The National Fastener Act of 1997
I am looking for some information pertaining to the National Fastener Act, which is supposed to take effect at the end of May, 1997. As a job shop doing plating for the fastener industry, what are my responsibilities versus my customers ? My understanding is that samples from each lot of fasteners which are plated need to be tested and certified. Is this correct ? If so, what is involved in setting up to do the necessary testing and certification in-house ? Any help would be greatly appreciated. Thank you.Keith Rosenblum
- St. Paul, Minnesota
The answer to your question (as stated) if fairly simple.
Public Law 101-592 as amended by PL 104-113, puts the burden of testing and certification of fasteners on the manufacturer, or a person who Significantly Alters certified fasteners. Alteror is designed as "a person who owns a fastener and causes it to be altered."
If you are plating product for a fastener manufacturer, the tests that are required by the plating specification on a lot basis must be performed by an accredited laboratory (in-house or independent.
These could be Stress Durability, Salt Spray, Dimensional, or others. The three choices available are
1) Get your laboratory accredited,
2) Send this testing out to an accredited laboratory, or
3) Return the plated product to the manufacturer and they must have it tested by an accredited lab.
The law does not add any additional testing requirements for plating fasteners prior to certification, only that the lot by lot tests used to certify fasteners must be performed by an accredited lab. Each plating house will make decisions on testing and accreditation based on their customer base.
If you are plating fasteners for a distributor, or other persons that purchase certified product and alters them (in your case plating) for resale, your choices are similar. As far as plating goes, the law states that when fasteners are Significantly Altered, the Alteror must assign a new lot number and must conduct stress durability on each lot, in addition to the tests required by the plating spec on a lot basis. All of the tests must be performed by an accredited laboratory.
Please note that under the law, only electroplating fasteners with a specified core hardness of 32 HRC or greater is considered a significant alteration. If you electroplate fasteners with a specified core hardness of less than 32 HRC, you must still perform all of the tests required on a lot basis by the plating specification, but you do not have to do any additional testing. All tests used to certify the product as meeting a consensus standard must be done in an accredited laboratory.
If you are not lost yet, the definition of what is and what is not a fastener under the law is even worse. I hope that this will help. Currently only NIST's NVLAP program is able to accredit labs. I expect that the American Association for Laboratory Accreditation (A2LA) and NADCAP will soon be able to audit labs for the FQA also.
MMA conducts a six (6) hour seminar on PL 101-592 and the effect that this law will have on manufacturers, distributors, importers and support industries (heat treat, NDT, Labs, plating shops). If you have additional questions, feel free to follow up.Matthew J. Horton
- St. Paul, Minnesota
I am sure, that no matter what the recent laws say, that if a plater can be proven to have known that a fastener should be baked after her process, and fails to do this, or to get written waiver from her customer, that plater shall be guilty of negligence.
Falls Township, Pennsylvania
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