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

validated. Therefore it needs to be removed and not referenced. Our
concerns for why this is important to do are discussed in our previously
submitted August 5, 2009 letter.
2) While we agree that the ANSI/ASME A112.19.8-2008a standard, and
the Tables therein, are incorporated by reference into the VGBA, we
feel it is critical that Table 1 in this standard be referenced by the
Commission at every appropriate opportunity. It is our belief that
compliance with VGBA and the ASME standard is not possible without
evaluating the system to the standard. By referencing Table 1, the
reader has no choice but to refer to the standard, or more
appropriately, to use a qualified professional with experience
complying with the standard. Our concern is that not to do so may lead
some people reviewing the CPSC Technical Guidelines to mistakenly
conclude that they do not need to also reference the ANSI/ASME
A112.19.8-2008a standard.
Attached for the Commission's convenience are our prior comments and support
data with examples that have been updated with additional new calculations that
replaces the support data previously submitted on August 5, 2009.
We thank the CPSC for the opportunity to provide comments.
Carvin DiGiovanni,
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Senior Director, Technical and Standards
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