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