Global Fastener News

Insignias, Hotline, Private Label Distributors
And Foreign Accreditation Dominate Comments

John Wolz

Complaints about the delay in establishing the fastener fraud hotline and insignia requirements were the most frequently mentioned issues in public comments on the proposed regulations for the Fastener Quality Act.
Several organizations, companies or individuals raised questions about not including foreign government laboratory accreditation bodies, listing of labs and accreditation bodies on the Internet and insignia recordal.
The Industrial Fasteners Institute noted that the proposed regulations for the original FQA totaled 111 pages. The proposed regulations issued in December 1999 for Public Law 101-592, as amended by P.L. 106-34, totaled only 21 pages.
Previous public comment periods could draw as many as 700 pages in comments. This one garnered only about 10% of that amount.
Nearly half of the pages this time were from members of the Fastener Quality Association. Their comments were primarily expressing concerns about the changes in the law rather than on the proposed regulations.
� The IFI called on the National Institute of Standards & Technology to create the hotline as soon as possible (see FIN, January 31, 2000).
� The National Fastener Distributors Association and the Western Association of Fastener Distributors expressed support for the newly amended FQA and urged the Secretary of Commerce �to move quickly in establishing the �fastener hotline.��
The NFDA also urged the Department of Commerce to �reconsider its decision relative to not allowing the recordal of insignia used by private label distributors and OEMs, and to permit the voluntary registration of such insignias as a means of assuring maximum traceability of fasteners bought, sold and used within the United States.�
� A2LA pointed out that ISO/IEC Guide 25 will be revised soon, and the changes should be acknowledged in the regulations.
� Automakers commented that the �raised or depressed insignia� requirements could �impair the function of the fastener, or the insignia could be undesirable for aesthetic reasons, and called for allowing private label distributors and OEMs to record their insignia.
� Black & Decker commented that the proposed regulations would �broaden the scope of violations under the Act, which alone is a sufficient ground to invalidate them under applicable principles of administrative law.�
Black & Decker also questioned NIST�s limits of �raised or depressed insignia.�
� Nippon Steel asked NIST to clarify mill test report requirements. The proposed regulations still present difficulties �to make the matter clear.�
� David Sharp of TurnaSure wrote that �references to �raised or depressed� insignias must remain. Should fasteners only have to �bear an insignia,� they will inevitably be marked by inadequate means for proper identification or traceability to their sources.�
� Richard Stump of Iowa City, IA-based Consultants in Quality Inc. called for NIST to lead a three-year study of fastener laboratories, including monitoring documentation and performance of test methods. Stump wrote that it is �predictable [labs�] performance will progressively deteriorate in the new, less demanding atmosphere� of the amended law.