June 10, 2020

MEMORANDUM FOR:
REGIONAL ADMINISTRATORS
EXECUTIVE STAFF
FROM:
LOREN SWEATT
PRINCIPAL DEPUTY ASSISTANT SECRETARY
SUBJECT:
Revisions to Policy Impacting Nationally Recognized Testing Laboratories Regarding Markings Applied to Certified Products

This memorandum implements OSHA's policy revision regarding markings applied to products certified by a Nationally Recognized Testing Laboratory (NRTL).

OSHA published CPL 01-00-004, NRTL Program Policies, Procedures and Guidelines (NRTL Program Directive) on October 1, 2019. The NRTL Program Directive, Annex B 4.1 B added a requirement for the test standard or similar marking to accompany the NRTL Certification mark:

  1. The applicant organization or NRTL's procedures shall require clients to apply the organization's mark to individual units of the product certified, or, if not feasible, to the smallest unit packaging of the product. The test standard(s), certification category, or a symbol or code that identifies the test standard(s) to which the unit is certified shall be shown adjacent to the NRTL's mark. [emphasis added] QR codes, barcodes or other machine readable codes may be used in conjunction with, but not as a replacement for, the required markings of this clause.

Several stakeholders indicated that the implementation of this change could be extremely costly to implement as it would require modifications to injection molds, silk screens and label stock.

NRTLs should fully implement the NRTL Program Directive, Annex B 4.1 B. However, at this time, OSHA will not issue nonconformances of the following portion of this requirement:

  • "The test standard(s), certification category, or a symbol or code that identifies the test standard(s) to which the unit is certified shall be shown adjacent to the NRTL's mark."

For questions about implementation of this new policy, and submitting applications under this revised policy, please contact Thomas Hannigan, Acting Director, Office of Technical Programs and Coordination Activities at 202-693-2110 or hannigan.thomas@dol.gov.