Comment Submitted by
Richard Winton
2008-01-29 13:52:22
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The proposed revisions to the information and formulation requirements are too broad and unnecessarily prescriptive.
The receipt and review of formulation information for a Drinking Water System Component is not an end in itself, but rather is the basis upon which:
a) an appropriate battery of analytical tests of extraction water is determined, and
b) extracted contaminants identified by spectral matches can be more positively identified.
We believe that to fulfill that two-fold purpose the certifier must as a minimum obtain and review:
a) a list of all water wetted parts and materials, including the generic description and the wetted surface area of each material, and
b) the formulation of each water wetted material as it is known by the formulator of the material.
For some materials, most notably those in Table 3.1 – Material-specific analyses, formulation information obtained at the level of detail described above may be sufficient for the intended purpose. For others and particularly those not in Table 3.1, more detailed formulation information as described in the proposed revisions, may be needed. It is the responsibility of the certifier’s toxicology department to determine the adequacy of the formulation information obtained for the dual purposes outlined above and to request additional information as needed, taking into consideration not only material formulation but also product design information such as wetted surface area.
While the specificity of the formulation information requirements in the proposed wording of 3.2 and 3.3 can be useful as an indication of the types of formulation information that a certifier’s toxicological dept. may need to obtain in order to develop an appropriate test program, the wording being balloted is unacceptable in that it goes beyond this in making the gathering of all such information that could conceivably be obtained a prerequisite.
We agree that the formulation requirements in section 3 need clarification and revision. We suggest that a task group be established to comprehensively consider all aspects of section 3 formulation information requirements including
a) requirements in the current edition,
b) requirements proposed in this ballot, and
c) proposed revisions NSF has stated it intends to submit regarding municipal water treatment applications.
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