June 2001
Volume 43 Number 6
 

Product Testing: Client Interactive Programs -- An Alternative Approach to Obtaining Certification
by Kenneth Jenke   Pages: 

Photographs, figures and/or graphics that may illustrate this article are visible in the printed version of the article only. To receive a copy, please make a request at info@wcponline.com. Be sure to include the article title, author(s) name(s), the issue, your name and your fax number or full address in the email.

Certifications of drinking water treatment units (DWTUs) involve the testing and examination of these products for performance claims, health effects and electrical safety. While Underwriters Laboratories Inc. and other organizations maintain extensive facilities for these purposes, it's also possible to utilize manufacturer's test facilities for testing of products under one of UL's Client Interactive Programs (CIP) for acceptance of client generated test data. CIPs have been established in an effort to assist manufacturers to achieve certification of products in less time and at less cost, and avoid unnecessary duplication of facilities and effort while maintaining the credibility and integrity of the certification mark.

Program components
Following is a description of the different programs within the CIP, starting with the first level, the Witness Test Data Program, and finishing with the top level, the Total Certification Program. Also described is the Third Party Test Data Program, which allows for acceptance of data from client test or subcontractor laboratories.

Witnessed Test Data Program (WTDP): The initial step in the CIP process, a manufacturer demonstrates the technical expertise that's required in most of the remaining programs. The manufacturer's personnel carry out tests at its facilities with direct supervision and witness of trained audit personnel. Under this program the manufacturer must have the physical resources, equipment and qualified personnel needed to conduct the testing. Adequacy of the facilities is reviewed and performance of tests and recording of data are overseen. This program requires the presence of a trained auditor to witness testing each time it's completed at the manufacturer's facilities.

Client Test Data Program (CTDP): Tests here are carried out at the manufacturer's facilities under a laboratory quality management program, which has been assessed and determined to be adequate for performance of the testing. Test data developed and utilized under this program are subject to review, audit and verification. Unlike the WTDP, this program doesn't require the presence of a trained auditor to witness testing each time such testing is completed.

The manufacturer must have a laboratory quality management program in place, physical resources, equipment, qualified personnel and procedures needed to conduct the tests. Before the manufacturer's test data can be accepted, an assessment is made of the test facilities and verification of test data must be performed. The test data verification may be completed as part of the CTDP or by verification studies conducted by UL. After the program is established, the facilities are periodically reassessed. All data submitted are thoroughly reviewed and audited.

Compliance Management & Product Assurance Program (COMPASS): This program permits greater involvement of client personnel in the product certification process by extending the concepts of the CTDP to the documentation of product compliance with certification requirements. Under this program, manufacturers are permitted to make minor revisions to the product while continuing to use the certification mark. Major product revisions and new product submittals can be handled on an expedited basis under this program.

Clients participating in COMPASS must meet criteria in four essential areas:
* Implementation of a product assurance system,
* Participation in the CTDP,
* Adherence to UL investigation and report-writing procedures, and
* Special COMPASS Follow-Up surveillance program. On an annual basis, the staff will make an assessment visit to each facility having responsibility for product engineering to assure continued compliance with requirements.

Total Certification Program (TCP): TCP provides a means for clients to reduce the time of "product concept to market cycle." TCP is an interactive, system-driven program, which integrates certification activities with the product development and manufacturing processes. TCP combines UL efforts with client capabilities in the areas of standards interpretation, and development and testing of products under a quality assurance system.

Third Party Test Data Program (TPTDP): TPTDP provides procedures for acceptance of test data developed by third party testing organizations that operate under a formal agreement, as a Client Test Laboratory or a Subcontractor Laboratory.

Each test laboratory undergoes an assessment of its operations program for conformance with generally accepted laboratory practices. An assessment based on ISO/IEC 17025, "General Requirements for the Competence of Testing and Calibration Laboratories," is conducted. Assessments shall be performed by individuals specially trained and familiar with these documents and techniques (see Figure 1 below).

Each laboratory also undergoes an assessment to determine its capabilities and qualifications to perform testing to specific standards. Knowledgeable individuals experienced in the testing conduct the assessments. Individuals performing specific technical assessments use an assessment checklist covering areas required to test according to the specific standards (see Figure 2 below).

Initial correlation studies are conducted to establish equivalence of testing conducted at the laboratory to UL test data.

Conclusion
The use of CIPs is a method for manufacturers to achieve certification of products in less time and cost, as well as to avoid unnecessary duplication of facilities and effort while still maintaining the UL Mark. These programs along with "One-Stop Delivery," which is the ability to obtain multiple certifications such as electrical, CE marking, ISO registration, ANSI/NSF Standards and even the WQA Gold Seal in one setting, are useful to many manufacturers looking to reduce certification costs and bring all of their certification needs under one roof.

About the author
Kenneth Jenke is senior project chemist working in the area of certification of drinking water treatment units for Underwriters Laboratories Inc., of Northbrook, Ill. He holds a bachelor's degree in chemistry from Western Illinois University. He can be reached at (847) 664-2656 or email: kenneth.s.jenke@us.ul.com

###

Figure 1. Conformance with Generally Accepted Laboratory Practices Assessment
Points of overall capabilities, qualifications and laboratory operations program covered are:
* Overall scope of activities,
* Organization and management,
* Quality system and manual,
* Personnel -- general qualifications,
* Equipment, materials and facilities -- general capabilities,
* Calibration and maintenance program for measurement and test equipment,
* Record keeping and reporting methods,
* Document maintenance,
* Subcontracting and use of outside services, and
* Internal audits.

Figure 2. Evaluating Ability & Qualifications for Testing to Specific Standards
The checklist covers:
* Facilities -- space, test rooms, environmental controls, power sources, fuel supplies, etc.,
* Measurement and test equipment -- meters, tools, chambers, etc.,
* Standards -- availability of specific standards,
* Personnel -- specific knowledge and skills,
* Test performance -- review of tests being performed, and
* Data recording -- review of practices.