By Karen Fierst, KerenOr Consultants
EDITOR’S NOTE: This article is an opinion piece written independently, and does not reflect the position of the ABPA or Body Language, which remain neutral on the issue of multiple certifying organizations. We are publishing it in the spirit of open communication.
A few months ago while I was traveling abroad I had a problem with the AC adapter to my laptop computer. Without going into details, the laptop was still covered by an extended warranty with DELL and they advised me to buy a new AC adapter and directed me to their local supplier. Luckily, it was only an hour drive from where I was staying. Going through this process involved picture taking and caused me to take a long hard look at the back of the AC adapter. I noticed that there were at least twenty logos. I assume that each of these marks represents compliance with either a voluntary or mandatory safety standard for a variety of countries. The new AC adapter had even more tiny logos on the back.
Seeing these certification marks got me thinking about standards and regulations, which, of course vary from country to country. I wondered whether it is necessary to bestow a monopoly on one company to audit compliance to a particular standard or regulation which brought me back to the recent industry discussion surrounding the existence of more than one aftermarket crash part certification “standard.” With these questions in mind I decided to do a little research. Here is a sample of what I discovered.
First step: define “standard”: According to Merriam Webster, a standard is something established by authority, custom, or general consent as a model or example; or, something set up and established by authority as a rule for the measure of quantity, weight, extent, value, or quality. So, my first revelation was that the “standard” is the end result, not the route taken to get there. In our industry we often mistakenly use the word “standard” as what should actually be referred to as an auditing “approach.”
As I dug further I discovered the following statement on the Occupational Safety and Health Administration (OSHA) website:
“OSHA’s Nationally Recognized Testing Laboratory (NRTL) Program recognizes private sector organizations to perform certification for certain products to ensure that they meet the requirements of both the construction and general industry OSHA electrical standards.”
Looking further I found 19 NRTL’s listed on OSHA’s website. In other words, 19 certification bodies certify to one standard and OSHA does not dictate the process by which the audit takes place.
Another example I found was the U.S. Department of Agriculture’s National Organic Program (NOP), which sets standards for organically produced agricultural products. They also accredit and oversee a network of organizations with third party auditors who certify food to the NOP standard, again with no direction on the process by which the audit takes place.
I found a few other examples of products with multiple certifiers auditing to a single American National Standard Institute (ANSI) standard, such as drinking water treatment products like filters. For example, Drinking Water Treatment Units – Aesthetic Effects establishes requirements for the certification of filtration systems designed to reduce specific aesthetic or non-health-related contaminants (chlorine, taste, odor and particulates) and Drinking Water Treatment Units – Health Effects establishes requirements for the certification of filtration systems designed to reduce specific health-related contaminants, such as Cryptosporidium, Giardia, lead and volatile organic chemicals (VOCs) that may be present in public or private drinking water.
As systems, rather than a product certification, the standards promulgated by the well-known International Organization for Standardization, known as “ISO standards” are audited by different companies throughout the world. Companies that pursue ISO 9001 certification (Quality Management) must meet a series of quality principles (i.e. risk management, communication, leadership, performance, etc.). However, the structure of the audit may differ by certifier. Using the same compliance standard, certifiers use different auditing approaches to evaluate whether or not a company meets the criteria to become ISO Certified.
There is an international network of private and not for profit companies which provide auditing services. These companies rely on auditor training programs conducted by organizations such as the International Register of Certificated Auditors (IRCA) and the Society of Automotive Engineers (SAE) to prepare professional auditors ready for employment.
There are also situations where a product may be certified to the same standard by a number of different parties. Juvenile recreation equipment (playgrounds) is among the many products which, for a variety of reasons, must meet more than one standard, each of which require third party certification. The AC adapter mentioned earlier is another one of those products.
The fact is that there is only one standard when it comes to a reverse engineered product – the original. Reverse engineering is a well-known and accepted engineering process which has been used for decades in such diverse industries as aerospace to plumbing and everything in between.
Too often we mistakenly refer to the auditing process as “the standard,” but in engineering circles there is a distinct difference. The standard for aftermarket replacement crash parts is the Original Equipment Service part (OES). It is not uncommon for there to be a variance between the OEM part, the part made specifically for assembly, and the replacement OES part. In spite of that, OES parts serve as the one and only standard for any replacement part not made by a vehicle manufacturer.
There are a few different auditing approaches which have been developed and are being used to establish equivalency between a certified aftermarket part and an OES. Each auditing approach differs from the other in its certification process to some degree. However, this should not be interpreted as one process being superior to the other. They are simply different approaches to reaching and maintaining the same goal.
Currently, I am aware of four different certified aftermarket part auditing processes, with more probably being developed somewhere in the world. Thatcham/TUV is the program recognized in the UK. Centro Zaragoza’s aftermarket part certification process is recognized in Spain and parts of Europe. NSF’s certified aftermarket crash part process is recognized in the U.S. and Australia. Long time player CAPA is also recognized in the U.S.
Each of these four programs has taken a slightly different approach to certifying a variety of crash parts to the OES standard. Their auditing processes differ, for example, between the actual number and type of audits required and a few required internationally recognized tests (e.g. SAE and ASTM). However, each process was developed to certify that any single certified aftermarket crash part is equivalent in fit, form and function to the OES part. There is no basis to suggest that any of these certification processes is superior to any other. In fact, all four certification bodies are accredited, highly respected and have a long history of providing certification services.
The bottom line is that it is not uncommon for a product or service to be certified utilizing different certification approaches to assure compliance to a quality standard. Those approaches to certification could be either a single standard with multiple auditors using different audit tools/approaches or multiple standards covering the same attributes and using multiple audit tools/approaches. As such, in our industry’s case, there is no reason for concern or confusion over the existence of more than one approach to achieving compliance to a particular standard, unless the procedures outlined in the auditing process and/or functions conducted are not in compliance to the process used to certify an aftermarket replacement part to its OES standard.
Karen Fierst
Principal
KerenOr Consultants
kfierst@kerenorconsultants.com
301-681-4383
