Public Hearing Virginia Graeme Baker Pool and Spa ... - Pool Safely

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Stevenson. Todd From: Sent: To: SUbject: Attachments: Carvin DiGiovanni Association of Pool & Spa Professionals Carvin DiGiovanni [CDiGiovanni@APSP.org] Wednesday, October 28, 2009 1:23 PM CPSC-OS APSP October 28, 2009 comments on "Unblockable Drains" 10-28-09 APSP Unblockable Comments to CPSC.pdf; 8-5-09 APSP Unblockable Comments to CPSC.pdf; CoverGrateFormulaExamples.pdf The APSP respectfully requests the opportunity to testify at the November 4, 2009 public hearing on "Unblockable Drains". Attached is the written presentation that the APSP would like to file and is the basis for our oral comments. We thank you for the opportunity to present. Carvin DiGiovanni ~APSP Carvin DiGiovanni Senior Director, Technical and Standards Association of Pool & Spa Professionals 2111 Eisenhower Ave Alexandria, VA 22314 (703) 838-0083, ext. 149 FAX (703) 549-0493 e-mail: cdigiovanni@apsp.org 1
APSP 211lE1lln....... Ai_dill VA 2231404885 7D3B3800B3 703.&49.0413 fa wn.APIP.oII October 28, 2009 To: CPSC Office of the Secretary Re: "Unblockable Drain Guidance" The Association of Pool & Spa Professionals (APSP) appreciates the opportunity to review the amendments to the Commission's Draft Technical Guidance Document on Unblockable Drains posted in the Federal Register, October 21, 2009. APSP continues however to respectfully disagree with the Commission's draft guidance and urges the Commission to use the definition submitted in our initial comment of August 5 th 2009 that reads: "Unblockable Drain: "A suction outlet such that its perforated(open) area cannot be shadowed by the area of the 18x23 Body Blocking Element of ANSI/ASME A 112.19.8-2008a and that the rated flow through the remaining open area cannot create a suction force in excess of the values in Table 1 of that Standard. For manufactured products, this is calculated or verified by laboratory testing in accordance with the Standard. For field- built outlets, this is calculated in accordance with Section 2.3.1.2 of the Standard." We do agree with the Commission's emphasis on the fastening of the covers and therefore suggest the following language be added to our above August 5, 2009 definition to now read: "Unblockable Drain: "A suction outlet defined as all components, including the sump and/or body, cover/grate, and hardware such that its perforated (open) area cannot be shadowed by the area of the 18x23 Body Blocking Element of ANSI/ASME A112.19.8-2008a and that the rated flow through the remaining open area cannot create a suction force in excess of the values in Table 1 of that Standard. For manufactured products, this is calculated or verified by laboratory testing in accordance with the Standard. For field- built outlets, this is calculated in accordance with Section 2.3.1.2 of the Standard." The reasons for our above comments are as follows: 1) The 29" diagonal dimension that appears in the CPSC Draft Technical Guidance document is an oversimplification of the problem, is not found in the ANSI/ASME A112.19.8-2008a standard and is not
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Page 5 and 6: 2111E111n.......... AI_.... VA 2231
Page 7 and 8: COVER/GRATE FORMULA EXAMPLES - See
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Page 18 and 19: How to define allowable flow? • A
Page 20 and 21: 24x24 inch outlet • 55% opening 2
Page 22 and 23: "Converting" 18x18" to 29" diagonal
Page 24 and 25: Key Points • "Unblockable" implie
Page 26 and 27: Who do we intend to protect? The 99
Page 28 and 29: The 2006 ICC Code had an 18 x 23 RE
Page 30 and 31: The rating for the 2006 ICC 18" x 2
Page 32 and 33: 3" x 31" Channel with 450/0 open ar
Page 34 and 35: An interesting Configuration • An
Page 36 and 37: Edge-Only Perforated Cover • Calc
Page 38 and 39: Key Points • "Unblockable" implie
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Page 45 and 46: David Stingl Stingl Products Todd A
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I. Current Staff Attempts to Provid
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INTERPRETATION VERBIAGE The ASME A1
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IN THE CPSC SURVEY IT WAS SAID "Th
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TYPICAL OF 7 DRAIN SUMPS @'l UTSA S
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l-- 45 FEET OF 10' PIPE ~ 100# CONC
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COVER FINALLY PULLED OUTOFPOOL FLOO
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Bonnie Snow BeeSafe Systems Written
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Individual Tubular Channels Functio
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WILLIAMS ARCHITECTS ARCHITECTS PLAN
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ASME A112.19.8 - IISuction Fittings
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Public Hearing Virginia Graeme Baker Pool and Spa ... - Pool Safely

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