Listing and approval use and compliance

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Listing and approval use and compliance is the activity of adhering to all the requirements of installing and/or using safety-related products and items in conformance with an active certification listing or approval that has been issued by an organisation that is accredited both for testing and product certification, such as those issued by Underwriters Laboratories, FM Global, American Nuclear Insurers, or the Deutsches Institut für Bautechnik (DIBt). In concept, if a safety-related item, such as a fire door or a fire extinguisher, or a toaster is used in the same manner as the listing or approval states, and conforming to the intent of he associated testing, then use of the component or system complies with the listing. The listing or test is often cited by a regulation, such as a building code or a fire code, and as such is made law. This concept is known as bounding in the nuclear industry. Products whose use is not mandated by any building codes or fire codes often lack a consensus test method. Unless there is a test standard in existence to prove the functionality and reliability of such a product, there can be no certification listing.

1 Governmental accreditation of laboratories
2 Testing by laboratories without national accreditation
3 Testing for the purpose of achieving product certification
4 Documentation
5 Confidentiality
6 Structural fire protection
7 See also
8 External links
- 8.1 Accredited testing and certification organisations

[edit] Governmental accreditation of laboratories

National, governmental accreditors, such as Germany's Deutsches Institut für Bautechnik or Canada's SCC (Standards Council of Canada) can "accredit" laboratories, meaning that such laboratories must conform to national standards and rules of conduct in the discharge of their duties. Compliance is routinely tested by the accreditor through inspections, where random client files are audited to see that the laboratory followed all appropriate procedures. Accreditors can accredit laboratories for testing, as well as for product certification. In product certification regimes, the laboratory and/or the accreditor (as in the case of Germany) become involved in witnessing the production of test materials, get copies of process standards, including chemical formulas and all details necessary to manufacture a product. Once the test product is made, it is shipped "under seal" to the laboratory for incorporation in the test. Certification listings and/or approvals that follow a successful test are subject to the maintenance of continuous factory auditing to make sure that what was tested is identical to that which was made, and/or documented proof that the products made continue to meet quality control standards set out as a function of the approvals process.

[edit] Testing by laboratories without national accreditation

Testing by organisations or laboratories who hold no national accreditation for testing purposes are not subject to mandatory governmental audits of compliance with applicable requirements. Even an organisation that is nationally accredited for testing purposes may not necessarily issue test reports that provide assurance that commercial products tested by it are the same as what is being sold or used by the public.

Safety related products undergo product certification to enable their use by the public. The value of testing by organisations without accreditation for product certification is based on faith in the organisation or its ethics, or culpability. In countries in which a national authority is a present (e.g., the United States), the listings provided by large well established third-party testing and certification companies are accepted as the societal standard. In such cases, the link to the building code is through regional standards, such as the Uniform Building Code, or the Standard Building Code.

Manufacturers of products routinely test their own products and competitors' products for their own purposes, as it makes good fiscal sense to test in one's own lab before incurring the costs of a third party facility.

[edit] Testing for the purpose of achieving product certification

Product certification involves testing a product to a test standard that is accepted in the region in which the product will be sold. For instance, in the case of a firestop, [[Underwriters' Laboratories of Canada|ULC]]-S115 is the test method that must be used by a laboratory whose tests are to be accepted in Canada. ULC is nationally accredited in Canada to write standards, test products and to certify products.

Because Canada uses the accredation model of a national accrediting authority, if an organisation tests a firestop in or for use in Canada, in accordance with the correct standard (ULC-S115), but is not accredited by the SCC, the test results cannot be used to in any approvals of field installations on Canadian construction sites. If, on the other hand, the test laboratory is also accredited for product certification, then before the test takes place, a follow-up or certification agreement is anticipated between the certifier and the submitter of the test who desires a rating or a listing. An inspector from the certifying organisation witnesses the manufacture of the product or products to be tested, and checks the manufacturing procedures against the process standard that is in place and by then on file with the certifying organisation. The process standard includes all information necessary to manufacture the product or products, including equipment descriptions, tolerances, chemical formulas and purchasing specifications for ingredients or components. The manufactured goods are sealed by the inspector and then shipped to the laboratory, where the contents are used to build the test specimen in accordance with the manufacturer's instructions.

Cheating in testing may include substitution of materials and components by the manufacturer, or additional measures to assure the product passes the test.

[edit] Documentation

After testing, the testing laboratory issues a test report to the manufacturer, who is not obliged to share it with anyone.

If the product passes the testing required for certification, the items in the test that passed are given a certification listing, which describes the product(s) that were tested, the application, and maximum and minimum tolerances for all components. Certification listings are short versions and interpretations of the test results.

A certification listing indicates that the test has been properly conducted, the tested systems passed, and that a follow-up agreement is in effect between the manufacturer or submitter and the certifier. This means that in addition to the original inspection where the test materials were produced, the certifier makes inspections of the manufacturing facility to ensure that what is being manufactured and sold is still the same as what was originally tested.

In the event that irregularities are discovered on the part of the manufacturer - substitutions of cheaper ingredients or components, deliberate irregularities, or an ingredient or component of a tested system which is no longer be available has been substituted - the listing can be de-activated and the manufacturer asked to remove all logos of the certifier from product literature, promotional materials, packaging, etc.

[edit] Confidentiality

Organisations accredited for testing and certification of safety-related items typically operate in large facilities where many test submittors work to build test specimens and then go to test. Confidentiality is of importance to most submittors as well as the laboratories. Some manufacturers are extremely reluctant to share their proprietary process standards with any third parties.

In Germany's system, formulas and process standards are shared with the governmental accreditor: DIBt [1]. DIBt uses the laboratories to audit the factories, but the audits are restricted to quality control tests of the finished products - not their chemical compositions or exact process standards. In North America, manufacturers are obliged to share their process standards with the laboratories, as there is no national accreditor that issues "approvals". This has resulted in the use of "fingerprinting" procedures, where manufacturers will permit their laboratory inspectors to conduct infrared spectroanalysis and other QC tests, in place of the process standards.

North American laboratories are usually private sector companies, though some of them are non-profit organisations, such as Underwriters Laboratories. There have been migrations of private sector laboratory engineers to manufacturers. Concerns over the sharing of confidential proprietary information are mitigated through confidentiality agreements.

[edit] Structural fire protection

Fire protection products used in the construction of buildings, ships and offshore facilities are required to conform with the certification listings and/or approvals. The field installation will comply with code requirements if it is configured within the maximum and minimum tolerances in the listings and approvals. For example, if a drywall assembly has a listing of a 2 hour fire-resistance rating, and all the provisions of the listing were kept in the field, including materials, spacing, workmanship, etc., the 2 hour wall required by the building's designer is likely to withstand a 2 hour fire.

A case of the lack of mandatory bounding in US and Canadian nuclear power plant construction was the Thermo-Lag scandal, which was exposed by whistleblower Gerald W. Brown. The disclosure of the inadequacy of fire testing employed in the circuit integrity product led to widespread and costly remedial work for licensees of the Nuclear Regulatory Commission.