The US Consumer Product Safety Commission (CPSC) has issued a new set of certification rules applicable to architectural glazing materials installed in hazardous locations. As per these new regulation…
The US Consumer Product Safety Commission (CPSC) has issued a new set of certification rules applicable to architectural glazing materials installed in hazardous locations. As per these new regulations, which took effect on 11 February 2010, manufacturer certifications of compliance with CPSC 16 CFR 1201, which are the federal safety standard for architectural glazing materials, must include: manufacturer“s name; postal address and phone number; month and year of manufacture; city and state where manufactured; safety standard; identification of the product by a “unique identifier;” custodian of testing records“ name, e-mail address, postal address and phone number; date and place where the product was tested; as well as the third-party test laboratory“s name, postal address and phone number. According to John Kent, administrator for the Safety Glazing Certification Council (SGCC), each and every manufacturer or importer of architectural glazing material that is subject to 16 CFR Part 1201 will be obliged to comply with these new regulations, and this will certainly mean many fabricators will have a lot of questions. For example, what happens if a fabricator has to remove and reinstall the same piece of glass? Does the glass then need to be labelled? Kent says that in his opinion, the regulations apply, in effect, during the shipping period or process. “The manufacturer or importer shall provide the required information to a distributor or retailer,” says Kent. For companies that buy labelled glass to cut, the required information will still be available as it can appear on a paper certificate, the product label, or by reference to a website, or also a combination of these. “The required certificate, or information, must accompany the product, and a copy must be furnished to each distributor and retailer of the product,” explains Kent. “This implies that each crate or shipment must bear the information, not necessarily each piece of glass.” Kent adds, “I believe most people will continue to label as they have in the past. They may add “date of manufacture“ to the label if that is viable. They then will provide a statement on shipping documents that certified they meet the regulation, addresses the date of manufacture, identified the product, and references a website where the remainder of the information may be obtained.” With regards to how the new requirements will be enforced, Kent said that the regulation states to make the certificate available to the FTC or to the Customs authorities or to CPSC. “I believe a review during a customs inspection is the most likely avenue for enforcement, although CPSC could certainly police the process as well,” Kent says. According to Kim Mann, general counsel for the Glass Association of North America (GANA), the CPSC has made it clear “that its first priority will not be policing certification and labelling requirements,” but, rather, trying to ensure these consumer products meet the safety requirements in these standards. Manufacturers not complying with the new requirements could be subject to an up to USD 100,000 penalty for each known violation. “I don“t see a big change for most of the fabricators; if they are currently using a third-party certification organization such as SGCC I believe they are already in fairly good shape,” says John Bush, who has been working for more than 20 years with safety glazing materials, most recently with Oldcastle Glass. “However, those who choose to continue to self-certify have to seriously ask themselves if they are doing this in a way where they can defend the “reasonable testing“ statement. There is too much required information to put it all on the permanent logo on the glass and still have the glass acceptable to owners and architects. Therefore, I see most manufacturers using a hybrid approach with the information being distributed between the permanent logo, the shipping documentation and the fabricators website.” He adds, “As always is the case with new rules and regulations, we will have to wait to see how some of this is interpreted.”