1. Satellite Notification and Acceptance Program (SNAP)
Summary
SNAP is a proposed new segment under OSHA’s NRTL Program
It is a voluntary program that provides:
Increased flexibility for NRTLs
More effective monitoring of NRTLs by OSHA

2. Satellite Notification and Acceptance Program (SNAP)
Background on NRTL Program
Current NRTL Program Policy
Overview of Proposed SNAP

3. Background - NRTL Program
Approval Requirement and NRTL Program
OSHA requires that NRTLs approve (i.e., test and certify) certain categories or types of products to ensure they can be used safely in the workplace
There are 37 different types of products, and the largest of these types is electrical products and equipment
The full listing of these categories is available at

4. What is a Nationally Recognized Testing Laboratory (NRTL)?
An independent, i.e., third-party, organization
Capable of providing product safety testing – must have a product safety testing program
Capable of providing product safety certification services, - must operate listing and labeling products and following-up inspection programs.
Program Regulation (29 CFR ) contains requirements and specifies general recognition process
Program Directive (CPL 1-0.3) contains program policies, procedures, and guidelines

5. Background - NRTL Program
Organizations interested in seeking recognition as an NRTL must apply to OSHA’s NRTL Program.
Part of OSHA’s Directorate of Science Technology and Medicine.
Seeks to prevent accidents through assuring safety of products used by American workers.
OSHA established the NRTL Program in 1988.
There are presently 18 organizations operating a total of 52 recognized sites. Two NRTLs are foreign-based.

6. Background - NRTL Program
NRTL Scope of Recognition (3 elements)
Types of products: listing of product safety test standards that the NRTL may use in approving products.
Recognized Sites: wholly-owned by NRTL and has capability to perform full range of testing and certification activities.
“Programs”: mainly allows use of other-party testing if NRTL meets certain criteria. SNAP would be one of these programs, but it serves other purposes.

7. Current NRTL Program Policy
Product testing – can be performed by:
NRTL’s recognized site
NRTL’s SATELLITE (currently, must be wholly-owned unrecognized site)
Other parties (specifically, independent labs and product manufacturers) if NRTL is approved by OSHA

8. Current NRTL Program Policy
OSHA uses a “program” approach to allow NRTLs to use other-party testing
Called March 9 programs due to date adopted.
Each specifies category of testing and criteria that NRTLs must meet to receive OSHA approval to use.

9. Current NRTL Program Policy
Product certification – can only be performed at NRTL’s recognized site
NRTL Program staff only audit these NRTL sites
Examples of product certification activities
Perform final technical evaluation of product
Render final decision on certification
Authorize use of the NRTL’s mark

10. Overview of Proposed SNAP
Role of Satellites would be expanded to performing certification activities
Would allow NRTLs to locate approval activities closer to manufacturers, which are located in many foreign countries
Uses “program” approach to implement policy: Satellite Notification and Acceptance Program (SNAP).
Satellites under SNAP (“SNAP sites”): NRTL would generally need to have majority ownership and would need to locally administer and control.

11. Overview of Proposed SNAP
SNAP describes two basic sets of criteria that any NRTL must meet to receive OSHA approval to use program
One set focuses on the degree of ownership and control by NRTL, and eligible sites and organizations
Other set focuses on the detailed criteria for NRTL’s satellite qualification and audit program (addresses quality controls, competency, and increased frequency and depth of internal audits)

12. Overview of Proposed SNAP
NRTL would qualify its own SNAP sites
Specifies each SNAP site’s testing and certification functions
NRTL would need to annually audit and re-qualify each SNAP site
NRTLs would need to notify OSHA of qualified SNAP sites
Their qualification and functions
Their auditing schedule

13. Overview of Proposed SNAP
OSHA would audit SNAP sites and main satellite operation’s office.
OSHA could drop a SNAP site or the NRTL from SNAP if warranted.
NRTLs not approved for SNAP by OSHA would not be able to use satellites to perform certification activities.

14. Overview of Proposed SNAP
If SNAP is approved, OSHA plans to publish a Federal Register notice to make the public aware of adoption of new program
Similar to action taken when other “programs” adopted in 1995
There would be a 12 month transition period to implement SNAP