Letter writing campaign. We used the
AIHA and AIHA-LAP, LLC websites to ask
members and labs to write policymakers
about this issue. The letters asked CPSC to
either recognize AIHA laboratories outright or to recognize NACLA laboratories
that have been peer reviewed to the standard that ties together all ILAC MRA signatories—ISO/IEC 17011. We were
supported in these requests by several
members of Congress and our one-hun-dred-plus lead laboratories, many of which
have been recognized by AIHA for the
better part of a decade.
Meetings with policymakers and CPSC
officials. I accompanied AIHA Executive
Director Peter O’Neil and Director of Gov-
ernment Affairs Aaron Trippler on several
trips to Capitol Hill for face-to-face meet-
ings with staff from key Congressional
committees, the Small Business Adminis-
tration and CPSC. We recommended that
CPSC amend its requirements so that test-
ing laboratories could achieve CPSC
third-party status by demonstrating com-
pliance with ISO/IEC 17025 and receiving
accreditation from an accreditation body
that demonstrated compliance with
ISO/IEC 17011. AIHA also supported an
alternative recommendation espoused in
our October 22 written comments—that
CPSC third-party testing laboratories
should be compliant with ISO/IEC 17025
and be accredited by an accreditation body
that is either an “ILAC MRA signatory or
recognized by the National Cooperation for
Laboratory Accreditation (NACLA).”
Asia Pacific Laboratory Accreditation Co-
operation (APLAC). AIHA-LAP, LLC has ap-
plied for ILAC membership and for MRA
status under both regional bodies. Recogni-
tion by either body would translate into
ILAC MRA recognition status for AIHA-
LAP, LLC. A joint APLAC/IAAC evaluation
of AIHA-LAP, LLC was scheduled for July
2009. The results of this evaluation were
not known at the time of publication; how-
ever, if all goes well, we can attain ILAC
MRA status before the end of the year.
Lessons Learned
Although we did not achieve our goal of
third-party listing with CPSC, we feel priv-
ileged to have partnered with AIHA-ac-
credited laboratories and their customers
(AIHA members) to fight the good fight.
We got the attention not only of CPSC but
also of policymakers in Washington. They
now understand that AIHA-accredited lab-
oratories meet or exceed the ILAC MRA
standards. We have learned many lessons
through this process; most importantly, we
have sharpened our ability to identify
federal proposals that approach laboratory
accreditation in the same way.
Cheryl O. Morton is director of AIHA
AffiliateLaboratoryPrograms,LLC.
Reading the Alphabet Soup
Definitions for the acronyms used in this article:
ILAC: The International Laboratory Accreditation Cooperation ( www.ilac.org). ILAC
is an international cooperation of laboratory accreditation bodies. In 2000, 36 accreditation bodies recognized by ILAC signed an agreement known as the ILAC Mutual Recognition Arrangement (MRA). MRA signatories undergo peer review to
demonstrate that they meet ILAC’s criteria for competence.
Plan B
Despite our best efforts, CPSC officials told
us that they will most likely not amend the
third-party testing requirements. CPSC
cited concerns about the increasing volume of goods imported into the U.S. and
the validity of the scientific data submitted from other countries as reasons for
denying our request.
We continue to believe that adding
AIHA-accredited labs to the CPSC third-party list does not compromise CPSC’s
broader trade-related goals. However, we
have accepted the commission’s decision.
AIHA-LAP, LLC is now focused almost
exclusively on efforts to achieve ILAC
MRA status.
We are already members of two ILAC
regional bodies—the Inter-American Accreditation Cooperation (IAAC) and the
NACLA: The National Cooperation for Laboratory Accreditation ( www.nacla.net). Established in 1998, NACLA evaluates U.S. laboratory accreditation bodies and grants
recognition to those in compliance with NACLA procedures and relevant international standards. AIHA Laboratory Accreditation Programs, LLC is a NACLA-recog-nized accreditation body.
ISO: The International Organization for Standardization ( www.iso.org). The world’s
largest developer and publisher of international standards, ISO includes the national
standards institutes of 161 countries.
IEC: The International Electrotechnical Commission ( www.iec.ch). IEC publishes international standards for all electrical, electronic and related technologies.
ISO/IEC 17011: This standard, “General Requirements for Accreditation Bodies,” is
the standard to which all ILAC-recognized accreditation bodies conform.
ISO/IEC 17025: This standard, “General Requirements for the Competence of Testing and Calibration Laboratories,” is the standard to which all accredited laboratories (including AIHA-accredited laboratories) must demonstrate conformance. It
covers testing and calibration performed using standard methods, non-standard
methods, and laboratory-developed methods.
