23 Dec Maintaining compliance in challenging times
Every market and industry segment has faced enormous struggles throughout 2020 and 2021, and in the fire safety certification business, the pandemic has added another layer of difficulties to an already complex process. Fortunately, reflects Len Swantek, Director – Global Regulatory Compliance, Victaulic today’s technology has enabled us to continue forward, albeit at a much slower pace.
In early 2020, we watched as the global Covid-19 infection rate escalated at an alarming pace. By February, we learned of random business closures in certain regions, however, we were unaware of how our work would be so greatly impacted. Within one month, the most prominent testing laboratories had sent their employees home with no clear indication of a recovery plan. As we sought alternate ways to maintain business continuity, we began experimenting with existing technology both in the on-site laboratories and through staff working remotely.
Validating a manufacturer’s data
The first challenge involved the development of remote video witnessing of a wide range of agency qualification tests. While live-streaming video technology has been part of our social lives for many years through cell phones and other personal devices, there were limitations on the types of tests the certifying agencies could allow within the scope of their own policies and accreditation rules.
The ensuing discussions with many of these organisations did not yield immediate acceptance. From their perspective, the authenticity and validation of the tests being displayed via video; including data acquisition systems, gauges and their calibration, test equipment and test assembly preparation, sources and fit-for-purpose of all components, extending all the way to the most intricate detail of each wire connection, seal material and bolt torque was now left in the hands of the client/manufacturer and their suppliers. To say this is a true test of trust and credibility is a significant understatement.
The US fire protection certification authorities (UL LLC and FM Approvals) were the first to respond in an extremely supportive way with collaborative methods and resources to meet these challenges. These agencies were able to validate pressure systems, equipment connections, load cell readings, as well as analog and digital data acquisition and recording systems; while working with new camera technology, wireless video and simultaneous transmission of multiple video channels through a series of computers and audio conference links. The initial tests were intentionally basic to ensure the information being transmitted to the certifying authority would be secure, meet the requirements of the governing test standards and comply with the agency’s accreditation requirements. At the time, this process seemed to be quite slow
However, before long, remote product testing and certification put many manufacturers back on a schedule that could accommodate construction timelines by early summer 2020. While there were certainly some delays in completing the more complex qualification programmes, the support and cooperation these agencies provided was and continues to be of the highest standard. Completing the required certifications that enable product launches to stay on schedule
is at the core of our business and we are truly grateful for the cooperation and professionalism these certifying bodies have demonstrated.
While the story thus far has been quite positive, there are numerous instances where other testing organisations were not immediately able to provide the same level of support. With increasing numbers of confirmed Covid-19 cases throughout the world, the manufacturers continued to experience complete communication outages with many certifying authorities. With daily email traffic at an unprecedented low, information updates on critical programmes was completely unavailable.
Equally concerning was the fact, that even into early 2021 many certification agencies still refused to participate in remote video testing based on perceived risk, and the absence of an internal method for validating the process. This situation left the manufacturers with no clear path forward for dozens of open programmes that were now at a complete standstill. Where the product launch schedule is based on the completion of these critical agency qualification tests, any projects placed on hold certainly impacted the manufacturers’ ability to remain competitive.
While product testing and qualification via remote video access expanded slowly into other product categories and technologies, the routine surveillance auditing of manufacturing facilities was the next challenge to be addressed. Because of the sensitivity and confidentiality of each manufacturer’s technology and factory assembly processes, there was a new concern for this information being exposed and possibly compromised through live-stream video.
While video technology today is at its highest form of quality, speed and clarity, transmitting proprietary processes and operations from a factory floor over a live video feed posed a valid security concern. As such, the IT Systems experts were called into action to ensure proper securities could be employed for both the transmitting and receiving parties. While hundreds of data points were being communicated over the internet, modern encryption techniques were the best form of protection.
Soon, specialised cameras were used to capture only the most specific and intricate attribute that each agency required to complete their manufacturing survey. As the process became more widely proven and refined throughout the fire safety and other industries, the certifying agencies now realised they had an efficient and economically viable means to stay connected with their client’s global production processes in real-time.
Today, the fire protection agencies utilise a combination of on-site, socially distant audit practices together with remote video auditing and many will quickly convert to complete remote video audits in the event of an unexpected surge in Covid-19 cases in a particular region.
The next wave of challenges
Just when we thought the agency certification process was back on track, the impact of factory shutdowns and what some have called “The Great Resignation” was a new reality. Where we had previously focused our attention on creating new methods and systems for communicating product performance tests through remote witness programmes, the new problem was gaining access to the materials and components required to build the final product or system that is the subject and objective of the test program itself. With factory resources and operations at a fraction of their normal capacity, material shortages were being reported across many industries that support the fire protection manufacturers and in nearly every product category.
An item as seemingly simple as an elastomeric O-ring seal that could not be supplied to facilitate the completion of a valve assembly now left the manufacturer’s production line at a standstill.
The rush to qualify new and alternative suppliers became the highest priority for both the product manufacturers and the certifying agencies alike. While this may sound simple, the reduced work force and resulting factory closures greatly complicated what would normally be a routine process. Locating suppliers with sufficient capacity and resources was an immediate goal for many producers. Once the new source was identified, an intensive internal qualification of the supplier and the finished component had to be undertaken in the shortest amount of time possible. If not done properly, the manufacturer could risk an unexpected non-conformance during the external agency testing process.
In parallel, the certifying agencies became inundated with new applications and requests to test and certify new or
alternate materials and qualify new sources of supply and their factories that produce components displaying the agency’s certification mark. These new factories would also be subjected to process audits by each certifying agency before the finished component or assembly could be released to the market. Keep in mind; certain industries rely heavily on specific raw materials and finished components in extremely large volumes, which also creates a new competitive challenge both technically and commercially. The material required to mold the O-ring in the previous example may become completely unavailable as the large volume manufacturers secure their stake in that existing material inventory.
All these factors placed enormous strain on the fire protection manufacturers as well as the agencies, while each carefully navigating through Covid-19 variants in their regions.
Moving forward together
Having witnessed the broad effects of the pandemic while working closely with many global certifying agencies throughout the past two years, we are again reminded of how vulnerable we are as human beings and as collective business organisations. The electronic technology that is often taken for granted has become the leading method for keeping us
connected and functioning with our business partners globally. Many of our testing authorities now have new protocols in place to keep their laboratories operational and their employees safe, while providing service levels that meet or exceed their clients expectations.
The selection and qualification of suppliers has new meaning and focus for many organisations. These suppliers as well, have a renewed sense of purpose along with new demands from their OEM clients to create stronger partnerships, exclusivity for critical applications and a firm commitment to adapt to changing market conditions. The global auditing process has also been tested along with the trust for the manufacturing community to follow the rules without the need for direct oversight. Having faced these challenges head-on while developing new and innovative solutions, the parties involved in this process continue to work diligently together to ensure our fire protection and life-safety systems remain at their highest quality and serviceability.
As the world enters its third year battling the Covid-19 Pandemic, Len would like to pay respect to those who have been directly and indirectly impacted by this relentless virus and its variants. Equally important is our recognition and appreciation for the medical community and front-line health care workers who have sacrificed their own safety in providing continuous care for those infected. The pharmaceutical industry, as well, has worked tirelessly to formulate vaccines to help protect us from new variants as we all try to resume some sense of normalcy.