Comment Submitted by
Rand Ackroyd
2008-05-09 22:16:33
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Annex G shouild not be included in NSF 61 for the following reasons.
(1) This is a "single state issue"
(2) There is currently no scientific evidence that the lead content approach California is more protective than existing NSF performance standards.
(3) NSF 61 is a health effects document, a preformance standard. It is not a material standard and the perscriptive requirements of Annex G does not full under the scope.
(4)Guidlines should be established for a lead content evaluation for California but existing NSF/ANSI 61 document is not the appropriate place.
(5)A separate document would be appropriate for the contents of Annex G.
(6) California Bill does not stated how they will enforce the Bill or if they would accept Annex G for demonstrating compliance.
(7) Since the manufacture has the option of meeting the requirements of Annex G or not this would lead to confusion in the field for NSF61 Listed products. Would another marking on products be required?
(8) A new California Bill is being proposed for third party certification but there is great opposition.
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