Jason Snider has updated the comment ANSI/APSP/ICC-16 does not specify colors or bracketing to the document 50i195r1 - JC memo & ballot.pdf in the Joint Committee on Recreational Water Facilities group. Subject : ANSI/APSP/ICC-16 does not specify colors or bracketing Category : N/A Comment I am the ANSI/APSP/ICC-16 Standard Writing Committee Chair and it is in this capacity that Ken Gregory suggested I review and comment on this proposal given the reference to the APSP-16 standard's UV testing procedures and the 70% strength retention-based performance language. First, the UV test was introduced in the 2007 edition, the year the drain cover standard was designate as a U.S. Consumer Product Safety Standard, (federal law). Second, the standard does not reference polymer colors or the bracketing concept, instead it is the duty of the ISO 17025 testing lab and ISO 17065 certifying agency to assure all requirements of the standard are being met. Third, certifying agencies are required to make safety-related testing judgment calls in all areas of the standard (structural integrity, flow ratings, tested sump documentation, product markings, compliant instructions, etc.) and the safety risks associated with the selection of what color(s) product to test is no different. If I was a voting member of the JC, I would vote yes. (These comments are submitted on my own behalf, they were not reviewed or approved by PHTA, the APSP-16 SDO.) Proposal No proposal provided. Changes response added Response Hello, The response letter to your comment has been uploaded. Thanks, Comment Number : #11089 Submitter : Jason Snider Date submitted : 2022-09-29 12:22:59 Status : New View Comment Details View Document Details Download Document