Pamela Gilbert
Cuneo Gilbert & LaDuca, LLP
507 C Street NE
Washington, DC 20002
main: (202) 789-3960, ext. 228
fax (202) 789-1813
cell (202) 253-3561
pamelag@cuneolaw.com
or
Underwriters Laboratories Inc.
333 Pfingsten Road
Northbrook, IL 60062-2096 USA
Fax: +1-847-272-8129
or to send comments electonically click here: http://ulstandardsinfonet.ul.com/commentform.cfm
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phone: (202) 898-1610, fax: (202) 898-1612, email: info@healthybuilding.net
If you haven't already, please read our related HBNews piece: Certification Manipulation
↓ sample letter ↓
George E. Laverick
Principal Engineer
Fire Sprinkler Systems and Extinguishing System Equipment
Underwriters Laboratories
333 Pfingsten Road
Northbrook, IL 60062-2002
Dear Mr. Laverick:
We write to register our strong opposition to the proposed revisions to UL 1285 recently submitted to UL.
The proposed revisions were submitted by an industry group, and to date, UL has received input only from industry. That is unfortunate, since UL Standards such as 1285 are supposed to reflect the needs and opinions not only of industry but also those of consumers, public-safety organizations, government agencies, labor, and academics, among others. The need for input from constituencies other than industry is especially pronounced in this case, given the public-safety importance of regulating PVC pipe. In fact, the consistent theme of the proposed revisions is to relax the requirements of PVC pipe, making it cheaper to produce and more likely to fail in the field. The proposed revisions serve only the profit interests of industry, and do so at the cost of imposing greater expense and risk on the public as a whole.
It is evident that the common theme of the proposed revisions is to significantly reduce the performance requirements of PVC pipe, and thus to weaken the safety and reliability of covered products. None of the revisions' proponents or supporters have even attempted to claim otherwise. The net effect can only be more failures in the field; more serious and even fatal injuries to those handling the pipe; and more expense to taxpayers to repair or replace pipe that fails prematurely.
We are further concerned with what appears to be a stealth attempt on the part of the revisions proponents to cut costs by reducing safety. Consumers and public-safety proponents look to UL above all for clear and reliable guidelines. The proposed revisions to UL 1285 mask some of the most significant changes in technical jargon that will be impenetrable to the average consumer or government purchaser.
This is most evident with respect to the proposed change to section 17 of UL 1285, which based on the comments from industry appears to be the primary motivation for the proposal. Section 17 is currently clear in mandating testing "from the pipe." The proposed revision would change that to a requirement that "[t]he pipe compound shall have a minimum tensile strength of 7000 psi." This revision would apparently permit manufacturers to test not the actual product UL will certify but a completely different specimen made from the same raw materials, or "compound.." Since a given compound can be processed in several different ways, some of which result in stronger final products than others, the net effect of the proposed revision is to license a manufacturer to sell a product bearing a UL mark that has been processed in a slipshod manner and that can never satisfy the 7,000 psi requirement of section. It appears that this change will result in a covert reduction of the tensile strength requirement by as much as 500 psi. Such a change is both sneaky and unsafe. We can conceive of no rational purpose - and the proponents of the revisions have offered none -- to allow manufacturers to certify the tensile strength of PVC pipe by testing a specimen that has been processed in a completely different fashion from the actual product sold. It seems to be no more than a cynical and fairly outrageous ruse played on unwary consumers to conceal what is actually a naked reduction in the strength and safety of PVC pipe. (The same criticisms apply, with even greater force, to the suggestions from industry in commenting on the proposal that UL should just eliminate section 17 altogether.)
The thrust of the other revisions, particularly to sections 12 and 18, is likewise to license manufacturers to produce a product that is less strong and safe and more likely to fail in the field. As with the proposed change to section 17, the proponents have offered no engineering, much less public-safety, rationale for these various changes, and UL has received no input from sources other than the industry in support of them.
It would be very unfortunate if UL would simply defer to industry's effort to dilute the safety requirements that protect consumers and the public from some of the risks posed by PVC pipe. We believe that PVC pipe needs to be made more safe, not less, and standard setting bodies like UL have an important part to play in that process. We strongly urge UL not to adopt the proposed revisions to UL 1285.