Comment from Paul Verling

Document ID: CPSC-2009-0061-0002
Document Type: Public Submission
Agency: Consumer Product Safety Commission
Received Date: August 14 2009, at 01:36 PM Eastern Daylight Time
Date Posted: August 28 2009, at 12:00 AM Eastern Standard Time
Comment Start Date: August 13 2009, at 12:00 AM Eastern Standard Time
Comment Due Date: October 13 2009, at 11:59 PM Eastern Standard Time
Tracking Number: 80a095ff
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This is comment on Proposed Rule

Audit Requirements for Third Party Conformity Assessment Bodies

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The text published in the Fedral register under the subtitle "1112.7 What must an audit address or cover?" states that the accreditation body audit "may cover the management systems, specific tests.." and then ""could have the accreitation body assess..". The text also says "the rulewould not specify the precide scope of a re-assessment by an accreditation body". STR has many many tests on its schedule of accreditation and only a fraction of these are assessed on our annual re-assessment. The choice of which tests to choose on any year is up to the accreditation body. Our accreditors may not choose to re-assess our competency for tests for which we are listed as approved by the CPSC for years. Does STR have to insist that our accreditors re-assess our competency for CPSC listed CPSIA-linked tests at least every two years, or some other maximum interval, to satisfy the Commission and the proposed rule? Will just our continued accreditation as a lab to 17025 and the continued appearance of CPSIA-linked tests on our schedule of accreditation be sufficient to satisfy the examination requirements of the proposed rule?