Pools/Aquatics: Avoiding Entrapment
The Impact of the Virginia Graeme Baker Pool & Spa Safety Act
By Dennis Berkshire
In December 2007 the United States Congress passed the Virginia Graeme Baker Pool and Spa Safety Act. This act was the result of the efforts of Nancy Baker, whose 7-year-old daughter Graeme Baker died in 2002 when a spa main drain trapped her underwater causing her to drown. After her daughter's death, Baker started a campaign to introduce legislation to protect against such future accidents or deaths. Between 1985 and 2004 there have been 33 documented cases of children dying as a result of pool or spa entrapment. The new federal law aims to prevent the sale or installation of suction devices in residential or commercial pools and spas that can contribute to underwater entrapment. This law goes into effect in December 2008 and will make it illegal to sell, distribute or install a pool or spa drain or suction device that is not certified to meet the anti-entrapment requirements of ASME/ANSI A112.19.8-2007, a performance-based standard for suction fittings used in swimming pools, wading pools, spas and hot tubs. The Virginia Graeme Baker Pool and Spa Safety Act in section 1402 states that the U.S. Congress has found the following:
- Of injury-related deaths, drowning is the second leading cause of death in children aged 1 to 14 in the United States.
- In 2004, 761 children ages 14 and under died as a result of unintentional drowning.
- Adult supervision at all aquatic venues is a critical safety factor in preventing children from drowning.
- Research studies show that the installation and proper use of barriers or fencing, as well as additional layers of protection, could substantially reduce the number of childhood residential swimming pool drowning and near drownings.
In section 1404 of this act, Congress defines this law as a consumer product safety rule. Therefore it is assigned to the Consumer Product Safety Commission (CPSC) for enforcement under the Consumer Product Safety Act (15 U.S.C. 2015 et seq.). Effective one year after the enactment of the act (Dec. 20, 2008), each swimming pool or spa drain cover manufactured, distributed or entered into commerce in the United States shall conform to the entrapment protection standards of the ASME/ANSI A112.19.8 performance standard, or any successor standard regulating such swimming pool or spa drain covers. This law appropriates $2 million for each fiscal year 2009 and 2010 for the CPSC to establish state grants for the enactment or amendment of state laws to comply with this act. In addition Congress also appropriated $5 million for each fiscal year 2008 through 2012 for the CPSC to establish and carry out an education program to inform the public of methods to prevent drowning and entrapment in swimming pools and spas.
The Virginia Graeme Baker Pool and Spa Safety Act section 1404 addresses public swimming pools and spas. Per this section:
- Each public pool and spa in the United States shall be equipped with anti-entrapment devices or systems that comply with ASME/ANSI A112.19.8 performance standard or any successor standard.
- Each public pool or spa in the United States with a single main drain other than an unblockable drain shall be equipped, at a minimum, with one or more of the following devices or systems: a safety vacuum release system, suction-limiting vent system, gravity drainage system, automatic pump shutoff system, drain disablement, or other system determined to be equally effective as or better than one of these systems.
As noted in the Pool and Spa Safety Act the ASME/ANSI A112.19.8-2007 standard establishes minimum standards for construction, configuration and testing to ensure that a pool or spa main drain does not pose a suction entrapment hazard. This standard requires that the drain must be tested and certified by a nationally recognized testing lab. The standard requires that a main drain is configured such that a tool is required for disassembly of a suction fitting. Slotted screws are not permitted. The screw must have a corrosion resistance to the intended environment equivalent to grade 316 stainless steel. The screw must be installed with no less than three threads of engagement. The drain screws and screw receivers shall be designed for a minimum of 15 secure insertions, tightening and removal cycles with any stripping or failures. The drain fitting must pass tests for structural integrity, ultraviolet resistance, body entrapment, hair entrapment, finger and limb entrapment.
The ASME/ANSI A112.19.8-2007 standard also provides for field-fabricated main drains. A field-fabricated drain outlet must have a spacing from the top of the suction pipe to the bottom of the drain grate of not less than 1.5 times the diameter of the pipe. It must also be operated in a worst case at not more than 1.5 feet per second water velocity through the grates. If the grate is a single main drain, then it must be sized so that it cannot be completely covered by an 18-inch by 23-inch body blocking element and will not cause a differential pressure that could cause body entrapment. In the absence of this configuration, a minimum of two or more drains are required that are separated by no less than three feet. The two or more main drains should be hydraulically balanced so that a pressure differential cannot create an entrapment hazard. Field-fabricated drains that operate at less than 1.5 feet per second are not required to have a hair entrapment test certification.
Even if a pool is designed and constructed with two or more main drains that are at least three feet apart, and plumbed in a hydraulically balanced fashion, the only way to confirm that a main drain or main drain frame and grate meets the ASME/ANSI Standard is to have a drain tested and certified by a nationally recognized testing lab. The standard requires that all main drains be labeled with information including designation that the drain has been tested and certified, the certified maximum flow rate for the drain, the intended application for the fitting, the manufacturer's intended life of the drain and more.
Various nationally-recognized testing laboratories have only recently been set up to conduct tests to the ASME standards. At this time, the National Swimming Pool Foundation (NSPF) reports that there is only one 8-inch diameter drain that has been certified to meet the ASME standard. There are several other manufacturers that are submitting their drains for testing and certification. One of the problems that the manufacturers are having is the ultraviolet (UV) structural testing. The temperatures that the drains must be tested for during the UV tests have proven to be problematic for some materials such as polyvinyl chloride (PVC). Unless the ASME standard can be modified, the drain manufacturers must find alternate materials that can comply with the ASME testing protocol.
The Association of Pool and Spa Professionals (APSP) is in contact with the CPSC to discuss the implementation of the Virginia Graeme Baker Pool and Spa Safety Act. Given the lack of approved products, it will be difficult, if not impossible, for public pools to meet the drain requirements by the Dec. 20, 2008 deadline. The APSP has been working for years with ANSI in establishing standards for swimming pools.
One such standard is ANSI/ASPS -7 2006, the American National Standard for Suction Entrapment Avoidance in Swimming Pools, Wading Pools, Spas, Hot Tubs, and Catch Basins. The ANSI/APSP-7 standard identifies five forms of potential entrapment that can occur in a swimming pool or spa. They include hair entrapment, limb entrapment, body suction entrapment, evisceration/disembowelment and mechanical entrapment. APSP reports that it is their position that the only way to ensure a defense against all five recognized forms of entrapment is to have a drain tested and certified to meet the performance standards of ASME/ANSI A112.19.8.
The APSP also reports that test findings show that the use of a Safety Vacuum Release System (SVSR) may only activate when there is only a single source of suction to a pool or spa. They go on to state that while SVSRs may improve the entrapment safety of a single suction device, that alone cannot protect against evisceration, limb, hair or some types of mechanical entrapment. The APSP notes that a review of pools and spas in all 50 states with multiple outlets separated by no less than three feet have not had a single reported incidence of suction entrapment.
On March 28, 2008 the APSP submitted comments to the CPSC explaining their interpretation of the Pool and Spa Safety Act. Furthermore, the APSP has requested a deadline extension to June 18, 2009 for public pools to comply with the Pool and Spa Safety Act. Currently, the state of Florida has both a Senate Bill (SB 1580) and a House Bill (HB 963) in the works to enact state compliance with the Federal Pool and Spa Safety Act. In the absence of certified main drains from recognized testing agencies, public pools and spas cannot comply. Once the market has approved products, a reasonable time will have to be given to allow all of the public pools and spas in the U.S. to comply. Until then, all we can do is ensure we design and construct pools and spas with multiple drains in compliance with the ASME/ANSI A112.19.8 standards.
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