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Comment 60
Withdrawn (Resolved)
61i77r1 JC Ballot (Revision 0)
Approval of 61i77r1 JC Ballot
Comment Submitted by
Joseph Harrison
2008-01-30 13:21:37
The Joint Committee members should be cautious about approving this 61i77r1 proposal as written because it will substantially increase the cost and time for product certifications and there may very well be alternatives to provide equal public health protection without the concomitant and undue burden of excessive certification time and cost. This proposal has not been adequately vetted through the toxicology support services of the other comparable ANSI-accredited certification programs for alternative considerations. As proposed this standard revision will significantly add to the cost of certification and slow down the entire process because certifiers will spend weeks and months waiting for ingredient specific formulation information that will not affect the final analytical test battery that needs to be selected to assure materials safety.

It is important to preserve the discretion of qualified toxicologists that are familiar with drinking water system components - health effects to specify the appropriate analytical test batteries in instances where the wetted parts list information can not be reasonably known to the CAS number level. Materials’ formulations can be reviewed by qualified toxicologists and more sensitive analytical techniques than currently specified can be required (i.e., EPA Method 524.2 over EPA Method 502.2 specified currently). The 502.2 method does not involve the use of a mass spectrometer (MS). Only the 524.2 scan can search for non-target VOC analytes since it involves the use of an MS.
Submitter Proposed Solution
This proposed NSF 61i77r1 version is much too prescriptive and costly without an improvement in public health protection. The Joint Committee has not heard then views of the other equally qualified toxicology programs supporting the other accredited agencies experienced in Standard 61 certifications. It is recommended at a minimum that a joint committee task group be organized of representatives from the toxicology support departments of each of the certifiers and that this task group be tasked to report appropriate consensus recommendations on this issue to the JC.