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NATA/CNAS Interaction on Product Testing

Overview

NATA and our Chinese counterparts (CNAS) are working together to review conformity assessment processes and the associated accreditation activities relating to building and construction products specifically in the areas of windows, structural steel, fasteners (including high-tensile bolts) and electrical fixtures. The work is being funded with assistance from the Commonwealth through the Department of Industry.

The trading relationship between Australia and China combined with a well established and cooperative relationship with CNAS made it an obvious choice for a bilateral project to examine what accreditation bodies might do to improve product compliance outcomes.

It is hoped that the outputs of the project might then be shared with other MRA partner accreditation bodies and used to improve product compliance outcomes more widely.

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What’s being considered?

The project’s primary intention is to identify differences and to use these as the basis for a learning process to enhance confidence in accreditation in both countries. Since building products are a particular subject of interest of bodies such as the Australian Industry Group (AIG) and the Australian Procurement and Construction Council (APCC) there was some logic in starting with this sector.  Within this sector we are limiting our investigation to a small number of products simply for logistical reasons.

Not all factors that contribute to the supply of product that is compliant with regulatory and industry expectations are within the domain of accreditation and conformity assessment. That said, both NATA and CNAS recognised from the beginning that accreditation and conformity assessment aspects of a supply chain could not be considered without the consideration of the broader context. As such, the project is considering elements such as:

  • product standards;
  • the regulatory requirements and processes applied in both countries;
  • conformity assessment activities associated with products - components and finished products;
  • customer (importer) specification and purchasing arrangements;
  • the level of industry understanding of “mutual recognition”;
  • the incidence of fake conformity assessment reports;
  • the need for supply chain education.
        

Processes

A number of NATA staff have been involved in background research into regulatory processes and appropriate industry stakeholders in both Australia and China to inform the direction of these activities. CNAS has also appointed an experienced team of senior staff to the project.
Mutual visits facilitating technical level discussions have taken place in recent months. These have included site visits to accredited facilities.

What has been revealed so far?

Our initial focus has been on windows with NATA and CNAS and we are grateful to Ms Tracy Gramlick and her colleagues from the Australian Window Association for their invaluable assistance and support.

The results so far indicate that significant issues exist around poorly defined standards and specifications and inadequate oversight of the supporting information provided with imports. There is also a culture in Australia of purchasing at the lowest end of the price scale without adequate consideration of the implications for product quality.

Testing issues have been identified but not relating to competence or capability. Indeed, the majority of these have so far been centred upon a lack of clarity in the specifications and standards - suggesting there is currently a need for “local knowledge” about intent and context before they can be correctly applied.

It is clear that action is required in Australia to provide better information and assistance to importers of products, and their end-users, to improve their understanding of the conformity assessment systems that exist and the importance of asking the right questions of both suppliers and conformity assessment bodies.

A significant number of actions have been identified which will require NATA to liaise with industry groups within the construction sector, government agencies, JAS-ANZ, the Australian Building Codes Board and Standards Australia.

Additional work on suspect test reports

Another outcome of the project will be a more formal process for review and reporting on the outcomes of investigations into suspect test reports. 

Concerns relating to the authenticity of test reports and certificates and/or whether a laboratory is actually accredited for the testing that has been reported are commonly raised. From time to time, such concerns relate to a product recall as decisions have been made to certify product on the basis of that test report.

Up to now, NATA has undertaken initial review of suspect reports and, when appropriate, referred the reports on to the relevant accreditation body (AB). This most often occurs by email interaction and the AB then deals directly with the end-user or provides a response to NATA to pass on to the enquirer.

NATA would generally recommend that the end-user deal directly with the AB that is said to have accredited the laboratory that has issued the test report. That is because the AB has current information on the accreditation and scope coverage of their laboratories, and in the case of China in particular, can read the test report.

NATA is developing a more formal system to collect relevant information associated with any suspect reports. This will assist with any review and investigation of the specific matter and also facilitate the identification of trends.  It should also make it easier to lodge enquiries about test reports.

Looking forward

Introductory research work is underway regarding issues around steel and steel products and we have already made contact with a number of key organisations in this sector.

As mentioned, our project is aimed at improving conformity assessment outcomes to underpin compliance of building and construction products with Australian Standards, building codes and regulatory requirements. The work being undertaken by NATA and CNAS has a long way to go and will require the cooperation of many of our stakeholders. If you are one of them, we will no doubt be in touch and hope  that you will be able to assist us.

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