On behalf of Jim Darr and the textiles task group of chairs, Issue proponents, the ballot for NSF/ANSI 336, issue 3, revision 1, Section 6.5.3 has been recommended to be sent to the Joint Committee for consideration. Please review the proposal and return your ballot by the ballot due date of April 27, 2012 via the online workspace (http://standards.nsf.org).
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Purpose
An Issue Paper was submitted requesting language to clarify Section 6.5.3. The purpose of this ballot is to approve the proposed clarification for 6.5.3 on Possible or suggested carcinogens. The Issue Paper and the Meeting Summary for the February 13, 2012 meeting when this Issue Paper was discussed have been included with this ballot as reference items. Please see those documents. Only the proposed change to section 6.5.3 is within the scope of this ballot.
Background
This proposed change will provide clarification about the references to use to earn credit in this section.
Section 6.5.3, Possible or Suggested Carcinogens, uses Prop 65 as one of the source lists for this credit. Prop 65 contains Known Carcinogens. Known carcinogens are prerequisites that must be met under section 6.4.2-Carcinogens. Section 6.5.3 is an optional credit for identifying Possible or Suggested Carcinogens.
Using Prop 65 as a source for identifying possible or suggested carcinogens for section 6.5.3 is problematic due to the fact that the Prop 65 lists contains "chemicals known to the state to cause cancer." Known carcinogens are prerequisites that must be met under section 6.4.2-Carcinogens. Section 6.5.3 is an optional credit for identifying possible or suggested carcinogens. Users of the standard will be rightfully confused by the language and the reasoning to use a list of "known carcinogens" to comply with the "possible or suggested carcinogens" credit.
If the intent was to use the Prop 65 list (which casts a much broader net and identifies many more chemicals than the other source lists of "known carcinogens" in section 6.4.2) as a way to capture chemicals beyond the known carcinogens met in the prerequisite credit, and cast them as "possible or suggested carcinogens" for the purposes of section 6.5.3, that intent must be made clear. |
