As authorized by the Occupational Safety and Health Act of 1970, OSHA issues and enforces workplace safety and health standards (OSHA standards). Some OSHA standards require that certain products used in the workplace, such as a variety of electrical equipment, be safety-tested and approved by OSHA-accredited laboratories. 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). 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. 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 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. OSHA collects fees from applicants and accredited NRTLs, and uses the fees for program expenses. OSHA first instituted fees in 2000 and calculated them with the intention of covering core application processing costs and audits of accredited labs. 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. 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. conform to the test standards.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. 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). 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). 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. 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.Labor attorneys also assist the NRTL program. The program is structured so that these staff members are responsible for the following: 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. Oversight activities for existing labs. According to NRTL program policy documents, accredited labs and satellite offices should be audited by OSHA personnel. In total, this includes auditing approximately 120 sites worldwide. The staff are also responsible for investigating any complaints OSHA receives about accredited labs. 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. 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 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.