These days everyone is talking about it: this pandemic that is beginning to seriously affect our habits, both personal and professional. And it’s the impact on our work that is the real game changer.
CATAS has decided to stop all business trips during March and April, as of today.
As you are aware, one of our services is
product certification through our CATAS Quality Award (CQA), and we’re also Third Party Certifiers (TPC) for the California Air Resource Board (CARB) and for the Environmental Protection Agency (EPA).
If we look at formaldehyde, the chosen CQA scheme demands from 2 to 4 audits per year, in order to conduct
quality control audits and also sample certified material from production lines or warehouses.
In detail, the American certifications ATCM 93120 (best known as CARB Phase 2) and TSCA Title VI require quarterly audits. By definition, a quarter is a calendar quarter, so the first quarter is January-February-March, the second April-May-June, and so on.
So, what can we do?As the CETPC Group (group of European TPCs) we sent a specific, direct question to the EPA, referring to a CARB bulletin from 2012 which contains the paragraph “Unusual circumstances at the time of quarterly mill audit”.
The EPA replied very quickly, with an amendment to its Frequently Asked Question (FAQ) number 13, which included “epidemics and pandemics” in their list of “Unsafe conditions” (natural disasters, outbreaks, political unrest).
In this case, TPCs are required to
conduct a remote quarterly inspection via teleconference to satisfy the requirements of the law, and notify the EPA, through the established channels, when this remote method of quarterly inspection is being used.
They also make it clear that remote audits should be seen as an exception to the standard practice whereby a TPC conducts quarterly inspections in person.
In the light of the latest developments, during March and April (and May, perhaps) CATAS will carry out remote inspections, in the hope that the situation will normalize so that everyone can go back to living and working as before.
At least until the next exceptional circumstances come along …
For information:Sandro Ciroi
+39 0432 747235
ciroi@catas.com
