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

length of 30 inches. The 99 percentile male torso would be able block the original
square, and part of the channels, leading to a calculated force of 1413 pounds,
well exceeding the 120 pound limit. Hence, the possibility exists that a cover
would exceed or appear to exceed the 29" diagonal, and yet still not be
unblockable. This further demonstrates why the attempt at simplification, while
understandable, would run afoul of the 19.8 criteria, and, therefore, the VGB Act.
For these reasons, we suggest that the Commission reference the performance
test found in 19.8. As an alternative, the Commission might wish to consider the
following language which is consistent with the 19.8 and ANSI/APSP-7
Standards as well as the pending draft APSP/IAPMO -16 Standard.
"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
A112.19.8-2008a and that the rated 'I~ow 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 thank the Commission for its time and consideration.
Carvin DiGiovanni,
~
Senior Director, Technical and Standards