 1910.7.   
• Annexes A and B describe NRTL P rogram  specific -testing and certification policies , 
which supplement  Clauses 4 and 5 of ISO/IEC 17025: 2005 and Clauses 4 thru 8 of 
ISO/IEC 17065: 2012.   
• Annex C presents terms and definitions.   
• Annex D presents NRTL program forms.  
• Annex E presents NRTL program fees.  
   
 
 
2 III. Scope  
 
This Directive  applies to all OSHA offices engaged  in or supporting the operations of the 
OSHA NRTL Program.  
 
IV. References  
 
• 29 CFR 1910.7 
• 53 FR 12102 (4/12/1988)  
• 65 FR 46798 (7/31/2000)  
• 76 FR 10500 (2/25/2011)   
• OSHA Directive  CSP 01 -01-022 (formerly STP 2 -1.147A) – Safety Testing or 
Certification of Certain Workpl ace Equipment and Materials, ( 8/7/1989)  
• ISO/IEC 17025:2005, General Requirements for the competence of testing and 
calibration laboratories  
• ISO/IEC 17065:2012, Conformity Assessment – Requirements for bodies 
certifying products, processes and services  
• ISO/ IEC 17000:2004, Conformity Assessment – Vocabulary and general 
principles  
 
V. Cancellations  
 OSHA Directive  CPL 01 -00-003, NRTL Program Policies, Procedures and Guidelines 
(12/2/1999) ; Application Guidelines for the OSHA NRTL Program, (10/1/2000); and all 
policies, procedures and interpretations contained in Federal Register notices 60 FR 
12980 (3/9/1995), and 74 FR 923 (1/9/2009)  are hereby rescinded.  
 
VI. Responsibility  
A. Director of the Office of Technical Programs and Coordination Activities (OTPCA)  
• Administers the NRTL Program under authority from the DTSEM Director.  
• Establishes and ensures compliance with policies and procedures for the NRTL 
Program; modifies or clarifies this Directive, as needed.  
• Ensures the performance of all activities necessary for process ing applications for 
NRTL recognition, including the preparation of Federal Register  (FR) notices 
required for activities under the NRTL Program. 
 
B. Director of Directorate of Technical Support and Emergency Management (DTSEM)  
• Oversees the administration of the OTPCA.  
• Reviews and approves policies and procedures for the NRTL Program.    
 
 
3 • Reviews and approves NRTL Program -related FR notices originated by OTPCA, 
following their approval by the Office of the Solicitor (SOL).  
 
C. Office of the Solicitor (SOL)  
• Reviews an d approves NRTL Program related FR notices originated by OTPCA, 
for legal issues and requirements.  
• Reviews and approves policies and procedures for the NRTL Program, including 
changes.  
• Provides legal advice on other regulatory or legal issues regarding the  NRTL 
Program.  
 
D. Assistant Secretary (AS)  
• Reviews and approves NRTL Program -related FR notices originated by OTPCA.  
• Approves letters of recognition or other formal notifications for organizations  
recognized by OSHA as Nationally Recognized Testing Laborator ies. 
• Makes final determinations on the approval or revocation of OSHA NRTL 
recognition. 
 
VII. Action Offices  
A. Responsible Offices  
Directorate of Technical Support and Emergency Management (DTSEM), Office of Technical Programs and Coordination Activities (OTPCA) . 
 
B. Action Offices  
1. OTPCA and DTSEM .  OTPCA administers the NRTL Program under authority 
from the DTSEM Director; establishes and ensures compliance with policies 
and procedures for the NRTL Program; modifies or clarifies this Directive, as 
needed; and ensure s the performance of all activities necessary for processing 
applications for NRTL recognition, including the preparation of Federal 
Register (FR) notices required for activities under the NRTL Program.  DTSEM 
oversees the administration of OTPCA and is therefore responsible for administering the NRTL Program on behalf of OSHA. This includes reviewing and approving policies and procedures for the NRTL Program, reviewing and 
approving all components of NRTL recognition applications, performing onsite 
visits in support of these applications, identifying non- conformances and 
providing recommendations to the Assistant Secretary ( AS) to approve NRTL 
applicants and to revoke approval of recognized NRTLs.  DTSEM also reviews FR Notices  related to the NRTL Program . 
   
 
 
4 2. SOL .  The Solicitor of Labor ( SOL ) reviews and approves NRTL Program -
related FR notices and Directives, originated by DTSEM , for legal issues and 
requirements.  SOL additionally provides legal advice on other regulatory or 
legal issues regarding the NRTL program.  
 
3. AS.  The Assistant Secretary for Occupational Safety and Health (AS) reviews 
and approves NRTL Program -related FR notices originated by DTSEM ; 
approves  letters of recognition or other formal applications for organizations 
recognized by OSHA as Nationally Recognized Testing Laboratories ; and 
makes final determinations on the approval or revocation of OSHA NRTL recognition . 
 
C. Information Offices . 
 National Office, Regional Offices, State Plan States, OSHA Training Institute.  
 
VIII. Federal Program Change . 
 
Action Required.  The responsible and the action offices will implement the policies, 
procedures and guidelines contained in this Instruction. 
 
Regional and State Impact  
 Regional Administrators (RAs) and Area Directors (ADs) will ensure that this Instruc tion 
is forwarded to appropriate administrative and compliance staff to review for changes pertinent to their areas of responsibility.  RAs will also ensure that this Instruction is 
forwarded to each State Designee.  As detailed in CSP 01 -01-022 (formerly STP 2 -
1.147A), State Plan States are encouraged to adopt standards that rely on Nationally 
Recognized Testing Laboratories recognized by Federal OSHA, but State Plan States choosing to establish their own program for recognizing testing laboratories may do so as 
long as they:  
 
A. Accept certifications of NRTLs recognized by OSHA for testing of equipment 
and materials where State safety requirements are the same as the Federal.  
B. Ensure that organizations receiving State recognition understand that it applies only within that State.  
C. Establish a program which is at least as effective as the OSHA NRTL Program.  
 
IX. Significant Changes . 
   
 
 
5 In this Directive, OSHA has revised its policies regarding compliance with meeting the 
criteria in the NRTL Program regulation, 29 CFR 1910.7, for recognition as an NRTL.  
Under the revised policy, OSHA deems compliance with ISO/IEC 17025:2005, General requirements for the competence of testing and calibration laboratories, ISO/IEC 17065:2012, Conformity Assessment – Requirements for bodi es certifying products, 
processes and services , and the testing and certification policies in this Directive as 
compliance with the requirements for recognition under the NRTL Program regulation.  This revision impacts several OSHA policies and creates sev eral new policies.  
Significant revisions include:  
 
1. A revision to OSHA’s policy on how NRTLs can comply with the r equirement 
in the NRTL Program r egulation that NRTLs be “completely independent of 
employers subject to the tested equipment requirements, and of any 
manufacturers or vendors of equipment or materials being tested for these 
purposes ” (29 CFR 1910.7(b)(3) ).  The revised policy focuse s on the NRTL’s 
ability to effectively identify, eliminate and control any risk to its impartiality.  
 
2. A revision t o OSHA’s policies and procedures on supplemental programs and 
the Satellite Notification and Acceptance Program (SNAP).  OSHA no longer refers to procedures and criteria for specific programs as “supplemental programs” and no longer includes them within an NRTL’s scope of recognition.  OSHA also eliminated SNAP.  Under the revised policy, NRTLs may apply to 
OSHA to make existing SNAP sites recognized sites .  
 
3. OSHA has developed new procedures for the acceptance of inspections and test data from organizations that function as part of the IECEx Certified Equipment 
Scheme (IECEx Scheme).  
 
4. A revised definition for the term “recognized site”.  Under this new definition, sites that were formally “SNAP sites” may become recognized sites.  OSHA’s 
revised  definition  provides that, to be recognized, a site must be administratively 
and operationally controlled by the NRTL and must perform testing and 
inspection (and/or accept test data or inspections), perform reviews, and make certification decisions with the NRTL man agement system.  As such, OSHA 
eliminated ownership requirements contained in the prior definition; and  
 
5. A revision to OSHA’s policy on calibration to include new policies for external and internal calibration laboratories used by NRTLs or applicants.  
    
 
 
6 Chapter 2 – NRTL Program Administrative Procedures  
 
A. Summary of the NRTL Program Regulation, 29 CFR 1910.7. 
 
The purpose of this Chapter of the Directive is to supplement the administrative 
procedures contained in Appendix A to the NRTL Program regulation, 29 CFR 1910.7 
(“Appendix A” or “App A”).  
 NRTLs are organizations that OSHA has recognized as qualified to perform independent 
(i.e. third- party) product safety testing and certification.  To be recognized as an NRTL, 
the organization must operate a product safety -testing program and a product -certification 
program meeting the requirement s in 29 CFR 1910.7.  A product -certification program, 
for purposes of OSHA requirements, consists of listing/labeling and factory surveillance programs.  
 
OSHA requires org anizations applying for NRTL recognition to provide, in their 
application, detailed and comprehensive written descriptions of  their programs, 
processes , and procedures.  When an organization makes an initial application to be 
recognized as an NRTL, OSHA reviews the written information contained in the organization’s application and conducts an on -site assessment to determine whether the 
organization meets the requirements of 29 CFR 1910.7.  OSHA uses a similar process when an NRTL applies for expansion or r enewal of its recognition, although the type and 
amount of information in some areas can differ significantly from those of initial applications.  
The burden is generally “on the applicant to establish by a preponderance of the evidence 
that it is entitled  to recognition as an NRTL” (App. A. Introduction).  Thus, in its 
application, an applicant must “provide sufficient information and detail demonstrating that it meets the requirements set forth in §1910.7, in order for an informed decision concerning reco gnition to be made” by the Assistant Secretary for Occupational Safety 
and Health (“Assistant Secretary”), and must also “identify the scope of the NRTL -
related activity for which the applicant wishes to be recognized” (i.e., the test standards the applicant will use for testing products) (App. A.I.A.2).  To meet its burden, the applicant may include any documentation (i.e. enclosures, attachments, or exhibits) it 
deems appropriate (App.A.I.A.2.c).  
 
OSHA accepts “ [a]pplications submitted by eligible testin g agencies ” and acknowledges 
their receipt in writing  (App. A.I.B.1.a).  In addition, “[a]fter receipt of an application, 
OSHA may request additional information if it believes that information relevant to the 
requirements for recognition has been omitted”  (Id).  OSHA “ conduct [s] an on- site   
 
 
7 review of the testing facilities of the applicant, ” as necessary, “ as well as the applicant’s 
administrative and technical practices, and, if necessary, review s any additional 
documentation underlying the application”  (App. A.I.B.1.b).  
 
Following review of the application, and any additional information and on- site review 
report , OSHA has two options .  On the one hand, if “ the applicant appears to have met 
the requirements for recognition,” responsible OSHA staff must ma ke a “positive 
finding” to the Assistant Secretary, which consists of “a written recommendation . . . that the application be approved, accompanied by a supporting explanation” (App. A.I.B.2).  
Once this recommendation is made, OSHA follows the procedures in the Appendix for 
making preliminary and final findings on the application (App. A.I.B.4, A.I.B.5, A.I.B.6) .   
 On the other hand, if “the applicant does not appear to have met the requirements for 
recognition,” responsible OSHA staff must make a “negati ve finding” to the “applicant in 
writing, listing the specific requirements of §1910.7 and [Appendix A] which the applicant has not met, and allow[ing] a reasonable period for response” (App. A.I.B.3.a).  
After the applicant receives the  notification of ne gative finding , the applicant may , within 
the response time provided in the notification, either (1) “[s]ubmit a revised application 
for further review, which could result in a positive finding” (the procedures for which are 
explained in the previous parag raph), or (2) “[r]equest that the original application be 
submitted to the Assistant Secretary with an attached statement of reasons, supplied by the applicant of why the application should be approved” (App. A.I.B.3.b.i).  In either 
case (i.e., if a posit ive finding is made on a revised application or if the applicant requests 
that the original application be submitted to the Assistant Secretary), OSHA would follow the procedures in the Appendix for making preliminary and final findings on the application (App., A.I.B.4, A.I.B.5, A.I.B.6) .  The “procedure for applicant notification 
and potential revision may only be used once during each recognition process” (App. A.I.B.3.b.ii).  
 
B. Confidentiality  
 
The name of an applicant seeking recognition becomes public information at the time OSHA publicly announces its preliminary finding on an application by publishing a n FR  
notice .  OSHA posts the application online at www.regulations.gov
 in the NRTL’s 
docket.  S upporting inf ormation submitted with, or in support of an application will 
remain confidential only to the extent required by law.  For more information, see 29 
CFR Part 70, “Production and Disclosure of Information or Materials.”  
 
C. Complaints  
   
 
 
8 The NRTL Program employs a formal  system to address complaints, which includes 
procedures for determining the validity of complaints, taking appropriate and effective 
actions, responding to complainants, and recordkeeping.  A complaint regarding the activities of the NRTL Program,  a recognized testing laboratory, or a product certified by 
an NRTL  may be lodged by any person or organization.  Complaints may be sent to 
OSHA via email at nrtlprogram@dol.gov
 or telephone at 202- 693-2110 and sh ould 
include any supporting information, if available.  A complaint concerning an NRTL  
should first be made to the laboratory it concerns before forwarding that complaint to OSHA.  
OSHA will accept complaints concerning a particular NRTL, the products it ce rtifies, or 
the NRTL Program. OSHA reviews the complaint, contact s the complainant or other 
parties as necessary, and reports findings to the OTPCA Director. Based on the OSHA 
investigation, and the input of the Office of the Solicitor, t he OTPCA Director makes an 
initial determination that the complaint is either not valid, or warrants a response from the 
subject of the complaint.  
1. If the  OTPCA Director can determine, on the basis of the OSHA investigation, 
that the complaint is not valid , OSHA communicate s the rationale to the 
complainant (if known), and takes no further action. 
 
2. If the OTPCA Director determines that the complaint warrants a response, , the 
OSHA contacts the subject NRTL or other entity(ies), and takes appropriate steps 
to resolve the issues , including asking the subject NRTL or other entity(ies) to 
respond, in writing, to the issues raised by the complaint . 
 
3. If the OTPCA Director determines that a written response from the subject NRTL 
or other entity(ies) adequately resolves the complaint , the OTPCA Director or 
OSHA informs the complainant that the matter has been adequately resolved.  
 
4. If the OTPCA Director determines that the written response from the subject 
NRTL or other entity(ies) does not adequately resolve the complaint, or if the 
subject NRTL or other entity(ies) does not respond within a reasonable period set 
by OSHA, OSHA will conduct a post -recognition assessment/monitoring visit, 
following the procedures in Chapter 2 of this Directive.  
 
5. To the extent permitted by law, the OTPCA Director and OSHA will keep 
confidential the nature of the resolution of the complaint, as well as the name of 
the complainant and if appropriate, the nature of the inquiry.  
   
 
 
9 6. OSHA will document whether and how the complaint was resolved, and the 
OTPCA Dire ctor will ensure that any control measures necessary to resolution of 
the complaint are implemented.  
 
D. Supplemental Procedures for Processing Applications for Initial Recognition 
 
1. Supplemental Procedures for Submission of Application and  Related Documentati on 
a. Any organization based within or outside the United States may apply to OSHA 
for recognition.   
b. To be recognized as an NRTL, an o rganization applying for recognition must 
meet all the requirements in 29 CFR 1910.7.     
 
2. Information  to be Submitted with Application  
Organizations that submit the following information when they apply for recognition 
will be considered to meet the requirement in Appendix A that an applicant “provide sufficient information and detail demonstrating that it meets the requiremen ts set 
forth in  §1910.7, in order for an informed decision concerning recognition to be 
made.”  
 a. An applicant organization shall complete an application for recognition that includes, but is not limited to, the following:  
i. The NRTL Initial Application, Expan sion and/or Scope Reduction Request 
Form  and the Initial Application and Expansion Test Standard Worksheet 
(See Annex D) ; 
ii. The name and address of the organization;  
iii. The point of contact’s name , e-mail address and telephone number ; 
iv. A secondary point of conta ct’s name, e- mail address and telephone number ; 
v. A description of the organization’s management structure;  
vi. An organizational chart defining relationships that are relevant to performing testing and certifications covered in the recognition request;  
vii. The requ ested scope of recognition; and  
viii. The applicable test standard(s).  
 
b. The organization’s quality manual and related management system 
documentation, which will constitute  evidence of conformance with 29 CFR 
1910.7, and this Directive , including  the OSHA NRTL Testing and Certification 
policies  (see Annex A and B).  The quality manual and related documentation 
shall contain or refer to documentation that describes the procedures covering all of the provisions  in ISO/IEC 17025: 2005, ISO/IEC 17065: 2012 and the N RTL 
testing and certification policies in Annex A and B  of this Directive .   
   
 
 
10 c. A cross matrix indicating where each provision of ISO/IEC 17025:2005, 
ISO/IEC 17065:2012, and OSHA NRTL Program -specific testing policies  in 
Annex A and certification policies  in Annex B are identified within the  
organization’s quality system  (i.e., the organization’s quality manual and related 
management system documentation and any other relevant documents).  
 
d. A complete list of test equipment used for NRTL testing.  The list sho uld include 
an equipment ID #, last calibration date, calibration due date and a short 
description of the equipment. 
 e. Any other documents re quested or that will assist OSHA in better assessing an 
applicant organization.  Any additional documents submitted should be for illustration or clarification, and not in lieu of the information listed above .  In 
addition, each document shall be clearly labeled, and a reference to the document made in the application . 
 
3. Agreement Conditions for R ecognition  
The signatory  must certify that he or she is the legal signatory for the organization 
applying for recognition and that the organization will comply with all the conditions for recognition listed in 29 CFR 1910.7(b), and with all the policies, conditions and requiremen ts for recognition that OSHA imposes through its regulations, Directives 
and Federal Register notices; operate as an NRTL only within the NRTL’s approved 
scope of recognition (applicable test standards, sites and programs), following the 
policies, procedur es, structures and practices described in the NRTL’s original or 
amended application accepted by OSHA, or in appropriate and approved revisions made after recognition; and promptly submit details to OSHA of any major changes 
in the NRTL’s operations. 
 
4. Fees for R ecognition  
The NRTL Program regulation, 29 CFR 1910,7(f), requires payment of fees.  Applicants must pay the applicable fees at time of application.  OSHA will not 
process and may return an application if it does not receive payment for the applicabl e fees.  In addition, payment for any activities for which there is a fee must 
be received in advance of OSHA performing the particular activity.  Once recognized, 
the NRTL generally pays audit fees each year.  The Fee Schedule and the Payment 
Instructions  in Annex E  detail the required fee amounts, and when and where to pay 
the fees.   
 
5. Amend ing and Withdrawing Applications    
 
 
11 An applicant may amend its application at any time prior to the publication in the 
Federal Register of the preliminary notice on the a pplication.  However, substantial 
amendments may result in a delay in processing the application.  An application may 
be withdrawn by an applicant, without prejudice, at any time prior to the final decision by the Assistant Secretary.  The OTPCA Director  will acknowledge requests 
to amend or withdraw an application. 
 
6. Supplemental Procedures for Acceptance of Application  
A. Upon receipt of an application:  
 
i. OSHA will establish a Case File  and send an acknowledgment to the 
applicant ; 
ii. OSHA performs a limited review of an application for completeness (i.e., 
whether the application contains  sufficient information to determine whether 
the applicant meets the requirements for recognition) in deciding whether to 
accept the application .  The limited review does not determine whether an 
applicant’s submittal is adequate to demonstrate the applicant has the capabilities necessary to become recognized by OSHA as an NRTL.  OSHA’s 
review for adequacy, and any on -site review, occurs only afte r OSHA accepts 
an application; and  
iii. Receipt of the application is acknowledged, in writing, and next  steps in the 
recognition process are specified.   
 
B. If OSHA determines that an application is complete , OSHA accepts the 
application.  
C. If OSHA determines tha t an application is not complete:  
 
i. The OTPCA Director  notif ies the applicant in writing that it has 30 days from 
the date of the notice to provide the missing or additional information.  The 
OTPCA Director also informs the applicant, in t he notice, that it is unable to 
review the merits of the application because the application itself does not contain sufficient information to show that the requirements for recognition can be met.  Finally, the OTPCA Director informs the applicant, in the  notice, 
that this review involves no technical determination, only an administrative one of whether the application has all of the necessary documentation.  
 
ii. If the applicant does not respond by the 30- day deadline, or does not 
adequately respond, and the application remains incomplete, OSHA informs   
 
 
12 the applicant that OSHA cannot accept the application, and the applicant must 
reapply for NRTL recognition.  
 
iii. If the applicant provides a complete application within 30 days, OSHA 
accepts the application.  
 
7. Suppl emental Procedures for Applicants Located Outside the United States  
If an initial or renewal application  for NRTL recognition  is received from an 
organization headquartered outside of the United States, OSHA will:  
 
A. Send a copy of the application to the US Trade Representative (USTR) .  USTR 
will consider whether the foreign country where the organization is located provides reciprocity as described in Appendix A .I.A.1.b.  A f oreign countr y 
fails to provide reciprocity when, fo r example, it does not allow U.S.- based 
safety -related testing bodies to apply for accreditation or recognition on the 
same terms and conditions as safety -related testing bodies based in the country’s 
own territory.  If USTR has concerns that a country doe s not provide 
reciprocity, USTR will inform OSHA of its concerns, and OSHA will take such 
concerns into consideration in determining whether to grant the application.   
 
B. Perform any additional procedures to comply with any special agreements with the forei gn country in which the organization is headquartered, if any.  
 
8.     Supplemental  Procedures for Revie w of Application and Supporting    
    Documentation  
A. Summary of Review for Adequacy  
i. After it accepts the application, OSHA reviews it for adequacy . 
 
ii. OSHA first conducts a technical review of the application (i.e., a detailed review of all of the application’s administrative and technical procedures 
and content.)  This technical review consists of a detailed management 
procedures review and review of test st andards submitted for recognition.  
 
iii. Following the technic al review, OSHA determines whether  to conduct an 
on-site assessment as part of evaluating the management system and 
technical capability of the organization.  OSHA generally conducts an on-site revie w for initial applications.  
 
B. Completion of Detailed Management Procedures Review    
 
 
13 i.  The OSHA personnel  assigned to the Case File reviews the organization’s 
quality manual and related management system documentation submitted 
with the application to ensure compliance to the requirements in 29 CFR 1910.7. 
 
ii. During the document review, OSHA may ask for additional management system document s to facilitate the review.  
 
iii. Non-conformances are discussed with the applicant’s p oint of c ontact , and 
the organization is given the opportunity to address them prior to the on- site 
assessment.  Based on the document review, OSHA may determine that there are major deficiencies in the application and require that the organization address the non- conformances before an on- site asse ssment is scheduled.  In 
such cases, OSHA will provide a list of the non- conformances to the 
organization in writing . Where the management system documentation 
requires significant revision, OSHA may require that the organization improve its documentation and submit it for further review.  
 
iv. The applicant has 30 days to respond to the list of non- conformances unless 
otherwise specified.  Extensions may be granted on a case -by-case basis.  
 
v. If the applicant timely responds to the list of non- conformances and OS HA 
determines that the response resolves all non -conformances, OSHA will 
proceed with an on- site assessment.  If , however, OSHA determines that the 
response does not resolve all of the non- conformances identified, OSHA will 
proceed to the Positive or Negat ive Finding stage of the recognition process 
on the limited issue of whether OSHA’s determination is correct.  
 
vi. If the applicant fails  to timely respond to the list of non- conformances , 
OSHA will deem the application to be withdrawn , and OSHA would take no 
further action on it. In such cases, the OTPCA Director sends a letter to this effect to the applicant and closes the case file.  
 
9.     Test Standard Approval Criteria  
A. The NRTL Prog ram Regulation ( 29 CFR 1910.7(c) ) sets forth the criteria for 
determining whe ther a test standard is appropriate.  Only appropriate test 
standards may be approved for recognition. 
 
B. An appropriate test standard is a document that is:    
 
 
14 i. Recognized in the United States as a safety standard providing an adequate 
level of safety ;  
 
ii. Compat ible with and maintained current with periodic revisions of 
applicable national codes and installation standards.  ( OSHA deems this 
requirement met only if the standards organization has appropriate policies 
and procedures for maintaining its standards as current ); and 
 
iii. Developed by a standards organization under a method providing for input 
and consideration by a broad spectrum of views for those experienced in 
the safety field involved.  
 
iv. Alternatively, standards that are currently design ated as an America n 
National Standards Institute (ANSI) safety -designated product standard or 
an American Society for Testing and Materials (ASTM  International ) test 
standard used for evaluation of products or materials  are appropriate test 
standards . 
 
C. In addition:  
 
i. Documen ts issued by acceptable organizations (see 29 CFR 1910.7(c)) are 
only appropriate test standards if they allow an NRTL to determine through 
testing or examination that a specific product conforms to safety 
requirements specified in the document.  Safety re quirements are features, 
parts, capabilities, usage limitations, or installation requirements that would 
create a potential hazard in using the equipment if they did not exist.  
 
ii. To be approved for recognition, the scope of the test standard must pertain 
primarily to equipment or materials (products) covered under the NRTL 
Program, and its requirements must be consistent with applicable OSHA safety standards.  
 
D. Alternative test standard.  If a testing laboratory desires to use a test standard 
other than one t hat meets the requirements specified above, then the Assistant 
Secretary shall evaluate the proposed standard to determine that it provides an adequate level of safety before it is used. Among other criteria, OSHA 
deems this requirement met only if the alternative test standards organization 
has appropriate policies and procedures for maintaining its standards as current.  
   
 
 
15  
10. Supplemental Procedures for Review of Test Standards  
A. OSHA makes a determination whether a test standard is appropriate:  
 
i. When OSHA proc esses an NRTL’s application for recognition (either 
initial or expansion); or  
 
ii. When a test standard is withdrawn by a standards development 
organization and an NRTL requests recognition for a replacement standard; 
or 
 
iii. When OSHA otherwise becomes aware of n ew test standards (for example 
by monitoring notifications issued by certain standards development organizations, other government agencies, or other parties that a new test 
standard may be appropriate to add to the list of appropriate standards ). 
 
The rem ainder of this section will detail the procedures OSHA follows 
under these three scenarios.  
 
B. When OSHA processes an NRTL’s application for recognition (either initial or expansion):  
 
i. OSHA reviews the listing of test standards submitted for recognition and , 
for each test standard,  verifies whether it is an appropriate test standard 
under the NRTL Program.  OSHA maintains a list of previously approved appropriate test standards on the NRTL webpage.  
 
ii. For a test standard  that OSHA has not listed as an appropria te test standard, 
but has  been issued by an acceptable organization, such as ANSI or ASTM  
(see 29 CFR 1910.7(c)) :   
 
a) OSHA determines whether the test standard is listed in the organization’s  current index of published test standards.  If the test 
standard is not listed in a current index of published test standards, it 
shall not be approved.  
 
b) OSHA reviews the scope and technical requirements of the test standard 
to determine if the standard is appropriate.  If the test standard is not appropriate, it shall not be approved.  
   
 
 
16 c) OSHA determines whether the product(s) within the scope of the test 
standard require certification by an NRTL under 29 CFR Part 1910.  If 
the product(s) within the scope of the test standard do not require certification by an NRTL under 2 9 CFR Part 1910, the test standard 
shall not be approved.  
 
iii. For test standards not issued by an acceptable organization, OSHA informs the applicant that it must submit the information showing each test standard can be approved for recognition (see 29 CFR 1910.7(d)) . 
 
iv. OSHA documents the rationale for approving or denying each test standard and informs the applicant in writing of test standards that  it does not 
approve .   
 
v. For an application to be considered adequate, at least one test standard requested must be approved for recognition.  In cases where OSHA determines that no test standards submitted for recognition can be approved, OSHA will proceed to the Positive or Negative Finding stage of 
the recognition process on the limited issue of whether OSHA’s 
determination is correct.  In cases where OSHA determines that at least one 
test standard submitted for recognition can be approved, OSHA will proceed with the onsite assessment, provided that OSHA determines that 
the applicant’s timely response to a list of nonconformances , prepared in 
conjunction with  the Detailed Management Procedures Review, resolves all nonconformances .   
 
C. When a test standard is withdrawn by a standards development organization and an NRTL requests recognition for a replacement standard:  
 
i. Since a test standard withdrawn by a standards development organization 
is no longer considered an appropriate test standard, OSHA removes 
acceptance of a withdrawn test standard by issuing a correction notice in the Federal Register for all NRTLs recog nized for the withdrawn test 
standard.  
 
ii. However, OSHA will recognize an NRTL for an appropriate replacement test standard (provided such a standard exists) if the NRTL has the requisite testing and evaluation capability for implementing the replacement tes t standard.  
   
 
 
17 iii. An NRTL that was recognized for the withdrawn test standard may 
request recognition for a replacement test standard that is both appropriate 
and comparable (i.e. completely or substantially identical) to the withdrawn test standard.  A replace ment test standard is comparable to a 
withdrawn test standard if the replacement test standard does not require 
additional  or different technical capability than the withdrawn test 
standard.  OSHA will follow the procedures in Chapter 2.D.10.D.i and 
2.D.10.D.ii in making a determination whether a replacement test standard is both appropriate and comparable to a withdrawn test standard.  
 
iv. An NRTL may also request recognition for a replacement test standard that is not comparable to the withdrawn test standard by either filing an application for expansion of recognition or, where applicable, 
demonstrating via the process described in Chapter 2.D.10.D. iii that the 
NRTL has the capability to perform the testing and evaluation required in 
the areas of the replacem ent test standard that are not equivalent or 
comparable to the withdrawn test standard.  
 
D. When OSHA becomes aware of a new test standard : 
 
i. OSHA first makes a preliminary determination that a new test standard is 
appropriate under the NRTL Program Regulations (29 CFR 1910.7(c) ). 
 
ii. OSHA then:  
 
a) Periodically issues a Federal Register notice proposing to include new 
test standards that it identifies as appropriate in its list of appropriate 
test standards ; 
 
b) May propose in a Federal Register notice to incorporate i nto NRTLs ’ 
scopes of recognition a new test standard to replace a test standard that OSHA is removing from the NRTLs ’ scopes of recognition (because, 
for example, OSHA makes a preliminary determination that a replacement test standard is both appropriate a nd comparable to a 
withdrawn test standard); and 
 
c) In either case, after OSHA publishes such a preliminary determination in a Federal Register notice, gives the public an opportunity to comment and, after reviewing these comments and other record 
evidence, issues, in the Federal Register, a final determination.    
 
 
18  
iii. When OSHA determines that a replacement test standard is not comparable 
to a test standard that OSHA is removing from an NRTL’s scopes of recognition:  
 
a) OSHA may provide for an abbreviated recognition process that allows 
the NRTL to submit to OSHA, in lieu of a full application for expansion, only information that demonstrates that the NRTL has the capability to perform the testing and evaluation required in the areas of 
the replacement test standard t hat are not equivalent or comparable to 
the standard being replaced.  
 
b) Per this abbreviated process, OSHA invites the NRTL, via email or letter, to submit specified information that OSHA believes 
demonstrates the requisite testing  and evaluation capability.  
 
c) OSHA includes, in the letter or email, a comparability table for the replacement test standard that details proposed substantive differences 
between the existing and replacement test standards that OSHA 
believes the NRTL must address for OSHA to recogniz e the NRTL for 
the replacement standard.  
 
d) OSHA the n follows the procedures specified by 29 CFR 1910.7. 
App.A, and in this Directive, for processing applications  for expansion 
of scope of recognition in determining whether it should incorporate the replacem ent test standard into the affected NRTL’s scope of 
recognition. 
 
11. Supplemental Procedures for On -site Assessment  
A. Scheduling on- site assessment  
i. If OSHA determines that an  application has no major deficiencies  (i.e., 
deficiencies in the application and supporting documentation that prevent OSHA from moving forward with the recognition process), or that all major deficiencies have been resolved , OSHA will schedule an on -site assessment.   
 
ii. OSHA schedules the on -site assessment at a mutually agreed -upon date an d 
time at the organization. The time span for the assessment is dependent upon the applicant’s scope of recognition. Typically, the assessment will span about two to three days and will be performed by two or more OSHA 
personnel .    
 
 
19  
iii. OSHA prepare s a schedule of on- site assessment activities prior to the 
assessment.  The on -site assessment schedule documents those areas of the 
organization’s operations that OSHA will review during the on -site 
assessment.  The applicant will have an opportunity to review the sc hedule 
before the on -site assessment , and the schedule will be discussed during the 
opening meeting.  
 
iv. If an applicant organization needs to change its established assessment date , 
it shall contact OSHA as soon as possible .  The applicant organization is 
responsible for any costs associated with the date change.  
 
B. Conducting On- site A ssessment  
i. In conducting an on- site assessment:  
a) OSHA reviews whether the applicant meets or exceeds the testing and 
certification minimum performance policies contained in Annex A  
and Annex B; and  
 
b) OSHA uses checklists to ensure that each organization receives an assessment consistent  with  that received by other  organizations.   
 
ii. The on- site assessment activities include: 
a) Opening meeting :  OSHA conducts an  opening conference with t he 
applicant’s personnel to discuss the scope and objectives of the on-site assessment, and review the schedule for the assessment activities.  
 
b) Laboratory tour:   OSHA tours the applicant’s facilities, including, 
but not limited to: areas for product safety  testing, equipment 
storage and receiving areas.  
 
c) On-site review :  OSHA review s and discusses the applicant’s 
activities in the areas specified in the on -site schedule.  
 
d) Closing meeting :  OSHA  conducts the closing conference with the 
applicant’s personnel to discuss any findings documented by OSHA 
during the assessment.  OSHA will present a summation of the 
findings, if any, and a copy of the Report of Findings.  OSHA will respond to any questions from the applicant’s staff concerning the 
findings.    
 
 
20  
12. Supplem ental Procedures for Report of Findings  
A. OSHA delivers  a Report of Findings on the compliance of the organization with 
the recognition requirements  to the organization at the conclusion of the closing 
meeting (unless OSHA specifies at the closing meeting th at the Report will be 
delivered at a later date) . 
 
B. A copy of the Report of Findings is retained by OSHA’s Office of Technical 
Programs and Coordination Activities . 
 
C. The Report of Findings include s at a minimum: 
i. Date(s) of on -site assessment;  
 
ii. The names of the OSHA personnel who conducted the assessment ; 
 
 
iii. The names and addresses of the organization sites assessed;  
 
iv. Non-conformances and observations cited by OSHA on the compliance of 
the organization with the recognition requirements. 
 
D. OSHA is responsible for the content of the Report of Findings, including the 
stating of non- conformances  and observations.  
 
13. Supplemental Procedures for Responding to Report of Findings  
A. The applicant has  90 days to respond to the Report of Findings unless otherwise 
specified.  E xtensions may be granted by the OT PCA Director on a case- by-case 
basis.   For example, the OTPCA Director may extend this period up to 6 months 
if the organization demonstrates that its delay was due to factors beyond its 
control.  On the other hand, the OT PCA Director may limit any response period to 
fewer than 90 days for existing NRTLs (that are the subject  of a post -recognition 
assessment/monitoring visit, for example) if the NRTL’s non -conformances pose 
or could likely pose a safety or health risk to em ployees engaged in its operations 
or to us ers of the products it is testing and certifying under the NRTL Program. 
 
B. In responding to the Report of Findings, the applicant needs to demonstrate it corrected all deficiencies and provide evidence to OSHA that the corrections have been implemented into the applicant’s or NRTL’s management systems.  As part of meeting this burden, u nless otherwise specified by  OSHA or the OTPCA 
Director, the applicant must provide OSHA with a root cause analysis, corrective   
 
 
21 actio n, and objective evidence that address  each non -conformance identified in 
the Report of Findings.  
 
C. If the organization submits a timely response to the Report of Findings, OSHA 
will proceed to the Positive or Negative Finding stage of the recognition proce ss. 
 
D. If the organization fails to submit a timely response to the Report of Findings , the 
application becomes inactive.  If this occurs, the DTSEM  Director  then sends a 
follow -up notice to the applicant requesting that it respond to the Re port of 
Findings within 10 days of the date of the notice.  If the organization responds within the 10- day period, the application is returned  to active status.   Failure to 
respond by the 10- day deadline would constitute a withdrawal of the application 
by the applicant, and OSHA would take no further action on it.  In such cases, the 
DTSEM  Director  sends a letter to this effect to the applicant and closes the Case 
File. 
 
14. Supplemental Procedures for Making Positive or Negative Finding s 
A. OSHA first complete s a Preliminary Evaluation on whether the applicant should 
receive recognition.  In conducting this eva luation, OSHA considers the record 
as a whole including (where applicable):  
o The application and any supporting documentation;  
 o The Detailed Management Procedures Review and any response thereto  
 
o The Review of Test Standards and any response thereto; and  
 
o The Report of Findings and any response thereto.  
 
B. After OSHA completes the Preliminary Evaluation, the OTPCA Director 
completes a Final Evaluation on whether the applicant should receive recognition. 
 
C. Based on the Final Evaluation, the DTSEM Director recommends a positive or 
negative  finding on the application. 
 
i. If the DTSEM Director recommends a negative finding, the OTPCA Director issues th e applicant a notification of negative finding (i.e., for intended 
disapproval of the application to the applicant).  In that case, the applicant has 
two options under Appendix A.I.B.3:  
   
 
 
22 o Option 1.  The applicant has one additional chance to revise its 
application within 30 days of receipt of OSHA’s written notice. 
 
o Option 2. The applicant may request that its original application (as 
supplemented during the review for adequacy) be submitted to the 
Assistant Secretary.  The applicant must also make this request  within 
30 days of receipt of OSHA’s written notice.  In this case, the applicant 
must attach a statement of reasons to the application explaining why the application should be approved.  
 
o Where the applicant takes no action within the 30- day deadline, O SHA 
will consider the application withdrawn and take no further action on it.  In such cases, the OTPCA Director sends a letter to this effect to the 
applicant and closes the Case File.  
 
o The procedure for applicant notification and potential revision shall  be 
used only once during each recognition process.  
 
ii. Revision of Application (Option 1):  
o If the applicant opts to revise its application, OSHA invoices the 
applicant for the fee to review its revised submission.  This fee equals the estimated hours for the  review multiplied by the hourly rate for the 
applicable Miscellaneous Fee in the NRTL Program’s fee schedule.  Like other application fees, this review fee is not refundable.  The applicant must pay this fee before OSHA performs the review of the revised application.  OSHA considers a failure to pay the fee within 30- days of 
receipt of the invoice as a withdrawal of the application.  
 o When OSHA receives the fee, OSHA reviews the revised application to 
determine whether to sustain the negative finding or cha nge it to a 
positive one.  If OSHA decides to sustain the recommendatio n for a 
negative finding, OSHA first affords the applicant the opportunity to 
withdraw the application.  If the applicant does not withdraw the application, OSHA follows the procedures in Appendix A and in this 
Directive for making a preliminary finding and final decision on the application (App. A.I.B.4, A.I.B.5, A.I.B.6) . 
 
iii. Once the DTSEM Director recommends a positive finding on either an original or revised applicat ion, sustains the r ecommendation for a negative 
finding after a review of a revised application, or the applicant requests that   
 
 
23 the original application be submitted to the Assistant Secretary, OSHA 
follows the procedures in Appendix A and in this Directive for making a 
preliminary finding and final decision on the application (App. A.I.B.4, 
A.I.B.5, A.I.B.6).  
 
15. Supplemental Procedures for Preliminary Findings and Final Decisions by the 
Assistant Secretary.  
A.   Preliminary Finding  
i. The OTPCA Director notifies the applicant in writing of the preliminary 
finding.  
 
ii. OSHA prepares an FR notice for a preliminary finding.  
 
iii. SOL reviews and approves the FR  notice before it is sent to the Assistant 
Secretary for approval . 
 
iv. If the Assistant Secretary approves the FR notice, OSHA submits the notice 
for publication in the FR . 
 
B. Final Decision  
i. OSHA completes a Preliminary Recommendation on whether the Assistant 
Secretary should approve or deny recognition in the Final Decision.  OSHA  
bases this recommendation on the record as a whole, including t imely 
comments received in response to the preliminary finding and other relevant information. 
 
ii. The DTSEM Director then recommends approval or denial of recognition, and OSHA prepares an FR  notice for a Final Decision on the application. 
 
iii. The FR  notice pre pared by OSHA is reviewed and approved by the 
OTPCA Director, DTSEM Director and SOL before being sent to the Assistant Secretary for review and approval.  
 
iv. If the Assistant Secretary issues a Final Decision for initial recognition, the 
Assistant Secretary approves a letter or other document of recognition, 
which the DTSEM Director sends to the applicant.  This letter or document 
sets forth the terms of recognition, which include the scope of recognition, specific conditions and limitations imposed by OSHA, general conditions required by the NRTL Program regulations, and references to applicable 
policies and requirements with which the NRTL must comply.    
 
 
24  
v. If the Assistant Secretary does not approve the recognition, the DTSEM 
Director sends an explanatory letter to the applicant and closes the case file. 
 
E. Post-Recognition Assessments/Monitoring Visits  
1. Schedule of Assessments /Monitoring Visits  
The OTPCA Director will prepare a schedule of assessments /monitoring visits  
each year.  These assessments are performed t o determine whether each NRTL 
continues to meet its terms of recognition.  
 
2. On-site Assessments/Monitoring Visits  
OSHA will perform a n on- site assessment/ monitoring visit of each NRTL and its 
recognized sites on a frequency determined by the OTPCA Director,  but at least 
once every two years.    OSHA will request information from the NRTL i n 
advance of an on -site assessment/monitoring  visit to help determine the scope 
and objective of the assessment.  
 
3. Electronic Assessments  
OSHA may supplement or replace an on -site assessment/monitoring visit of an 
NRTL with an electronic assessment using web technology and teleconferencing capabilities.   OSHA will request information in advance of an electronic 
assessment to help determine the scope and objective of the asses sment.  
 
4. Office Assessments  and Requests  of Information 
OSHA may perform an office  assessment  or otherwise request information from  
an NRTL to support an on- site assessment /monitoring visit; the O TPCA Director 
may also request the NRTL to update relevant in formation and to provide 
records to show that the NRTL is conforming to  its terms of recognition.   
 
5. Unscheduled and Special Assessments  
OSHA may perform unscheduled assessment s when warranted, in the OTPCA 
Director’s discretion.  For example, an unschedul ed assessment may be 
warranted if the OTPCA Director determines that the NRTL or one of its recognized sites may have a serious violation of its terms of recognition.  OSHA 
may also perform special assessments, at the discretion of the OTPCA Director, 
such as monitoring  of an organization that an NRTL uses for purposes of testing 
and certif ication of  products. 
 
F. Supplemental Procedures for Post -Recognition Assessments/Monitoring Visits    
 
 
25 1. With the following modifications, OSHA will follow the Supplemental 
Procedures for On -site Assessment, Report of Findings and Responding  to 
Report of Findings , in Chapter 2.D of this Directive, when scheduling and 
conducting post -recognition assessments/monitoring visits . 
 
2. If the NRTL submits a timely and adequate response to t he Report of Findings, 
OSHA will issue a report acknowledging receipt of the timely and adequate 
response to close out the assessment. 
 
3. If the NRTL fails to submit a timely response to the Report of Findings, or if OSHA determines that a timely response is  not adequate (because, for example, 
the NRTL did not provide OSHA with a root cause analysis, corrective action, or 
objective evidence that addresses each non- conformance identified in the Report 
of Findings):  
 
i. OSHA will contact the NRTL to discuss the inadequate response or the failure to file a timely response.   
ii. If a resolution is not reached during this discussion:  
 
• The OTPCA Director will notify the NRTL, in writing, of a final 
deadline to submit an adequate response to the Report of Findings.  
This written notification constitutes OSHA’s notification under 
Section II.E.2.a of Appendix A to 29 CFR 1910.7, of the alleged deficiencies which would form the basis of a proposed revocation of 
the NRTL’s recognition and allows the NRTL the opportunity to re but 
or correct these alleged deficiencies.    
 
• If the NRTL does not timely respond to OSHA’s notification by the final deadline, or does not adequately respond to the Report of 
Findings, the OTPCA Director will propose, in writing to the NRTL, to revoke re cognition of the NRTL, in whole or part.  This written 
notification constitutes OSHA’s notification under Section II.E.2.b of Appendix A to 29 CFR 1910.7.   
 
G. Supplemental Procedures for Processing Applications for Expansion of Scope of 
Recognition  
1. Any orga nization recognized by OSHA as an NRTL may apply for expansion of 
its scope of recognition at any time.  
   
 
 
26 2. With the following modifications, OSHA will follow its Supplemental Procedures 
for Processing Applications for Initial Recognition, detailed in Chapter  2.D, of 
this Directive to process an application for expansion of NRTL scope of 
recognition. 
 
i. In lieu of the information to be submitted with the application provided in Chapter 2.D.2, when it applies for expansion of recognition, an NRTL shall submit the  NRTL Initial Application, Expansion and/or Scope Reduction 
Request Form and the Initial Application and Expansion Test Standard 
Worksheet (See Annex D);  
 
ii. OSHA generally does not conduct a Detailed Management Procedures 
Review, but always conducts a review  of test standards submitted for 
recognition, as part of its technical review of an application for expansion of recognition (see Chapter 2.D.8 through 2.D. 10).  OSHA may conduct a 
Detailed Management Procedures Review at its discretion.  If OSHA does conduct a Detailed Management Procedures Review, it will notify the NRTL of any additional information it needs to submit in connection with the 
application. 
 
iii. OSHA also conducts a testing capability review and a site capability review as 
part of its technical review of an application for expansion of recognition.  In 
its review of an application for initial recognition, the testing capability review and site capability review typically occur in connection with the on- site 
assessment.  However, OSH A does not generally conduct an  on-site 
assessment for an expansion application unless the application involves new 
areas of testing for the NRTL or areas of concern to OSHA .  If OSHA does 
not conduct an on- site assessment for an expansion application, OSHA will 
proceed  to the Positive or Negative Finding stage of the recognition process 
after completing the technical review of the application . 
 
iv. In evaluating  whether to grant an application for expansion, OSHA will take 
into account the record as a whole, including any e vidence about the 
following criteria on whether the NRTL, in practice, meets the requirements for recognition:  
 
o Whether the NRTL has corrected all non -conformances discovered during 
assessments;  
   
 
 
27 o Whether the NRTL has not significantly or consistently viola ted its terms 
of recognition during the previous 24 months; and 
 
o Whether the NRTL has resolved all significant issues concerning its 
recognition raised, for example, in valid complaints or petitions, or which 
OSHA otherwise determines to be valid. 
 
H. Supplem ental Procedures for Processing Applications for Renewal of Recognition 
1. OSHA’s recognition of an NRTL is valid for five years from the date of recognition unless OSHA revokes recognition before the expiration of the five -
year period or the NRTL voluntarily  terminates its recognition.  An NRTL may 
renew its recognition by filing a renewal request.  Alternatively, after the first 
renewal has been granted, an NRTL may apply to renew its recognition by 
certifying its continued compliance with the terms of its letter of recognition and 
29 CFR 1910.7.  An NRTL applying for renewal of recognition must do so not less than nine months or more than one year before the current expiration of the term of its current recognition.  
 
2. With the following modifications, OSHA will follow its Supplemental Procedures for Processing Applications for Initial  Recognition, detailed in 
Chapter 2 .D of this Directive, to process an application for renewal of 
recognition. 
 
i. In lieu of the information to be submitted with the application pro vided in 
Chapter 2.D.2, when it applies for renewal of recognition, an NRTL shall submit a Request for Renewal/NRTL Certification of Continued Compliance 
Form (see Annex D);  
 
ii. The R equest for Renewal/NRTL Certification of Continued Compliance 
Form serves as  a renewal request and, as applicable, as a certification of 
continued compliance with the terms of the NRTL’s letter of recognition and 
29 CFR 1910.7. 
 
iii. The form asks the NRTL to verify its general information as well as verify its 
continued compliance wit h NRTL Program requirements.  
 
iv. The NRTL may submit information in addition to that contained in the 
Request for Renewal/NRTL Certification of Continued Compliance Form to demonstrate its continued compliance with NRTL Program Requirements.  
   
 
 
28 v. At the time of s ubmission, the NRTL must also submit any applicable fees.  
 
vi. Completing the Request for Renewal/NRTL Certification of Continued 
Compliance Form is entirely voluntary.  Each NRTL is free to apply for renewal or certify continued compliance with the terms of its recognition and 
29 CFR 1910.7 in any form it chooses.  However, OSHA will consider a 
renewal request or certification that does not contain the information requested in this form to be deficient, which may result in delay or denial of the renewal.  
 
vii. OSHA does not follow the S upplemental P rocedures for Completion of 
Detailed Management Procedures Review  in Chapter 2.D.8 or the 
Supplemental Procedures for Review of Test Standards in Chapter 2.D.10 in 
connection with applications for renewal of recognition.  
 
viii. If OSHA has not conducted an on- site assessment of both the NRTL 
headquarters and any recognized sites that have unique capabilities crucial to 
the NRTL’s scope within the previous 18 months, OSHA will conduct an on-
site assessment in conjunction with the  NRTL’s application for renewal.  
 
ix. In the discretion of the OTPCA  Director, OSHA may conduct an on- site 
assessment in conjunction with the NRTL’s application for renewal, even if OSHA has conducted one within the previous 18 months. 
 
x. If OSHA does not conduc t an on- site assessment for a renewal application, 
OSHA will proceed to the Positive or Negative Finding stage of the recognition process after reviewing the Request for Renewal/NRTL 
Certification of Continued Compliance Form and any additional information the NRTL submits to demonstrate its continued compliance with NRTL Program Requirements.  
 
xi. In evaluating whether to grant an application for renewal of recognition, OSHA will take into account the record as a whole, including any evidence about the followi ng criteria on whether the NRTL, in practice meets the 
requirements for recognition:  
 
o Whether the NRTL has corrected all non -conformances discovered   
during assessments ; 
   
 
 
29 o Whether the NRTL has not significantly or consistently violated its 
terms of recogni tion during the previous 24 months; and 
 
o Whether the NRTL has resolved all significant issues concerning its 
recognition raised, for example, in valid complaints or petitions, or 
which OSHA otherwise determines to be valid.  
 
o To expedite the completion of r enewals, expansion requests for 
additional sites or test standards shall not be submitted in conjunction with renewal requests.  All expansion requests shall be submitted 
separately, with a separate check to cover applicable fees.  All expansions shall be handled in accordance with the Supplemental Procedures for Processing Applications for Expansion of Scope of 
Recognition in Chapter 2 .G of this Directive . 
 
I. Revocation of Recognition 
1. Upon receipt of information that an NRTL may have committed one of the 
potential causes to initiate revocation of recognition stated under Section II.E.1 in 
Appendix A of the NRTL Program regulations, 29 CFR 1910.7, the OTPCA Director  shall review relevant documentation and determine if the information 
appears t o be valid.  
 
2. If the OTPCA Director determines that the information appears to be in valid, the 
OTPCA Director  documents the decision and takes no further action.   
 
3. If the OTPCA Director determines that the information appears to be valid, the 
OTPCA Director, with the concurrence of SOL and the DTSEM Director , 
recommends an appropriate course of action, which may include:  
 
a. No action to revoke recognition, 
 
b. Partial revocation of recognition, or  
 
c. Complete revocation of recognition. 
 
4. If it is decided to commence partial or complete revocation proceedings , the 
OTPCA Director  and appropriate personnel will follow the process in Sections 
II.E.2 through 5 in Appendix A  of the NRTL Program regulations , 29 CFR 
1910.7. 
   
 
 
30 5. OSHA may  satisf y its obligation to notify an NRTL under Section II.E.2 of 
Appendix A to 29 CFR 1910.7, of the alleged deficiencies which would form the 
basis of a proposed revocation of the NRTL’s recognition in several ways.  For example, OSHA may notify the NRTL, in wr iting of a final deadline to submit an 
adequate response to a Report of Findings in connection with a Post -Recognition 
Assessments/Monitoring Visit (see Chapter 2 .F), or satisfy its obligation in 
connection with the processing of a valid complaint, or in c onjunction with some 
other communication to the NRTL . 
 
6. The OTPCA Director  will specify the form, content and timing of the response 
required for the NRTL to rebut or correct alleged deficiencies after the NRTL  
receives notification, under Section II.E.2.a of Appendix A to 29 CFR 1910.7.  
 
7. If the alleged deficiencies are not corrected or reconciled within the time period specified by the OTPCA Director, OSHA will propose, in writing to the NRTL, to revoke recognition.  A revocation becomes e ffective 60 days from the date of  
receipt  unless, within that period , the NRTL does one of the following:  
 
i. Submits a written request for a  hearing, or  
 
ii. Establishes, in a written response, that it has corrected the alleged deficiencies forming the basis of  the proposed revocation.  The written 
response shall include appropriate documentation that demonstrates all deficiencies have been corrected.  The DTSEM Director will formally accept or reject the NRTL’s response. Acceptance by the DTSEM Director means the NRTL adequately corrected the alleged deficiencies. Rejection means the 
NRTL failed to adequately correct the alleged deficiencies.  
 
8. OSHA may give public notice in the Federal Register  regarding a proposed 
revocation.  
 
J. Voluntary Termination of Recognition 
 
An NRTL may request a full or partial termination of its recognition by sending a 
letter with appropriate information to the OTPCA Director  (see Section II.D of  
Appendix A of 29 CFR 1910.7).  The request shall state the effective date of the 
termination.  Once the request is received, t he DTSEM  Director confirms the request 
and submits a F ederal R egister  notice to terminate recognition by the effective date.  
Upon publication, the OTPCA Director will send a copy of the notice to the NRT L.   
 
 
 Annex A-1 
 Annex A -  Testing Minimum Performance Policies  
 
The testing minimum performance policies specified in this Annex provide guidance for the 
recognition of organizations under the OSHA NRTL Program.  Annex A contains OSHA -
specific policies that supplemen t the general provisions in ISO/IEC 17025:2005, General 
requirements for the competence of testing and calibration laboratories.  Annex B contains 
OSHA- specific policies that supplement the general provisions in ISO/IEC 17065:2012, 
Conformity Assessment – Requirements for bodies certifying products, processes and 
services.   
 
Paragraph (b) of the NRTL Program standard (29 CFR 1910.7) contains criteria that an 
organization must meet to be recognized as an NRTL.  Appendix A to 29 CFR 1910.7 provides that, in evaluation of whether an organization meets the criteria in 29 CFR 1910.7(b), OSHA “ will use either consensus -based standards currently in use nationally, or 
other standards or criteria which may be considered appropriate.”  Per this provision, in the testing and certification minimum performance policies in Annex A and Annex B , OSHA 
uses the specific criteria in ISO/IEC 17025:2005, ISO/IEC 17065:2012, and the OSHA -
specific testing and certification supplemental policies in Annex A an d Annex B, to evaluate 
whether an applicant organization or NRTL meet s the criteria in 29 CFR 1910.7(b)  for 
NRTL recognition .   
Organizations should disregard the statements in both ISO /IEC  17025:2005 and ISO /IEC  
17065:2012 that “[f]or undated references, the latest edition of t he referenced document 
(including any amendments) applies.”  Organizations should consult the edition of the 
referenced document in effect at the time of the issuance of the Directive.  OSHA may 
review and provide guidance on newer editions of referenced documents as necessary.  
  The numbering in this Annex correlates to the numbering in ISO/IEC 17025:2005.   
 
4. Management Requirements  
 To meet this policy, an applicant organization or NRTL shall comply with all of Section 4 of ISO/IEC 17025:2005 and the foll owing additional management policies: 
4.1 Organization  
A. The applicant organization or NRTL shall ensure that its management system 
shall cover work conducted at recognized sites. 
B. If any services, such as consulting, design, or research, are offered by the appli cant organization or NRTL, it shall have a policy and procedure for   
 
 
 Annex A-2 
 maintaining impartiality through separation of those services from its testing 
activities.  
4.2   Management system  
A.  The  applicant organization or NRTL shall follow all programs, proced ures and   
      policies it develops in compliance with this Annex.  
4.3   D ocument control  
There are no management polices supplementing Section 4.3 of ISO/IEC 17025: 
2005. 
4.4   Review of requests, tenders and contracts  
There are no management polices s upplementing Section 4.4 of ISO/IEC 17025: 
2005. 
4.5   Subcontracting of tests and calibrations  
A. If an applicant organization or NRTL accepts test data and witnessing of 
testing from subcontractors, the applicant organization or NRTL shall ensure that:  
i. procedures are in place to ensure that each test package has been 
completed for the applicable test standard (s) by the subcontractor  and 
reviewed by technical personnel  from the applicant organization or 
NRTL , and to  ensure that the subcontractor’s technical personnel meet 
the standards contained in ISO/IEC 17025:2005 Section 5.2 and 
Annex A Section 5.2;  
ii. procedures are in place to ensure that all test data originates with the subcontractor  
iii. technical personnel from the applicant organization or NRTL  who 
meet th e requirements of Annex A, Section 5.2 are used for witness 
testing; 
iv. procedures are in place to ensure the subcontractor is accredited, or 
qualified to Section 5 of ISO/IEC 17025:2005 using the applicant 
organization’s  or NRTL ’s own qualification program; and  
v. the qualification of the subcontractor for its scope of testing is verified by the applicant organization or NRTL  on at least an annual basis, and 
when the subcontractor is expanding or modifying its approved scope of testing.  
 
B. An applicant organizatio n or NRTL shall state in its organization’s procedures 
whether it accept s test data and witnessing of testing from subcontractors.    
 
 
 Annex A-3 
 4.6   Purchasing services and supplies  
A. Except as allowed in Sections 4.6.B and 4.6.C below, the applicant 
organization or NRT L shall use a calibration laboratory accredited for the 
appropriate measurement calibration of its test equipment, even if this calibration laboratory is internal to the applicant organization or NRTL .   
 
B. If no calibration laboratory is accredited for a particular type of testing 
equipment, the applicant organization or NRTL  may use the equipment 
manufacturer, or use an unaccredited calibration laboratory, provided the calibration laboratory is qualified by the applicant organization or NRTL using the appli cant organization or NRTL procedures.  
 
C. The applicant organization’s or NRTL’s internal calibration laboratory does not need to be accredited to calibrate its own equipment in two situations:  
 
i. equipment whose physical properties are unlikely to change and is not used for quantitative measurements (e.g., accessibility probes, impact spheres, rulers/measures, and containers used to measure or hold liquids) ; or 
 
ii. equipment whose measurement parameters meet any of the following requirements:  
 
• mass above 0.5kg a nd where an accuracy of ± 2% or greater is 
required; or  
• linear dimensions not less than 0.5mm and where an accuracy of ±0.1mm or greater is required; or  
• time for periods of 60 seconds or more, unless the test standard requires a specific accuracy of measurement . 
Such equipment shall initially be calibrated by an accredited calibration 
laboratory, or if none, by the manufacturer or a qualified calibration laboratory, before being placed into service.  
D. Whenever the applicant organization or NRTL calibrates its own equipment, it shall have p rocedures in place to  ensure appropriate calibration  of that 
equipment. Each applicant organization or NRTL must also verify equipment that does not need to be calibrated against documented specifications and/or 
procedures.  
4.7   Service to the customer  
There are no management polices supplementing Section 4.7 of ISO/IEC 17025: 
2005.   
 
 
 Annex A-4 
 4.8   Complaints  
There are no management polices supplementing Section 4.8 of ISO/IEC 17025: 
2005. 
4.9   Control of nonconforming testing and/or c alibration work  
There are no management polices supplementing Section 4.9 of ISO/IEC 17025: 2005. 
4.10  Improvement  
There are no management polices supplementing Section 4.10 of ISO/IEC 17025: 2005. 
4.11  Corrective action  
There are no management polices s upplementing Section 4.11 of ISO/IEC 17025: 
2005. 
4.12  Preventive action  
There are no management polices supplementing Section 4.12 of ISO/IEC 17025: 2005. 
4.13  Control of records  
There are no management polices supplementing Section 4.13 of ISO/IEC 17025: 2005. 
4.14  Internal audits  
There are no management polices supplementing Section 4.14 of ISO/IEC 17025: 2005. 
4.15  Management reviews  
There are no management polices supplementing Section 4.15 of ISO/IEC 17025: 2005.  
5. Technical Requirements  
 
To meet t his policy, an applicant organization or NRTL shall comply with all of Section 
5 of ISO/IEC 17025:2005 and the following additional technical policies:  
5.1   General  
There are no technical polices supplementing Section 5.1 of ISO/IEC 17025: 2005. 
5.2   Per sonnel  
A. The applicant organization or NRTL shall maintain competent technical 
personnel that are:    
 
 
 Annex A-5 
 i. permanent employees or employees contracted by the applicant 
organization or NRTL;  
ii. knowledgeable in appropriate evaluation, test procedures, and test standards  for the types of products covered by the NRTL’s scope of 
recognition; and  
iii. knowledgeable in the risks and hazards associated with conducting safety testing, including laboratory safety regulations, safeguards and procedures to reduce laboratory risks.  
B. The applicant organization’s  management or NRTL ’s management shall be 
knowledgeable in OSHA’s NRTL Program regulations, 29 CFR 1910.7, the criteria set out in ISO/IEC 17025:2005 and the OSHA -specific testing policies 
contained in this Directive .  A list of laboratory management shall be 
maintained.  
C. The applicant organization or NRTL shall:  
i. maintain a written training program for new and current technical personnel, which shall include the proper procedures for applying new/updated test procedures and perform ing required tests.  
ii. provide current technical personnel additional training, if necessary , when 
test standards or procedures are updated or developed, or when responsibilities have changed.  
iii. conduct training through appropriate training mechanisms, such as on- the-
job training or formal classroom training.  
iv. maintain written records of training for each individual who is a member of 
the technical staff.  
 
D. The applicant organization or NRTL shall maintain r ecords document ing 
competence in the particular testing, inspection, or other technical subjects, procedures, or practices that technical personnel will perform.  For example, a record may include past project work in testing, education, and/or formal training in testing, appropriate test standards, and relevant  test procedures.   
5.3   Accommodation and environmental conditions  
There are no technical polices supplementing Section 5.3 of ISO/IEC 17025: 
2005. 
5.4   Test and calibration methods and method validation 
A. The applicant organization or NRTL shall ensure t hat each test procedure it 
uses adequately address es all of the applicable requirements for the types of 
products or components to be tested to a particular test standard.  Each  test 
procedure shall include or specify, as appropriate, the:    
 
 
 Annex A-6 
  
i. title;  
ii. effect ive date;  
iii. specific test equipment to use along with their required ratings;  
iv. minimum accuracy requirements;  
v. warnings/caution statements to alert the operators of potential hazards;  
vi. normal and any unusual ambient conditions (including tolerances) for 
tests;  
vii. test data to be obtained and recorded;  
viii. the minimum resolution of measurements;  
ix. objective acceptance criteria for results;  
x. testing techniques; and  
xi. test operator instructions on equipment operation and on handling and preparation of test samples (in cluding instructions on multiple sample 
marking, if applicable).   
B. The applicant organization or NRTL shall ensure that it has procedures in place and it has written and complete instructions for performing the review for the construction requirements of t he standard when this review involves 
more than a visual pass/fail determination.  
 
C. The applicant organization or NRTL, shall ensure that the procedures specify all aspects of developing, reviewing and maintaining tests or other technical methods and proce dures (including related data collection methods, forms, 
and checklists), and include steps for:  
 
i. identifying the personnel responsible for developing, reviewing, and maintaining these documents; 
ii. specifying the frequency of review by technical personnel a nd 
management;  
iii. ensuring consistency with applicable test standard(s); and    
 
 
 Annex A-7 
 iv. ensuring test modifications are reviewed by personnel who are 
competent to the applicable test standard(s).  
5.5   Equipment  
A. The applicant organization or NRTL shall ensure that a ll equipment used for 
testing and evaluating products is available and in proper working order for NRTL work.  However, equipment needed only occasionally for a special or unique type of product that is seldom tested, may be rented, as needed.   
B. The applicant  organization or NRTL must own, lease, or rent its equipment, 
and shall have procedures requiring that new, leased, rented, and repaired equipment is calibrated prior to first use.    
C. The applicant organization or NRTL shall ensure that its procedures addr ess 
adding, deleting, modifying, or maintaining information in equipment records in an accurate and timely manner, and specify the personnel responsible for these tasks.  
D. The applicant organization or NRTL shall ensure that its procedures specify the steps  for establishing calibration intervals for each type or item of 
equipment, and specify criteria, steps, and approvals for extending the calibration interval of an instrument.  
E. The applicant organization or NRTL shall have procedures to examine the effects of defective equipment on calibrations and tests. The procedures shall identify the personnel  responsible for such examinations , specify their 
responsibilities, and provide the steps for the examination, including:  
i. determining whether the effects are unac ceptable (including the 
accept/reject criteria);  
ii. identifying the products affected;  
iii. analyzing the particular tests impacted for these products; and  
iv. determining whether retesting is required.   
     Procedures shall also specify the report or document that is prepared for this    
     examination, the notification provided to clients and certification body when  
     retesting is required, and the steps to follow to perform the retesting.  
 
F. If a piece of test equipment is found to be out -of-tolerance, the applicant  
organization or NRTL shall have procedures to:    
 
 
 Annex A-8 
 i. identify and document any product(s) tested by the out -of-tolerance 
equipment after the last known date the equipment was in- tolerance;  
ii. review and document any testing conducted using the out -of-tolerance 
equipment to determine if the out -of-tolerance condition impacted test 
results;  
iii. retest the products impacted by the out -of-tolerance condition, and 
document the results; and 
iv. document the corrective actions taken to comply with Section 5.5.F.i, 
ii, and iii, above, and retain such documentation in the test equipment 
records and the technical files or test records for any tested products impacted by the out -of-tolerance condition.  
5.6   Measurement traceability  
There are no technical polices supplement ing Section 5.6 of ISO/IEC 17025. 
5.7   Sampling  
There are no technical polices supplementing Section 5.7 of ISO/IEC 17025. 
5.8   Handling of test and calibration items  
There are no technical polices supplementing Section 5.8 of ISO/IEC 17025. 
5.9   Assuri ng the quality of test and calibration results  
There are no technical polices supplementing Section 5.9 of ISO/IEC 17025. 
5.10   Reporting the results  
A. The applicant organization or NRTL shall have procedures to record the following for each test conducted:   
 
i. test procedure(s) and test standard(s) used;  
ii. product or component(s) tested;  
iii. test equipment used for testing, measurement, or review (including the equipment’s ratings and accuracies, unless otherwise readily available);  
iv. date of the test;  
v. test repor t number;  
vi. signature of the personnel performing the test(s);    
 
 
 Annex A-9 
 vii. the test conditions as specified by the test standard, e.g., required 
voltage, power, temperature, or humidity for the test;  
viii. test or inspection results; and  
ix. all of the applicable data required  by the laboratory's procedures.   
 
   
 
Annex B - 1 
 
 Annex B -  Certification Minimum Performance Policies  
 
The certification minimum performance policies  specified in this Annex provide guidance for the 
recognition of organizations under the OSHA NRTL Program.  Annex A  contains OSHA -
specific policies that supplement the general provisions in ISO/IEC 17025:2005, General 
requirements for the competence of testing and calibration laboratories.  Annex B contains OSHA- specific policies that supplement the general provisions in ISO/IEC 17065:2012, 
Conformity Assessment – Requirements for bodies certifying products, processes and services.   
Paragraph (b) of the NRTL Program standard (29 CFR 1910.7) contains criteria that an organization must meet to be recognized as an NRTL.  Appendix A to 29 CFR 1910.7 provides that in the evaluation of whether an organization meets the criteria in 29 CFR 1910.7(b), OSHA  
“will use either consensus -based standards currently in use nationally, or other standards or 
criteria which may be consider ed appropriate.”  Per this provision, in the testing and certification 
minimum performance policies in Annex A and Annex B, OSHA uses the specific criteria in ISO/IEC 17025:2005, ISO/IEC 17065:2012, and the OSHA -specific testing and certification 
supplemental policies in Annex A and Annex B, to evaluate whether an applicant organization or NRTL meets the criteria in 29 CFR 1910.7(b) for NRTL recognition.  
Organizations should disregard the statements in both ISO /IEC  17025:2005 and ISO /IEC  
17065:2012 that “[ f]or undated references, the latest edition of the referenced document 
(including any amendments) applies.”  Organizations should consult the edition of the referenced document in effect at the time of the issuance of the Directive.  OSHA may review and pr ovide 
guidance on newer editions of referenced documents as necessary.  
The numbering in this Annex correlates to the numbering in ISO/IEC 17065:2012.   
4. General Requirements  
To meet this policy, an applicant organization or NRTL must comply with all of Sect ion 4 of 
ISO/IEC 17065:2012 and the following additional general policies:  
4.1   Legal and contractual policies  
A. The NRTL shall maintain r egistration of a certification mark with the U.S. Patent 
and Trademark Office (USPTO).  USPTO records shall show the fo llowing:  
i. USPTO records shall show the mark registered as a product 
certification mark; and  
ii. USPTO records shall show that:  
a. the NRTL owns the certification mark; or   
 
Annex B - 2 
 
 b. another NRTL owns the certification mark (provided OSHA 
has accepted a formal agreement bet ween the NRTLs 
controlling the use of the mark); or  
c. the certification mark is owned by an entity that the NRTL wholly owns (provided OSHA has evidence that only the NRTL has exclusive use of the mark).  
Note : An organization applying to become a NRTL shall  provide evidence with its 
NRTL application of having submitted an application for registration with the 
USPTO.  An applicant must provide evidence of registration of the certification 
mark prior to OSHA recognizing the organization as a NRTL.  
 
B. The applicant organization or NRTL’s procedures shall ensure that the 
organization’s mark is applied to each unit of the product certified, or, if not 
feasible, to the smallest package.  The test standard(s), certification category, or a 
symbol or code that identifie s the test standard(s) to which the unit is certified shall 
be shown in the marking.  
 
C. The applicant organization or NRTL shall have procedures and resources in place to control the use of the certification mark when the product is initially certified as well as in cases when the manufacturer proposes to modify the certified product, 
and to monitor advertisements, catalogues, and brochures for incorrect references 
or misleading use of its certification mark.  
 
D. The applicant organization or NRTL shall have res ources to ensure that corrective 
actions are taken for incorrect references or misleading use of the certification mark.  
 4.2   Management of impartiality  
A. The applicant organization or NRTL’s policies and procedures shall ensure that the 
organization:  
i. documents how any risks to its impartiality are identified on an ongoing basis, 
including how it determines if an activity or relationship presents or does not present a risk to its impartiality;  
ii. identifies and describes each such risk; and  
iii. describes how su ch risks will be eliminated or controlled.   
B. The applicant organization or NRTL shall ensure that risks to impartiality which are not eliminated are adequately controlled such that the confidence of a  
 
Annex B - 3 
 
 reasonable person in the impartiality of the applicant organization or NRTL 
would not be undermined.  Risks to impartiality to be considered by the applicant organization include, but are not limited to, those specified in paragraph A.2.2. of ISO/IEC 17065:2012.  
       4.3 Liability and financing  
There are no g eneral policies supplementing Section 4.3 of ISO/IEC 17065:2012. 
4.4 Non-discriminatory conditions  
There are no general policies supplementing Section 4.4 of ISO/IEC 17065:2012. 
       4.5 Confidentiality  
 There are no general policies supplementing Section 4.5 of ISO/IEC 17065:2012. 
       4.6 Publicly available information  
 There are no general policies supplementing Section 4.6 of ISO/IEC 17065:2012. 
 
5. Structural Requirements  
 
To meet this policy, an applicant organization or NRTL must comply with all of Sect ion 5 of 
ISO/IEC 17065:2012.  
5.1 Organizational structure and top management  
There are no structural policies supplementing Section 5.1 of ISO/IEC 17065:2012. 
5.2 Mechanisms for safeguarding impartiality  
There are no structural policies supplementing Section 5.2 of ISO/IEC 17065:2012. 
 
6. Resource Requirements  
 
To meet this policy, an applicant organization or NRTL must comply with all of Section 6 of 
ISO/IEC 17065:2012 and the following additional resource policies:  
6.1   Certification body personnel  
A.   The applic ant organization or NRTL  shall maintain competent certification   
  personnel that are:  
 
i. permanent employees or employees contracted by the certification body;  
ii. knowledgeable in the evaluation and test processes for test standards in the 
organization’s scope of recognition;  
iii. knowledgeable in the NRTL’s certification processes;   
 
Annex B - 4 
 
 iv. trained to conduct factory surveillance, as appropriate; and  
v. not involved in testing of the product to be certified. 
B.   The applicant organization or NRTL  management shall be knowledgea ble in the     
   OSHA NRTL Program regulations, 29 CFR 1910.7, the criteria set out in ISO/IEC  
   17065:2012, and the OSHA -specific NRTL certification policies contained in this  
   document.  A list of certification management shall be maintained.  
 
C. A training program for new and current certification  personnel  shall be documented 
by the applicant organization or NRTL .  Training shall include use of certification 
processes as well as test standards and procedures. Current certification personnel  
shall receive additional training, when certification processes are updated, test 
standards or procedures are updated or developed, or when responsibilities have changed.  All training shall be conducted through appropriate training mechanisms, such as on- the-job training or formal classroom training.  Records of training shall 
be documented in individual training records.  
 
D. For certification personnel performing evaluation, or review, or making certification decisions, personnel or training records shall document competence in the particular certification functions, procedures, or practices they perform.  For example, a record may include past project work in testing or certification, education, and/or formal training in appropriate test standards and relevant procedures.  
6.2   Resources for evaluation  
When the applicant organization or NRTL  performs evaluation activities, the 
organization (recognized or unrecognized site) used for product testing shall meet  the 
Testing Minimum Performance Policies specified in Annex  A. 
 
7. Process Requirements  
 
To meet this policy, an applicant organization or NRTL  must comply with all of Section 7 of 
ISO/IEC 17065:2012 and the following additional process policies:  
7.1 General  
  There are no process policies supplementing Section 7.1 of ISO/IEC 17065:2012. 
      7.2  Application  
A. The applicant organization or NRTL shall use a ppropriate contracts, covenants, or 
agreements in providing certification services to clients, which  shall include, but not 
be limited to, the following:  
 
i. provision( s) for submitting products for testing;  
 
Annex B - 5 
 
 ii. provision(s) for permitting periodic factory surveillance;  
iii. provision(s) for permitting samples of products to be selected, from 
production or stock, for independent testing;  
iv. covenants from the client to observe and c omply with the applicable test 
standards;  
v. controls to prevent the client from releasing products resulting from changes (in the product, manufacturing, process or management system) until the applicant organization or NRTL has notified the client that the change is acceptable;  
vi. provision(s) for unobstructed access to the  manufacturing facilities without prior notification;  
vii. provision(s) that the product will be produced to the same specifications as the sample submitted for initial testing; and  
viii. controls to e nsure that all management system and production records will be 
open and readily available for factory surveillance by the certification body. 
B. The applicant organization or NRTL shall have procedures or agreements with its 
customers to address each of the following situations:  
 
i. instituting a product recall;  
ii. removing the mark of conformity from products;  
iii. rebuilding a product so it will comply with applicable test standard(s); and  
iv. scrapping or replacing a returned product if it is not practical to remove t he 
mark or rebuild the product.   
      7.3 Application review  
There are no process policies supplementing Section 7.3 of ISO/IEC 17065:2012. 
      7.4 Evaluation 
A. The applicant organization or NRTL shall have procedures for the evaluation process that  requ ire certification personnel to:  
 
i. verify and use the applicable test standard (s) and appropriate edition of the 
test standard (s);   
 
Annex B - 6 
 
 ii. provide written justification for how a product complies with each section of 
the test standard [s] (including a reference to a test procedure for sections that 
require tests be conducted);  
iii. identify the reason for waiving or excluding particular sections of the test standard (s);  
iv. address components that are not certified or have a non- standard design;   
v. handle newly developed or  unique technologies , when the test standard does  
not apply, in part or in whole , using test standard s for which the NRTL is 
recognized;  
vi. indicate how interpretations of the test standards are documented and made readily available for personnel; and  
vii. address  failures identified against  the product test standard without engaging 
in the redesign of the product. 
B. Procedures an NRTL must follow for acceptance of another NRTL’s listing, 
where an NRTL client  has terminated, or will terminate, certification with another 
NRTL, shall include procedures for:  
 
i. identifying the information the NRTL client  must submit for the product(s), 
including:  
a) the other NRTL’s full listing report;  
b) the other NRTL’s factory surveillance reports issued during the most recent 12 months for each manufacturing location;  
c) evidence of the resolution of any factory surveillance variances noted in these factory surveillance reports, or if not resolved at the time of review by the NRTL , documentation to enable the NRTL  to adequately resolve 
the v ariance(s); and  
d) documentation of any changes to the product that are not addressed in the other NRTL’s listing report.   
ii. performing  factory surveillance, in compliance with the policies contained in 
this document, before certifying a product for which no f actory surveillance 
occurred during the most recent 12 months.  
iii. conducting the following activities before certifying the product:   
 
Annex B - 7 
 
 a) reviewing a sample of each product being transferred;  
b) performing an inspection; and  
c) conducting any product evaluation to ass ure the product complies         
with the applicable test  standard(s).   
C. Prior to issuing a new certification, the applicant organization or NRTL shall 
conduct factory surveillance of the manufacturing facility(s), and it shall prepare a 
record or report o f this factory surveillance that shows the findings in the areas 
described in i to iv below. The factory surveillance shall verify the manufacturer maintains:  
 
i. procedures to control production, including:  
a) mechanisms to identify batches or production runs, 
b) procedures to isolate non -conforming products, 
c) procedures to notify the applicant organization or NRTL  of changes to the 
product, production or management systems that may impact a product’s compliance,  
d) procedures for periodic review and update of master specifications,  
e) procedures for the retention of production records, and 
f) procedures for the tracking and documentation of product defects, claims and complaints;  
ii. adequate separation of duties between quality assurance personnel and production personnel;  
 
iii. procedures to conduct periodic quality assurance verification of production runs, including:  
a) sampling procedures, and 
b) a requirement for verification inspections and tests to be conducted by individuals who are independent of production; and 
iv. procedures for production line verifications and tests requiring the use of properly calibrated and maintained test equipment that is routinely checked by the manufacturing facility.  
 
D. The need to conduct factory surveillance to determine that the client  is capable of 
producing a product in conformance with the requirements of Annex B Section 7.4 C  
 
Annex B - 8 
 
 may be waived prior to new certification if the manufacturing facility is currently 
under factory surveillance with the applicant organization or NRTL  for the same, or a 
similar , product test standard.  The applicant organization or NRTL shall document in 
its records the decision to waive the factory surveillance prior to new certification.  
 
E. If the applicant organization or NRTL accepts inspection reports, the applicant organizat ion or NRTL shall ensure that:  
 
i. procedures are in place to ensure that each inspection report has been completed for the applicable test standard(s) by the organization conducting the inspection and reviewed by qualified personnel  from the applicant 
organi zation or NRTL , and to ensure that personnel conducting the inspection 
meet the standards contained in ISO/IEC 17065:2012 Section 6.1 and Annex B 
Section 6 .1; 
ii. procedures are in place to ensure that all inspection data originates with the organization conducting the inspection;  
iii. procedures are in place to ensure that the organization conducting the inspection has an accreditation  to ISO/IEC 17020:2012 by an International 
Accreditation Cooperation (ILAC) signatory  for an appropriate scope, or 
qualified to ISO/ IEC 17020:2012 using the NRTL’s own qualification 
procedures ; 
iv. the qualification of the organization conducting the inspection for its scope of 
testing is verified by the NRTL on an annual basis, and when the organization conducting the inspection expands or modifies its approved scope of inspection;  
v. documentation of technical correspondence and test interpretations  has been 
maintained; and  
vi. records of any procedural or product deficiencies identified and the corresponding corrective actions have been maintai ned. 
F. If the applicant organization or NRTL accepts inspections and test data from organizations that function as part of the International Electrotechnical Commission Certification Body (IEC -CB) scheme, the NRTL  (including, as applicable the 
applicant orga nization, once the application for NRTL recognition is approved)  shall: 
 
i. be recognized by OSHA for a test standard that is harmonized with the one being accepted under the IEC -CB scheme;   
 
Annex B - 9 
 
 ii. physically inspect (i.e., perform a hands -on inspection of ) each product model, 
type, or representative family member;  
iii. review each certification body (CB) test certificate and CB test report to 
determine that the correct test standard(s) have been used and that any United States deviations have been applied;  
iv. use procedures  for evaluation and interpretation of inspection results;  
v. determine that components used comply with the policies adopted in compliance with Annex B  Section 7.4.I and J ; and  
vi. ensure compliance with Annex B Section 7 .9.  
G. If the applicant organization or NRTL  accepts inspections and test data from 
organizations that function as part of the IECEx S cheme , the NRTL (including, as 
applicable, the applicant organization, once the application for NRTL recognition is approved) shall: 
i. be recognized by OSHA for a test standard that is harmonized with the one being  accepted under the IECEx Scheme;  
ii. physically inspect (i.e., perform a hands -on inspection of ) each product model 
or type;  
iii. review each IECEx test certificate (ExCB) and IECEx test report (ExTR) to determine tha t the correct test standards  have been used and that any United 
States deviations have been applied;  
iv. use procedures for evaluation and interpretation of results;  
v. determine that components used comply with the policies adopted in compliance with Annex B S ection 7.4.I and J ; and  
vi. ensure compliance with Annex B Section 7 .9.   
H. If the applicant organization or NRTL does not accept inspection reports, inspections or test data from organizations described in Annex B Section 7 .4 E, F, or G , 
procedures shall state this.  
 
I. The applicant organization or NRTL shall have procedures address ing the initial 
verification required when accepting safety critical components (components) for use in an end product.  These procedures shall include:  
  
 
Annex B - 10 
 
 i. policies that address acceptance of component certifications from organizations 
recognized by OSHA (i.e., NRTLs);  
ii. policies that address acceptance of component certifications from organizations not recognized by OSHA, including any additional factory surveillance activity that may be ne cessary;  
iii. policies that address acceptance of uncertified components, including policies addressing acceptance of certified components used outside the range of the components’ certifications based on evaluation or testing in the end product  
and, policies a ddressing any additional factory surveillance activity that may be 
necessary; and  
iv. a requirement to confirm that all limitations, engineering considerations, technical considerations, or conditions of acceptability stated as part of the component’s certific ation are addressed in the end product.  
J. If an applicant organization or NRTL accepts uncertified components or certified components used outside the range of the component certification, the applicant organization or NRTL shall not evaluate the component f or the applicable use in the 
end product if it does not have the capabilities, including trained personnel, procedures, equipment, or facilities, to evaluate or test the component.  
      7.5 Review  
There are no process policies supplementing Section 7.5 of ISO/IEC 17065:2012. 
      7.6 Certification decision  
The applicant organization or NRTL shall have procedures identify ing all the necessary 
steps that must occur before an applicant organization or NRTL issues an authorization 
to mark or otherwise approves the release of the product, including the completion of 
factory surveillance at a new or an existing manufacturing facility making a new type of product.   
      7.7   Certification documentation  
A. Procedures shall identify the information to include in t he factory surveillance 
report, including, at a minimum:  
 
i. listing or certification number;  
ii. name of client (and if different, name of manufacturer);  
iii. factory location(s);  
iv. product description;   
 
Annex B - 11 
 
 v. location of testing;  
vi. product rating(s);  
vii. list of critical comp onents;  
viii. critical or necessary constructional features and specifications that are 
compliant with the applicable test standard(s) and tests that were performed; and 
ix. limitations, conditions, or restrictions on the listing.  
      7.8   Directory of certified  products  
A. The applicant organization or NRTL shall have procedures and controls in place to ensure information in the directory of certified products or record is added, deleted, 
or modified as needed.  The procedures shall also address the issuance, termi nation, 
and modification of the authorization to mark, and updating the listing records 
accordingly.   
B. Where a certification applies to a family or series of products, the directory of certified products shall identify the individual items covered by the c ertification.  
      7.9   Surveillance  
A.   The applicant organization or NRTL shall conduct f actory surveillance, at each 
manufacturing facility, of products that have been certified, to provide the applicant 
organization or NRTL  with confidence that certifi ed products continue to be 
manufactured in compliance with applicable test standards.  Factory surveillance shall involve an actual visit to each manufacturing facility.  
B. Certification personnel shall conduct factory surveillance at manufacturing facilities  
without advance warning or notice to the manufacturer, except in situations when there is limited seasonal production, or when production has not been available for factory surveillance for a period exceeding 12 months.   Procedures shall be in place to address factory surveillance that may be impacted due to travel restrictions  (e.g. 
war, military activity or bad weather that prevents travel) . 
C. The applicant organization or NRTL shall perform no fewer than four (4) factory surveillance visits per year at m anufacturing facilities where any of the following 
situations occur:  
i. the products are intended for use in hazardous locations;  
ii. the applicant organization or NRTL has evidence, or suspects, that the manufacturer has not been producing a product in conforma nce with product  
 
Annex B - 12 
 
 safety requirements or maintaining appropriate controls over its production 
process at a facility; or  
iii. the applicant organization or NRTL has evidence or suspects that the manufacturer is not using or controlling the NRTL’s  (including, as a pplicable, 
the applicant organization, once application for NRTL recognition is approved) certification mark(s) correctly.  
D. Factory surveillance may be performed less frequently, but no fewer than two (2) factory surveillance visits per year, at any facilit ies where concerns as described in 
Annex B Secti on 7.9.C  do not exist, provided the manufacturer demonstrates 
ongoing quality assurance programs, control programs, and effectiveness in meeting product safety requirements.  Evidence or justification that supports the decision to allow less than four (4) factory surveillance visits per year shall be retained.  
E. Each certified product type or model shall be physically inspected at least once every two years.  
F. The applicant organization or NRTL may use the factory surveillance of a product at a manufacturing facility to meet the factory surveillance requirements for similar products manufactured at the same facility. Similar products are products grouped in a category based on the same or equivalent product manuf acturing characteristics 
or technical requirements.  
G. Factory surveillance activities, and the content of reports or records of these 
activities, shall include or address the following, at a minimum:  
i. physical examination of the certified product being inspec ted compared with a  
document that describes the product, or, when no product is available at the time of a factory surveillance visit, examination of appropriate documentation (such as specification and purchasing documents);  
ii. verification of in -process an d final testing that is required by the applicable 
test standard(s), or that is regularly conducted at the factory as a part of the manufacturer's management system;  
iii. confirming the use of accepted components;  
iv. monitoring the use and control of the NRTL’s (i ncluding, as applicable, the 
applicant organization, once application for NRTL recognition is approved) certification  mark; and  
v. calibration of equipment used in testing.  
H. Factory surveillance procedures shall address:   
 
Annex B - 13 
 
 i. justifying the factory surveillance fre quency and changes to the frequency that 
the certification body has adopted for a facility or for a particular type of 
product;  
ii. products having seasonal or non- regular production cycles, as well as any 
concerns that can exist with production lines that ar e intermittent; 
iii. reinstatement of factory surveillance when the surveillance has been suspended due to lack of  production or stock of certified products;  
iv. adding, deleting, or modifying information about manufacturing locations for products tested and certi fied; 
v. scheduling factory surveillances, verifying they have been performed, and taking any corrective action when the schedule is not met; and  
vi. surveying the manufacturer’s products, processes and/or management systems.  
I. The use of factory surveillance perfo rmed by another NRTL is acceptable.  
However, use of factory surveillance data provided by another NRTL does not relieve the applicant organization or NRTL from ensuring that required factory surveillances are performed.  The applicant organization or NRTL  and the other 
NRTL shall have a formal agreement that allows for use of the other NRTL’s factory surveillance data. In addition, procedures shall be in place that require : 
i. retention of all factory surveillance reports from the other NRTL, including retent ion of any non- conformances and corrective actions  
ii. review of all factory surveillance reports from the other NRTL, including review of non -conformances and corrective actions; and  
iii. adequate resolution of  issues that may call into question the other NRTL’s  
factory surveillance, such as inadequate factory surveillance data or failure to address non- conformances.  
J. The applicant organization or NRTL shall have procedures to address deficiencies 
found during factory surveillance, including procedures for trackin g these 
deficiencies and ensuring the deficiencies are resolved.  
K. The applicant organization or NRTL shall have procedures for performing field inspections, including procedures for identifying where each field inspection will be performed, the nature and f requency of the activities that will be performed, and 
when such field inspections are necessary.   
 
Annex B - 14 
 
      7.10   Changes affecting certification  
If any NRTL -certified product is identified as nonconforming, or recalled for safety 
issues, the NRTL  shall immed iately notify OSHA.  
    7.11  Termination, reduction, suspension or withdrawal of certification  
 There are no process policies supplementing Section 7.11 of ISO/IEC 17065:2012. 
7.12 Records  
 There are no process policies supplementing Section 7.12 of ISO/IEC 17065:2012.  
     7.13  Complaints and appeals  
  There are no process policies supplementing Section 7.13 of ISO/IEC 17065:2012. 
8. Management System P olicies  
To meet this policy, an applicant organization or NRTL must comply with Section 8 of      
ISO/IEC 17065:2012, as follows , and the following additional management system policies.  
8.1  Options  
To meet the management system policies, an applicant organization or NRTL  shall 
comply with all of Section 8, Option A, of ISO/IEC 17065:2012.  Compliance with 
Sectio n 8, Option B, does not constitute compliance with the management system 
policies.  
8.2 General management system documentation (Option A)  
There are no management system policies supplementing Section 8.2 of ISO/IEC 17065:2012. 
 
8.2.1 Applicability  
A. The applicant orga nization or NRTL shall follow all policies, programs and   
procedures it develops in compliance with this Annex.  
      8.3   Control of documents (Option A)  
There are no management system policies suppl ementing Section 8.3 of ISO/IEC 
17065:2012. 
      8.4   Control of records (Option A)  
There are no management system policies supplementing Section 8.4 of ISO/IEC    
17065:2012. 
       8.5  Management review (Option A)  
  There are no management system policies supplementing Section 8.5 of ISO/IEC    
  17065:2012.  
 
Annex B - 15 
 
        8.6 Internal audits (Option A)  
There are no management system policies supplementing Section 8.6 of ISO/IEC 
17065:2012. 
       8.7   Corrective actions (Option A)  
  There are no management system policies supplementing Section 8.7 of ISO/IEC    
  17065:2012. 
       8.8 Preventive Actions (Option A)  
  There are no management system policies supplementing Section 8.8 of ISO/IEC    
  17065:2012.  
 
Annex C -1 
 Annex C -  Terms and Definitions  
 
For the purposes of Annex A and Annex B , the terms and definitions given in ISO/IEC 
17000:2004, and the terms and definitions given in ISO/IEC 17065:  2012,  apply unless 
otherwise defined below.  
 
a. Accredited  
Unless otherwise specified in Annex A or Annex B, “accredited” means 
accreditation to ISO/IEC 17025:2005 by an Internati onal Accreditation Cooperation 
(ILAC) signatory for the appropriate scope of testing.  
 
b. Accreditation  
As defined in ISO/IEC 17000:  2004. 
 
c. Applicant  Organization  
An o rganization that is applying for initial recognition as an NRTL.  
 
c. Attestation  
As defined in ISO/IEC 17000:  2004. 
 
d. Certification  
An NRTL’s  attestation , indicated by the NRTL’s certification mark on a product, 
that the product conforms to one or more specific U.S. safety standard(s).  
 
e. Certification Mark  
A third party mark of conformity as  defined i n ISO/IEC 17030:2003.  
 
f. Certified Product  
Assurance by an NRTL that a product is in conformity with the applicable test standards for which the NRTL is recognized. 
 
g. Conditions of Acceptability  
The limitations and conditions for the use of a component in an end product, based on the inspection and testing of the component.  
 
h. Conformity Assessment  
As defined in ISO/IEC 17000: 2004. 
 
i. Conformity Assessment Body   
 
Annex C -2 
 As defined in ISO/IEC 17000: 2004. 
 
j. Engineering Considerations  
A record of the conditions (i.e., physic al, environmental) or assumptions under 
which a  product was tested or inspected.  These conditions or assumptions may 
include additional testing or inspection when incorporating a component (s) into an 
end product.  
 
k. Evaluation 
A determination of the extent to which a product, process or service fulfills specified requirements.  
 
l. Factory Surveillance  
Surveillance, a s defined in ISO/IEC 17000: 2004.  
 
m. Field Inspection 
An inspection of a product that an NRTL has certified to monitor and to assure the proper use o f the NRTL’s identifying mark or labels on the product.  Field 
inspections are required by 29 CFR 1910.7(b )(2)(iii). 
 
n. Foreign -based Testing Agency or Organization  
A testing agency  or organization is foreign -based if (1) it is incorporated or 
otherwise lega lly registered outside  the U S or its territories , or (2) it is incorporated 
or otherwise legally registered in the US or its territories but is headquartered or has 
its main office o r place of business outside the US  or its territories . 
 
o. Inspection  
As def ined in ISO/IEC 17000: 2004. 
 
p. International  Electrotechnical Commission Certification Body (IEC -CB) Scheme  
A certification body scheme that requires participating members to accept test 
reports from other participating members, unless there are documented technical 
reasons why a test report is unacceptable.  
 
q. IECEx Certified Equipment Scheme (IECEx Scheme)  
A certification body scheme for equipment that is intended to be use d in potentially 
explosive atmospheres .  Such a scheme  requires participating member s to accept 
test reports from other participating members, unless there are documented 
technical reasons why a test report is unacceptable.   Products are inspected and 
tested using the International Standards listed on the  IECEx Certificate.   
 
Annex C -3 
  
r. Laboratory Management  
Laboratory personnel that ensure overall compliance with applicable test standards 
as well as compliance to OSHA’s NRTL Program regulations, 29 CFR 1910.7, the 
criteria set out in ISO/IEC 17025:2005 and OSHA- specific testing requirements  and 
polic ies. 
 
s. Manufacturing Facility  
An establishment used for fabricating or assembling a product (model or item).  This does not include a facility that distributes but does not fabric or assemble products. 
 
t. Nationally Recognized Testing Laboratory (NRTL)  
A legal entity recognized by OSHA as meeting the requirements in 29 CFR 1910.7. 
 
u. Procedure  
As defined in ISO/IEC 17000: 2004. 
 
v. Recognized Site  
A site included in a n NRTL’s scope of recognition.  To be recognized, a site must 
be administratively and operationally  controlled by the NRTL and must perform 
testing  and inspection (and/or accept test data or inspections) , perform review s, and 
make certification decisions with the NRTL management system.  
 
w. Review  
As defined in ISO/IEC 17000:2004.  
x. Safety Critical Componen t (Component)  
A product -part whose functions or features are essential for maintaining compliance 
with an applicable test standard.  
 
y. Sampling  
As defined in ISO/IEC 17000: 2004.  
z. Specified Requirement  
As defined in ISO/IEC 17000: 2004. 
 
aa. Technical Considerat ions 
A term synonymous with, and commonly used in place of, “engineering 
considerations”, defined above.   
 
Annex C -4 
  
bb. Test Procedure  
Instructions to follow in examining and testing a type of product, or in performing a 
specific type of test.  A test procedure must be consistent with the product safety 
test standard(s) applicable to the products under test and must contain instructions that will yield repeatable results.  A test standard may be used, partly or completely, as a test procedure if it contains instructions that will yield repeatable results.  
 
cc. Test Standard  
Within the context of the requirements under 29 CFR 1910.7, a document that provides, for common and repeat use, specific tests, characteristics or results that 
products must meet for purposes of assuring they are safe for use.  
 
dd. Unrecognized Site 
A site at which testing and inspection activities are performed that is not a recognized site.
   
 
Annex D -1 Annex D - NRTL Forms  
 
The NRTL Program uses the following forms  for Initial NRTL Recognition, Expansion of NRTL 
Recogn ition and Renewal of NRTL recognition . 
 
• NRTL Initial Application, Expansion and/or Scope Reduction Request  
• NRTL Initial Application and Expansion Test Standard Worksheet  
• Request for Renewal/NRTL Certification of Continued Compliance  
 
OSHA is currently seek ing approval for these draft forms from the Office of Management and 
Budget, as required by the Paperwork Reduction Act of 1995.  OSHA intends that the regulated 
community use the se draft forms  for informational purposes only .  The regulated community 
should not rely on the se draft form s for any other purpose, and should not assume that OSHA 
will implement these draft forms , or that , if OSHA implements a ny form s, they will be in the 
format, or even contain identical substantive material, as that contained i n the se draft form s.  
These draft form s have no legal effect, and are not an expression of OSHA policy or procedure.    
 
Annex D -2  
NRTL Initial Application, Expansion and/or Scope Reduction Request  
 
NRTL Initial Application, Expansion,  
and / or Scope Reduction Reques t  
OMB No. 1218 -0147 / Expires:  
10/30/2016  
Annex A  Part I:  General Information  
1.  Legal Name of Applicant:  
2.  Applicant Headquarters Physical Address  
a.  Street Address:  
b.  City:  c.  State/Province  (as applicable) : d.  Postal Code:  
3.  Applicant Headqu arters Mailing Address (if different from physical address)  
a.  Street Address:  
b.  City:  c.  State/Province  (as applicable) : d.  Postal Code:  
4.  Applicant  Website Information  
a.  Website Address:  
b.  Web Address of online certification directory:  
c.  Web Address of online certification mark page:  
5.  Primary Point of Contact Information  
a.  Name:   b.  
Title/Position:   
c.  Telephone 
Number:   d.  Fax Number:   
e.  Email Address:   
6.  Alternate Point of Contact Information  
 
 
Annex D -3 a.  Name:   b.  
Title/Position:   
c.  Telephone 
Number:   d.  Fax Number:   
e.  Email Address:   
Annex B  Part II:  Reason for Request  
7.  Type of Request (Check all that apply)  
  a.  Initial 
Recognition    b.  Expansion – 
New Site(s)    c.  Expansion – 
Additional Test Standards    d.  Scope Reduction    e.  Other  
8.  Brief Explanation of Request:  
 
Annex C  Part I II:  Site Information  
Enter information as indicated for each site to be included in this request.  
9.  Applicant  Site Information  
a.  Site Name and Contact 
Information  b.  Site 
Information  c.  Physical Address and Phone Numbers  
Site Name:  Site Type  
  HQ Site  
  Recognized Site   Address:  
Site POC:  Key Location  
  HazLoc Testing  
  LP Gas Testing  
  Fire Suppression  
  Medical Equipment  Site Phone Number(s):  
POC Email:  POC Phone Number(s):  
Site Name:  Site Type  
  HQ Site  
  Recognized Site  Address:  
Site POC:  Key Location  
  HazLoc Testing  
  LP Gas Testing  
  Fire Suppression  
  Medical Equipment  Site Phone Number(s):  
POC Email:  POC Phone Numb er(s):  
Site Name:  Site Type  
  HQ Site  
  Recognized Site  Address:   
 
Annex D -4 Site POC:  Key Location  
  HazLoc Testing  
  LP Gas Testing  
  Fire Suppression  
  Medical Equipment  Site Phone Number(s):  
POC Email:  POC Phone Number(s):  
Site Name:  Site Type  
  HQ Site  
  Recognized Site  Address:  
Site POC:  Key Location  
  HazLoc Testing  
  LP Gas Te sting  
  Fire Suppression  
  Medical Equipment  Site Phone Number(s):  
POC Email:  POC Phone Number(s):  
Site Name:  Site Type  
  HQ Site  
  Recognized Site  Address:  
Site POC:  Key Location  
  HazLoc Testing  
  LP Gas Testing  
  Fire Suppression  
  Medical Equipment  Site Phone Number(s):  
POC Email:  POC Phone Number(s):  
Site Name:  Site Type  
  HQ Site  
  Recognized Site  Address:  
Site POC:  Key Location  
  HazLoc Testing  
  LP Gas Testing  
  Fire Suppression  
  Medical Equipment  Site Phone Number(s):  
POC Email:  POC Phone Number(s):  
Annex D  Part IV:  Verification of NRTL Requirements  
The legal  signatory’s initials in this part constitute the applicant ’s certification of compliance  / intent to 
compl y with the NRTL Program requirements contained in 1910.7 and the terms of the NRTL’ s recognition  as 
identified in Chapter II , Section F2 (required information) of the NRTL Program Policies, Procedures and 
Guidelines update . 
Part V:  Certification of Information  
11.  As legal signatory for  _____________________________, the applicant , I attest that all statements and information 
contained in this form are correct to the best of my knowledge and are made in  good faith.  I also attest that 
my initials in Part III, “Verification of NRTL Requirements,” constitute the applicant ’s certification of intent to 
comply / continuing compliance with the NRTL Program requirements contained in 1910.7.  In addition, I 
attest that the applicant  will:  a) comply with all the policies, conditions, and requirements for recognition 
that OSHA imposes through its regulations, Directive s, and Federal Register notices of recognition; b) operate 
as an NRTL only within the NRTL’s approved scope of recognition (applicable test standards, sites, and programs), following the policies, procedures, structures, and practices described in the NRTL’s original or 
amended application accepted by OSHA, or in appropriate and approved revisions made after recognition; 
and c) promptly submit details to OSHA of any major changes in the NRTL’s operations.   
 
Annex D -5 12.  Legal Signatory (type  or print name) :  
13.  Signature:  14.  Date:  
   
 
Annex D -6 Paperwork Reduction Act Statement  OMB Control Number:  1218 -0147 
According to the Paperwork Reduction Act of 1995, no person is required to respond to a collection of 
information unless such collection disp lays a valid OMB control number.  Public reporting burden for this 
collection of information is estimated to average  160  hours  for an initial application and no more than 24 
hours for an expansion .  This burden includes locating and assembling information required to complete the 
application.  It may also include an on -site inspection / audit.  The obligation to respond to this collection is 
voluntary .  Information obtained from this form will be used to determine if the appl ication and supporting 
information meets the requirements of the NRTL Program as outlined in 29 CFR 1910.7 .  Send comments 
regarding the burden estimate or any other aspect of this collection of information, including suggestions for 
reducing this burden, to:  U.S. Department of Labor, O SHA, Office of Technical Programs and Coordination 
Activities, Directorate of Technical Support and Emergency Management, 200 Constitution Avenue, NW,  
Room N365 5, Washington, DC 20210.    
 
Annex D -7 Annex E  Form Completion Directions  
General Guidance  
OSHA safety standards require that specified equipment  and materials (products) be tested and certified for 
safety by an OSHA -recognized organization.  OSHA’s  Nationally Recognized Testing Laboratory (NRTL) 
Program fulfills this responsibility by recognizing the  capabilities of  mainly private sector testing 
organizations to test and certify such products for  manufacturers.    
To be recognized, an organization must meet OSHA’s requirements.   Initial recognition  is granted if the 
application and an on -site audit of the  organization  demonstrate the applicant is completely has the 
capability to test and certify products  for safety.  An organization must have the necessary capability both as a 
testing laboratory and as a product certification body to receive OSHA recognition as an NRTL .  Once 
recognized, OSHA  reviews each NRTL’s activities to assure it continues to comply.  The NRTL can also request 
an expansion of its recognition.  This  form, and its attachments,  asks the NRTL to verify its general 
information as well as provide specif ic information related to its facilities and capabilities to meet NRTL 
Program requirements .  Completing this form is entirely voluntary.  Each applicant  is free to submit an 
application for initial recognition or expansion using  any form it chooses.  Howe ver, OSHA will consider  
applications that do not contain the information requested in this form to be deficient a nd may delay or deny 
the request . 
An applicant  that chooses to use this form for initial recognition or expansion  must send:  (1) this complete d 
form; (2) any additional information it wishes to submit to demonstrate capabilities to meet NRTL Program 
requirements ; and (3) payment to:  
Director  
Office of Technical Programs and Coordination Activities  
Directorate of Technical Support and Emergency Management  
Occupational Safety and Health Administration  
US Department of Labor  
200 Constitution Avenue NW, Room N3655  
Washington, DC 20210  
Completed and signed forms and any accompanying documentation may also be scanned and 
emailed to nrtlprogram@dol.gov .  For questions, contact the Office of Technical Programs and 
Coordination Activities  at +1.202.693.2110  
   
 
Annex D -8 Part I  Directions  
Part I of this form provides basic information  related to the applicant.  The informa tion will be used to update 
applicant records and information posted on OSHA’s NRTL webpage.  Complete each bock as indicated below.  
Block 1:   Enter the legal business name of the applicant as currently recognized or requested.  Note:   If the 
applicant w ishes to use a name that is different from the name listed on OSHA’s NRTL page (see 
http://www.osha.gov/dts/otpca/nrtl/nrtllist.html ), the applicant  must submit a request for 
name change to O SHA’s NRTL Program office using the contact information listed above.  
Block 2:   Enter the physical street address, city, state, and postal code for the headquarters office of the 
applicant.  For international addresses, enter the province followed by the  country name in 
Block 1c. 
Block 3:  Enter the physical street address, city, state, and postal code for the headquarters office of the 
applicant.  For international addresses, enter the province followed by the country name in 
Block 2c. 
Block 4:  Block 4a.  Enter the URL for the applicant’s home webpage.  
Block 4b.   Enter the URL for the applicant’s online product certification listing.  Note: if the 
applicant does not have a resource online, include a URL to a webpage that provides directions 
as to how a p roduct certification may be obtained.  
Block 4c.   Enter the URL to the webpage or online resource that explains the usage of the 
applicant’s certification mark as it applies to OSHA’s NRTL Program.  
Block 5:  Enter contact information of the applicant’s prim ary point of contact.  Include their name, title, 
telephone number, fax number, and email address.  
Block 6:  Enter contact information of the applicant’s alternate point of contact.  Include their name, title, 
telephone number, fax number, and email addres s. 
Part II Directions  
Please identify the reason for the application.  For initial requests, ensure to include the Company Profile 
Worksheet.  For initial requests and expansions of test standards, ensure to the Test Standard Worksheet.  
Block 7:  In Bloc k 7a  through Block 7f, place a check next to each action that applies to this application.  
Place a check mark in Block 7d when applying for a supplemental program.  For Block 7f , 
ensure a description of the action is included in Block 8 . 
Block 8:  Provide  a brief description of the action being requested.  
Part I II Directions  
Please enter the site name and address for each site to be included in this application .  Use additional pages as  
 
Annex D -9 required.  
Block 9:  Block 9a.   Enter the full name of the laboratory  to be included with this application.  Enter the 
point of contact (POC) for this site and the POC’s email address.  
Block 9b.   Place a check n ext to the box that is most appropriate site type for the site being 
added in this application.  
Block 9c.   Enter t he complete physical address, site phone number and the POC phone number 
for the site being added.  Be sure to include the name of the country and the telephone country 
code for international sites.  
 
Part V  Directions  
Part V is the applicant’s certificat ion that it will comply / continue to comply with the requirements of the 
NRTL Program as outlined in 29 CFR 1910.7, its letter of recognition, and supporting NRTL Program Directive  
and guidelines.  The blocks in Part V must be completed by the legal signa tory for the applicant.  
Block 11:  Enter the legal business name of the applicant.  See note in Block 1  for additional information 
related to a name change for an NRTL.  
Block 12:  Print or type the name of the individual having legal signatory authority fo r the applicant.  
Block 13:  Enter the signature of the individual having legal signatory authority for the applicant  
Block 14:  Enter the date the individual with legal signatory authority signed this document.  
   
 
Annex D -10 NRTL Initial Application and Expansion Tes t Standard Worksheet  
 
NRTL Initial Application and Expansion  
Test Standard Worksheet  
OMB No. 12 18-0147  / Expires:  
10/30/2016  
Annex F  Part I:  General Information  
1.  Test Standard 
Designation:  2.  Test Standard Title : 
3.  Year of Issue or Revision:  4.  Appro ved By (ANSI, ISA, ASTM, etc.) : 
5.  Name of Laboratory Test Site:  
6.  Laboratory Test Site  Physical Address  
a.  Street Address:  
b.  City:  c.  State/Province /Country : d.  Postal Code:  
Annex G  Part I I:  Test Equipment  
7.  For each item below, identify special requirements / considerations when capturing test data  
a.  Test Standard 
Clause(s)  b.  Type Test or 
Measurement  c.  Equipment Name and Model Number  
   
   
   
   
   
   
 
 
Annex D -11 Annex H  Part III:  Test Procedure  
8.  For each item below, identify special requirements / considerations when capturing test data  
a.  Test Standard 
Clause(s)  b.  Laboratory Test Procedures  c. Procedures  in 
Place?  
   Yes   No 
   Yes   No 
   Yes   No 
   Yes   No 
   Yes   No 
   Yes   No 
   Yes   No 
   
 
Annex D -12 Annex I  Part IV:  Test Data Recording Approach ( Data Sheets)  
9.  Describe approach for recording test data :  
10.  For each item below, identify the test clauses covered and the name (or filename) of the 
corresponding datasheet  
a.  Test Standard 
Clause(s)  b.  Name of Test Datasheet  and Datasheet Item  (datasheet title or filename as 
appropriate)  
  
  
  
  
11.  For each item below, identify special requirements / considerations when capturing test data  
a.  Test Standard 
Clause(s)  b.  Special Requirements / Considerations  
  
  
  
  
Annex J  Part V :  Special Apparatus or Facilities  
12.  For each item below, identify special requirements / considerations when capturing test data  
a.  Test Standard 
Clause(s)  b.  Laboratory Test Procedures  c. Facilities in Place?   
 
Annex D -13    Yes   No 
   Yes   No 
   Yes   No 
   Yes   No 
   Yes   No 
   Yes   No 
   Yes   No 
   
 
Annex D -14 Annex K  Part VI:  Program Integration and Plan Validation  
13.  How will this test standard be integrated into the laboratories training and qualification system?  
14.  How will this test standard be integrated into the applicant ’s factory surveillance program?  
15.  Number of products currently evaluated under this standard.   
16.  Number of products currently listed under this standard.   
17.  Approved By  (type or print name) :  
18.  Signature:  19.  Date:  
   
 
Annex D -15 Annex L  Part VII:  Co mparability Analysis Matrix (optional)  
13.  For each item below, identify special requirements / considerations when capturing test data  
a.  
Comparable 
Standard  b.  Clause  c.  Requirement  d.  Significant Difference  e.  Information NRTLs need to submit  
     
     
     
     
     
     
     
     
     
     
     
     
      
 
Annex D -16      
 
Paperwork Reduction Act Statement  OMB Control Number:  1218 -0147 
According to the Paperwork Reduction Act of 1995, no person is required to respond to a collection of 
info rmation unless such collection displ ays a valid OMB control number.  Public reporting burden for this 
collection of information is estimated to average  2 hours  for each test standard.  This burden includes 
locating and assembling information required to co mplete the application and is included in the burden 
calculated for initial applications and expansions.  The obligation to respond to this collection is voluntary .  
Information obtained from this form will be used to determine if the appl ication and supporting information 
meets the requirements of the NRTL Program as outlined in 29 CFR 1910.7 .  Send comments regarding the 
burden estimate or any other aspect of this collection of information, including suggestions for reducing this 
burden, to:  U.S. Departm ent of Labor, OSHA, Office of Technical Programs and Coordination Activities, 
Directorate of Technical Support and Emergency Management, 200 Constitution Avenue, NW,  Room N365 5, 
Washington, DC 20210.    
 
Annex D -17 Annex M  Form Completion Directions 
General Guidance  
OSHA sa fety standards require that specified equipment  and materials (products) be tested and certified for 
safety by an OSHA -recognized organization.  OSHA’s  Nationally Recognized Testing Laboratory (NRTL) 
Program fulfills this responsibility by recognizing the  capabilities of mainly private sector testing 
organizations to test and certify such products for  manufacturers.    
To be recognized, an organization must meet OSHA’s requirements.   Initial recognition  is granted if the 
application and an on -site audit of the  organization demonstrate the applicant is completely has the 
capability to test and certify products  for safety.  An organization must have the necessary capability both as a 
testing laboratory and as a product certification body to receive OSHA recognition as an NRTL.   Once 
recognized, OSHA  reviews each NRTL’s activities to assure it continues to comply.  The NRTL can also request 
an expansion of its recognition.  This  form, and its attachments,  asks the NRTL to verify its general 
information as well as  provide specific information related to its facilities and capabilities to meet NRTL 
Program requirements .  Completing this form is entirely voluntary.  Each applicant  is free to submit an 
application for initial recognition or expansion using  any form it chooses.  However, OSHA will consider 
applications that do not contain the information requested in this form to be deficient a nd may delay or deny 
the request . 
An applicant  that chooses to use this form for initial recognition or expansion  must send:  (1 ) this completed 
form; (2) any additional information it wishes to submit to demonstrate capabilities to meet NRTL Program 
requirements ; and (3) payment to:  
Director  
Office of Technical Programs and Coordination Activities  
Directorate of Technical Support  and Emergency Management  
Occupational Safety and Health Administration  
US Department of Labor  
200 Constitution Avenue NW, Room N3655  
Washington, DC 20210  
Completed and signed forms and any accompanying documentation may also be scanned and 
emailed to nrtlprogram@dol.gov .  For questions, contact the Office of Technical Programs and 
Coordination Activities  at +1.202.693.2110  
Part I  Directions  
Part I of this form provides basic information  related to the test stand ard.  The information will be used to 
determine if the standard is appropriate and the.  Complete each bock as indicated below.  
Block 1:   Enter the designation for the requested test standard (e.g. UL 2305).   
 
Annex D -18 Block 2:   Enter the full title for the requ ested test standard (e.g. Exhibition Display Units, Fabrication , and 
Installation ). 
Block 3:  Enter the year the test standard was recognized or revised by the standard development 
organization.  
Block 4:  Enter the name of the standards development organiz ation that developed and approved the test 
standard  
Block 5:  Enter the name of the test site that is currently recognized or requested where this testing will 
be conducted.  If more than one test site, list the primary test site or company headquarters.  
Block 6:  Enter the physical street address, city, state, and postal code for the headquarters office of the 
applicant.  For international addresses, enter the province followed by the country name in 
Block 6c. 
Part II Directions  
Please identify the test equipment owned by the applicant that will be used to meet the requirements 
outlined in the requested test standard.  
Block 7:  Block 7a.   Enter the clause(s) in the test standard that require the use of the test equipment.  
Block 7b.   Enter the type of mea surement the test equipment will be used for in relation to the 
clause identified in Block 7a . 
Block 7c.   Enter the name and model number of the test equipment used to take the 
measurement defined in Block 7b . 
Part I II Directions  
Please enter test clause s associated with the requested test standard that require special consideration or 
special requirements when capturing test data.  Identification of special requirements will facilitate the 
analysis of newly identified test standards.  
Block 8: Block 8a.   Enter the clause(s) in the test standard that contain special requirements and / or 
consideration.  
Block 8b.   Enter the procedure the applicant proposes to use to address the special 
requirements and / or consideration as outlined in the clause identified in Block 8a . 
Block 8c.   Check Yes or No to verify if the procedure defined in Block 8b is currently in place at 
the applicant test site.  
Part I V Directions  
Please enter the approach to meeting the requirements for capturing and recording test data defin ed in the  
 
Annex D -19 test standard.  
Block 9: Provide a detailed description of the approach the applicant intends to use to capture and record 
test data.  Include any test datasheets associated with this test standard with the applicant’s 
submission.  
Block 10  Block  10a.   Enter the clause(s) in the test standard that contain specific data collection 
requirements.  
Part I V Directions  (continued)  
Block 10  
(continued)  Block 10b.   Enter the name of the datasheet and the item number used to capture this 
information.  If using an alternate data collection procedure, identify the procedure clause that 
describes how the test data for the clause(s) identified in Block 10a.  
Block 11.  Block 11a.   Enter the clause(s) in the test standard that contain special requirements and / or 
consideration when capturing and recording test data.  
Block 11b.   Enter the procedure the applicant proposes to use to address the special 
requirements and / or consideration as outlined in the clause identified in Block 11a . 
Part V  Directions  
Please enter the special facilities or apparatus that is required to conduct the test for which the applicant 
applied.  
Block 12  Block 12a.   Enter the clause(s) in the test standard that have requirements for special facilities 
or apparatus.  
Block 12b.   Enter the  procedure the applicant proposes to use to address the required special 
facility and / or apparatus outlined in the clause identified in Block 12a.  
Block 12c.   Check Yes or No to verify if the facilities and /or apparatus defined in Block 12b is 
currently  in place at the applicant test site.  
Part VI  Directions  
Please enter the special facilities or apparatus that is required to conduct the test for which the applicant 
applied.  
Block 13  Provide a description of how the requirements of the proposed test p rocedures will be 
integrated into the organization’s training and qualification programs.  
Block 14  Provide a description of how the requirements of the proposed test procedures will be 
integrated into the organization’s factory surveillance programs.   
 
Annex D -20 Block 15  Enter the number of products currently tested by the applicant under this standard (includes 
testing conducted outside the NRTL Program).  
Block 16  Enter the number of products currently listed by the applicant under this standard (includes 
testing c onducted outside the NRTL Program).  
Block 17  Type or print the name of the individual that approved the test standard for incorporation into 
the applicants testing and certification program (the test standard technical point of contact for 
the applicant) .   
Block 18  Place the signature of the individual identified in Block 17 . 
Block 19  Enter the date the individual identified in Block 17  signed the worksheet.  
Part VII  Directions  
Part VII provides an alternative method for validating an NRTL has the req uisite capabilities to meet the 
requirements to conduct a test in accordance with the specifications outlined in the requested test standard.  
Part VII relies on comparing the currently recognized capabilities of an NRTL with comparable requirements 
outlin ed in the requested test standard.  Part VII can be used to identify similarities in capabilities and 
differences.  In identifying differences in capabilities, the NRTL need only demonstrate how these differences 
will be addressed in their operations.  Bec ause Part VII relies on currently recognized capabilities, it is not 
available for use by new initial applicants.   
 
Annex D -21 Block 13  Block 13a.   Enter the name of the comparable test standard.  
Block 13b.   Enter the clause(s) in the test standard listed in Block 13a  that defines comparable 
requirements to a requirement in the requested test standard.  
Block 13c.   Enter a description of the requirements outlined in the test standard listed in Block 
13a  and how these requirements compare to those outlined in the request ed test standard.  
Include the specific clauses in the requested test standard when defining the comparable 
requirements.  
Block 13d.   Enter a description of the significant differences, if any, between the requirements 
outlined in the test standard listed in Block 13a  and those outlined in the requested test 
standard  
Block 13e.   Enter any additional information the NRTL would need to include to demonstrate 
their capabilities in being able to perform the requirements identified in Block 13d . 
 
   
 
Annex D -22 Request for Renewal/NRTL Certification of Continued Compliance  
 
Request for Renewal /  
NRTL Certification of Continued 
Compliance   
OMB No. 12 18-0147  / Expires:  
10/30/2016  
Part I:  General Information  
1.  Legal Name of NRTL:  
2.  NRTL Headquarters Physical Address  
a.  Street Address:  
b.  City:  c.  State /Province (as applicable) : d.  Postal Code : 
3.  NRTL Headquarters Mailing Address (if different from physical address)  
a.  Street Address:  
b.  City:  c.  State /Province /Country ): d.  Postal Code : 
4.  NRTL Websit e Information  
a.  Website Address:  
b.  Web Address of online certification directory:  
c.  Web Address of online certification mark page : 
5.  Primary Point of Contact Information  
a.  Name:   b.  
Title/Position:   
c.  Telephone 
Number:   d.  Fax Number:   
e.  Email Address:   
6.  Alternate Point of Contact Information  
a.  Name:   b.  
Title/Position:   
c.  Telephone 
Number:   d.  Fax Number:   
e.  Email Address:   
 
 
Annex D -23 7.  Additional Information : 
   
 
Annex D -24 Part II:  Site Information  
8.  The information shown for each site listed on the OSHA NRTL Program w ebpage for the NRTL 
is complete and accurate .  (Check only if no changes are needed to OSHA’s webpage listing of your 
sites).  a.  
Note:  A list of recognized sites is available at:  http://www.osha.gov/dts/otpca/nrtl/nrtllist.html     
9.  NRTL Site Information Update  
a.  Site Name  b.  Type Site  c.  Physical Address  
   HQ Site  
  Recognized Site   
  New Site     Update  listing     Remove Site  
   HQ Site  
  Recognized Site  
  
  New Site     Update  listing     Rem ove Site  
   HQ Site  
  Recognized Site  
  
  New Site     Update  listing     Remove Site  
   HQ Site  
  Recognized Site  
  
  New Site     Update  listing     Remove Site  
   HQ Site  
  Recognized Site  
  
  New Site     Update  listing     Remove Site  
   HQ Site  
  Recognized Site  
  
  New Site     Update  listing     Remove Site  
   HQ Site  
  Recognized Site  
  
  New Site     Update  listing     Remove Site  
   HQ Site  
  Recognized Site  
  
  New Site     Update  listing     Remove Site  
   HQ Site  
  Recognized Site  
  
  New Site     Update  listing     Remove Site  
   HQ Site  
  Recognized Site  
  
  New Site     Update  listing     Remove Site  
   HQ Site  
  Recognized Site  
  
  New Site     Update  listing     Remove Site  
   HQ Site  
  Recognized Site  
  
  New Site     Update  listing     Remove Site  
   HQ Site  
  Recognized Site  
  
  New Site     Update  listing     Remove Site  
   HQ Site  
  Recognized Site  
  
  New Site     Update  listing     Remove Site  
   HQ Site    
 
Annex D -25   New Site     Update  listing     Remove Site    Recognized Site  
 
   
 
Annex D -26 Part III:  Verification of NRTL Requirements  
The legal  signatory’s  initials in this part constitute the NRTL’s certification of continuing compliance with the 
NRTL Program requirements contained in 1910.7 and the terms of the NRTL’s recognition.  
Part IV:  Certification of Information  
11.  As legal signatory for  _______ ______________________, the NRTL, I attest that the NRTL requests to renew its 
recognition and that all statements and information contained in this form are correct to the best of my 
knowledge and are made in  good faith.  I also attest that my initials in  Part III, “Verification of NRTL 
Requirements,” constitute the NRTL’s certification of continuing compliance with the NRTL Program 
requirements contained in 1910.7 and the terms of the NRTL’s recognition.  In addition, I attest that the NRTL 
will:  a) cont inue to comply with all the policies, conditions, and requirements for recognition that OSHA 
imposes through its regulations, Directive s, and Federal Register notices of recognition; b) continue to 
operate as an NRTL only within the NRTL’s approved scope o f recognition (applicable test standards, sites, 
and programs), following the policies, procedures, structures, and practices described in the NRTL’s original 
or amended application accepted by OSHA, or in appropriate and approved revisions made after recognition; 
and c) promptly submit details to OSHA of any major changes in the NRTL’s operations.  
12.  Legal Signatory (type or print name) :  
13.  Signature:  14.  Date:  
   
 
Annex D -27 Paperwork Reduction Act Statement  OMB Control Number:  1218 -0147  
According to the Pa perwork Reduction Act of 1995, no person is required to respond to a collection of 
information unless such collection displays a valid OMB control number.   Public reporting burden for this 
collection of information is estimated to average  5 hours  per respo nse.  This burden includes locating and 
assembling information required to complete the renewal or certification , and completing the renewal / 
certification form.  The obligation to respond to this collection is voluntary .  Information obtained from this 
form will be used to determine if renewal of recognition will be granted to the applicant.   Send comments 
regarding the burden estimate or any other aspect of this collection of information, including suggestions for 
reducing this burden, to:  U.S. Departme nt of Labor, OSHA, Office of Technical Programs and Coordination 
Activities, Directorate of Technical Support and Emergency Management , 200 Constitution Avenue, NW,  
Room N365 5, Washington, DC 20210 . 
Form Completion Directions  
General Guidance  
OSHA’s rec ognition of a Nationally Recognized Testing Laboratory (NRTL) is valid for five years unless OSHA 
terminates recognition before the expiration of the five -year period.  A recognized NRTL may renew its 
recognition by filing a renewal request not less than n ine months or more than one year before the 
expiration of its current recognition.   Each NRTL may apply for a continuation of its recognition status by 
following the procedures in 29 CFR 1910.7, App. A.II.C.  Th is form serves a Renewal Request and as a 
Certification of Continued Compliance with NRTL Program requirements.  The form asks the NRTL to verify 
its general information  as well as verify its compliance with NRTL Program requirements .  Completing this 
form is entirely voluntary.  Each NRTL is free to apply for renewal or certify continued compliance with the 
terms of its recognition and 29 CFR 1910.7 in any form it chooses .  However, OSHA will consider a renewal 
request or certification that does not contain the information requested in this form to b e deficient and may 
delay or deny the renewal.  
An NRTL that chooses to use this form for a renewal request or to certify its continued compliance with the 
terms of its recognition and 29 CFR 1910.7 must send:  (1) this completed form; (2) any additional 
information it wishes to submit to demonstrate its compliance with the terms of its recognition and 29 CFR 
1910.7; and (3) payment to:  
Director    
Office of Technical Programs and Coordination Activities  
Directorate of Technical Support and Emergency Managem ent 
Occupational Safety and Health Administration  
US Department of Labor  
200 Constitution Avenue NW, Room N3655  
Washington, DC 20210  
Completed and signed forms and any accompanying documentation may also be scanned and emailed to 
nrtlprogram@dol.gov .  For questions, contact Office of Technical Programs and Coordination Activities  at 
+1.202.693.2110 . 
   
 
Annex D -28 Part I  Directions  
Part I of this form provides basic information related to the NRTL.  The information will be us ed to update 
NRTL records and information posted on OSHA’s NRTL webpage.  Complete each bock as indicated below.  
Block  1:   Enter the legal business name of the NRTL as currently recognized by OSHA.  Note:   If the NRTL 
wishes to use a name that is differe nt from the name listed on OSHA’s NRTL web page (see 
http://www.osha.gov/dts/otpca/nrtl/nrtllist.html ), the NRTL must submit a request for name 
change to OSHA’s NRTL Program office using the contact information listed above.  
Block  2:   Enter the physical street address, city, state, and postal code for the headquarters office of the 
NRTL.  For international addresses, enter the province followed by the country name in Block 
1c. 
Block  3: Ente r the physical street address, city, state, and postal code for the headquarters office of the 
NRTL.  For international addresses, enter the province followed by the country name in Block 
2c. 
Block  4: Block 4a.  Enter the URL for the NRTL’s webpage.  
Block  4b.  Enter the URL for the NRTL’s online product certification listing.  Note: if the NRTL 
does not have a resource online, include a URL to a webpage that provides directions as to how a 
product certification may be obtained.  
Block 4c.   Enter the URL to the webpage or online resource that explains the usage of the NRTL’s 
certification mark as it applies to OSHA’s NRTL Program.  
Block  5: Enter contact information of the NRTL’s primary point of contact.  Include their name, title, 
telephone number, fax numb er, and email address.  
Block  6: Enter contact information of the NRTL’s alternate point of contact.  Include their name, title, 
telephone number, fax number, and email address.  
Block 7:  Enter any additional information the NRTL would like to include with  the application for 
renewal.  Additionally, provide a description of any enclosures to the renewal application that 
the NRTL has included with their request.  
Part II Directions  
Please verify that the site name and address for all recognized sites identi fied on the OSHA NRTL website are 
accurate.  If no changes are necessary, please check the box indicating that you reviewed this information on 
the OSHA NRTL website, and that it is complete and accurate.  If changes are necessary, please update the 
inform ation  as outlined below .  Use additional pages as required.  
Block  8: Review the listing that OSHA has for your recognized NRTL sites using the web addresses listed 
in Block 8 .  If the listing is correct and complete, place a check in Block 8a  and proceed to Block 
10.  If additions or corrections are required, proceed to Block 9 . 
Block  9: Update information f or each site that is not listed, sites where information listed on OSHA’s 
NRTL site webpage is incorrect, or sites that need to be removed.   
Note:   The purpose of this section of the form is to update information related to previously 
recognized sites.  Do not use this form to add new sites that have not previously been 
recognized.  To have new sites considered for formal recognition, submit an expansi on  
 
Annex D -29 application in accordance with Appendix II B. of 29 CFR 1910.7.   
Block 9a.   Enter the name of the site as the NRTL wishes it to be displayed.  Place a check next to 
New Site, Update Listing,  or Remove Site  as applicable.  
Block  9 
(continued) : Block 9b.   Place a check n ext to the box that is most appropriate site type for the site being 
added or updated.  
Block 9c.   Enter the complete physical address for the site being added or updated.  Be sure to 
include the name of the country for international sites.  
Part IV  Directions  
Part IV is the NRTL certification that it will continue to comply with the requirements of the NRTL Program as 
outlined in 29 CFR 1910.7, its letter of recognition, and supporting NRTL Program Directive  and guidelines.  
The blocks in Part IV must be completed by the legal signatory for the NRTL.  
Block  11: Enter the legal business name of the NRTL as currently recognized by OSHA.  See note in Block 1  
for additional information related to a name change for the NRTL.  
Block  12: Print or type the name of the individual having legal signatory authority for the NRTL.  
Block  13: Enter the signature of the individual having legal signatory authority for the NRTL  
Block  14: Enter the date the individual with legal signatory authority signed thi s document.  
  
 
Annex E -1 Annex E -  NRTL Program Fees   
 
 
Reserved – Pending revision to NRTL Program Fee Schedule  
 
OSHA intends to publish a revised NRTL Program Fee S chedule in the near future .