Entela, Inc.; Application for Recognition as a Nationally Recognized Testing Laboratory

DEPARTMENT OF LABOR

[Docket No. NRTL-2-93]

Entela, Inc.; Application for Recognition as a Nationally

Recognized Testing Laboratory

agency: Occupational Safety and Health Administration, Department of

Labor.

action: Notice of application for recognition as a nationally

recognized testing laboratory, and preliminary finding.

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summary: This notice announces the application of Entela, Inc. for

recognition as a Nationally Recognized Testing Laboratory (NRTL) under

29 CFR 1910.7, and presents the Agency's preliminary finding.

dates: The last date for interested parties to submit comments is May

2, 1994.

addresses: Send comments to: NRTL Recognition Program, Office of

Variance Determination, Occupational Safety and Health Administration,

U.S. Department of Labor, 200 Constitution Avenue, NW., room N3653,

Washington, DC 20210.

for further information contact: Office of Variance Determination, NRTL

Recognition Program, Occupational Safety and Health Administration,

U.S. Department of Labor, Third Street and Constitution Avenue, NW.,

room N3653, Washington, DC 20210.

supplementary information:

Notice of Application

Notice is hereby given that Entela, Inc. (ENT) has made application

pursuant to section 6(b) of the Occupational Safety and Health Act of

1970, (84 Stat. 1593, 29 U.S.C. 655), Secretary of Labor's Order No. 1-

90 (55 FR 9033), and 29 CFR 1910.7 for recognition as a Nationally

Recognized Testing Laboratory.

The address of the laboratory covered by this application is:

Entela, Inc., 3033 Madison, SE., Grand Rapids, Michigan 49548.

Regarding the merits of the application, the applicant contends

that it meets the requirements of 29 CFR 1910.7 for recognition to

certify products in the areas of testing which it has specified.

Entela, Inc. states that its application documents demonstrate that

for each specified item of equipment or material to be certified, it

has the capability (including proper testing equipment and facilities,

trained staff, written testing procedures, and calibration and quality

control programs) to perform testing and examination of equipment and

materials for workplace safety purposes to determine conformance with

appropriate product test standards. (See Ex. 2.A.).

The applicant states also that it shall provide, to the extent

needed for the particular equipment or materials listed, labeled, or

accepted, the following controls or services: (i) Implementation of

control procedures for identifying the listed and labeled equipment or

materials (see exhibit 2.A., appendix VII, and exhibit 2.H.).

(ii) Inspection of the run of such item at factories for product

evaluation purposes to assure conformance with the test standards (see

exhibit 2.A., appendix VIII, and exhibit 2.H.).

(iii) Conduction of field inspections to monitor and to insure the

proper use of its identifying mark or labels on products (see exhibit

2.H.).

Entela claims that it is completely independent of employers

subject to the tested equipment requirements, and of any manufacturers

or vendors of equipment or materials being tested for these purposes

(see exhibit 2.B. and 2.J.).

The applicant also claims that it maintains effective procedures

for producing creditable findings or reports that are objective and

without bias, and for handling complaints and disputes under a fair and

reasonable system (see exhibit 2.H. and 2.J.).

In summary, Entela, Inc. claims that it maintains the experience,

expertise, personnel, organization, equipment, and facilities suitable

for accreditation as an OSHA Nationally Recognized Testing Laboratory.

Entela's Grand Rapids facility consists of two adjacent structures

that each contain two buildings covering a total of 40,000 square feet.

Approximately 20,000 square feet of floor space is allocated to product

testing. The main reception area is housed in the main building, along

with the conference room, main records storage area, the wet chemistry

labs, small scale flammability test room, tensile test area, with the

metallurgical laboratories located on the upper floor. The weathering

and environmental aging chambers, administrative offices, and nuclear

records storage area are located in a leased building attached to this

main building. The third building contains the appliance test area,

vibration and electronics laboratory. The fourth building contains the

Quality Assurance Department, certain records storage, California

flammability test chamber, fabrication shop, and a metrology

laboratory.

Natural gas and city water and electricity are supplied to all of

the buildings. Special utilities include liquid nitrogen which is

stored outside the second building, and a de-ionized water system.

Environmental conditions are controlled in specific laboratory

areas. The temperature and humidity variations in these laboratories

are continuously monitored and recorded, as required by specific test

requirements. There are temperature and humidity chambers to control

and monitor environmental conditions for specific product testing.

The laboratory has a shipping and receiving department for receipt,

retention, and disposal of samples for testing. Incoming samples are

inspected and identified with numbered tags. All samples for one test

have tags with the same number. Each unique tag number, the samples,

and the purchase order, are reviewed, and the shipping/receiving clerk

prepares a work order request, after which the samples are distributed

to the test areas and copies of the work order distributed to the

appropriate departments. A copy of each unique tag and work order is

retained by the shipping and receiving department. Another copy of the

work order is sent to the test department with the samples. The test

department completes the work order when all product evaluations are

accomplished, and returns it to the shipping and receiving department

for sample disposition. The sample inventory and traceability

information is kept in the shipping and receiving log, and work order

information is maintained on a computer data-base. All storage

locations for incoming samples are in the shipping and receiving areas,

which are located indoors. The laboratory is automating the shipping

and receiving numbering system so that the work order numbers are

identical with the sample tags.

Each staff member wears an Entela photo I.D. Visitors can only

enter via the front lobby and are required to sign in on the visitor

log. They are issued safety glasses and name tags by the receptionist

and are escorted while on the premises. Other entrances are kept locked

with limited access. Separate test and conference areas are available

for those clients requiring confidentiality. The use of screens and

partitions are also utilized in the laboratory.

Entela Inc. has recently upgraded their fire protection and

security systems to include smoke detectors and proximity sensors.

These are connected to the security system which dispatches local fire

and police departments.

Test equipment is available to perform most measurement and testing

in accordance with the identified test standards. Unavailable unique

test equipment is purchased or leased through an Entela-approved

source.

An inventory list identifies all pieces of equipment by the

department number or location in the laboratory, gage number,

instrument name, manufacturer, model and serial number, range of

operation, calibration frequency, and the date the instrument was

placed in service. Operational and calibration information is located

in files in the Quality Assurance Office.

Test equipment is calibrated periodically depending upon the

application, ranging from daily to once every three years. Electrical

equipment is typically calibrated once per year, at a minimum.

Adjustments are made to the calibration frequency via a corrective

action report to address complaints or to ensure credible results. A

written general procedure identifying the calibration history, records,

and frequency of usage is utilized to determine any deviation from the

equipment manufacturer's recommended or Entela's usual calibration

intervals.

The Quality Assurance (QA) Department is responsible for

maintaining the calibration database, the department monthly recall

reports, and the procurement of calibration services. Each department

is responsible for timely calibration and preventive maintenance of its

equipment. The QA Department retrieves or locks out any equipment that

is not turned in for calibration. New and repaired test equipment is

calibrated prior to use. When a piece of equipment is received for

repair or routine calibration, its ``as received'' calibration status

is noted. This status is evaluated for its effect on testing that has

been performed with that equipment to determine whether retesting is

necessary.

Each item of test and measuring equipment is required to have a

label that depicts its calibration status. For example, it may have a

calibration label or may be labeled, ``Before Each Use'', ``Out of

Calibration'', ``Out of Service'', or ``For Reference Only''.

Calibration labels identify the date when last calibrated as well as

the date for the next calibration.

Repair and Calibration records are maintained for the life of the

equipment in the master calibration files and on the database computer

(calibration). Calibration standards are traceable to NIST or to

international standards bodies. Primary standards include: Gage and

hardness blocks, laser interferometers, and chemical references.

The QA Department issues monthly calibration recall notices and

preventive maintenance reports to each department based upon the master

calibration database. The department managers are responsible for

complying with any of the requirements noted in the report. The Quality

Assurance manager will remove any non-calibrated equipment and place it

in a locked storage area unless the equipment meets the criteria for

extension of calibration.

A number of test and evaluation procedures were reviewed in various

ongoing program areas. The specific ongoing programs the laboratory is

involved with that identify the records required to be maintained for

an investigation are followed. These programs use ANSI/UL Standards,

ASTM test procedures, the Quality Control Manual, Third Party

Certification Program (TPCP) Manual, Client Test Procedures, and

Departmental Operational Procedures. These procedures contain

construction or testing parameters to be met by the product being

evaluated and, as required, the chronological order of evaluation. The

staff responsible for safety testing generally consists of degreed

engineers and chemists. In most instances, the test standard provided

sufficient detail for laboratory personnel to conduct a step-by-step

approach to develop repeatable and accurate test and evaluation data.

Where appropriate, the test engineer provides a narrative report along

with the test data to document compliance of a product with the

standard. Standardized tests that are frequently run have a standard

test data sheet available that contains the necessary information for

the laboratory technician.

Sample test and evaluation procedures and reports for the NRTL

Program activities were reviewed. These sample reports include

narrative descriptions. The test procedure format and scope are

identified in the Third Party Certification Program Manual, and

describe the content and scope for the Standard Operational Procedure.

The laboratory has developed a generalized processing procedure for the

product classes of electrical appliances and lighting products in final

form, and in draft form for flammability testing.

Several Standard Test Procedures (STPs) were reviewed in various

program areas. Entela will develop and submit additional STPs, where

necessary, prior to listing products related to these procedures.

Specific program procedures and policies are developed by the

individual departments and are audited twice per year by the President

or Vice President of the laboratory. Management and the project manager

are responsible for assuring that procedures are followed. These

operating and testing procedures are determined by the work order which

specifies which standard(s) and provisions are to be utilized.

Operational procedures and policies are implemented through the

training program at Entela, Inc. The master copy is located in the

Standards Library, with controlled copies located in each department.

Present policy utilizes a technical committee and standards experts

to determine the appropriate standard in evaluating a product. Standard

interpretations are developed by consensus of the technical committee.

The Project Manager distributes technical advisory letters describing

standards policy on interpretation or deviation decisions to all

parties affected. The laboratory personnel are members of various

organizations which develop standards applicable to their on-going

programs in the automotive, flammability, metallurgical, quality,

electrical and chemical testing areas.

A technical committee and standards experts determine the

appropriate standard or standards to be utilized in evaluating the

product. Disagreements between the applicant and the laboratory

regarding standards applicability are resolved using the Entela Inc.

Third Party Certification Committee, technical experts, and input from

the standards-writing organization. The decision of the laboratory

regarding which standard is applicable is final.

The TPCP Manual addresses the interpretation of these standards and

the appeals procedure available to a client, when there is a

disagreement with that interpretation. The TPCP Committee interprets

the section of the standards, which are also available for distribution

to interested parties. Consumer inquiries and complaints are also

addressed in the TPCP Manual.

Entela personnel serve on technical committees to enable them to be

cognizant of changes to the standards with which they are involved. The

laboratory is continuing to develop committee membership in various new

product areas of interest.

Test procedures contain the following: Instructions on equipment;

preparation of test samples; standard testing techniques; references to

specific standards, including titles and dates; testing equipment and

accuracies; precautionary statements for operator safety; test data

obtained, measurement resolution and data recording time; ambient

conditions and/or adverse environmental conditions; and acceptance

criteria tests. These test procedures are reviewed annually and are

approved by the technical department manager and the QA manager.

Sample test data sheets and attached work orders contain the

following: Standard and clause numbers; product model number; measuring

and test equipment I.D.; test date and report number, signature of

tester/reviewer; and Q.A; ambient conditions; test observations and

deviations; test data in the form of compliance, non-compliance, or the

need for further review.

Permanent records are compiled to document all technical and

quality related activities of the Certification and Testing Division.

The system for controlling all technical and quality records is

described in the Quality Assurance Manual.

The certification reports contain the following: Name and location

of submitter and factory; title, number, and date of standard use for

evaluation; file number, report date, edition number and revision date;

description of product including drawings, specifications, and

photographs; conditions of product use; construction and testing

narratives which describe how the product(s) comply with the standard;

tests and results of tests; deviations and technical rationale for

acceptance. The Quality Assurance Manual and the Third Party

Certification Program Manual identify the minimum information and

reporting format required for an investigation. Most reports followed

the required format. Entela has documented specific procedures for the

recording of any deviations and the associated technical rationale, or

for the modification of testing protocol.

The project manager, department manager, and test engineer, are

responsible for the preparation and review of the final report. The

test report is written by the test engineer or senior technician. The

senior technician is also responsible for reviewing and signing the

test data before it is reviewed by the project manager. A modified

review process of data sheets and reports has been instituted to ensure

that all signatures are in place and that any abnormalities or unusual

test results are identified.

Listings are revised with replacement pages. A new report is

prepared if extensive changes are required. Copies of the listing

report are given to the customer and to jurisdictional authorities,

where required, and placed in follow-up inspection files.

Standards updates are secured by maintaining update services for a

variety of standards. For example, UL standards quarterly index update

service is subscribed to and used to verify the latest edition of their

standards.

The project manager is responsible for providing the test engineer

with the latest revision of the appropriate standards. Superseded

standards are archived in the library and labeled as such, superseded

standards beyond 5 years are placed in filing boxes, labeled, and

stored in records storage.

The NRTL Program checklist has been developed so that the file of a

product listing is evaluated to assure its completeness through the

project manager's review of the file and use of the file checklist.

Safety testing records (OSHA/NRTL) are to be stored with the

nuclear files which are in a locked fireproof storage room in a

fireproof filing cabinet in the third building. No flammability testing

is conducted in this building. A procedure for control of files is in

place to protect them from damage, theft, or records loss. Duplicate

records are not stored off site.

The records are alphabetized by client. The verification and

identification of test reports of listed products is accomplished

through the use of the director of certified products. A label

numbering system is to be utilized for the NRTL program that will take

into account the various products, manufacturing sites, and variations

of a model line.

The office manager is responsible for filing and maintaining these

records. Procedures are in effect to distribute, recall, and revise

test records.

The Quality Assurance System consists of separate but interrelated

functional areas that report directly to the President or the Vice

President of operations. The Quality Assurance Manager is responsible

for the internal quality of the laboratory and its operations, and

reports directly to the President of the laboratory. The director of

Quality Assurance Services reports to the Vice President of Operations

and is responsible for the various programs that address the client's

preproduction qualifications, suppliers of laboratory services, follow-

up program, manufacturing monitoring and quality assurance assessment.

The individuals in the two positions assist each other in accomplishing

the workload without interfering with their job requirements or the

lines of authority. The Quality Manager is independent of operations

and has the responsibility and authority for overseeing all activities

related to the internal laboratory quality program.

An internal audit program performed every six months is in place on

behalf of management to determine if all operations are complying with

the requirements of the current quality systems, procedures, policy

decisions, calibration programs, test procedures, and safety programs.

This audit evaluates both the operational function and the quality

assurance program at the same time, and is performed by the president

or vice president of the laboratory. Personnel interviewed in the

electrical and calibration areas were actively aware of the program.

The corrective action reports and the corrective action logs showed no

discrepancies.

Variations and discrepancies are addressed via a Corrective Action

Report (CAR). CARs not finalized in an appropriate time frame are

discussed at the directors' and managers' meetings and monitored by the

laboratory President.

Entela, Inc. is devoting additional resources in the quality

assurance area and will review weekly all open corrective action

reports of problems and root cause analysis. A corrective action system

is in place to document audit findings and to implement corrective

actions with specified time limits.

Entela performs follow-up inspections at various facilities for

other ongoing programs. Written procedures are in place for the various

programs. For example, the TPCP Manual, which is presently used in the

Government Services Administration (GSA) Furniture Certification

Program, identifies the various steps, policies and procedures that

will be used in the NRTL Program. A separate manual is presently used

in Entela's Certified Automotive Parts Association (CAPA) Program. The

Nuclear Program is covered under the Quality Manual.

The Entela, Inc. follow-up inspection procedure for the NRTL

program requires quarterly inspections on an unannounced basis at the

manufacturing facility. This program is designed to assure that:

1. The Entela, Inc. mark is applied only to certified products;

2. That the terms of agreement are adhered to when the Entela Inc.

mark is used;

3. Defects noted during previous inspections have been corrected;

4. Document control procedures and support staff training should

provide the assurance that all facility assessment records are on file.

NRTL factory inspections will be performed at the rate of at least

four inspections per factory per year. The frequency varies with

product volumes, types of products, and the manufacturer's prior

record.

When products fail to meet the requirements, the Quality Services

Division takes action to either have the manufacturers correct the

defect immediately, quarantine stock until the product can be reworked

or reevaluated by the Entela testing engineer, or remove the Entela,

Inc. mark from the product.

Entela, Inc. has a standard follow-up inspection form that will be

used to document the findings at the manufacturing site. The inspector

or inspecting engineer will use this form along with the follow-up

inspection file for that manufacturing site and product to evaluate the

product.

Entela, Inc. has a pre-qualification checklist for the evaluation

of a manufacturing facility that will be used prior to the factory

labeling of any products in the NRTL Program, as well as a Follow-Up

Service Inspection Report. The TPCP Manual identifies the procedures

required for the selection of product samples to test.

Entela, Inc.'s Quality Services Division will monitor products in

the field, when prompted by either factory anomalies of complaints, and

investigate field complaints. Entela, Inc. reserves the right to

utilize safety related public notification and mandatory recall

procedures. All consumer complaints are forwarded to the Quality

Services Director, Vice President, or President, as appropriate.

Distribution of labels placed on products is controlled, requiring

the manufacturer to obtain labels only from Entela. These labels are

then cached in a locked storage room.

An organizational chart identifies key laboratory personnel and

shows the relationship between administration, operation, and quality

control. There are approximately 65 personnel in the Entela

organization.

A written position description for each job title of personnel

involved with product testing and evaluation includes the necessary

education, training, technical knowledge, and the experience required

for the position. The position description specified the extent and

limitation of responsibility for the position. New position

descriptions and training programs are in place for the follow-up

inspection areas.

Written job descriptions are referenced in the Quality Control

Manual for staff involved with product testing and evaluation. These

job descriptions contain minimum requirements, education, technical

knowledge and experience requirement for their respective position.

The President and Vice President of Operation, who have overall

responsibility for the technical operations of the laboratory, have

technical degrees. Personnel assigned to the TPCP have the necessary

education, training, technical knowledge, and experience specified by

their position description. Training logs reviewed in the electrical

and in the calibration areas were current. Calibration training records

showed that the calibration supervisor qualified his staff on each

piece of equipment prior to any technician being allowed to perform

independent calibrations. The training records identify each staff

member and the test methods, procedures, and evaluations he or she is

qualified to perform. Continuing education and training programs are

held to instruct personnel on the proper methods of testing and

evaluation. This documented training program incorporates appropriate

test methods, equipment and operational procedures, product

evaluations, inspections, and technical/engineering course work, and is

updated annually.

The laboratory has a progressive performance appraisal system that

provides for self-evaluation, peer-evaluation and supervisory-

evaluation. The evaluation factors are both quantitative and

qualitative. The laboratory also includes a company evaluation as a

part of the employee program.

The laboratory has developed procedures that will enable it to

accept components and materials tested and evaluated by another NRTL

laboratory. These procedures include evaluating the listing report, and

reserving the right to retest and audit the components as it deems

necessary. Components tested and evaluated by Entela will fall under

their follow-up service agreement. An approved source list has been

revised to include company name, address, and area of expertise.

The TPCP identifies the circumstances when testing and evaluation

of a product may be accomplished at the client's facility, such as when

the equipment is large and not easily shipped or when specialized test

facilities are required. The TPCP also identifies the general criteria

for qualifying the manufacturer's facility to include the witnessing of

the tests.

A procedure exists for the qualification of subcontractors for the

supply of services in support of the laboratory functions. The

laboratory maintains a listing of approved external testing sources for

general laboratory support and a separate list for those suppliers that

qualify under 10 CFR part 50 for the nuclear industry. This listing and

any associated files has been reviewed for its completeness.

Background

The applicant states that Entela, Inc., was originally founded in

1974 as a Michigan Corporation called Entel Engineering Services (no

longer in existence) specializing in structural steel inspection, with

departments in structural engineering, field service inspection,

asbestos inspection, and geotechnical engineering. In 1981, equipment

and personnel were added to initiate an in-house materials laboratory.

Through a continued growth commitment and dedication to meet its

client's needs, the applicant states that it experienced dramatic

growth, necessitating the formation of certification programs within

Entela, Inc.

The services offered at Entela, Inc. (also doing business as Entela

Laboratories, Inc., but one in the same company according to the

applicant), include metals chemistry, simulated environmental testing,

plastics/non-metals testing, product testing, electrical/electronics

testing, metallurgy, mechanical engineering, third party certification

programs, metrology, and calibration. As of this time, Entela, Inc.

employs over 75 individuals and has two facilities, located in Grand

Rapids, Michigan and Taipei, Taiwan. Presently, all testing is

performed at the Grand Rapids facility, and only follow-up inspections

are carried out in Taiwan.

Entela, Inc. desires recognition for testing and certification of

products when tested for compliance with the following test standards:

ANSI/UL 45--Portable Electric Tools

ANSI/UL 48--Electric Signs

ANSI/UL 50--Electric Cabinets and Boxes

ANSI/UL 67--Electric Panelboards

ANSI/UL 73--Electric-Motor-Operated Appliances

ANSI/UL 82--Electric Gardening Appliances

ANSI/UL 94\1\--Tests for Flammability of Plastic Materials for Parts in

Devices and Appliances

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\1\Exclusive of radiant panel testing.

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ANSI/UL 98--Enclosed and Dead-Front Switches

UL 141--Garment Finishing Appliances

ANSI/UL 153--Portable Electric Lamps

ANSI/UL 174--Household Electric Storage-Tank Water Heaters

ANSI/UL 197--Commercial Electric Cooking Appliances

UL 213--Rubber Gasketed Fittings for Fire Protection Service

ANSI/UL 250--Household Refrigerators and Freezers

ANSI/UL 298--Portable Electric Hand Lamps

ANSI/UL 325--Door, Drapery, Louver, and Window Operators and Systems

ANSI/UL 469--Musical Instruments and Accessories

ANSI/UL 471--Commercial Refrigerators and Freezers

ANSI/UL 482--Portable Sun/Heat Lamps

ANSI/UL 484--Room Air Conditioners

ANSI/UL 496--Edison-Base Lampholders

ANSI/UL 506--Specialty Transformers

ANSI/UL 507--Electric Fans

ANSI/UL 508\2\--Electric Industrial Control Equipment

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\2\Limited to equipment of no greater than 500 amperes.

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ANSI/UL 541--Refrigerated Vending Machines

ANSI/UL 542--Lampholders, Starters, and Starter Holders for Fluorescent

Lamps

UL 544--Electric Medical and Dental Equipment

ANSI/UL 559--Heat Pumps

ANSI/UL 560--Electric Home-Laundry Equipment

ANSI/UL 609--Local Burglar-Alarm Units and Systems

ANSI/UL 751--Vending Machines

ANSI/UL 756--Coin and Currency Changers and Actuators

ANSI/UL 778--Motor-Operated Water Pumps

ANSI/UL 796--Printed-Wiring Boards

ANSI/UL 813--Commercial Audio Equipment

ANSI/UL 817--Cord Sets & Power-Supply Cords

ANSI/UL 863--Electric Time-Indicating and -Recording Appliances

ANSI/UL 869--Electrical Service Equipment

ANSI/UL 869A--Reference Standard for Service Equipment

ANSI/UL 873--Electrical Temperature-Indicating and -Regulating

Equipment

ANSI/UL 883--Fan-Coil Units and Room-Fan Heater Units

ANSI/UL 923--Microwave Cooking Appliances

ANSI/UL 935--Fluorescent-Lamp Ballasts

ANSI/UL 961--Hobby and Sports Equipment

ANSI/UL 984--Hermetic Refrigerant Motor-Compressors

ANSI/UL 998--Humidifiers

ANSI/UL 1004\3\--Electric Motors

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\3\Limited to motors rated no greater than one-half horsepower.

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ANSI/UL 1005--Electric Flatirons

ANSI/UL 1012--Power Supplies

ANSI/UL 1026--Electric Household Cooking and Food-Serving Equipment

ANSI/UL 1029--High-Intensity Discharge Lamp Ballasts

ANSI/UL 1042--Electric Baseboard Heating Equipment

ANSI/UL 1082--Household Electric Coffee Makers and Brewing-Type

Appliances

ANSI/UL 1096--Electric Central Air-Heating Equipment

ANSI/UL 1230--Amateur Movie Lights

UL 1244--Electrical and Electronic Measuring and Testing Equipment

ANSI/UL 1261--Electric Water Heaters for Pools and Tubs

ANSI/UL 1270--Radio Receivers, Audio Systems, and Accessories

ANSI/UL 1286--Office Furnishings

ANSI/UL 1410--Television Receivers and High-Voltage Video Products

ANSI/UL 1433--Control Centers for Changing Message Type Electric Signs

ANSI/UL 1438--Household Electric Drip-Type Coffee Makers

ANSI/UL 1445--Electric Water Bed Heaters

ANSI/UL 1459--Telephone Equipment

ANSI/UL 1570--Fluorescent Lighting Fixtures

ANSI/UL 1571--Incandescent Lighting Fixtures

ANSI/UL 1572--High Intensity Discharge Lighting Fixtures

ANSI/UL 1647--Motor-Operated Massage and Exercise Machines

ANSI/UL 1950--Information Technology Equipment Including Electrical

Business Equipment

Preliminary Finding

Entela, Inc. addressed all of the criteria which must be met for

recognition as an NRTL in its initial application and in its further

correspondence. For example, the applicant submitted a list of its test

equipment and instrumentation; a roster of its personnel including

resumes of those in key positions and copies of position descriptions;

copies of a typical test report; a factory inspection form and an

inspection summary; a summary of its listing, labeling, and follow-up

services; a statement of its independence as a testing laboratory;

appeals procedure; typical calibration forms; and a copy of its Third

Party Certification Manual and its Quality Assurance Manual. This QA

Manual includes a description of its document control; identification

and control of materials, parts, and components; inspection; test

control; control of measuring and test equipment; inspection, test, and

operating status; quality assurance records; and audits.

Nine major areas were examined in depth during the on-site

laboratory evaluation: Facility; test equipment, calibration program;

test and evaluation procedures; test reports; records; quality

assurance program; follow-up listing program; and personnel.

The discrepancies noted during the on-site evaluation were

adequately responded to (Ex. 3.A.(2)) prior to the preparation of the

final on-site evaluation (Ex. 3.A(1)). With the preparation of the

final report, the survey team was satisfied that the testing facility

appeared to meet the necessary criteria required by the standard, and

so noted in the On-Site Review Report (Survey). (See Ex. 3.A.).

Following a review of the application file and the on-site survey

report of the Entela facility, the NRTL Recognition Program staff

concluded that the applicant appeared to have met the requirements for

recognition as a Nationally Recognized Testing Laboratory and,

therefore, recommended to the Assistant Secretary that the application

the preliminarily approved.

Based upon a review of the completed application file and the

recommendation of the staff, the Assistant Secretary has made a

preliminary finding that Entela, Inc. can meet the requirements for

recognition as required by 29 CFR 1910.7.

All interested members of the public are invited to supply detailed

reasons and evidence supporting or challenging the sufficiency of the

applicant's having met the requirements for recognition as a

Nationality Recognized Testing Laboratory, as well as appendix A, of 29

CFR 1910.7. Submission of pertinent written documents and exhibits

shall be made no later than (May 2, 1994), and must be addressed to the

NRTL Recognition Program, Office of Variance Determination, room N

3653, Occupational Safety and Health Administration, U.S. Department of

Labor, 200 Constitution Avenue, NW., Washington, DC 20210. Copies of

the Entela, Inc. application, the laboratory survey report, and all

submitted comments, as received, (Docket No. NRTL-2-93), are available

for inspection and duplication at the Docket Office, room N 2634,

Occupational Safety and Health Administration, U.S. Department of

Labor, at the above address.

The Assistant Secretary's final decision on whether the applicant

satisfies the requirements for recognition as an NRTL will be made on

the basis of the entire record including the public submissions and any

further proceedings that the Assistant Secretary may consider

appropriate in accordance with appendix A of Sec. 1910.7.

Signed at Washington, DC, this 25th day of February 1994.

Joseph A. Dear,

Assistant Secretary.

[FR Doc. 94-4898 Filed 3-2-94; 8:45 am]

BILLING CODE 4510-26-M