www.anab.org | Fort Wayne, IN | Washington, DC

September 24, 2023

Submitted via email

Nathalie Rioux

Standards Coordination Office

National Institute of Standards and Technology

100 Bureau Drive, Stop 2100

Gaithersburg, MD 20899–2100

RE: Proposed Voluntary Product Standard PS 1–22, Structural Plywood

Dear Ms. Rioux, 

The ANSI National Accreditation Board1(ANAB) welcomes the opportunity to provide 

comments to the National Institute of Standards and Technology on Proposed Voluntary Product 

Standard PS 1–22, Structural Plywood. These comments are intended to improve consistent 

implementation by conformity assessment bodies and accreditation bodies. Comments are 

identified by the clause and paragraph numbers in the draft PS 1-22.

Clause 7.1, second paragraph: This text should be moved to Clause 8. The current text is a 

mixture of requirements for initial certification and ongoing “surveillance” (see ISO/IEC 17065 

7.9). The requirements will be easier to understand, assess and fulfill if all requirements for 

“surveillance” are in Clause 8.

Clause 7.1, third paragraph: Add text to describe the role of the Accredited Inspection Agency 

and Accredited Testing Agency in terms of ISO/IEC 17065 and to clarify that approval by the 

Accredited Certification Agency means verification of requirements in 7.3 and 7.4; otherwise,

the document is ambiguous by specifying requirements for Accredited Inspection Agencies and 

Accredited Testing Laboratories and requiring some additional “approval” of same on some 

unspecified basis. Suggested text (additions underlined): 

“The Accredited Inspection Agency and Accredited Testing Laboratory shall be approved 

by the Accredited Certification Body. Approval means verification of fulfillment of 

requirements in 7.3 and 7.4 respectively. The Accredited Inspection Agency and the 

Accredited Testing Laboratory shall perform all “Evaluation” activities as defined in 

ISO/IEC 17065 (see ISO/IEC 17065 6.2.1 and 6.2.2.1.) An organization can be any 

combination of an Accredited Certification Agency, Accredited in Inspection Agency, 

1 ANAB (www.anab.org) is a wholly owned subsidiary of the American National Standards Institute 

(ANSI, www.ansi.org).
and Accredited Testing Laboratory so long as the requirements in 7.2, 7.3 and 7.4 

respectively are fulfilled.”

Clause 7.3.1: Accreditation of inspection bodies is covered under the International Laboratory 

Accreditation Cooperation Mutual Recognition Arrangement. Change the reference from IAF to 

ILAC. 

Clause 8: A more appropriate title, consistent with ISO/IEC 17065, would be “Surveillance 

Requirements”.

Clause 8, first paragraph: In order to be consistent with ISO/IEC 17065, change text as follows:

The Accredited Certification Agency shall implement surveillance (ISO/IEC 17065 7.9)

an in inspection and test program as specified in Section 8.2.

Clause 8.1, first paragraph: In order to clearly differentiate the requirements that apply to the 

manufacturer from the requirements that apply to the Accredited Certification Agency, move this 

paragraph (including the bullets) to a new clause in Section 5 (similar to requirements for mill 

specifications). 

Clause 8.1, second paragraph: Move first sentence along with the text from the first paragraph to 

a new clause in Section 5 that includes requirements for the manufacturer’s quality program. The 

second sentence can be deleted because it is redundant with 8.2.1.2.

ANAB again welcomes the opportunity to comment on this Proposed Voluntary Product 

Standard. If these comments are unclear or if you have any questions, please don’t hesitate to 

contact me.

Sincerely,

Warren Merkel

Vice President, Policy

ANSI National Accreditation Board (ANAB) 

wmerkel@anab.org