Volume 46, Issue 11 - December 2011


CPSC Postpones Changes to Safety Glass “Reasonable Testing Programs”

The U.S. Consumer Product Safety Commission (CPSC) has abandoned, at least for the immediate future, its plan to specify and regulate the required content of “reasonable testing programs” of manufacturers of non-children’s consumer products, including architectural glass, that are subject to CPSC safety standards such as 16 CFR 1201, and that must contain certifications of compliance with those standards. This will save manufacturers of architectural safety glazing materials time and money, industry members say.

In May 2010, the CPSC proposed requiring manufacturers of consumer products subject to a CPSC safety standard to include five specified elements in their mandatory reasonable testing programs, says Kim Mann, general counsel of the Glass Association of North America (GANA). The five required elements were: product specification, certification testing, production testing, a remedial action plan and recordkeeping (see October 2010 USGlass, page 38, for related article).

“These elements of the proposed rule would require changes in how most safety glazing manufacturers, whether temperer, laminator or mirror producer, conduct their reasonable testing programs,” says Julia Schimmelpenningh, global architectural applications manager, for Advanced Interlayers at Solutia Inc. in St. Louis. “However, these changes should be, with one notable exception, manageable, especially for those participating in third-party testing programs, such as the Safety Glazing Certification Council’s, although the changes will add paperwork and cost to the entire process.”

Once in effect, the new reasonable testing program rules would apply only to safety glazing materials installed in hazardous locations still falling within the jurisdiction of the CPSC, namely, in doors and shower/tub enclosures.

In response to CPSC’s proposal, GANA submitted written comments, focusing on persuading CPSC to make one critical change in its proposal: “Under the proposed CPSC rule, if a safety glazing manufacturer were to encounter a test failure in the course of conducting its in-plant quality control or assurance testing, that manufacturer would have to take whatever steps were needed to correct the manufacturing process, probably making adjustments in the furnace or oven, and then subject test specimens to impact testing, using the CPSC 16 CFR 1201 lead-filled shot-bag impactor, and obtain passing results before it would be permitted to resume production,” Schimmelpenningh says. She adds, “GANA sought to convince CPSC to permit the glass fabricator to use an alternative impact test, either the center-punch or drop-ball test, in lieu of the full-blown 16 CFR 1201 test, after incurring an in-plant test failure.”

On November 8, CPSC published a Federal Register notice addressing its proposed changes, Mann says. “With respect to non-children’s products such as architectural glass, it decided to postpone making any changes at this time, claiming it needed more time to study the issues.”

According to CPSC’s Federal Register notice: “We received many comments on proposed subpart B [testing of non-children’s products] … The commenters raised many concerns about the cost and burden of the proposal as well as practical issues …. Consequently, we are deferring action with respect to finalizing subpart B. We will reserve subpart B in the final rule and … continue evaluating the issues raised in the comments regarding a reasonable testing program.”

The CPSC’s rationale for “deferring action” on adopting any changes in reasonable-testing programs for non-children’s products is “startlingly and refreshingly honest and testimony to the value of industry-submitted comments in shaping federal agency rulemaking,” Mann says.

ASTM Revises Test Method for Measuring Roll Wave Distortion
C1651 - Standard Test Method for Measurement of Roll Wave Optical Distortion in Heat-Treated Flat Glass has been revised to C1651-11 by Committee C14.11.

This test method is a procedure for determining the peak-to-valley depth and the wavelength of roll wave in flat glass and then calculating the optical distortion resulting from that roll wave. Peak-to-valley measurements provide a means of monitoring the roll wave distortion in a heat processed glass product.

Measured peak-to-valley depth provides information required by some specifiers of heat-treated glass products.

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