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BEE 11 Develop National Labeling Standards for Pool and Spa Safety Products

Key area

Barriers

Develop and implement national labeling standards for barriers and other pool and spa safety products.

Spectrum level: Changing Organizational Practices Influencing Policy and Legislation

Evidence level: Low

Implementation levels: National

Rationale:

Evidence shows that there are many regulations already in place that require permanent markings or labels be displayed with important product safety information included. Recently, incorporated into the Virginia Graham Baker Act (VGBA), suction drain covers must now have specific information displayed on a product sticker. This voluntary standard became effective May 24, 2021 (ANSI/APSP/ICC 16-2017 American Standard for Suction Outlet Fitting Assemblies for use in pools, spas and hot tubs.)

Anticipated Impact:

After implementing this recommendation, you can expect to experience the following outcomes.

  • Consumer access to important information in case of a recall, product failure, or need to repair/replace the product or any of its parts.
  • Building code official and home inspector access to important information in advance of installation, or, if already in use, in the assessment of compliance with applicable voluntary standards, regulations, or barrier code requirements.

Evidence:

Regulations governing many types of products already require permanent markings or labels be displayed with important information included.

Recently incorporated into the Virginia Graham Baker Act (VGBA), suction drain covers must now have specific information displayed on a product sticker. This voluntary standard became effective May 24, 2021 (ANSI/APSP/ICC 16-2017 American Standard for Suction Outlet Fitting Assemblies for use in pools, spas and hot tubs.)

Evidence Sources:

Virginia Graeme Baker Pool & Spa Act, TITLE XIV—POOL AND SPA SAFETY (2014). https://www.poolsafely.gov/wp-content/uploads/2016/04/pssa.pdf

Products that require identification and tracking labels -

Federal regulation for full sized baby crib, full sized - ASTM. (2022). Standard Consumer Safety Specification for Full-Size Baby Cribs. (F1169-19). 16 CFR Part 1219 , Vol Standard ASTM F1169-19 ;
Code of Federal Regulations (2023). Title 16. Chapter II. Part 1112. Subpart B. § 1112.15. http://www.ecfr.gov/cgi-bin/text-idx?SID=aad30823a0502a664455e6d9caebe30c&mc=true&node=se16.2.1112115&rgn=div8 ;
Mattresses https://www.federalregister.gov/select-citation/2020/10/30/16-CFR-1632 ;
Bunk beds https://www.law.cornell.edu/cfr/text/16/part-1213 , Bunk Bed Vol Standard http://www.astm.org/Standards/F1427.htm ; Consumer Products Federal Hazardous Substances Act (hazardous materials) https://r.search.yahoo.com/ylt=AwrgDuinealhAjEAED1XNyoA;_ylu=Y29sbwNncTEEcG9zAzEEdnRpZANGT05UQ09OVFJPTF8xBHNlYwNzcg--/RV=2/RE=1638525479/RO=10/RU=https%3a%2f%2fwww.cpsc.gov%2fBusiness--Manufacturing%2fBusiness-Education%2fBusiness-Guidance%2fFHSA-Requirements/RK=2/RS=h6S6yz2cfJ4DZL5kdp8WxIjCVzc-

High Risk Populations Addressed:

Populations whose risk of drowning decreases the most with the implementation of this recommendation may have one or more of the following characteristics:

  • Children 1-4 years old
  • Pool and spa owners
  • Pool and spa managers
  • Pool and spa bathers

Evaluation Metrics:

Indicators of long-term impact:

  • Proper use of safety devices
  • Increased access to important information in case of inspection, recall, repair or replacement.
  • Increase in pool safety products that are up-to-date, meet code and regulatory requirements, and are in proper working order.
  • Faster inspections, and quicker turnaround time, during pool construction, remodeling, and during point of home sale

Implementation:

Consider the following recommendations to ensure successful implementation.

  • Develop new ways to create permanent markings and labels.
  • Determine what to include on the permanent marking and labels. - Decide where on the safety devices to place the information.
  • Retool manufacturing equipment to automate the labeling process.
  • Duplicate the process used by manufacturers of other regulated safety products where permanent labeling is required.

Challenges to Implementation:

When implementing this recommendation, you might encounter challenges related to the following factors.

  • Manufacturers may have the increased responsibility in creating the labels and placing them onto safety devices.
  • Increased label costs may also increase the product pricing.
  • Standardization will be a challenge as many similar products perform differently, and manufacturers will need to determine if necessary information should be placed on each label for comparison or included on a specification sheet or other marketing.

Potential Facilitators:

The following factors might facilitate the implementation of this recommendation.

  • Legislators, code councils, voluntary standards committees, manufacturers of safety devices, print shops, labeling apps and technical programs used by individuals could all advocate for this recommendation and support implementation.

GAP Recommendation:

NOT A RESEARCH GAP -> Minor gap: not much specific language or information is in use at this time for certain types of pool safety device labels or markings although most have basic information attached. Most labeling is currently voluntary.