ASTM E651/E651M-22

Standard Practice for Evaluating Capabilities of Agencies Involved in System Analysis and Compliance Assurance for Manufactured Building

ABSTRACT
This practice is intended as a companion standard to ASTM Standard E 541, Standard Specification for Agencies Engaged in System Analysis and Compliance Assurance for Manufactured Building. Standard E 541 covers criteria by which the technical resources of agencies may be evaluated for their capability to perform the system analysis or compliance assurance function, or both, in the evaluation and inspection of manufactured building. This standard includes questions that should be asked of system analysis and compliance assurance agencies in order for the administrative agency to evaluate their competency. The preferred method for utilizing this standard is for qualified personnel of the administrative agency to visit the system analysis and compliance assurance agencies’ headquarters to speak to qualified personnel and examine pertinent records and documentation. Alternatively, the evaluation may be done at any location provided the agency being evaluated is fully informed as to the material and personnel they will need to have on hand for the evaluation.
SCOPE
1.1 This practice is intended as a companion standard to Specification E541, Specification for Agencies Engaged in System Analysis and Compliance Assurance for Manufactured Building. Specification E541 covers criteria by which the technical resources of agencies may be evaluated for their capability to perform the system analysis or compliance assurance function, or both, in the evaluation and inspection of manufactured building. This standard 2 includes questions that should be asked of system analysis and compliance assurance agencies in order for the administrative agency to evaluate their competency. Personnel matters are not highlighted in this standard since they are covered in detail in Specification E541. This is not meant to imply that they are not important.  
1.2 The preferred method for utilizing this practice is for qualified personnel of the administrative agency to visit the system analysis and compliance assurance agencies' headquarters to speak to qualified personnel and examine pertinent records and documentation. Alternatively, the evaluation may be done at any location provided the agency being evaluated is fully informed as to the material and personnel they will need to have on hand for the evaluation.  
1.3 Some of the following will not be applicable in the evaluation of an agency that has not had prior experience as a building-evaluation organization. It is not the intent of this practice to preclude acceptance of such an agency provided it can otherwise demonstrate that its organizational procedures and experience in other product categories and experience of key personnel reflect a keen awareness of the problems and processes involved in manufactured building evaluation and thus warrant acceptance. In such instances the administrative agency may wish to consider extending provisional acceptance over a definite period of time, during which it is expected that the agency will have opportunity to gain the requisite experience and demonstrate its capabilities and compliance assurance functions for manufactured building.  
1.4 Failure of an agency to respond satisfactorily to one or more criteria in the following should not be sole cause for rejection. Such failure should be brought to the agency's attention and be subject to close scrutiny during subsequent reevaluations.  
1.5 This practice is intended to achieve uniformity in the regulation of manufactured building. It may be necessary to make changes and modifications in order to adapt to legislative or other regulatory requirements of some jurisdictions.  
1.6 This standard does not purport to address all of the safety concerns, if any, associated with its use. It is the responsibility of the user of this standard to establish appropriate safety, health, and environmental practices and determine the applicability of regulatory limitations prior to use.  
1.7 This i...

General Information

• Status: Published
• Publication Date: 31-May-2022
• ICS: 91.010.10 - Legal aspects
• Technical Committee: E36 - Accreditation & Certification
• Drafting Committee: E36.70 - Agencies Performing Construction Inspection, Testing and Special Inspection

Relations

• Refers: ASTM E541-08 - Standard Specification for Agencies Engaged in System Analysis and Compliance Assurance for Manufactured Building
• Effective Date: 15-Dec-2008
• Refers: ASTM E541-84(1998)e1 - Standard Specification for Agencies Engaged in System Analysis and Compliance Assurance for Manufactured Building
• Effective Date: 10-Dec-2001
• Refers: ASTM E541-01 - Standard Specification for Agencies Engaged in System Analysis and Compliance Assurance for Manufactured Building
• Effective Date: 10-Dec-2001

Overview

ASTM E651/E651M-22 - Standard Practice for Evaluating Capabilities of Agencies Involved in System Analysis and Compliance Assurance for Manufactured Building provides a comprehensive framework for evaluating the competence and effectiveness of agencies responsible for system analysis and compliance assurance within the manufactured building industry. This standard acts as a companion to ASTM E541, focusing on the systematic review, on-site inspection, and reporting procedures necessary for ensuring that manufactured building regulatory agencies can meet applicable codes, standards, and project requirements.

The intent of ASTM E651/E651M-22 is to support administrative agencies in making informed decisions about the competency of system analysis and compliance assurance agencies. It emphasizes uniformity in the regulation of manufactured building, while allowing for adaptations to specific legislative and regulatory contexts.

Key Topics

• Evaluation Criteria: Outlines the key questions and documentation administrative agencies should review when assessing a system analysis or compliance assurance agency. This includes verifying the agency’s familiarity with relevant standards and ensuring the availability of necessary manuals, directories, and checklists.
• On-site Assessments: Details the preferred practice of conducting agency evaluations through on-site visits, including interviews with qualified personnel and examination of records.
• Reporting Requirements: Specifies the necessary elements for agency reports, including documentation of compliance and non-compliance, descriptions of corrective actions, and inclusion of all pertinent technical and administrative data.
• Quality Assurance Practices: Provides guidelines for reviewing manufacturers’ compliance control programs, inspection practices, recordkeeping, and corrective action procedures.
• Manufacturer Evaluations: Establishes the need to review manufacturers’ control manuals, test records, inspection checklists, and other supporting documentation as part of the compliance assurance process.
• Continuous Improvement: Encourages periodic re-evaluation and follow-up to monitor agency performance and ensure ongoing conformity with industry best practices.

Applications

• Regulatory Approval: Administrative authorities can utilize the criteria in ASTM E651/E651M-22 to ensure third-party inspection and compliance assurance agencies meet the stringent requirements for evaluating manufactured buildings.
• Accreditation of Agencies: Serves as a practical tool for accrediting agencies that perform system analysis, factory inspections, and compliance assurance for prefabricated and modular buildings.
• Quality Management: Supports agencies in developing robust compliance control manuals, inspection procedures, and factory visit protocols.
• Risk Reduction: By implementing the practices described, manufacturers and regulatory bodies can minimize non-compliance risk and improve the reliability and safety of manufactured building systems.
• Uniformity and Consistency: Promotes standardized evaluation processes across jurisdictions, enhancing the consistency of compliance assurance in the manufactured building sector.

Related Standards

• ASTM E541 - Specification for Agencies Engaged in System Analysis and Compliance Assurance for Manufactured Building
• Building Science Series 87: Model documents for the evaluation and approval of manufactured buildings
• Applicable Building Codes and Product Standards: The standard requires agencies to refer to the latest technical codes specific to manufactured building systems.

Practical Value

ASTM E651/E651M-22 enhances the regulatory landscape for manufactured construction by establishing a repeatable, transparent, and objective method for evaluating agency capabilities. By following this standard, regulatory agencies, manufacturers, and agencies themselves can improve both the quality and documentation of compliance assurance activities, foster better oversight, and build confidence in manufactured building processes.

Keywords: compliance assurance, manufactured building, system analysis agency, agency evaluation, regulatory inspection, quality assurance, ASTM E651/E651M-22.

Standards Content (Sample)

This international standard was developed in accordance with internationally recognized principles on standardization established in the Decision on Principles for the
Development of International Standards, Guides and Recommendations issued by the World Trade Organization Technical Barriers to Trade (TBT) Committee.
Designation: E651/E651M − 22 An American National Standard
Standard Practice for
Evaluating Capabilities of Agencies Involved in System
Analysis and Compliance Assurance for Manufactured
Building
This standard is issued under the fixed designation E651/E651M; the number immediately following the designation indicates the year
of original adoption or, in the case of revision, the year of last revision. A number in parentheses indicates the year of last reapproval.
A superscript epsilon (´) indicates an editorial change since the last revision or reapproval.
1. Scope processes involved in manufactured building evaluation and
thus warrant acceptance. In such instances the administrative
1.1 This practice is intended as a companion standard to
agency may wish to consider extending provisional acceptance
Specification E541, Specification for Agencies Engaged in
over a definite period of time, during which it is expected that
SystemAnalysis and ComplianceAssurance for Manufactured
the agency will have opportunity to gain the requisite experi-
Building. Specification E541 covers criteria by which the
enceanddemonstrateitscapabilitiesandcomplianceassurance
technical resources of agencies may be evaluated for their
functions for manufactured building.
capability to perform the system analysis or compliance
assurance function, or both, in the evaluation and inspection of 1.4 Failure of an agency to respond satisfactorily to one or
manufactured building. This standard includes questions that more criteria in the following should not be sole cause for
should be asked of system analysis and compliance assurance rejection. Such failure should be brought to the agency’s
agenciesinorderfortheadministrativeagencytoevaluatetheir attention and be subject to close scrutiny during subsequent
competency. Personnel matters are not highlighted in this reevaluations.
standard since they are covered in detail in Specification E541.
1.5 This practice is intended to achieve uniformity in the
This is not meant to imply that they are not important.
regulation of manufactured building. It may be necessary to
1.2 The preferred method for utilizing this practice is for make changes and modifications in order to adapt to legislative
qualified personnel of the administrative agency to visit the or other regulatory requirements of some jurisdictions.
system analysis and compliance assurance agencies’ headquar-
1.6 This standard does not purport to address all of the
ters to speak to qualified personnel and examine pertinent
safety concerns, if any, associated with its use. It is the
records and documentation. Alternatively, the evaluation may
responsibility of the user of this standard to establish appro-
be done at any location provided the agency being evaluated is
priate safety, health, and environmental practices and deter-
fully informed as to the material and personnel they will need
mine the applicability of regulatory limitations prior to use.
to have on hand for the evaluation.
1.7 This international standard was developed in accor-
dance with internationally recognized principles on standard-
1.3 Some of the following will not be applicable in the
ization established in the Decision on Principles for the
evaluation of an agency that has not had prior experience as a
Development of International Standards, Guides and Recom-
building-evaluation organization. It is not the intent of this
mendations issued by the World Trade Organization Technical
practice to preclude acceptance of such an agency provided it
Barriers to Trade (TBT) Committee.
can otherwise demonstrate that its organizational procedures
and experience in other product categories and experience of
2. Referenced Documents
key personnel reflect a keen awareness of the problems and
2.1 ASTM Standards:
E541 Specification for Agencies Engaged in System Analy-
This practice is under the jurisdiction of ASTM Committee E36 on Accredi- sis and ComplianceAssurance for Manufactured Building
tation & Certification and is the direct responsibility of Subcommittee E36.70 on
Agencies Performing Construction Inspection, Testing and Special Inspection.
3. System Analysis
Current edition approved June 1, 2022. Published August 2022. Originally
“6.2.1 Drawings, calculations, and specifications of manu-
approved in 1978. Last previous edition approved in 2008 as E651/
E651M – 01 (2008), which was withdrawn in January 2017 and reinstated in June
factured building shall be reviewed by agency’s engineering
2022. DOI: 10.1520/E0651_E0651M-22.
In preparation of this practice, much assistance was gained by referring to
Building Science Series 87, “Model Documents for the Evaluation, Approval, and For referenced ASTM standards, visit the ASTM website, www.astm.org, or
Inspection of Manufactured Buildings,” prepared by the Center for Building contact ASTM Customer Service at [e-mail]. For Annual Book of ASTM
Technology, Institute forApplied Technology, National Bureau of Standards, issued Standards volume information, refer to the standard’s Document Summary page on
July 1976. the ASTM website.
Copyright © ASTM International, 100 Barr Harbor Drive, PO Box C700, West Conshohocken, PA 19428-2959. United States
E651/E651M − 22
staff and details compared with provisions of applicable 3.1.5.5 Tabulation of numerical values associated with test,
requirements. The construction of assemblies or components or such as loadings, voltage, etc., and corresponding result
both, including material identification, shall be compared with readings (for example, deflections), giving the time scale
published descriptions of listed, approved, or recognized de- involved.
signs where applicable.”
3.1.5.6 Listing or identification of any significant test con-
3.1 Questions:
ditions not indicated above (such as ambient air temperature,
3.1.1 Does the system analysis agency have on hand copies
humidity, etc.).
ofthestandard(s),codes(s),specification(s),etc.,againstwhich
3.1.5.7 Date of test.
the product is being evaluated?
3.1.5.8 Name and address of testing organization or labora-
3.1.2 Does the system analysis agency have on hand “how
tory.
to” manuals such as UPC Plumbing Code Interpretations
3.1.5.9 Signature of the laboratory’s officer or authorized
Manual, NFPAHandbook of the National Electrical Code, etc.,
representative (generally a test engineer in charge who is a
and similar manuals which provide the agency with useful
professional engineer), and date of signature.
background information? Does the agency maintain copies of
3.1.6 Does product bear the seal, label, or mark of product
current product directories, lists, certification directories, etc.,
certifying agency or organization? If “no” for some or all
published or issued by independent organizations, trade
products, ask agency to explain basis of acceptance. If “yes”:
associations, and other groups?
3.1.6.1 Is seal, label, or mark of product certifying agency
3.1.3 Ask to see checklists and other evaluation aids devel-
registered?
oped by the system analysis agency, or developed by others
3.1.6.2 Does the product certifying agency have strict pro-
and used by the agency, in their evaluation process. Does the
cedures for controlling the use of its seal, label, or mark?
agency have: (a) a data collection checklist for determining the
3.1.6.3 Does product certifying agency or organization con-
adequacy of data submitted by the manufacturer for review
duct routine factory audit of products bearing its seal, label or
(that is, how does the agency know when it has sufficient data
mark?
to start a review?); (b) a comprehensive review checklist for
“6.2.2 Where production has been instituted, and subse-
determining compliance with applicable standards and proce-
quent to the review of drawings and specifications, qualified
dures that cover the full range of architectural, structural,
personnel from the system analysis agency (or compliance
mechanical, etc., features to be reviewed? Does the review
assurance agency) shall visit the factory of the producer of
checklist include provisions for convenient notation of those
manufactured building to:
itemsfoundtobeandnottobeincompliancewiththecode(s)?
6.2.2.1 Compare the actual construction with the drawings
3.1.4 Ask the system analysis agency to explain the criteria
and specifications.
upon which they base their acceptance or rejection of a
6.2.2.2 Examine and record all features required by the
component, material, device, etc., used in the building system.
codes and standards if not included in the drawings and
3.1.4.1 Is the product specifically identified as to make,
specifications.
model, type designation, etc.?
3.1.4.2 Is the code or standard that forms the technical basis 6.2.2.3 Evaluate all required production tests to ascertain
for certification of a product known, such as by being marked that the correct equipment, instruments, and procedures are
ontheproduct,orincludedinthecertifier’sseal,label,ormark, followed and to determine that the building, assembly, or
or referenced in the certifier’s test report or other available subassembly is capable of meeting the test requirements.
documents?
6.2.2.4 Discuss items of noncompliance with the manufac-
3.1.5 Ask the system analysis agency to explain the criteria
turer’s representative, identify the source of the requirement,
upon which they base their acceptance or rejection of tests on
and explain the requirement.”
individual products used in the building system. Does the
3.2 Questions:
criteria include at least the following elements:
3.2.1 Confirm that building evaluation agency (system
3.1.5.1 Identification of the specimen tested (manufacturer,
analysis agency or compliance assurance agency) arranges for
type, model number, source of supply, etc.).
its personnel to visit a manufacturer’s factory after review of
3.1.5.2 A detailed description or drawing of the physical
drawings and specifications to perform the steps enumerated in
characteristics of the specimen, including condition (age,
the evaluation process outlined in 6.2.2.1 through 6.2.2.4
repair, etc.).
above.
3.1.5.3 Number of tests and sampling technique used in
3.2.2 Ask to see representative reports prepared by the
selection of specimens.
building evaluation agency subsequent to such factory visits as
3.1.5.4 Identification of test method used (if a standard test
evidence of documenting the replies to the following, as
method) or a detailed description of the test procedure,
appropriate:
equipment, and instrumentation used.
3.2.2.1 Does the agency examine manufactured buildings in
various phases of construction to ascertain that they are being
Criteria in italics are extracted without change from ASTM Standard E541,
constructed in accordance with the drawings and specifications
Specification forAgencies Engaged in SystemAnalysis and ComplianceAssurance
submitted by the manufacturer?
for Manufactured Building.
3.2.2.2 Does the agency examine the manufactured build-
Questions to be asked of the building evaluation agencies (system analysis
agency or compliance assurance agency) by the administrative agency. ings for the purpose of disclosing and recording features of
E651/E651M − 22
construction, workmanship, etc., not shown in the drawings or numerous, or (2) may relate to workmanship, or (3) corrections
specifications that may be at variance with the codes and are comparatively complicated and corrections cannot be
standards? readily verified by review of corrected drawings or specifica-
3.2.2.3 Does the agency have a written procedure or check- tions?
list for review of manufacturers’ test methods and frequency?
“6.2.5 The system analysis agency shall prepare a final
3.2.2.4 Does the agency procedure or report contain ad- report describing the manufactured building, confirming the
equate documentation of the applicable standards that are to be
tests performed, stating the basis for judgement of acceptibility
used in each manufacturer’s test? of assemblies and components, and itemizing the edition of the
3.2.2.5 Are all manufacturers’ test methods reviewed by
codes and standards against which the building was evalu-
qualified agency technical staff? ated.”
3.2.2.6 Does the agency require the manufacturer to main-
3.5 Questions:
tain a record of all tests?
3.5.1 Ask the system analysis agency to provide copies of
3.2.2.7 Does the agency require the manufacturer to main-
reports it has prepared that cover manufactured buildings the
tain a record documenting periodic calibration of inplant test
agency has evaluated.
equipment?
3.5.2 Is the report signed and dated by responsible system
3.2.2.8 Does the agency discuss with the manufacturer’s
analysis agency personnel?
representative how the material or component used, the assem-
3.5.3 Does the report contain a clear statement of the
bly or installation procedure followed, or the workmanship
applicable standards to which the evaluation has been made
accepted can or does result in a failure to conform to the
and the approval is issued?
code(s), standard(s), or specification(s)?
3.5.4 Doesthereportaccuratelyandclearlystatethevarious
3.2.2.9 Does the agency determine through discussion with
zones for which the units are approved (that is, wind, snow,
the manufacturer’s representative how the failure to conform
heating, etc.)?
will be corrected on the deficient unit or units and avoided in
3.5.5 Does the report contain a complete index?
subsequent production?
3.5.6 Does the report clearly identify the manufacturer and
3.2.2.10 Does the agency require that the nature of the
which manufacturing facility locations are covered by the
deficiency and the corrective action taken be so documented
report?
that the compliance assurance agency can readily anticipate
3.5.7 Does the report contain system analysis agency pro-
and detect future deficiencies of like nature?
ceduresforcoordinatedcontinuingrevisionandupdatingofthe
“6.2.3 The system analysis agency shall issue a written
document?
report to the manufacturer confirming all items of noncompli-
ance from the applicable requirements and summarizing the 3.5.8 Does the report contain appropriate manufacturer
certification statements, labeling and data plate instructions?
steps needed to proceed with the system analysis.”
5 3.5.9 Does the report contain the manufacturer’s authoriza-
3.3 Questions:
tion for the agency to conduct inspection, if applicable?
3.3.1 Ask the system analysis agency to provide examples
3.5.10 Does the report contain the manufacturer’s serial
of written reports they have prepared on manufactured build-
numbering system?
ings. Do the reports:
3.5.11 Does the report contain adequate detail to show
3.3.1.1 Clearly state the features found to be in
compliance with planning consideration requirements?
noncompliance, with reference to the specific source of the
3.5.12 Does the report contain adequate list of typical
requirement?
appliances, equipment, fixtures, and structural materials to be
3.3.1.2 Summarize the steps needed to proceed with the
used?
system analysis (that is, provide corrected drawings and
3.5.13 Does the report contain specifications or samples of
specifications, additional test reports, revised compliance as-
all required instruction labels?
surance manual, etc.)?
3.3.1.3 Include the date and place of the factory visit, if 3.5.14 Does the report contain a complete list of approved
models, options, and option combinations?
conducted, list the agency and manufacturer’s personnel
involved, and delineate between the features found to be in 3.5.15 Does the report contain floor plans of each approved
noncompliance as a result of the review of drawings and
model?
specifications versus those found to be in noncompliance as a
3.5.16 Does the report adequately document options and
result of the factory visit?
combinations of options by floor plan?
“6.2.4 The system analysis agency shall verify that all items
3.5.17 Does the report contain adequate detail to show
of noncompliance are corrected by the manufacturer.”
compliance with fire safety requirements?
3.5.18 Does the report adequately document all structural
3.4 Questions:
systems (that is, general structural criteria, floors, walls,
3.4.1 Ask the system analysis agency to explain the proc
...