The statement (reprinted in a succeeding paragraph) was distributed to major certifying bodies and testing agencies to highlight U.S. and Canadian plumbing manufacturers' goal of products to be "tested and certified once, and recognized worldwide." The statement specifically urged that test data generated by testing laboratories accredited under ISO Guide 25 be accepted by certification agencies accredited through the Standards Council of America (SCC) and the American National Standards Institute (ANSI) without further review. Manufacturers also strongly urged that plumbing products and materials already listed/certified by an accredited certification agency using test data generated by an accredited testing laboratory should have that listing/certification accepted by other certification agencies, without further review. The statement concludes that certification agencies meeting those criteria would be the "preferred provider" for plumbing manufacturers in the U.S. and Canada.

Canadian manufacturers of the CIPH Plumbing Industry Advisory Council (PIAC) met with certifying organizations accredited by the Standards Council of Canada to express concern about the high costs of certification duplication. CIPH General Manager Ralph Suppa states that "industry pressure will continue until universal conformity is attained." The next meeting will be in Toronto in January 2001.

Panel Discussion on Duplicative Concerns

A panel discussion on Sept. 26, 2000, included James Beyreis, vice president of Global Programs and Services--Americas for Underwriters Laboratories, Inc.; Ron Coiner, general manager of the plumbing product certification program at NSF International; Joe Gryn, director of engineering quality assurance at CSA International; Norman Hester, technical director of Truesdail Laboratories, Inc.; and Shahin Moinian, senior director of IAPMO Research & Testing.

During the two-hour discussion, each organization responded to a specific set of questions developed by PMI members, regarding current procedures and conformity assessment initiatives (see paragraph on Questions). PMI members who attended the panel presentation, while cautiously optimistic that agencies are moving forward in addressing plumbing manufacturer concerns, acknowledged that the goal of universal conformity assessment is still far from the current reality of business practices.

Product Approval Model Recognized

In September 1996, NCSBCS launched a five-year regulatory reform project (NCSBCS Streamlining Project) consisting of national organizations and federal, state and local regulatory agencies working toward reforming the nation's building regulatory process by eliminating regulatory overlap, duplication and costly, unnecessary and lengthy processing time. The project promotes state and local economic development by streamlining the nation's building process through workable model processes, procedures, rules and regulations. This reform project was looking for models of the best practices addressing a particular regulatory problem.

PMI submitted its plumbing product approval model, which provides regulatory agencies with a method of determining product performance and compliance with a high level of confidence while eliminating duplicate testing and product certification. The model specifically addresses products that are tested and certified by accredited agencies to nationally recognized product standards that are determined to be in compliance with the plumbing code. At the Fall Meeting, the NCSBCS Regulatory Affairs Committee determined that the PMI model would reduce unnecessary duplication and complexity in conformity assessment requirements and approved it for use.

The PMI model also received recognition from NIST, which published a white paper titled, "Conformance Assessment Applications for Recognition of Plumbing Product Approvals," that supports the current model.

PMI, CIPH Joint Position Statement on Universal Conformity Assessment, Issued June 14, 2000

As representatives of U.S. and Canadian plumbing manufacturers, both PMI and CIPH urge that test data generated by testing laboratories accredited under ISO Guide 25 by organizations such as SCC, National Voluntary Laboratory Accreditation Program of the National Institute of Standards & Technology (NVLAP), American Association of Laboratory Accreditation (A2LA), National Evaluation Services (NES) and International Conference of Building Officials--Evaluation Services (ICBO-ES), should be accepted by certification agencies accredited through SCC and ANSI without further review.

In addition, plumbing products and materials already listed/certified by an accredited certification agency for specific referenced standards using test data generated by an accredited testing laboratory should have that listing/certification accepted by other certification agencies without further review or auditing. The goal of both PMI and CIPH is for plumbing products to be tested and certified once, and recognized worldwide.

It is imperative that test data generated by nationally and internationally accredited testing laboratories be recognized and accepted by certification agencies in order to reach this goal. Similarly, the listings and certification of accredited certification agencies must also be recognized and accepted universally by the appropriate certifying agencies in each jurisdiction.

Accredited certification agencies providing such a service will be the preferred provider for plumbing manufacturers.

Questions for NSF 61 Certifiers

• As you know, PMI has identified the unnecessary duplication of testing and certification as one of our primary concerns as an industry association. Duplicate testing and certification to NSF 61 has recently become a serious concern with the incorporation of NSF 61 into the CSA B125 and ASME A112.18.1 standards. In response, PMI and CIPH developed a position statement that was distributed to your organizations regarding the elimination of unnecessary duplication in NSF 61 testing and certifications. What has each of your organizations done to respond to industry's concerns?

• We understand that each of your organizations will accept NSF 61 test data generated by other organizations. It is our understanding that at least one organization will only accept this data for a limited amount of time, citing the need to form a mutually acceptable partnership with other organizations. What is your company's position on this issue?

• Will materials and components certified by another agency be accepted by your organization?

• We have been told that in some instances, manufacturers have had a difficult time providing all the necessary information. Please clarify what the initial policies and procedures are for acceptance of certifications and/or data from other organizations.

• Once initial test data has been accepted from another agency and certification has been issued, what are the on-going requirements to maintain certification? Once the products are certified by your organization, will your organization require additional plant auditing and follow-up testing to that of the other agency?

• We understand that one of the requirements of accreditation is to implement a policy to ensure compliance on an on-going basis. We also understand that some of the certifiers require complete re-testing of all products every five years, even for products that have not had changes in design, manufacturing process or materials. Since testing for compliance with NSF 61 is extremely costly, can each of you discuss your policy for re-testing and explain why this is necessary to ensure products continue to comply with the standard?

• What is NSF's position with respect to other listing agencies' attendance at the Joint Committee meetings? What is the opinion of the other listing agencies in regards to participation in these meetings?

• At least one certifier announced that a change in certification marking was required for the Canadian market to demonstrate compliance with the applicable fitting standard and NSF 61 (adding a Canadian and U.S. qualifier under the certification monogram). In response to concerns expressed by PMI and CIPH about cost increases and legibility, that agency has since agreed to make the Canadian and U.S. qualifiers optional. Can you tell us what your agency has done to address the NSF 61 certification marking issue?

• With regards to marking requirements, can you explain any special marking requirements you have, beyond your certification mark (e.g. file numbers, year of the standard)?

• As stated earlier, PMI's primary conformity assessment goal is to have products tested once to gain worldwide acceptance. Certainly, third party certifiers with the broadest recognition would be preferred. What is your organization doing to promote recognition of its certifications in the U.S., North America and Internationally? What has your organization done to get jurisdictions operating duplicative certification programs to recognize your certifications?