Cynthia Esher
Transkript
Cynthia Esher
MCAA Positions NRTL Mark & Audit Frequency What Who we are … What’s our goal today … What’s our Position … Use of NRTL Mark on certified products Reducing the frequency of facility audits Feedback The Measurement, Control & Automation Association is the North American trade association of leading companies who manufacture and distribute a wide variety of process controls, field measurement and analysis instrumentation, systems and software used in industrial process control and factory automation around the world. ✤ Recorder-Controller, Inc. (Illinois, 1940) ✤ Recorder-Controller Section of Scientific Apparatus Makers Association (SAMA) ✤ Process Measurement & Control Section of SAMA ✤ Measurement,Control & Automation Section of SAMA Group of Associations ✤ Measurement, Control & Automation Association (Virginia, 1994) ...By Any Other name Manufacturers ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ABB Instrumentation Division Acromag Inc. Ametek Measurement & Calibration Technologies Anton Paar USA Ashcroft Inc. Automation Products Group, Inc. A-W Lake Company Azbil North America Badger Meter - Racine Berthold Technologies USA LLC Bronkhorst USA Inc. Brooks Instrument Burkert Fluid Control Systems Burns Engineering Inc. Cameron Measurement Systems ControlAir, Inc. DocBoss Dwyer Instruments Emerson Power & Water Solutions Emerson Process Management Emerson Process Systems Business Endress + Hauser Extrel CMS ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ FasTest, Inc. Festo Corporation Fisher Controls International LLC Fluid Components International Gems Sensors & Controls Georg Fischer signet LLC GF Piping Systems Great Plains Industries, Inc. Hach Corporation Ham-Let USA Hawk Measurement America Hoffer Flow Controls, Inc. Honeywell International Invensys Process Systems Iwaki America Inc. Kessler Ellis Products K-Patents Inc. Krohne, Inc. Madison Company Magnetrol International McCrometer Meriam Process Technologies Metso Automaton MANUFACTURERS ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ Micro Motion, Inc. Mid-West Instrument Mitsubishi Electric automation, Inc. Monitor Technologies LLC Moore Industries International, Inc. Orange Research Inc. Palmer Wahl Instrumentation Group Pepperl + Fuchs Inc. Phoenix Contact Inc. Precision Digital Corporation ProComSol, Ltd. Pyragon Ind. Pyromation, Inc. Red Lion Controls Reotemp Instruments RJ Global WIKA LLD Rosemount Analytical Liquid Division Rosemount Flow Rosemount Inc. Schneider Electric, Telemeter & Remote SCADA Siemens Industry, Inc. ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ Sierra Instruments Inc. Sierra Monitor Corporation Smart Sensors Inc. SOR Inc. SpectraSensors, Inc. Spirax Sarco SSP Corporation StoneL Teledyne Hastings Instruments Tel-Tru Manufacturing Co. Thompson Equipment Company Thuemling Instrument Group Inc. Ultra Electronics NSPI United Electric Controls Co. UWT Level Controls, LLD Vega Americas Inc. Venture Measurement Company LLC VorTek Instruments WIKA Instrument Corporation WIKA Process Solutions LP Channel Partners ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ Andon Specialties Applied Measurement & Control, Inc. Branom Instrument Company Carotek Inc. Centro, Inc. Compass Controls & Instrumentation, Inc. Control Management Technology Cross Company Daitron Inc. Dave Allert Co. Dave Ray & Associates DynaTech Control-solutions Engineered Sales Co. Ernie Graves Company Flowmaster Inc. Fluid Flow Products, Inc. FLW Southeast, Inc. Forberg Scientific, Inc. GSI Automation Gilson Engineering Sales, Inc. Heartland Controls Hile Controls of Alabama, Inc. Instrumart Instruments Direct IPT Group ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ ✤ Ives Equipment Corporation Jasper Engineering & Equipment Co. Lesman Instrument Co. Miller Energy, Inc. Miller Mechanical Specialties, Inc. Moody-Price LLC NSI Neal Systems Inc. Petro-Chem Equipment PR Electronics Precision Fitting and Gauge Company Process Controls Corp. Ritec Enterprises Incorporated Robert S. Hudgins Company, Inc. R. STAHL Inc. Rust Automation & Controls Inc. Smith Instrument Sterling Engineering solutions SW Controls, Inc. TALON Technical Sales Transcat Valin Corporation V-F Controls, Inc. Wilson-Mohr Womack Machine Supply Company, Inc. PRESS / Consultants Flow Research, Inc. ✤ Global Automation Research ✤ ISA - International Society of Automation ✤ RB Marketing Communications ✤ SellTiS LLC ✤ Spitzer & Boyes ✤ Industry Partners CSA International ✤ Intertek Testing Services NA, Inc. ✤ MET Laboratories ✤ Who??? Measurement and Control Instrumentation: ➡Temperature ➡Pressure ➡Flow ➡Level ➡Weight Recorders, Indicators, Controllers Control Valves and Regulators Physical or Chemical Property Continuous Measuring Devices/Analyzers General Purpose Control Systems Industrial Automation Controls Telemetry Equipment Signal Conditioners Digital Electronic Data Processing Equipment/ Computers Software Calibration Equipment ✤ UL 347: High-voltage Industrial Control Equipment ✤ UL 508: Electric Industrial Control Equipment (including control panels and boxes) ✤ UL 698: Industrial Control Equipment for Use in Hazardous (Classified) Locations ✤ UL 913: Intrinsically Safe Apparatus and Associates Apparatus for use in Class I, II and III, Division 1, Hazardous (Classified) Locations ✤ UL 1002: Electrically Operated Valves for Use in Hazardous (Classified) Locations ✤ Explosion-proof and Dust-Ignition-Proof Electrical EQuipment for use in Hazardous (Classified) Locations ✤ UL 1604: Electrical Equipment for use in Class I and II, Division 2 and Class III, Hazardous (Classified) Locations ✤ UL 61010B-1: Electrical Measurement & Test Equipment Part 1--General Requirements ✤ UL 61010C-1: Process Control Equipment Major Standards for our Industry What’s Our Pain? ✤ Customers often think they need a product certified by a specific NRTL; that limits our market choices ✤ Customers say their insurers require product certification by a specific NRTL; that limits our market choices ✤ Audits of our facilities, our production practices and our product specifications consume time, money, and human resources and divert focus from our true business ✤ Quarterly audits limit our market choices as we seek to minimize the interruptions/cost What we Believe ✤ Worker and Product Safety is assured through the application of appropriate safety standards by accredited conformity test facilities ✤ OSHA’s program to accredit laboratories under the Nationally Recognized Testing Laboratory banner insures that laboratories have the requisite skills and knowledge and apply the proper test practices to certify products. ✤ Some NRTLs test to a very broad range of standards while others have been accredited more narrowly. ✤ The breadth of accreditation has no bearing on the quality of a lab’s certification where accreditation has been granted. i.e. no one NRTL is better than any other NRTL. “NRTL Approved” ❖ Customers should have assurance that products are safe for the use intended. ❖ Customers would benefit if they understood that “NRTL Approved” stood for that assurance. ❖ Few understand that there are numerous testing laboratories that could provide such assurance. ❖ NRTLs should also include their brand in such a NRTLapproved mark--many have worked hard to achieve brand awareness. “NRTL Approved” 3-8 year phase in to require the “NRTL-Approved” labeling depending on product life cycles. We support branding by NRTLs and the inclusion of those brands in information about what safety standards a product meets. Assurance more like the CE Mark in Europe Audit Frequency ✤ All of our members whose products require certification must undergo semi-annual audits of their manufacturing facilities, manufacturing process and even product specifications (sometimes retesting against those specs) for every product or class of products they sell. ✤ At least 2 times a year; often Quarterly ✤ Most of our members also maintain ISO 9001 quality certifications which requires constant maintenance of documentation and annual inspections of the manufacturing process. ISO 9001 Certification ISO certification requires manufacturers to selfaudit (and document) the internal process ✤ It forces companies to correct deviations from the original production plans ✤ Ensures ongoing consistency and adherence to the original specification ✤ Very detailed and well documented ✤ Audit Frequency Redundant ✤ Costly ✤ Time consuming ✤ Diverts attention of skilled employees from manufacturing activities that could actually make money and create other jobs ✤ Provides no discernible public benefit ✤ Audit Frequency ✤ For any company maintaining an ISO 9001 Quality Certification Reduce semi-annual audits to biennial ✤ Reduce quarterly audits to annual ✤ EXCEPT if the NRTL suspects activity that could pose a danger ✤ Audit Frequency The audit frequency is an internal OSHA policy, not a regulation ✤ We asked OSHA to change their internal policies ✤ They said that NRTLs have the ability to audit UP TO twice a year or UP TO four times a year and NRTLs could make the judgment on a case-by-case basis ✤ Audit Frequency ✤ What we recognize: ✤ An annual (or biennial) audit will be more comprehensive than semi-annual or quarterly audits and will require higher fees ✤ The fee is only a part of the expense that manufacturers experience ✤ Puts US manufacturers in line with the rest of the world – ATEX/IECEx/VAR and VAN Feedback ... Thank you.