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

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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.

...By Any Other name

✤ 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)

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

✤ 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

MANUFACTURERS

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

Major Standards for our Industry

✤ 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

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 NRTL-approved 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 self-audit (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

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