PRODUCT SAFETY 

LABORATORIES

OSHA’s Accreditation 

Process Needs 

Reexamination

Report to Congressional Requesters

December 2012

GAO-13-88

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-13-88, a report to 

congressional requesters

December 2012

PRODUCT SAFETY LABORATORIES

OSHA’s Accreditation Process Needs Reexamination

Why GAO Did This Study

American workers interact with many 

types of products that could pose risks 

to their safety. The NRTL program, 

administered by OSHA, works to 

support employers and workers by 

establishing a process for safetytesting certain equipment and other 

products for use in the U.S. workplace. 

Under this program, which is supported 

by user fees, OSHA accredits thirdparty labs as NRTLs, which then 

determine whether certain types of 

products meet safety standards. 

Because the availability of NRTLs is 

essential to ensuring that employers 

have timely access to products that 

meet safety standards, GAO was 

asked to examine (1) how long it takes 

to make accreditation decisions and 

the key factors that affect timeliness, 

and (2) the extent to which OSHA has 

adopted commonly used strategies for 

improving timeliness. GAO reviewed 

relevant documents and data from 

OSHA; interviewed OSHA officials, 

other NRTL stakeholders, and officials 

from four federal agencies that 

administer accreditation programs for 

other purposes; and reviewed 

information on strategies for improving 

timeliness from past GAO reports and 

other sources. 

What GAO Recommends

GAO recommends that Labor review 

its current structure and procedures for 

accrediting NRTLs and implement

alternatives that would maintain 

effectiveness while improving 

timeliness. Labor agreed with the 

recommendations and described its 

plans to address them.

What GAO Found

The Department of Labor’s (Labor) Occupational Safety and Health Administration’s 

(OSHA) process for accrediting Nationally Recognized Testing Laboratories (NRTL) 

is lengthy due to the scope of staff members’ responsibilities and unclear application 

procedures for accreditation. Among the 13 recently approved applications, OSHA 

took between 1 and 5 years to make accreditation decisions. All of these applications 

took much longer to approve than OSHA’s desired time frames, and in some cases, 

years longer. In addition, 12 of the 29 applications that were awaiting final decisions 

by OSHA as of June 2012 had been under review longer than the 5-year period for 

which the accreditation decision would be valid. This lengthy process has potentially 

negative economic consequences for laboratories and requires OSHA staff to divert 

their time from other oversight activities. Two key factors led to the long time frames:

• Imbalance between staffing levels and scope of responsibilities: The way 

that OSHA has designed the NRTL program requires its four staff members to 

balance many wide-ranging responsibilities. These responsibilities include: 

reviewing all aspects of accreditation, auditing existing laboratories, and 

responding to information requests from other federal agencies. Consequently, 

accreditation applications were sometimes set aside for significant amounts of 

time while OSHA personnel attended to their other responsibilities. 

• Unclear application requirements: OSHA’s requirements for the content and 

level of detail to be provided in accreditation applications—such as detailed 

information to assess independence—differ in important ways from international 

standards used for accrediting safety labs. Lack of clarity in guidance about 

these and other requirements create confusion among applicants and extend 

both the amount of time applicants spend preparing the applications and the time 

OSHA officials spend reviewing them. OSHA said its additional requirements are 

important to the agency’s mission, but it has not formally compared them to 

current international standards or recently assessed the risks, costs, and benefits 

of any procedures that deviate from international standards. 

While OSHA plans to take some steps to improve timeliness, it has not taken 

advantage of a range of promising strategies, including some that might address its 

resource constraints and improve efficiency. GAO identified three key strategies for 

improving timeliness: (1) aligning program design with program mission and 

resources; (2) providing clear guidance and timely communication to stakeholders; 

and (3) developing performance measures and using data to identify inefficiencies. 

GAO found that OSHA has not evaluated the NRTL accreditation process to assess 

whether its current structure is the most efficient for processing and approving 

applications in a timely manner and meeting the program’s goals. Consequently, 

OSHA’s processes may be slower than necessary and planned hiring may not 

adequately address timeliness issues. Since the NRTL program was created in 1988, 

several new approaches to accreditation have been developed. For example, some 

federal agencies have collaborated with outside entities to complete select tasks in 

the accreditation process while continuing to make key oversight decisions in-house. 

The NRTL staff’s current workload has made it difficult for them to implement other 

timeliness strategies, such as providing timely communication to stakeholders. In 

addition, OSHA recently stopped using its NRTL performance measures because 

View GAO officials believed that meeting them was impractical. -13-88. For more information, 

contact Revae Moran at (202) 512-7215 

or moranr@gao.gov. 
Page i GAO-13-88 Product Testing Laboratories

Letter 1 

Background 2

Scope of Staff Responsibilities and Unclear Application Procedures 

Lengthen the Accreditation Process 10

Strategies for Improving Timeliness Exist, but OSHA has Taken 

Limited Steps to Implement Them 22

Conclusions 31

Recommendation for Executive Action 31

Appendix I Objectives, Scope, and Methodology 34

Appendix II Comments from the Department of Labor 38

Appendix III GAO Contact and Staff Acknowledgments 40

Tables

Table 1: Accreditation Processes Used by Selected Federal 

Agencies, for Various Purposes 8

Table 2: Actual vs. Desirable Processing Time Frames for 

Applications Approved from June 11, 2007 to June 11, 2012 12

Figures

Figure 1: Summary of OSHA’s Process for Initial, Expansion, and 

Renewal NRTL Accreditation Decisions 4

Figure 2: Examples of NRTL Certification Marks 6

Figure 3: Duration of Application Processing Times for 

Applications Approved from June 11, 2007 to June 11, 

2012 11

Figure 4: Length of Time Pending Applications Had Been under 

Review, as of June 11, 2012 13

Contents 
Page ii GAO-13-88 Product Testing Laboratories

Abbreviations

CPSC Consumer Product Safety Commission

FCC Federal Communications Commission

HHS Department of Health and Human Services

ISO International Organization for Standardization

NIST National Institute of Standards and Technology

NRTL Nationally Recognized Testing Laboratory

ONC Office of the National Coordinator for Health

Information Technology

OSHA Occupational Safety and Health Administration

SNAP Satellite Notification and Acceptance Program

This is a work of the U.S. government and is not subject to copyright protection in the 

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Page 1 GAO-13-88 Product Testing Laboratories

United States Government Accountability Office

Washington, DC 20548

December 11, 2012

The Honorable Darrell Issa

Chairman

Committee on Oversight and Government Reform

House of Representatives

The Honorable John Kline

Chairman

Committee on Education and the Workforce

House of Representatives

American workers interact with many types of products that may pose 

risks to their safety on the job. Accordingly, the Department of Labor’s 

Occupational Safety and Health Administration (OSHA) requires that 

certain types of safety equipment and other products be safety-tested and 

approved by a Nationally Recognized Testing Laboratory (NRTL) before 

employers may use them in the workplace. Currently, there are 15 

NRTLs. OSHA recognizes, or accredits, laboratories as NRTLs that have 

met the necessary qualifications and requirements specified in program 

regulations and agency guidance. In turn, NRTLs determine whether 

certain types of products—ranging from fire extinguishers to coffee 

makers to power transformers—meet appropriate safety standards. If 

approved by an NRTL, the products are accepted by OSHA for use in the 

workplace.

Because the availability of such labs for product safety testing is essential 

to ensuring employers have timely access to products that meet safety 

standards, you asked that, within the context of OSHA meeting its 

mission, we examine (1) how long it takes to make accreditation 

decisions and the key factors that affect timeliness and (2) the extent to 

which OSHA has adopted commonly used strategies for improving 

timeliness.

To address both research questions, we reviewed relevant federal laws, 

regulations, and OSHA publications on the NRTL program. We also 

interviewed key program stakeholders such as OSHA officials, eight 

NRTL program applicants, and select public and private organizations, 

including non-profits, that accredit safety labs for other programs or 

purposes. To determine how long it took OSHA to approve accreditation 

applications, we reviewed data from OSHA and analyzed time frames for 

applications approved between June 2007 and June 2012. We also 

 
 

Page 2 GAO-13-88 Product Testing Laboratories

analyzed the length of time that applications for which OSHA had not 

made a final determination as of June 11, 2012, had been pending. After 

comparing the data to Federal Register notices, which identified key 

application dates, and through interviews with OSHA officials, we 

determined that the data provided by OSHA were sufficiently reliable for 

our purposes. To identify promising strategies for improving timeliness, 

we reviewed and synthesized findings from various sources, including 

GAO reports, international standards, guidance on accreditation, and 

materials from other organizations and federal agencies. We also 

interviewed officials from public and private accreditation programs and 

organizations, including consortiums of accreditation organizations, about 

their processes and practices to identify examples of promising strategies 

and learn how they have been implemented by others. We selected other 

accreditation programs and organizations to review based on 

recommendations from NRTL program stakeholders and gave priority to 

those accreditation programs that are similar to OSHA’s accreditation 

program in terms of mission or scope. While no other accreditation 

process is completely comparable to OSHA’s, the experiences of others 

provide illustrative examples of actions that federal agencies have taken 

to adapt the accreditation process to their own unique missions and 

circumstances. For more information about our sources and methods for 

identifying promising strategies for improving timeliness, see appendix I.

We conducted this performance audit from April 2012 to December 2012 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

As authorized by the Occupational Safety and Health Act of 1970, OSHA 

issues and enforces workplace safety and health standards (OSHA 

standards).1

 

1 Pub. L. No. 91-596, 84 Stat. 1590, codified as amended at 29 U.S.C. §§ 553, 651-78.

Some OSHA standards require that certain products used in 

Background 

NRTL Program
 

Page 3 GAO-13-88 Product Testing Laboratories

the workplace, such as a variety of electrical equipment, be safety-tested 

and approved by OSHA-accredited laboratories.2 To serve this purpose, 

OSHA established the NRTL program by regulation in 1988. The program 

is currently administered by four staff members and a director who was 

hired in August 2012. The NRTL accreditation process is designed to 

determine whether an organization has the capability and independence 

to test and certify (“approve”) that products meet consensus-based safety 

standards (test standards).3 The main purpose of the NRTL accreditation 

process is to ensure that these organizations are and remain qualified to 

test and certify products used in the workplace.4

OSHA makes three types of accreditation decisions, which are generally 

valid for 5 years:

1. Initial: Determinations about whether to accredit an organization 

as an NRTL for the first time.

2. Expansion: Determinations about whether to expand the purview 

of an accredited NRTL to include other categories of products to 

be tested or to allow an accredited NRTL to conduct testing 

activities at additional sites. For example, an NRTL that is already 

accredited by OSHA to test electric clothes washing machines 

may apply to add additional test standards to its NRTL scope, 

such as standards for testing heat detectors for fire. The duration 

of expansion accreditations may be shorter than 5 years because 

 

2 In this report, we use the term “accredit” to mean the same as “recognize.” OSHA 

officials told us that, while the program formally uses the term “recognize,” it is appropriate 

to describe its process for recognizing third-party laboratories as an accreditation process. 

In addition, we use the term “approved” to include a number of terms used in OSHA’s 

standards, including “approved,” “certified,” “listed,” “labeled,” and “accepted.”

3 29 C.F.R. § 1910.7 and app. A. OSHA standards that require NRTL approval do not 

specify the particular safety requirements that the products must meet; NRTLs generally 

test products against consensus-based safety standards developed by standardsdeveloping organizations. The process for developing these consensus-based safety 

standards involves soliciting input from various stakeholders. Only certain equipment and 

materials are required by OSHA standards to be approved by an NRTL. OSHA 

categorizes these products into 38 broad categories. The largest of these categories, 

according to OSHA, is electrical products and equipment. Other categories include 

portable fire extinguishers, employee alarm systems, and different types of scaffolding. 

4

 OSHA’s regulations specify the criteria that NRTLs must meet, which include testing 

capability, implementation of certain internal controls, independence from employers or 

manufacturers, and maintenance of effective procedures for reporting and handling 

complaints. See 29 C.F.R. § 1910.7(b).
 

Page 4 GAO-13-88 Product Testing Laboratories

expansion decisions expire at the end of the current accreditation 

period.

3. Renewal: Determinations about whether to continue accrediting a 

lab as an NRTL once its previous accreditation has expired. An 

NRTL that submits a sufficient renewal application 9 months to 1 

year before its existing accreditation expires retains its NRTL 

accreditation until the final renewal decision is made.

OSHA also conducts regular onsite audits of accredited NRTLs. The 

NRTL accreditation process generally includes the steps outlined in figure 

1.

Figure 1: Summary of OSHA’s Process for Initial, Expansion, and Renewal NRTL Accreditation Decisions
 

Page 5 GAO-13-88 Product Testing Laboratories

OSHA collects fees from applicants and accredited NRTLs, and uses the 

fees for program expenses.5 OSHA first instituted fees in 2000 and 

calculated them with the intention of covering core application processing 

costs and audits of accredited labs.6 In 2011, OSHA revised its 

calculation of these fees to cover additional program costs, with the intent 

that the NRTL program would be almost entirely funded through fees paid 

by the labs.7

Fifteen labs are currently accredited by OSHA as NRTLs. Combined, 

these labs approve hundreds of types of products for use in the 

workplace. All NRTL-approved products are labeled with the lab’s 

certification mark, so that employers and other consumers can identify 

them in the marketplace (see fig. 2).

Under the revised fee structure, the fee for application 

review will be $17,750 for an initial NRTL application, $8,280 for 

applications to expand to additional sites, and $300 for renewals and 

other expansion applications, in addition to fees for other stages of the 

process. Once fully implemented, OSHA expects that the fees will cover 

approximately 95 percent of program costs, but revenues from fees and 

the percentage of program costs they cover will vary from year to year 

based on the number of applications submitted and audits performed.

8

 

5 29 C.F.R. § 1910.7(f).

To maintain its accreditation, an 

NRTL is required to protect its certification mark by implementing control 

procedures and conducting inspections to monitor its proper use. NRTLs 

are also required to inspect manufacturers to ensure that products 

6 65 Fed. Reg. 46,798 (July 31, 2000).

7 76 Fed. Reg. 10,500 (Feb. 25, 2011). Prior to adjusting the fees, OSHA recovered about 

half of the allowable reimbursable costs of the NRTL program. The 2011 revision to the 

fee structure, which will be phased in over 3 years, allows OSHA to recoup additional 

program costs, including personnel costs for leave and ancillary activities that support the 

NRTL program. Ancillary activities include program administration, training, interagency 

and international coordination, responding to information requests, handling complaints, 

website maintenance, and meeting with stakeholders and interest groups. 

8 According to OSHA, the presence of the lab’s mark on a product does not necessarily 

mean that it meets OSHA requirements because NRTLs sometimes use the same or 

similar marks to denote testing or certification performed in accordance with other 

accreditations. OSHA accepts only products that contain the NRTL's mark and that the 

NRTL has certified within its scope of accreditation, which includes the test standards and 

testing sites that OSHA has recognized for the NRTL. For information on each NRTL's 

scope of recognition, consumers and employers may visit the OSHA website. 

http://www.osha.gov/dts/otpca/nrtl/#nrtls
 

Page 6 GAO-13-88 Product Testing Laboratories

conform to the test standards.9

Figure 2: Examples of NRTL Certification Marks

NRTLs carry out these responsibilities 

during follow-up inspections at the manufacturing facilities, where staff 

ensure that the mark is being controlled properly and that products are 

consistently being manufactured to meet safety standards.

Note: The certification marks listed above reflect marks that were in use as of October 2012. 

Certification marks are generally registered by the NRTL with the U.S. Patent and Trademark Office 

or an equivalent national or international body. While 15 labs are currently accredited by OSHA as 

NRTLs, only 13 marks are shown because two labs share the same certification mark with other labs.

In addition to OSHA, many other federal agencies administer programs 

that require laboratories to receive accreditation to approve products. 

Under these programs, labs are accredited for specialized purposes, such 

as to approve children’s products or ensure that electronic systems for 

records are consistent with federal standards.10

While the specific purposes of these accreditation programs differ, the 

various activities performed during the accreditation process are similar. 

Whether a particular activity is performed by federal agency staff inhouse, or by external entities, varies by agency. First, regulatory agencies 

Labs accredited by OSHA 

are sometimes also accredited to participate in other federal agencies’ 

programs to perform product approval activities for different types of 

products or purposes.

 

9 29 C.F.R. § 1910.7(b)(2) (i)-(iii). 

10 While similar accreditation processes may exist at the state or local government level, 

such processes are beyond the scope of this report.

Accreditation Processes at 

Other Selected Federal 

Agencies
 

Page 7 GAO-13-88 Product Testing Laboratories

establish the requirements that a lab must meet to determine whether 

manufacturers are making products that meet the program’s standards.11

Agencies may require that labs approve products by “testing” a sample of 

a product onsite within the lab’s facilities, “certifying” that products meet 

specific standards based on testing or activities such as inspecting the 

manufacturers’ facilities, or both.12

After the regulatory agency establishes its requirements, accreditation 

organizations then review the operations of specific labs to determine 

whether they are meeting the requirements of the regulatory agency. A 

federal agency may act as the accreditation organization, or an agency 

may designate outside entities to perform the accreditation function. Once 

accredited, the lab follows these requirements to test and certify whether 

products meet program standards. In some cases, the regulatory agency 

will require that separate entities perform the testing and certification 

functions, which is intended to increase the transparency and rigor of the 

process. Regulatory agencies may exercise various types of oversight or 

ongoing monitoring of the other actors in the accreditation process to 

ensure that each of the actors in the process is meeting the program’s 

requirements.

An NRTL accreditation by OSHA 

signifies that the lab is approved by the agency to both (1) conduct 

product safety tests and (2) certify that products meet relevant 

consensus-based safety standards.

Federal agencies and offices may take on different roles in accrediting 

labs depending on a variety of factors, including resource constraints, 

statutory requirements, and decisions on how to manage risks associated 

with non-compliance. In the case of the NRTL program, OSHA acts as 

both the regulatory agency and the accreditation organization, with

support from fees paid to OSHA by applicants and participating NRTLs. In 

contrast, some other agencies establish the requirements that labs must 

meet, but designate one or more outside entities—such as private 

organizations or other government entities—to perform the accreditation 

function. Officials at selected agencies we interviewed explained that, 

 

11 Some requirements may be established by statute, depending on the structure of the 

program.

12 Entities that certify products but do not conduct testing may be called “certification 

bodies” instead of labs. In this report, we use the term lab to mean entities that test, 

certify, or both. 
 

Page 8 GAO-13-88 Product Testing Laboratories

under this model, the outside accreditation organizations, rather than the 

regulatory agency, are responsible for charging and collecting fees from 

labs in order to cover the cost of accreditation application processing and 

approval. The agencies we interviewed do not pay the external 

organizations for performing accreditation duties. See table 1 below for a 

brief description of selected agencies’ accreditation processes.

Table 1: Accreditation Processes Used by Selected Federal Agencies, for Various Purposes

Federal agency OSHA

Federal Communications 

Commission

(FCC)

U.S. Department of 

Health and Human 

Services

(HHS)

U.S. Consumer 

Product Safety 

Commission

(CPSC) 

Program name NRTL Program Equipment Authorization 

Program 

Health Information 

Technology Certification 

Program 

Conformity Assessment 

Body Recognition 

Program 

Brief description of 

program

Labs are accredited to 

test and certify that 

products used in the 

U.S. workplace meet 

appropriate consensusbased safety standards.

Labs are accredited to test or 

certify that certain devices using 

the radio frequency spectrum 

meet FCC’s technical standards 

to prevent harmful interference.

Labs are accredited to 

test or certify that health 

information technology 

systems meet HHS’s 

relevant standards and 

certification criteria.

Labs are accredited to 

test children’s products 

for compliance with 

CPSC’s safety rules.

Designates an 

external entity or 

entities to assist with 

accrediting labs for

product approval 

activities

No Yes Yes a Yes b c

Source: GAO review of OSHA, FCC, HHS, and CPSC documents and interviews with officials.

 

a

b

HHS’s Office of the National Coordinator for Health Information Technology (ONC) has designated 

two different accrediting organizations to accredit labs to perform different types of activities. First, 

NIST’s National Voluntary Laboratory Accreditation Program accredits laboratories to test products. 

Second, for product certification activities, one accreditation organization is approved by ONC 

through a competitive process held every 3 years. Currently, the approved accreditation organization 

is a private organization. See generally 42 U.S.C. § 300jj-11(c)(5), 45 C.F.R. §§ 170.500-170.599.

FCC regulations may require a given piece of equipment to meet one of three levels of review before 

it can be imported or sold. According to officials, whether a given product requires testing or 

certification depends on FCC’s assessment of its risk. The agency has designated the National 

Voluntary Laboratory Accreditation Program, administered by the National Institute of Standards and 

Technology (NIST) of the U.S. Department of Commerce and two private organizations to accredit 

testing laboratories. NIST has currently designated two private organizations to accredit certification 

organizations for FCC’s purposes. For both testing and certification, FCC must agree with the 

accreditation recommendation made by the external organization before the decision is finalized. See 

47 U.S.C. § 302a, 47 C.F.R. §§ 0.241(f)-(g), 2.960, 2.962, 2.948(d).

c

Accreditation organizations must be a signatory to the International Laboratory Accreditation 

Cooperation-Mutual Recognition Arrangement.16 C.F.R. § 1112.3. Signatories have been peerreviewed and determined to meet the International Laboratory Accreditation Cooperation’s criteria for 

competence. Once a testing lab has been accredited, the accreditation must be registered with, and 

accepted by, CPSC. All regulated children’s products are required to be tested by third-party

laboratories, but the manufacturers and private labelers certify the products. See 15 U.S.C. § 
 

Page 9 GAO-13-88 Product Testing Laboratories

2063(a)(2). CPSC’s requirements for accreditation and testing were published in separate notices 

specific to particular safety rules. In May 2012, CPSC published a notice of proposed rulemaking that 

would establish general requirements consistent with these notices. 77 Fed. Reg. 31,086 (May 24, 

2012).

Guidance issued by the National Institute of Standards and Technology 

(NIST), in accordance with the National Technology Transfer and 

Advancement Act of 1995, encourages federal agencies to conduct their 

accreditation processes in a manner that promotes collaboration, reduces 

duplication, and harnesses the private sector, as appropriate.13 Many 

agencies, including OSHA, have incorporated aspects of these principles 

into their program design, such as by requiring the use of consensusbased standards developed by the private sector for product safety 

testing. Unlike OSHA, however, some accreditation programs explicitly 

require that labs meet international standards and guidelines developed 

by the International Organization for Standardization (ISO) as a condition 

of accreditation.14 This can reduce duplication and promote consistency 

among accreditation processes within and across countries. In addition to 

developing and disseminating guidance, NIST provides technical 

assistance services to federal agencies upon request to assist with 

designing and implementing accreditation processes.15

 

13 See Pub. L. No. 104-113, § 12(b), 110 Stat. 775, 783 (1996), codified at 15 U.S.C. § 

272(b)(13) and NIST’s Guidance on Federal Conformity Assessment Activities, 65 Fed. 

Reg. 48,894 (Aug. 10, 2000), codified at 15 C.F.R. pt. 287. The Act and guidance refer to 

conformity assessment, which NIST defines as any activity concerned with determining 

directly or indirectly that requirements are fulfilled. Conformity assessment includes 

accreditation and testing. 

This technical 

assistance often takes the form of one-on-one consulting, and NIST may 

help agencies start new accreditation programs or tailor an agency’s 

existing program to meet the agency’s specific needs. NIST’s National 

Voluntary Laboratory Accreditation Program also assists other federal 

agencies by performing testing lab accreditation. HHS and FCC, for 

example, utilize NIST’s National Voluntary Laboratory Accreditation 

Program to accredit testing laboratories.

14 ISO is the world’s largest developer of voluntary international standards, including 

standards on testing and certification. 

15 Congress established NIST (formerly the National Bureau of Standards) in 1901 to 

support industry, commerce, scientific institutions, and all branches of the government. It 

works with industry to develop and apply technology, measurements, and standards, 

among other activities.
 

Page 10 GAO-13-88 Product Testing Laboratories

None of the accreditation applications approved in the last 5 years were 

processed and approved within the time frames that OSHA officials 

consider desirable, and the time frames for some applications were 

significantly longer. In the 5-year period from June 2007 to June 2012, 

OSHA approved 13 applications. Processing and approval times ranged 

from 1.2 to 5 years (see fig. 3).16

 

16 Our analysis focused on applications with final approval decisions published in the 

Federal Register. The information above does not include cases in which OSHA denied 

accreditation or the application was closed before a final decision was made. Since 2007, 

one renewal application was formally denied by OSHA and it took OSHA over 8 years to 

complete its review of that application. In addition, OSHA closed some applications 

without publishing a final decision on them in the Federal Register. An application may be 

closed in this manner for reasons such as an applicant submitting a new application that 

supersedes the first; an applicant choosing to withdraw an application; or an applicant 

discontinuing communication with OSHA. In at least one case, OSHA suggested that an

applicant withdraw an application partway through the review process because the agency 

deemed the application unlikely to ultimately receive approval. Seven applications 

submitted since June 11, 2007, were closed without OSHA issuing a final decision.

Scope of Staff 

Responsibilities and 

Unclear Application 

Procedures Lengthen 

the Accreditation 

Process 

Application Processing 

and Approval Times Are 

Lengthy Compared to 

OSHA’s Desired Time 

Frames and Other 

Benchmarks
 

Page 11 GAO-13-88 Product Testing Laboratories

Figure 3: Duration of Application Processing Times for Applications Approved from June 11, 2007 to June 11, 2012

Note: These time frames include the time that the applications were with OSHA for review as well as 

any time that the applicants were addressing deficiencies identified by OSHA.

OSHA officials told us that the desirable time frame for processing and 

approving applications is 12 to 18 months for initial applications, 6 to 8 

months for expansion applications, and 3 to 4 months for renewal 

applications. OSHA officials said they expect an application to fall within 

this range if there are no major delays or application deficiencies. For all 

13 applications processed during the 5-year period we reviewed, it took 

much longer to process and approve the application than the desirable 

time frames, and in some cases, years longer (see table 2).
 

Page 12 GAO-13-88 Product Testing Laboratories

Table 2: Actual vs. Desirable Processing Time Frames for Applications Approved from June 11, 2007 to June 11, 2012 

Type and number of 

approved applications 

Range of processing times for 

approved applications

Desirable processing times 

identified by OSHA

Number of applications 

approved within the desirable 

processing time frames

Initial (2) 2.6 years and 5 years 12 to18 months 0 

Expansion (10) 1.2 years to 3.2 years 6 to 8 months 0 

Renewal (1) 4.4 years 3 to 4 months 0 

Source: GAO analysis of OSHA data.

The NRTL accreditation process is also lengthy in relation to the amount 

of time that NRTL accreditations are valid. Our analysis of the processing 

time frames for these initial, expansion, and renewal applications showed 

that it took OSHA 2.5 years or more to complete about half of them. 

These time frames signify a relatively long application period for an 

accreditation term of 5 years and, for some renewal applications, a 

lengthy period in which an existing lab is operating under an extension of 

its existing accreditation.

In addition to these lengthy time frames for approving applications, many 

application decisions have been under review by OSHA for substantial 

lengths of time and remain pending. Of the 29 applications pending 

approval as of June 2012, 12 had been pending for between 5 and 10 

years. Therefore, they had been under review by OSHA for at least as 

long as the term of the 5-year accreditation (see fig. 4). Almost all of the 

applications pending for this long were renewal applications. Further, the 

number of pending applications may underestimate the total number of 

accreditation cases that are awaiting review. At least two of the eight 

laboratories we interviewed had chosen not to submit new expansion 

applications until their earlier expansions were approved because they 

said that it is not productive to have multiple expansion applications going 

through OSHA’s process at once. Officials from one lab noted that they 

decided not to submit a second application to OSHA while the first was 

under review because they did not want OSHA to divide its time between 

the two applications.
 

Page 13 GAO-13-88 Product Testing Laboratories

Figure 4: Length of Time Pending Applications Had Been under Review, as of June 11, 2012

Note: This figure includes all applications for which OSHA had not made a final decision as of June 

11, 2012. For each application, it shows the elapsed time between the date it was submitted and 

June 11, 2012.
 

Page 14 GAO-13-88 Product Testing Laboratories

The lengthy NRTL accreditation process results in negative economic 

consequences for applying labs, according to most of the applicants with 

whom we spoke. Lab officials said that NRTL accreditation processing 

times make it difficult to attract or retain customers or hire and retain 

technical experts. For example, an official with a lab that had a pending 

NRTL expansion application told us that his lab had already been 

accredited by another organization to test and certify the same products 

for use outside the workplace. However, OSHA had not approved the 

lab’s application to test and certify these same products for use in the 

workplace although the lab’s application had been under review for 

several years. He said OSHA’s lengthy NRTL accreditation process hurt 

the lab’s relationship with clients because many manufacturers do not 

want to work with a laboratory unless it can approve products for use 

within the workplace. An official from another laboratory said that the 

company had lost staff members who were hired specifically to support 

the lab’s application for an expanded scope of work. Given the length of 

time that the lab’s expansion application has been under review, it could 

not retain these specialized staff members while it waited for NRTL 

approval. The laboratory will ultimately need to rehire individuals with this 

type of expertise if the application is approved.

The way the NRTL program is designed requires its four staff members to 

balance many wide-ranging responsibilities and can lead to delays in 

approving accreditation applications. Two senior engineers and two junior 

staff members share responsibility for all aspects of the NRTL program.17

• All aspects of approving accreditation applications. This includes 

reviewing all aspects of the accreditation applications; communicating 

with applicants regarding questions and application status; conducting 

site visits; making preliminary accreditation decisions; and preparing 

the Federal Register notices that formalize accreditation decisions.

Labor attorneys also assist the NRTL program. The program is structured 

so that these staff members are responsible for the following:

 

17 OSHA hired an NRTL program director in August 2012. According to OSHA staff, the 

director’s responsibilities focus on providing direction and leadership for the office. 

According to OSHA officials, the individual is not involved in making specific accreditation 

or audit determinations. 

Imbalance between 

Program Staffing Levels 

and Scope of 

Responsibilities Led to 

Long Time Frames and 

Delayed Approval of 

Applications 
 

Page 15 GAO-13-88 Product Testing Laboratories

• Oversight activities for existing labs. According to NRTL program 

policy documents, accredited labs and satellite offices18 should be 

audited by OSHA personnel.19

• Updating program guidance and procedures. This includes making 

revisions to program documents including the NRTL program directive 

on program policies, procedures, and guidelines, as well as other 

guidance on the application review process. Staff must also update 

OSHA’s NRTL website to provide information such as the names and 

approved products for each NRTL.

In total, this includes auditing 

approximately 120 sites worldwide. The staff are also responsible for 

investigating any complaints OSHA receives about accredited labs.

• Responding to requests from other federal agencies. OSHA staff 

told us that federal entities such as the Office of Management and 

Budget and the Office of the United States Trade Representative 

frequently request NRTL program staff input on questions related to 

international trade and product safety.

OSHA officials told us that balancing these responsibilities can be 

challenging and leads to difficult decisions about how to prioritize their 

tasks. They said that their workloads are often affected by tasks that 

originate outside the NRTL program office. For example, staff reported 

having to postpone accreditation work when urgent requests came in 

from the Office of the United States Trade Representative or other federal 

agencies.

Given these wide-ranging duties, NRTL program staff sometimes set 

aside applications for significant amounts of time while they attend to their

other responsibilities. OSHA often cited these competing demands when 

 

18 In May 2009, OSHA implemented a new segment of the NRTL program called the 

Satellite Notification and Acceptance Program (SNAP), which increased the number of 

sites that can be operated by NRTLs. SNAP allows NRTLs to use facilities referred to as 

“SNAP sites,” which the NRTLs control and audit, in order to perform particular functions 

necessary in the NRTL’s testing and certification operations. Participation in SNAP is 

voluntary, and NRTLs must apply to OSHA for approval to participate in the program. 74 

Fed. Reg. 923 (Jan. 9, 2009).

19 Policy documents direct OSHA staff to conduct a combination of onsite and office audits 

of accredited labs. Onsite audits should be performed for each NRTL either annually or on 

another frequency as determined by the NRTL program director. OSHA may perform an 

office audit of each NRTL not scheduled for an annual onsite audit. According to OSHA 

documents, OSHA officials select SNAP sites to audit, in part based on previous audit 

results. The number of SNAP sites that OSHA audits in any year will not usually exceed 

50 percent of the total number of SNAP sites.
 

Page 16 GAO-13-88 Product Testing Laboratories

explaining to applicants its slow process for approving their applications. 

For example, one applicant said that when he asked for a status update 

on his organization’s application several months after submitting it to 

OSHA, an agency official told him it had not yet been opened because no 

one had had time to start processing the application. OSHA officials also 

told us that more complex applications, which may take a lot of time to 

process, are sometimes set aside in order to process applications that are 

more straight-forward, but there is no formal method of prioritizing 

applications for review.

While OSHA does not systematically collect data on the proportion of time 

an application is being actively processed versus the time it is waiting for 

review, available information supports applicants’ concerns that OSHA 

may not be actively reviewing applications for a significant amount of the 

time they are at the agency. OSHA processing, applicant revisions, and 

public comment periods accounted for some, but not all, of the total 

duration of recent application reviews. The estimated time frames for 

each of these steps are described below, but the full duration of 

application processing and approval times for most applications approved 

between June 2007 and June 2012 took months or years longer than the 

estimated time frames for each of these steps combined. This suggests 

that a given application may be set aside for significant amounts of time 

while OSHA personnel attend to their other responsibilities.

• OSHA’s average processing times: OSHA documents show that, 

on average, staff actively work on initial applications for the equivalent 

of about 2.5 months and expansion or renewal applications for the 

equivalent of about 1 month.20

• Applicant revisions: OSHA officials noted that labs often have to 

revise their applications after deficiencies are identified, which 

extends the duration of the time frames for approving applications. 

This may involve two rounds of OSHA comments on written 

applications and two rounds of related applicant revisions. OSHA 

officials said they have sometimes allowed up to 1 year and 2 months 

 

20 OSHA calculated these estimates of the average time it takes the agency to approve 

applications in the course of establishing its new fees. See 76 Fed. Reg. 10,500, 10,505-

07 (Feb. 25, 2011). For initial applications, these estimates assume that two OSHA staff 

conducted an onsite review of one site for 3 days each. For expansion applications that do 

not involve expanding the number of testing sites, these estimates assume that two OSHA 

staff conducted an onsite review of one site for 1 day each. The estimate for renewal 

applications includes one onsite visit of 3 days by one person. 
 

Page 17 GAO-13-88 Product Testing Laboratories

for applicants to complete such revisions. Applicants may also correct 

deficiencies identified by OSHA during site visits, and OSHA allowed 

approximately 1 month for one recent initial applicant to do so. In our 

analysis of the application processing files for three recent initial 

applications, we found that all three applicants revised their 

applications at least once and the total revisions for each application 

took from 6 to 11 months.21

• Public comment period: For all types of applications, OSHA 

provides a public comment period that begins when it publishes its 

preliminary accreditation decision in the Federal Register. According 

to OSHA’s regulations, the minimum period for public comment on 

initial applications is 30 days, while the minimum period for public 

comment on renewal or expansion applications is 15 days.

In addition to extending the time it takes OSHA to approve applications, 

staff workload also leads to delays in responding to applicants’ questions 

about the status of their applications. Almost all of the applicants we 

interviewed expressed frustration about the amount of time it took to 

receive responses from OSHA and often said that OSHA officials 

attributed slow response times to their workload. Officials at one 

laboratory stated that there was about a 50/50 chance of ever receiving a 

response from OSHA when they contacted program staff. Officials of 

another laboratory described the OSHA accreditation process as a “black 

box” because applicants were uncertain about when their applications 

would reach the next milestone. Several applicants said that this 

uncertainty made the long application processing time frames even more 

difficult for their businesses because they could not plan for budgetary 

needs or update their clients on when they would offer new services. 

Several labs also noted that other accreditation programs respond to

questions within a few days, so the delays in receiving responses from 

OSHA staff make the program an outlier. OSHA officials told us they used 

to provide applicants with quarterly updates that included projected target 

 

21 We reviewed files of three initial applications approved or closed between June 2007 

and June 2012; one of these was not included in our analysis of approval times because it 

was withdrawn before a final decision was made. This applicant only provided one round 

of revisions prior to withdrawing its application. We calculated these estimates by 

identifying the date that OSHA provided letters of deficiency to applicants and the dates 

that applicants submitted revised applications. In cases where OSHA provided two letters 

of deficiency and applicants provided two revised applications, we included both revision 

time periods in our calculation. This calculation does not account for any other time 

periods when OSHA may have been waiting on more informal email responses from 

applicants, etc. 
 

Page 18 GAO-13-88 Product Testing Laboratories

dates for the various stages of the application approval process, but they 

stopped providing these quarterly updates because the agency could not 

meet its projected target dates.

Decisions about how to prioritize staff workload also affect the amount of 

internal review that accreditation decisions receive before they are 

finalized and can have negative impacts on applicants’ trust of program 

operations. GAO guidance on internal controls highlights the importance 

of separating key duties such as initial decisions and reviews of those 

decisions.22 International accreditation standards also require that final 

accreditation decisions be made by competent individuals or committees 

different from those who carried out the assessment.23

Further, staffing roles and responsibilities affect the level of oversight 

OSHA provides once an accreditation application is approved. For 

example, to reduce the number of pending applications, OSHA staff 

reprioritized their duties so that a senior engineer could spend the 

majority of his time processing and approving applications. While this 

provided more resources for the application process, officials said it 

reduced the time they can spend auditing existing NRTLs, and several 

labs we interviewed confirmed that they had been audited less frequently 

in recent years. Auditing the NRTLs less frequently increases the 

likelihood that any problems with an accredited lab will go unnoticed. The 

However, OSHA’s 

accreditation decisions for NRTLs are not consistently reviewed by a 

second technical reviewer before being finalized. OSHA officials said that 

the decisions are reviewed for legal accuracy, and are approved by upper 

management, but given the small size of the NRTL staff and their heavy 

workload, the person who conducts the initial reviews of applications is 

often the same person who makes the final recommendation about 

whether a lab should be accredited. While this might decrease the 

processing time for some applications or be the most feasible approach 

given program staffing levels, it can create a greater potential for error or 

bias. Two applicants we spoke with expressed concern about the 

absence of a second technical reviewer.

 

22 GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: Nov.1999).

23 See ISO, Conformity Assessment—General Requirements for Accreditation Bodies 

Accrediting Conformity Assessment Bodies, ISO/IEC 17011:2004, 4.3.5 and 7.8-7.9 

(Geneva, Switzerland, February 2005).
 

Page 19 GAO-13-88 Product Testing Laboratories

extensive time it takes OSHA to approve renewal applications also means 

that labs are sometimes operating under previous accreditations for much 

longer than the 5 years for which they are valid because OSHA 

regulations generally allow labs to retain their accreditation and continue 

approving products while they wait for OSHA’s decisions on their 

applications for renewal. This can minimize the impact that processing 

delays have on a lab’s business operations, but it also means that a lab 

with performance problems could operate for an extended period of time 

after its 5-year accreditation period, even if the lab’s renewal is ultimately 

rejected. For example, one lab’s recent renewal application was pending 

for 8 years before OSHA ultimately rejected it.

Most of the applicants we spoke with told us that OSHA’s guidance does 

not always provide adequate information about the program’s application 

requirements, which creates confusion and adds time to the review 

process. Applicants found the guidance particularly confusing because 

OSHA’s requirements for the content and level of detail labs must provide 

in their accreditation applications differ in important ways from those of 

many other organizations that accredit safety labs by using current 

international standards for accreditation.24

 

24 The key international standards for conducting safety lab accreditation were developed 

by the International Organization for Standardization (ISO). ISO/IEC 17011:2004 provides 

standards for how accreditation organizations conduct their work, ISO/IEC 17025:2005 

provides standards for how testing laboratories should be assessed for accreditation, and 

ISO/IEC 17065:2012 provides guidance on how certification organizations should be 

assessed for accreditation. 

For example, several NRTLs 

noted that the types of product approval activities they conduct or are 

applying to conduct for the NRTL program are similar to the work that 

they do under other accreditation programs. Some of the information 

OSHA requires during its application process to test those products 

differs from what other programs require in ways that applicants believe 

are not clearly articulated in NRTL guidance. When the program last 

updated its application policies in 1999, OSHA developed these 

deviations from international standards in order to ensure that NRTLs 

were qualified to meet all aspects of the program’s mission and 

requirements. At the time they completed their applications for the NRTL 

program, most applicants said they were unclear about how and why the 

NRTL requirements differed from international accreditation standards, 

which led to confusion and affected the timeliness of the process. For 

Unclear Application 

Requirements Further 

Increase the Length of 

Accreditation Reviews
 

Page 20 GAO-13-88 Product Testing Laboratories

example, officials at a lab that recently submitted an initial application to 

OSHA said the agency required them to provide additional detail about 

the work procedures they planned to use when conducting tests of 

equipment. This information was not required when they submitted similar 

applications to other accreditation organizations and lab officials were 

unaware of this difference when they initially prepared and submitted their 

accreditation application to OSHA. The lab ultimately had to revise its 

application to meet OSHA’s requirements, extending both the amount of 

time lab staff spent preparing the application and the time OSHA officials 

spent reviewing it. OHSA officials told us that such detail is key to 

ensuring that lab staff have the knowledge to perform the required safety 

tests. Officials stated that the agency intends to revise its policies and 

guidance to better convey its application expectations, but has not yet 

done so due to workload issues.

Confusion resulting from OSHA’s unclear guidance is compounded in 

cases where OSHA’s requirements are evolving. For example, OSHA has 

been revising its process for verifying the independence of labs since 

2008, but it has not updated the independence policies in its policy 

directive or other application guidance.25

 

25 OSHA’s regulations require that an NRTL 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 C.F.R. § 1910.7(b)(3). A 2005 

report by the Department of Labor’s Office of the Inspector General was the impetus for 

the change to NRTL program procedures for verifying independence. Department of Labor 

Office of the Inspector General, OSHA Correctly Denied ED&D’s Incomplete NRTL 

Application, 05-05-002-10-001, (March 31, 2005: Washington, D.C.). This report had three 

recommendations related to independence: (1) make independence reviews a mandatory 

part of application reviews and periodic audits; (2) modify current policy to ensure that all 

areas related to an NRTL’s recognition, including independence, are reviewed at least 

once during each 5-year recognition period; and (3) review two NRTLs’ current business 

practices to ensure conformance with the independence requirement.

OSHA officials said that the 

agency continues to process renewal applications while it revises its 

independence policies, but they have delayed making final decisions until 

the requirements are finalized. They noted that this process is timeconsuming. There were 13 renewal applications pending in June 2012, 10 

of which were pending for 5 years or more. Officials from several labs 

said that they have not received clear guidance from OSHA on the level 

of information required to illustrate independence and, therefore, they 

have had to provide several rounds of information to OSHA in their 

applications. One lab said that gathering this additional information is time 

consuming because it often involves obtaining information about 
 

Page 21 GAO-13-88 Product Testing Laboratories

individuals and companies with a minority financial interest in the labs, 

some of whom are located in different countries. Several applicants with 

pending expansion or renewal applications also said that some of 

OSHA’s requirements seem to have evolved over time and OSHA has not 

revised its guidance to include these new requirements. Representatives 

from these labs said OSHA identified deficiencies in their most recent 

expansion applications although they provided similar types of information 

in previous years on applications accepted by OSHA.

While OSHA’s application requirements may differ from international 

standards in order to meet the agency’s safety mission, OSHA has not 

compared its requirements to current international standards to identify 

differences and assess their costs and benefits in order to ensure that the 

time devoted to assessing applicants against additional requirements is 

well-spent. OSHA officials told us the additional information about work 

procedures and independence they require of applicants is necessary to 

ensure the quality of the product approval process and that applicants 

follow program requirements. For example, OSHA officials said that the 

requirement in OSHA regulations that labs be “completely independent” 

of manufacturers presents a high bar for application review, and 

international standards on accreditation do not include such extensive 

requirements. When OSHA developed its NRTL policy directive in 1999 

detailing the specific requirements for accreditation applications, it 

modified the international standards that were available at that time to fit 

NRTL program needs and requirements.26

 

26 The NRTL program application requirements are described in OSHA Directive CPL 01-

00-003: NRTL Program Policies, Procedures, and Guidelines. OSHA’s regulations state 

that an applicant shall “provide sufficient information and detail” demonstrating that it 

meets NRTL program requirements, and identify the scope of recognition it is seeking, 

including the testing methods it will use. 29 C.F.R. § 1910.7, app. A.

However, subsequently, the 

agency has not formally reviewed the NRTL procedures against the 

current versions of international standards on accreditation or recently 

assessed the risks, costs, and benefits of having procedures that deviate 

from these standards. NIST guidance recommends that agencies 

establish ongoing processes for reviewing their accreditation activities 

and, to the extent possible, coordinate with federal, private, and 

international organizations. Officials told us that they would like to

evaluate their procedures against current international standards, but 

have not had time to do so. Without OSHA conducting a risk assessment 

of its current requirements, the extent of any value added from the 
 

Page 22 GAO-13-88 Product Testing Laboratories

program’s additional application requirements is unknown, as are any 

trade-offs the agency makes by devoting more resources to the 

application review. In addition, the rationale for these requirements may 

be unclear to applicants. Perhaps as a consequence, about half of the 

NRTL applicants we spoke with questioned whether all of OSHA’s 

application procedures were necessary. For example, two applicants 

questioned whether it was necessary for OSHA’s independence review to 

cover individuals sitting on the boards of companies only marginally 

affiliated with the testing lab. On the other hand, representatives from two 

of the eight labs we interviewed said that certain OSHA requirements 

enhanced the quality of the program by, for example, providing detailed 

information about work procedures that was helpful in training new staff. 

While additional requirements imposed by OSHA may have value, where 

their purpose has not been articulated or their actual value has not been 

assessed, applicants may be more likely to question whether the 

requirements are justified and OSHA may not be expending its resources 

to optimum benefit. 

While a range of promising strategies for improving timeliness exist, 

including some that might help address resource constraints, mitigate 

confusion over application procedures, and improve efficiency, OSHA has 

taken limited steps to implement such strategies in its accreditation 

process. Based on our review of various sources, including GAO reports,

we identified three promising strategies for improving timeliness: (1) 

aligning program design with program mission and resources; (2) 

providing clear guidance and timely communication to program 

stakeholders; and (3) developing performance measures and using data 

to track progress in meeting them to identify inefficiencies. For more 

information on how we arrived at these three strategies and the sources 

we reviewed, see appendix I.

Past GAO work on program management has found that agencies can 

improve efficiency, including timeliness, by aligning program design with 

resources through various actions.27

 

27 See GAO, Streamlining Government: Key Practices from Select Efficiency Initiatives 

Should be Shared Governmentwide,

For example, in some instances, 

streamlining procedures can save resources, improve productivity, and 

GAO-11-908 (Washington, D.C.: Sept. 30, 2011).

Strategies for 

Improving Timeliness 

Exist, but OSHA has 

Taken Limited Steps 

to Implement Them

OSHA’s Program Design is 

Not Aligned with Program 

Resources
 

Page 23 GAO-13-88 Product Testing Laboratories

help staff focus more time on performing essential program activities. In 

other instances, a fundamental reexamination of program structure may 

be appropriate and can provide insight into whether government 

operations are outmoded and need to be restructured. According to 

guidance from the Office of Management and Budget and previous GAO 

reports on risk management, agencies can also benefit from evaluating 

program procedures by analyzing the associated risks, benefits, and 

costs of changes to program operations.28

We found that OSHA has not formally revisited its structure for accrediting 

testing laboratories since the NRTL program started over 20 years ago. 

Because the NRTL program was established by regulation and not by 

statute, OSHA has flexibility to define its requirements for accreditation. 

When the NRTL program was established in the 1980s and OSHA’s 

current approach to accreditation was determined, OSHA said that it 

intended to monitor the program and look for alternatives to its 

accreditation approach, including investigating the possibility of using 

other entities to carry out NRTL accreditation activities.

Conducting such analyses 

helps agencies effectively decide how to prioritize their work, consistent 

with their mission and resources. Furthermore, collaborating with other 

government agencies and similar industry organizations is another step 

that agencies can take to improve program design and align program 

structure with resources. Collaboration allows programs to capitalize on 

the expertise of others, coordinate activities, and avoid unnecessary 

duplication and complexity.

29

 

28 See Office of Management and Budget, Updated Principles for Risk Analysis, M-07-24 

(Washington, D.C.: Sept. 19, 2007), and GAO, Strategic Budgeting: Risk Management 

Principles Can Help DHS Allocate Resources to Highest Priorities, 

However, we 

found that OSHA has taken limited steps to think strategically about the 

future of the NRTL program and how alternatives to its current 

accreditation process may allow the program to fulfill its mission in a more 

efficient way. An NRTL official said there have been informal discussions 

at the staff level about working with an external organization to conduct 

aspects of the accreditation review process, but the agency has not 

formally assessed such approaches internally or in collaboration with 

GAO-05-824T 

(Washington, D.C.: June 29, 2005).

29 53 Fed. Reg. 12,102, 12,114 (Apr. 12, 1988).
 

Page 24 GAO-13-88 Product Testing Laboratories

other agencies such as NIST.30

Although OSHA has not recently revisited its overall approach to 

accreditation, it has begun implementing some steps to better align NRTL 

program design with its resources; the outcome of these actions, 

including how they will improve timeliness, remains unclear. For example, 

OSHA is in the process of phasing in increased fees for the NRTL 

program, which are intended to allow OSHA to recoup a larger 

percentage of the cost of administering the program, and OSHA plans to 

use that revenue to hire additional staff. However, even with these 

increased fees, OSHA estimates NRTL program expenditures for fiscal 

year 2012 to be almost $800,000 greater than the fees collected: 

revenues are estimated to be about $100,000 and expenditures to be 

$870,000.

Several NRTL applicants we interviewed 

thought that OSHA should reevaluate its approach to accreditation. For 

example, a few of the NRTL applicants we interviewed said there has 

been a shift in accreditation approaches since the NRTL program started 

in the late 1980s and OSHA has not always kept pace with these 

changes.

31 An NRTL program official said that the estimated revenues 

for fiscal year 2012 are relatively low mainly because staff were not able 

to perform many audits due to their workload.32

 

30 While NIST provides technical assistance services to federal agencies upon request to 

assist with designing and implementing accreditation processes, the Performance 

Management Center, which is housed within the U.S. Department of Labor’s Office of the 

Assistant Secretary for Administration and Management, strives to improve Labor’s 

program performance efforts through data-driven analysis and sharing best practices. 

Among its other activities, the Performance Management Center provides advisory 

services to those Labor programs seeking to improve performance, but only upon request. 

We found that OSHA has not consulted with the Performance Management Center.

The revenues from 

increased fees are intended to be used to hire additional staff to improve 

the timeliness of its application review process and to perform other 

necessary program functions. However, OSHA has encountered 

difficulties trying to find senior level staff with engineering experience and 

has been unable to fill the positions to date. Therefore, OSHA plans to 

revisit its hiring strategy and seeks to hire four additional staff members in 

31 The expenditure figure is based on the existing four NRTL program staff and includes 

estimates of salary and benefits for the program staff and for one Labor attorney who 

assists the program; travel expenses, mainly for performing audits; and general office 

expenses.

32 OSHA charges labs fees for the audits, which increases the agency’s revenues for that 

year.
 

Page 25 GAO-13-88 Product Testing Laboratories

2013. If the agency is successful in its hiring efforts, officials anticipate 

holding extensive training sessions for new staff members to prepare 

them for their responsibilities. While using higher fees to increase staffing 

is promising in theory as a means of improving timeliness, GAO has 

found in the past that, in practice, there may be problems associated with 

this approach. For example, it can be difficult to hire and train people 

quickly enough or retain them long enough to affect timeliness. 

Furthermore, if fewer accreditation applications are submitted than 

expected, fees may fall short of estimates, making it difficult to plan and 

budget for the program.33

Unlike OSHA’s NRTL accreditation process, other federal agencies we 

interviewed relied in part on other public or private organizations to carry 

out the accreditation process and maximize their resources. The outside 

accreditation organizations often charge and collect fees from the labs in 

order to cover the cost of accreditation application processing and 

approval, but according to the federal agencies we interviewed, these 

organizations do not charge fees to the federal agencies. The federal 

agencies we interviewed also worked with NIST to plan, design, and 

develop their accreditation programs. Although each federal agency has a 

unique mission and a distinct process for accrediting labs, the examples 

below illustrate varied actions that agencies have taken in their efforts to 

adapt their processes to maximize resources and meet their own unique 

missions and circumstances.

Due to the unpredictability of the volume of 

applications received, OSHA cannot be certain that increased fees will 

lead to higher revenues, as projected, and the outcome of OSHA’s efforts 

to hire and retain additional staff remains unclear.

34

 

33 See GAO, Food and Drug Administration: Effect of User Fees on Drug Approval Times, 

Withdrawals, and Other Agency Activities, GAO-02-958 (Washington, D.C.: September 

2002).

34 GAO did not evaluate the effectiveness of the selected agencies’ accreditation 

programs and processes, but we analyzed them for variations in structure. For more 

information on how we selected federal agencies for review, see appendix I.
 

Page 26 GAO-13-88 Product Testing Laboratories

• FCC’s Equipment Authorization Program35

• HHS’s Health Information Technology Certification Program - 

Like FCC, HHS officials decided to collaborate with external 

organizations in order to maximize program resources and harness 

the expertise of others. HHS officials said that because health 

information technology systems are complex, have important 

implications for patient safety, and present a high risk for potential 

fraud and abuse, it was important for HHS to be involved in 

developing policies and to tailor HHS’s accreditation processes to fit 

the unique needs of the program.

 - FCC officials told us 

the agency originally required labs to submit accreditation applications 

directly to FCC, but then restructured its approach to address 

resource constraints in the agency by collaborating with outside 

accreditation organizations. In order to satisfy FCC’s requirements, 

labs accredited through these outside accrediting organizations must 

meet both international standards and additional program-specific 

requirements. While the outside organizations evaluate labs and 

make recommendations about whether a lab meets FCC’s criteria and 

procedural requirements, FCC makes the final decision about whether 

to accept the lab into its programs. An FCC official said that working 

with outside accrediting organizations means that FCC has to 

constantly educate these organizations about program changes and 

new technology. However, the official said that using this structure 

allows FCC to use its limited resources to focus on critical compliance 

issues and the more technical aspects of the program while 

capitalizing on the expertise of organizations that have specialized 

backgrounds in accreditation.

36

 

35 The Communications Act of 1934, as amended, authorizes FCC to regulate devices 

that may cause radio interference, 47 U.S.C. § 302a. FCC has developed two separate 

accreditation programs to support its equipment authorization activities, one focused on 

testing and one focused on certification. Information included in this section largely refers 

to FCC’s certification program. For more information about FCC’s equipment authorization 

activities, please see table 1 of this report. 

For example, according to agency 

officials, HHS worked with NIST to develop sector-specific 

requirements for accrediting certification organizations in addition to 

using international accreditation standards. HHS officials said that by 

designating outside organizations to make accreditation decisions, 

36 The Health Information Technology for Economic and Clinical Health Act authorized 

certain Medicare and Medicaid incentive payments for the adoption and meaningful use of 

certified electronic health record technology, and required HHS to develop a voluntary 

certification program for health information technology. Pub. L. No. 111-5, div. A, tit. XIII, 

div. B, tit. IV, 123 Stat. 115, 226-79, 467-96 (2009).
 

Page 27 GAO-13-88 Product Testing Laboratories

they are better able to focus on the program’s goals and strategic 

planning, and are less focused on administrative tasks, such as 

collecting and tracking fees. They also said that using this structure 

has allowed them to make decisions about how to design their 

accreditation approach based on what will best fulfill their mission, 

rather than what resources are available in-house.

• CPSC’s Conformity Assessment Body Recognition Program - 

Officials at CPSC recognized that their relatively small staff was not 

prepared to perform accreditations themselves and that there were 

not enough time, resources, and expertise within the CPSC to run a 

large-scale international accreditation program.37

Another approach that may help a program align its design with its 

resources is to use contractors to supplement limited in-house staff. For 

example, representatives from some of the private accreditation 

organizations we interviewed, including some that conduct accreditation 

activities for the federal agencies discussed above, said they use 

individual contractors on an as-needed basis. This reduces the need for 

full-time staff and helps to ensure that those individuals performing 

accreditation activities possess the necessary expertise. These 

organizations said that using contractors provides organizations with the

flexibility to quickly adjust staffing levels based on the amount of work, 

and the particular accreditation work that needs to be performed. It also 

allows them to retain appropriately skilled people to perform the 

accreditation work. However, federal agencies’ use of private contractors 

is subject to various requirements, which limit the type of functions that 

After consulting with 

NIST and weighing its options, CPSC ultimately decided to leverage 

the expertise and experience of an international organization whose 

member accreditation organizations meet international standards for 

accreditation and have been deemed competent through a peerreview process. CPSC officials believe this approach provides 

additional transparency in the process. Although CPSC does not 

accredit labs itself, it maintains a list of approved labs by requiring 

labs to apply directly to CPSC and by verifying that different types of 

labs have been appropriately accredited.

 

37 Among other requirements, the Consumer Product Safety Improvement Act of 2008 

established a third-party safety testing requirement for children’s products (defined as 

consumer products designed or intended primarily for children 12 years of age or younger) 

and set deadlines for implementation. Pub. L. No. 110-341, § 102, 122 Stat. 3016, 3022. 

Prior to the passage of this act, CPSC had never participated in lab accreditation 

activities, according to officials. 
 

Page 28 GAO-13-88 Product Testing Laboratories

may be performed by contractors and entail a commitment of time and 

resources to meet.38 In addition, an OSHA official told us that if the 

agency were to rely on outside individuals, it would need to ensure their 

competency and independence.

Clear guidance and communication with applicants can also serve to 

improve the timeliness of the accreditation process. Guidance that does 

not give applicants the information they need to submit an acceptable 

application can delay approval. GAO’s internal control guidance states 

that program managers should ensure there are adequate means of 

communicating with, and obtaining information and feedback from, 

external stakeholders who may have a significant impact on the program 

achieving its goals.39 Not only do clear guidance and communication 

contribute to timely processes, but they also serve to enhance the 

transparency of programs and policies by explaining program criteria and 

may increase trust and confidence among stakeholders.40

OSHA’s current structure and workload have made it difficult to provide 

clear guidance and timely communication to applicants. Most of the NRTL 

applicants we interviewed stated that OSHA could enhance its guidance 

and communication in order to improve the timeliness of the accreditation 

process and to help make the accreditation process more transparent. 

The directive on NRTL program policies and procedures has not been 

revised since 1999, and OSHA has not updated its NRTL application 

guidelines since 2000. A new director assumed responsibility for the 

NRTL program in August 2012, and plans to focus on improving the 

consistency and clarity of program procedures and guidance, but it is too 

early to determine the timing and scope of such revisions. OSHA plans to 

issue interim program guidance in the short-term while later updating 

NRTL application guidelines and the directive on NRTL program policies 

and procedures.

 

38 For example, federal agencies generally must follow the procedures delineated in the 

Federal Acquisition Regulation. See, e.g., 48 C.F.R. § 7.5.

39 See GAO, Standards for Internal Control in the Federal Government, AIMD-00-21.3.1

(Washington, D.C.: November 1999). 

40 See GAO, Certification Requirements: New Guidance Should Encourage Transparency 

in Agency Decisionmaking, GAO/GGD-99-170 (Washington, D.C.: September 1999).

OSHA Lacks Clear 

Guidance and Timely 

Communication with 

Applicants 
 

Page 29 GAO-13-88 Product Testing Laboratories

We also found that OSHA had not adopted some of the measures to 

disseminate information used by other accreditation organizations we 

interviewed. For example, one of the accreditation organizations we 

interviewed holds an annual meeting specifically to hear from clients, and 

FCC hosts workshops twice a year where it shares program updates and 

explains program requirements to stakeholders. OSHA, on the other 

hand, occasionally speaks at trade association conferences and 

participates in workshops sponsored by NIST, but it does not hold regular 

meetings to update stakeholders and solicit feedback. An OSHA official 

did say that about 2 years ago, he started to initiate phone calls with labs 

interested in applying to the NRTL program to clarify the requirements for 

applications, with the intention of minimizing the back and forth that takes 

place during the application process. In his opinion, applicants have found 

these calls useful.

Other accreditation organizations we interviewed have taken steps to 

enhance guidance and communication with applicants, such as 

developing systems to provide applicants with status updates and 

information in “real time.” For example, two accreditation organizations 

we interviewed maintain online portals that allow applicants to check on 

the status of their applications throughout the various stages of the 

application process. Furthermore, FCC manages a database for providing 

information to stakeholders. This database provides answers to frequently 

asked questions submitted by stakeholders and helps to ensure that FCC 

is giving consistent advice and answers to questions. FCC officials also 

said that input from stakeholders helps inform their guidance publications.

Our research on program management underscores the importance of 

developing performance goals and measures to track progress and 

evaluate program performance. Developing a range of related 

performance measures and balancing these measures to address quality, 

timeliness, efficiency, cost of service, and outcomes also allows a 

program to balance priorities among other demands and gives managers 

crucial information on which to base their organizational and management 

decisions.41

 

41 See GAO, Tax Administration: IRS Needs to Further Refine Its Tax Filing Season 

Performance Measures, 

In addition, using data to understand time frames offers an 

GAO-03-143 (Washington, D.C.: Nov. 22, 2002).

OSHA Does Not Currently 

Track the Quality and 

Timeliness of Its 

Accreditation Process 

Using Performance 

Measures
 

Page 30 GAO-13-88 Product Testing Laboratories

opportunity to identify potential inefficiencies and strategies for improving 

timeliness.

OSHA developed performance measures for the NRTL program, 

including measures for timeliness of the approval process. However, it 

recently discontinued using these measures, because staff members’ 

workload increased to the point that it was impractical to achieve the 

metrics established. Through informal monitoring of the time it takes to 

approve accreditation applications, OSHA recognizes that its 

accreditation process has been taking longer than expected, especially 

for those applications with no major deficiencies or issues. OSHA officials 

are hoping that their plans to hire additional staff will bring the NRTL 

program closer to achieving their timeliness goals. It remains unclear, 

however, whether planned hiring efforts will adequately address 

timeliness issues or how OSHA plans to reinstitute its performance 

measures. OSHA also collects some program data, but it does not 

currently use the data to track timeliness or analyze trends. For example, 

in response to one of the recommendations included in a 2005 report by 

Labor’s Office of Inspector General, OSHA developed a contact log so 

that the NRTL program could maintain a log of calls, e-mails, and related 

details.42

OSHA does not have performance measures to assess the quality and 

timeliness of its accreditation process, although such measures have 

been adopted by most of the accreditation organizations we contacted. 

For example, one accreditation organization had target dates in place for 

each phase of its application process and tracked its performance in 

relation to the targets. Another accreditation organization with 

performance measures in place also had a corrective action system in 

place to review troubling data, identify the root cause of any problems, 

and implement solutions. This accreditation organization also measured 

customer satisfaction.

However, the contact log was developed primarily to document 

that OSHA had responded to inquiries from NRTLs, not necessarily to 

track the amount of time it took OSHA to respond. In the fall of 2012, 

OSHA officials told us they began developing a more robust system to 

track timeliness data and to address inefficiencies identified through the 

data, but this initiative is in the early stages.

 

42 U.S. Department of Labor, Office of Inspector General, Office of Audit. Occupational 

Safety and Health Administration: OSHA Correctly Denied ED&D’s Incomplete NRTL 

Application, March 31, 2005. Report Number: 05-05-002-10-001.
 

Page 31 GAO-13-88 Product Testing Laboratories

The NRTL program provides an important mechanism for protecting 

workers’ safety. However, if not addressed, the lengthy accreditation 

application processing and approval times resulting from the current 

scope of staff responsibilities and unclear guidance about the process will 

continue to have negative impacts on labs’ business operations and 

OSHA’s ability to conduct other oversight activities. Much has changed in 

the world of laboratory accreditation since the NRTL process was 

designed in 1988; for example, NIST issued guidance intended to reduce 

duplication and improve efficiency, in accordance with the National 

Technology Transfer and Advancement Act of 1995, and some federal 

agencies have used new approaches to accreditation to administer lab 

accreditation programs. This includes increasing use of new approaches 

for efficiently and effectively using resources and harnessing the 

expertise of other organizations, while retaining key oversight 

responsibilities within the federal government. While OSHA plans to take 

some actions to improve timeliness, it is too early to determine the extent 

of these actions and it is uncertain whether any incremental changes will 

be sufficient to fully address the program’s challenges. Without thinking 

strategically about the program as a whole, the agency may be missing 

opportunities to implement more comprehensive strategies for improving 

timeliness, such as modifying its program structure in a manner that 

better serves its mission and capitalizes on the expertise of agency staff 

and external resources. Even if some of these strategies require initial 

time investments, thinking strategically about the program’s structure can 

ultimately reap time savings and ensure that procedures and staff 

responsibilities are targeted in a way that optimizes the program’s 

effectiveness in addressing workplace safety.

To improve the timeliness of the NRTL accreditation process, we 

recommend that the Secretary of Labor direct the Assistant Secretary for 

Occupational Safety and Health to:

Review the NRTL program’s structure and accreditation application 

procedures to identify and implement any alternatives that better align 

program design with resource levels and improve program timeliness 

while remaining consistent with the agency’s mission. This review should 

draw upon the expertise of NIST or other organizations that provide 

guidance on developing effective and efficient accreditation schemes. It 

should include:

1. Identifying and evaluating the risks, costs, and benefits of various 

structural approaches for making accreditation decisions in terms of

Conclusions 

Recommendation for 

Executive Action
 

Page 32 GAO-13-88 Product Testing Laboratories

both timeliness and effectiveness in achieving OSHA’s mission. 

Approaches could include using an external accrediting organization 

to implement some or all of the lab accreditation duties, using 

contractors to support in-house portions of the accreditation process, 

or separating testing from certification accreditation activities.

2. Reviewing OSHA’s current regulations and procedures to identify 

areas where increased alignment with international standards on 

accreditation may result in time savings without impairing the 

agency’s mission to protect workers’ safety and health. This could 

include analyzing the risks, costs, and benefits to effectiveness 

involved in making any program modifications or changes to existing 

regulations.

3. Ensuring that all lab accreditation decisions are reviewed by an 

independent technical reviewer in order to better align the 

accreditation decision process with internal controls principles for 

separating key duties and international standards on making 

accreditation decisions. OSHA should evaluate options for achieving 

independent review based in part on their effects on process duration.

4. Improving overall program guidance and transparency to help prevent 

delays in the approval process.

5. Establishing program goals and performance measures, including 

timeliness goals for the approval of accreditation applications, and 

analyzing resulting performance measurement data to identify 

potential inefficiencies in the application process.

We provided a draft of this report to Labor for its review and comment. 

Labor’s Assistant Secretary for OSHA provided written comments, 

which are reproduced in appendix II. Labor agreed with our 

recommendations and described its plans to implement them, citing a 

commitment to use the most efficient and effective strategies in the 

NRTL program. For example, Labor states that it is assessing the 

NRTL program against alternative approaches used by other testing 

laboratory accrediting organizations and that it is coordinating with 

outside agencies, including the National Institute of Standards and 

Technology, to seek ways in which the NRTL program can improve its 

processes. In response to our recommendation to improve program 

guidance and transparency, Labor stated that it plans to develop and 

issue policy guidance on NRTL program requirements to ensure the 

program is administered consistently, and it plans to actively engage 

NRTL stakeholders in the policy-development process. In addition, 

Labor intends to use performance measures for processing 

Agency Comments
 

Page 33 GAO-13-88 Product Testing Laboratories

applications and to explore the development of a web-based customer 

service site where NRTLs could check the status of their applications 

throughout the review process. 

We are sending copies of this report to the appropriate congressional 

committees and the Secretary of Labor. In addition, the report is available 

at no charge on GAO’s website at http://www.gao.gov. 

If you or your staff have any questions about this report, please contact 

me at (202) 512-7215 or moranr@gao.gov. Contact points for our Offices 

of Congressional Relations and Public Affairs may be found on the last 

page of this report. GAO staff who made major contributions to this report 

are listed in appendix III.

Revae Moran

Director, Education, Workforce,

and Income Security Issues
Appendix I: Objectives, Scope, and 

Methodology

Page 34 GAO-13-88 Product Testing Laboratories

This study’s objective was to answer the following questions about the 

Occupational Safety and Health Administration’s (OSHA) Nationally 

Recognized Testing Laboratory (NRTL) program: (1) How long does it 

take to make accreditation decisions and what are the key factors that 

affect timeliness? and (2) To what extent has OSHA adopted commonly 

used strategies for improving timeliness? To address these research 

questions, we used a variety of methods including: analysis of OSHA’s 

data on recently processed accreditation applications; reviews of relevant 

federal laws, regulations, and OSHA publications on the NRTL program; 

interviews with key program stakeholders including OSHA officials, eight 

NRTL program applicants, and other public and private organizations, 

including non-profits, that accredit safety labs for other programs or 

purposes; a review and synthesis of findings from various sources, 

including GAO reports, international standards, guidance on 

accreditation, and materials from other federal agencies to identify 

promising strategies for improving the timeliness of accreditation 

decisions; and interviews with officials from selected federal agencies 

about their accreditation processes and practices.

To determine how long it took OSHA to approve accreditation 

applications between June 2007 and June 2012—as well as how many 

applications were pending during that time— we analyzed Federal 

Register notices and information from an internal OSHA database that 

included key application dates, such as application submission and final 

accreditation decision dates. We analyzed timing data on all initial, 

expansion, and renewal decisions that were approved between June 11, 

2007 and June 11, 2012. We also reviewed timing information for all 

applications that are currently pending. We selected this date range to 

ensure that our analysis included decisions for each of the three types of 

applications, reflected OSHA’s most recent time frames and processes, 

and included decisions made under two administrations. After 

interviewing OSHA officials and comparing Federal Register notices that 

identify key application dates for approved applications to separately 

generated data from OSHA’s internal database, we determined that the 

data on application submission dates and final decision dates were 

sufficiently reliable for our purposes. Our analysis focused primarily on 

application submission dates and final decision dates because the 

available data in OSHA’s database for intermediary stages of the review 

process were less reliable.

Appendix I: Objectives, Scope, and 

Methodology 
Appendix I: Objectives, Scope, and 

Methodology

Page 35 GAO-13-88 Product Testing Laboratories

We used the following criteria to assess the length of OSHA’s 

accreditation process:

• for completed applications, duration of the accreditation application 

and approval process relative to duration of the accreditation itself (5 

years);

• for pending applications, existence and duration of application 

backlogs;

• stakeholders’ views; and

• OSHA’s view on desirable time frames for accreditation reviews.

To gather more information about the amount of time that initial 

applications were with applicants for revisions versus with OSHA during 

the accreditation review, we also reviewed the application files for the 

three initial applications processed by OSHA between June 2007 and 

June 2012. Two of these applications were approved by OSHA and one 

was withdrawn by the applicant after the initial review and revision stages 

of the process.

To further understand the accreditation process and factors that might 

affect its timing, we interviewed OSHA officials and reviewed relevant 

federal laws, regulations, and NRTL program documents. We also 

interviewed eight NRTL applicants who represented a mix of initial, 

expansion, and/or renewal accreditation applications that have been 

pending, approved, or otherwise closed since June 2007. We selected 

labs so that our review would include the perspectives of applicants at 

different points in the decision-making process and with a variety of initial, 

expansion, and renewal applications. We also chose labs that 

represented a variety of sizes, as measured by the number of approved 

NRTL testing sites. In addition, we interviewed other stakeholders 

including a manufacturing organization and an employer organization to 

obtain information about any effects the duration of the NRTL 

accreditation process may have had on these sectors.

To identify promising practices for improving timeliness, we reviewed and 

synthesized findings from relevant GAO reports,1

 

1 See, for example, GAO, Streamlining Government: Opportunities Exist to Strengthen 

OMB’s Approach to Improving Efficiency,

international standards 

GAO-10-394 (Washington, D.C.: May 7, 2010) 

and GAO, Strategic Budgeting: Risk Management Principles Can Help DHS Allocate 

Resources to Highest Priorities, GAO-05-824T (Washington, D.C.: June 29, 2005).
Appendix I: Objectives, Scope, and 

Methodology

Page 36 GAO-13-88 Product Testing Laboratories

and guidance on accreditation,2 and materials from federal organizations 

such as the Office of Management and Budget,3 the National Institute of 

Standards and Technology (NIST),4 and the National Research Council.5

We also interviewed officials and reviewed relevant documents from 

seven public and private accreditation programs and organizations, 

including non-profit organizations, as well as two consortiums of 

accreditation organizations, to identify promising timeliness practices 

used by others. No other accreditation process is completely comparable 

to OSHA’s given differences in scope or mission. However, the 

experiences of other programs and organizations provide illustrative 

examples of actions that agencies have taken to adapt to their own 

unique missions and circumstances. After compiling an extensive list of 

accreditation programs and organizations, we ultimately selected 

organizations to review in more detail based on the following: 

recommendations from NRTL program stakeholders, those programs we 

identified as using one or more of the promising strategies for improving 

timeliness included in our report, or those programs that are similar to 

OSHA’s program in terms of mission or scope. We interviewed officials 

from four federal agencies with lab accreditation programs: the Consumer 

Product Safety Commission Conformity Assessment Body Recognition 

We identified these sources through literature searches and discussions 

with stakeholders and individuals who are knowledgeable about 

management practices that could improve timeliness. We compared the 

strategies we identified with OSHA’s current and planned actions to 

improve timeliness, as identified through interviews and relevant 

documentation. We also identified promising practices for improving the 

timeliness of the NRTL accreditation process by soliciting suggestions 

from the eight NRTL applicants that we interviewed.

 

2 See, for example, International Standard, ISO/IEC 17011: Conformity assessment – 

General requirements for accreditation organizations accrediting conformity assessment 

organizations, ISO 2004.

3

 Office of Management and Budget Circular A-119: Federal Participation in the 

Development and Use of Voluntary Consensus Standards and in Conformity Assessment 

Activities, 63 Fed. Reg. 8546 (Feb. 19, 1998).

4 NIST’s Guidance on Federal Conformity Assessment Activities, 65 Fed. Reg. 48,894 

(Aug. 10, 2000), codified at 15 C.F.R. pt. 287. 

5 See, for example, Standards, Conformity Assessment, and Trade: Into the 21st Century, 

National Research Council, National Academy Press (Washington, D.C.: 1995).
Appendix I: Objectives, Scope, and 

Methodology

Page 37 GAO-13-88 Product Testing Laboratories

Program; the Federal Communications Commission Equipment 

Authorization Program; the Department of Health and Human Services 

Health Information Technology Certification Program; and the NIST 

National Voluntary Laboratory Accreditation Program. In addition to 

speaking with officials from these four federal accreditation programs, we 

also interviewed representatives from three accreditation organizations 

outside the U.S. federal government: the American Association for 

Laboratory Accreditation, Standards Council of Canada, and the 

American National Standards Institute. Finally, we spoke with

representatives from two consortiums of accreditation organizations: the 

International Laboratory Accreditation Cooperation and the National 

Cooperation for Laboratory Accreditation.
Appendix II: Comments from the Department 

of Labor

Page 38 GAO-13-88 Product Testing Laboratories

Appendix II: Comments from the Department 

of Labor
Appendix II: Comments from the Department 

of Labor

Page 39 GAO-13-88 Product Testing Laboratories
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 40 GAO-13-88 Product Testing Laboratories

Revae Moran, Director, (202) 512-7215 or moranr@gao.gov

In addition to the contact named above, Betty Ward-Zukerman, Assistant 

Director; Elizabeth Dobrenz, Meredith Moore, Maria Stattel, and Barbara 

Steel-Lowney made significant contributions to all phases of the work. 

Also contributing to this report were James Bennett, Sarah Cornetto, 

Elizabeth Curda, Debra Johnson, Kathy Leslie, Jean McSween, Cathy 

Roark, Daren Sweeney, and Kate van Gelder.

Appendix III: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 

(131167)
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