Comment Submitted by
Franco Di Folco
2008-04-04 13:16:33
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I am still uncomfortable supporting the Addition of Annex G to the NSF/ANSI 61 standard for several reasons:
1. The NSF 61 standard is a performance based standard. Annex G is written as design requirements and does not include any performance requirements.
2. California has not officially stated how they will enforce this bill or if they would accept Annex G as a suitable vehicle for demonstrating compliance.
3. Other states (including California) have had and enforced prescriptive requirements for lead for years, which have never been part of NSF 61 standard.
4. The language proposed, states that the manufacture has the option of meeting the requirements of Annex G or not. This would lead to confusion in the field.
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