Comment : | Attached is a proposed new section (Vol. 2, Section 1.9: Transparency and Freedom of Information) that would attempt to bring transparency to the independent test labs and certification processes by mandating that certain documents relating to certification and testing be submitted by the test labs to the EAC to become part of the agency's records. This would bring the documents within the scope of the Freedom of Information Act, so that they may be publicly disclosed. There is an exception for proprietary information carved out in anticipation of the expected corporate vendor response. The proposed section further creates a requirement that the EAC make unscheduled visits to the test labs to verify compliance with the Guidelines, and it also allows members of the public to observe the test lab processes, subject to a scheduling mechanism to be created by the EAC.
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