Tips for handling third-party safety certification challenges
Manufacturers face many challenges in the current economic environment, so they must remain vigilant for opportunities to improve the bottom line. One way they can improve their financial and/or product performance is to change suppliers or components or to use new materials when constructing their products. Reasons to change sourcing may include:
More favorable commercial terms
Components made of alternative raw materials that are less expensive yet meet performance requirements
Favorable currency conversion rates obtained by sourcing from a different geographic region
However, manufacturers that decide to change suppliers of a component or material in a product that bears a third-party safety certification Mark need to be sure that their product continues to comply with applicable standards.
Considerations for Compliance
The majority of manufacturers have quality control and procurement processes to validate that new suppliers, components and/or materials continue to meet the design and performance requirements of the end product. While the physical and dimensional properties are critical to the continued satisfaction of distributors and end users, meeting or exceeding performance standards and cost considerations are not the only issues of the new construction that must be managed.
Examples of products in which additional considerations are necessary are potable water pumps and pumping products that are certified to NSF/ANSI Standard 61. Manufacturers of these products must also consider the health/safety aspects of the new components or materials to continue compliance to the standard.
While a variation of 0.1 percent in an ingredient of a plastic component may have a neutral or positive effect on the performance of the part, that small change might be enough to cause the product to surpass the health effect standards, exceeding the allowable levels—sometimes much greater than the associated limit. For this reason, third-party accreditation bodies are unable to accept changes to an existing product until they can determine that the change will not negatively impact public health and safety.
Making a change without informing the certification body early in the process may lead to unexpected problems and expense, including the costs of additional testing or design changes or the potential loss of certification.
Two Paths to Continued Compliance
With advanced consideration of the certification aspects of component or material changes, manufacturers can take proactive steps to mitigate potential pitfalls associated with design changes. There are two main options that a manufacturer may consider regarding continued product compliance:
Switch to components and materials that already have a stand-alone certification to NSF/ANSI Standard 61.
Have the new component or material investigated specifically for its intended, final-product use before changing the construction.
Certified Components and Materials
The first choice, sourcing materials that have stand-alone certification to NSF/ANSI Standard 61, is a common practice. Existing certification from a third-party testing body provides the manufacturer a high degree of certainty that the end product will also be compliant.
However, third party certification bodies have varying policies regarding the acceptance of each other's certifications, and in some cases, may not accept the certification of another party. Remembering this possibility is important. Generally, though, certification bodies will consider other third-party testing organizations' certifications to NSF/ANSI Standard 61 after reviewing the original test records and test data. Limited verification testing may also be required in these instances, but costs and time constraints are kept to a minimum. Manufacturers are encouraged to communicate the desired change to their certification body as soon as possible so that they understand its acceptance policies and receive direction on how to facilitate a smooth transition.
Manufacturers' should also alert their perspective vendor that data may be required to support the existing certification. This issue should be broached as soon as possible during negotiations to avoid costly delays and strained relations due to unclear expectations.
Manufacturers must also verify that the existing certification of the chosen component or materials is applicable to the intended use of the product. While the vendor may have obtained certification, it may be for a different end use. Taking any engineering use restrictions into consideration is also critical.
For example, a manufacturer sourced a coating for a pump that was certified to Standard 61. The coating could be certified only for use with potable water tanks of 1 million gallons or greater. Although the coating is indeed certified to Standard 61 and therefore acceptable for use in potable water applications, it was not suitable for the pump in question because of the difference in the surface area to volume ratio of a pump when compared to a storage tank. A pitfall such as this one is something that manufacturers should be cognizant of to avoid costly delays.
Another common engineering restriction for coatings is thickness. The coating may be certified to a specific dimension that is thinner than required for the end product. Again, understanding any engineering restrictions on the certified material or component and correlating that information to its intended use will help to avoid transition problems.
Additionally, NSF/ANSI Standard 61 contains multiple sections. Each is designed to evaluate different classes of products. The manufacturer should therefore verify that the product has been evaluated to the appropriate section. Compliance to one section of the standard does not guarantee that it will be found compliant in another section.
Pump manufacturer's must also be aware of the lead content in any new components, particularly in brasses, as this could jeopardize their compliance with California and Vermont low-lead laws.
Investigate Component Compliance
When a manufacturer has sourced materials that do not have stand-alone certification to Standard 61, it should request an investigation of the component or material for compliance to Standard 61 as it will be used in the end product.
Because the material or component chemical formulation information will be required for this investigation, the cooperation of the supplier is necessary. The chemical formulation information must be obtained to generate a toxicological review of the material and determine the analytical testing parameters. A key benefit of certifying the new material is that the manufacturer gains the ability to use this material throughout its product line, assuming that any engineering-use restrictions are addressed.
Often, the longest potential delay in updating a certification is the gathering of formulation data. For this reason, the manufacturer should communicate with their potential supplier about the information it needs so that the component or material can be used in the product. To alleviate any confidentiality concerns that the vendor may have with disclosure, the manufacturer should communicate that this information can be provided directly to the certifying body and does not need to be shared with the manufacturer.
Further, discussing the project with the certifying body early in the process can help prepare the manufacturer for the vendor conversation. In some cases, particularly with components, vendors deeper in the supply chain may need to submit formulation information. The earlier in the process that these conversations occur, the more likely the manufacturer will accomplish a smooth transition.
Conclusion
In summary, manufacturers should be aware that changing components and materials could directly impact the certification status of their products. While new materials and components can lead to improved financial or physical performance, third-party safety certifications must be addressed to avoid potential delays in bringing the revised product to market. Options for manufacturers to ensure compliance include:
Choosing components and materials that already have stand-alone certifications to the applicable standard
Submitting the product with the new component or material to their certifying body for additional testing
When choosing products that have been certified by a third-party certifier, manufacturers must keep in mind that certifiers have different requirements and may require a data review and/or additional testing of the product to continue certifying it. Understanding all engineering restrictions that have been applied to the new component or material as a condition of certification must also be clearly understood.
Transitioning to new components, materials or vendors requires good communication and advanced planning. The vendor needs to be aware of the certification of the end-use product and should be prepared to provide the data for their components that carry third-party certification.
For uncertified materials, the vendor should be alerted that the chemical formulation of each part will be required, including materials from their suppliers. Manufactures should not complete a great deal of component and material testing for performance before informing their certification body of the intent to change suppliers. Contacting the certification body as early in the design change phase as possible is strongly suggested. This way, the manufacturer can begin to gather the required information to help facilitate a smooth transition from the old to the new component or material.
Pumps & Systems, November 2010
Tom Bowman is currently the program owner for Underwriter's Laboratories' (UL) Water Systems program. In this role, he oversees quality and certification aspects of UL's Marks programs for water. Bowman has been with UL for 17 years and holds Bachelor of Science degrees in Biology and Chemistry.