Another example of multiple accreditation requirements imposed at the federal level is associated with American Society for Testing and Materials (ASTM) standard testing methods in many product sectors. For example, the standard test method for radiant panels used in lighting is ASTM E648. NVLAP accredits labs for testing to E648. The NRTL program operated by OSHA, however, does not accept NVLAP accreditation in this area, requiring laboratories to obtain a second accreditation. In fact, the GSA Furniture Center; DoD's Defense Electronics Supply Center and Defense Logistics Agency; the U.S. Coast Guard; and the Federal Aviation Administration also require E648 accreditation. In addition, state and local governments may impose their own requirements and are under no obligation to accept any of these federal accreditations—with the exception of NRTL accreditation, which states are required to accept as a result of regulatory preemption by the Department of Labor. The ASTM standard for radiant panel testing is only one of many standard test methods subject to this degree of multiple accreditation.74

Data from three private, independent testing laboratories illustrate the cost burden of multiple accreditation in the U.S. system. Accreditation costs for these laboratories, all of which have average annual revenues from testing of less than $1 million, range from $12,900 to $87,000 per year.75 To meet multiple accreditation requirements, one laboratory is accredited in a single area of testing, electromagnetic interference, by all of the following: NVLAP; the FCC; the U.S. Coast Guard Laboratory Approval Program; DoD's Defense Electronics Supply Center; and a European organization, Interference Technology International. The president of a second laboratory reports that accreditation costs ''could double or triple within the next 3-5 years" because of "unnecessary duplicative costs."

Economic data on the aggregate costs to the U.S. economy of multiple accreditation in product testing are unavailable. A 1993 study in a related area, however, provides compelling evidence of potential savings from consolidating redundant accreditation programs. The EPA commissioned a study in 1992 by a special advisory Committee on National Accreditation of Environmental Laboratories (CNAEL).76 Among other key findings, CNAEL concluded that environmental laboratories operating in multiple states face accreditation for the same tests by each state, often with arbitrarily differing criteria. CNAEL performed a detailed cost analysis and identified accreditation costs of $1,400 for small laboratories and between $10,773 and $21,546 for large laboratories. These costs include on-site audit costs, accrediting fees, and performance evaluation sample testing.

Aggregating these costs over the environmental testing industry, the CNAEL study found that replacing multiple state accreditation programs with a single, national program would significantly reduce costs. From a current, total cost estimated at between $17 million and $28 million per year, a streamlined system would reduce costs to between $13.5 million and $15.5 million, including a significant administrative fee charged by the national program.77 This reduction

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