August 25, 2020

MEMORANDUM FOR:

REGIONAL ADMINISTRATORS
EXECUTIVE STAFF

FROM:

LOREN SWEATT
PRINCIPAL DEPUTY ASSISTANT SECRETARY

SUBJECT:

Interim Policy Addressing Impact of 2017 ISO/IEC 17025 Revision on OSHA’s Administration of the Nationally Recognized Testing Laboratory (NRTL) Program

This memorandum establishes an interim policy addressing the impact of the 2017 revision of ISO/IEC 17025:2017, General requirements for the competence of testing and calibration laboratories, on OSHA’s administration of the NRTL Program.

OSHA published the revised NRTL Program Directive, CPL 01-00-004 on October 1, 2019, available at https://www.osha.gov/enforcement/directives/cpl-01-00-004. The revised NRTL Program Directive contains: (1) administrative procedures supplementing those contained in Appendix A to the NRTL Program regulation, 29 CFR 1910.7; and (2) policies deeming compliance with the applicable criteria in ISO/IEC 17025:2005, General requirements for the competence of testing and calibration laboratories, ISO/IEC 17065:2012, Conformity Assessment – Requirements for bodies certifying products, processes and services, and the corresponding testing and certification policies in the Directive, as compliance with the requirements for recognition under the NRTL Program regulation.

ISO/IEC 17025:2005 was updated on November 1, 2017 to ISO/IEC 17025:2017. This revision, which cancels and replaces 17025:2005, allows laboratories a transition period ending on November 30, 2020. This date has since been extended by the standards development organization to June 1, 2021.

The 2017 revision to ISO/IEC 17025 includes a modified outline of the requirements for all organizations performing testing, calibration and/or sampling. This modified outline includes Scope, Normative References, Terms and Definitions, General Requirements, Structural Requirements, Resource Requirements, Process Requirements, and Management System Requirements. The 2017 revision also updates language related to technology, along with a definition of a laboratory. Many of the substantive requirements for testing and calibration laboratories remain unchanged in ISO/IEC 17025:2017. However, these requirements are located in different locations than in the 2005 version.

OSHA will continue to base NRTL assessments and findings from those assessments on ISO/IEC 17025:2005. NRTLs may, however, use ISO/IEC 17025:2017 internally or to qualify calibration laboratories or Unrecognized Sites.

If you have questions about the revised NRTL Program Directive, please contact Charles Haggins, Acting Director, Office of Technical Programs and Coordination Activities at 202-693-2110 or haggins.charles@dol.gov.