UL-1175-BULLETINS-2004.pdf

Subjects 1123 (1175, 1177, 1180, 1191, 1197, 1517) (In reply, refer to Subject 1123) 12 Laboratory Drive Research Triangle Park, NC 27709 January 14, 2004 TO:Standards Technical Panel for PFDs (STP 1123) which covers: Standard for Safety for Marine Buoyant Devices, UL 1123; Standard for Safety for Buoyant Cushions, UL 1175; Standard for Safety for Buoyant Vests, UL 1177; Standard for Safety for Fully Infl atable Recreational Personal Flotation Devices, UL 1180; Standard for Safety for Components for Personal Flotation Devices, UL 1191; Standard for Safety for Immersion Suits, UL 1197; and Standard for Safety for Hybrid Personal Flotation Devices, UL 1517 SUBJECT:Standards Technical Panel Meeting Report Summary of Topics The following items and topics were discussed at the meeting: Responses to comments received regarding the proposals balloted in the STP 1123 Meeting Report, UL bulletin dated February 22, 2002, and subsequent action per disposition of the comments. UL 1123 and UL 1180 Grab Strap Proposals UL 1180 Automatic Battery Operated Infl ation System Proposal Responses to comments received regarding the proposals balloted in the STP 1123 UL Proposal bulletin dated April 15, 2003, and proposed changes in requirements or other subsequent action based on these comments. UL 1123 Work Vest Proposal UL 1123 Tensile Test Proposal UL 1123 Post Donning Ease of Adjustment Proposal UL 1180 Rearming Kit Proposal Document for Comment - Draft of New UL 1180 Rearming Kit Proposal New Proposals that were included in the November 11, 2003 STP Meeting Agenda: UL 1123 Excess Body Strap Length UL 1123 Tolerances to the Weight Range and the Chest Size for Selection of Test Subjects Copyright Underwriters Laboratories Inc. Provided by IHS under license with ULLicensee=North Carolina State University/5618801100 Not for Resale, 10/16/2006 02:13:42 MDTNo reproduction or networking permitted without license from IHS -,-,- UL 1123 Water Entry Test Specifi cations UL 1123 Shifting/Bunching of Internal Material Test UL 1123 Deletion of Turning Test for White Water PFDs UL 1180 Deletion of Survey Card UL 1180 Optional Wording for Rearming Kits UL 1180 Design Infl ation Range UL 1191 Weathering Requirements UL 1191 General Color Requirements UL 1191 Measuring Initial Thickness of Foam in the Compression Defl ection Test UL 1191 Deletion of Requirements for Measuring Compression Defl ection of Fabric Laminated Foams UL 1191 Miscellaneous Editorial Corrections UL 1177 Water Entry Test Discussion Items: Use of Infl atable PFDs in White Water Paddling Activities PFD Labeling and Re-Classifi cation Warning Statements for Type II and Type III Child PFDs Bolding of Warning Statement on Labels High Speed Activities Labeling on PFDs STP 1123 Working Groups COMMENTS DUE: February 16, 2004 A meeting of the Standards Technical Panel of UL for Personal Flotation Devices, STP 1123, was held on December 11 and 12, 2003 at ULs RTP office. The purpose of the meeting was to discuss personal fl otation devices and components for personal fl otation devices. Another objective of the meeting was to obtain agreement on the disposition of the comments received with the ballots dated February 22, 2002 and April 15, 2003. UL 1177 proposals were also discussed. However, UL 1177 is not an ANSI approved standards and consequently, proposals to UL 1177 are not balloted. JANUARY 14, 2004SUBJECT 1123-2- Copyright Underwriters Laboratories Inc. Provided by IHS under license with ULLicensee=North Carolina State University/5618801100 Not for Resale, 10/16/2006 02:13:42 MDTNo reproduction or networking permitted without license from IHS -,-,- INSTRUCTIONS STP Members: The matrix in Appendix A contains all the comments that were received with the ballots dated February 22, 2002 and April 15, 2003 and the disposition/actions that were determined during the STP meeting. If the STP concurs with the disposition/actions, then consensus will be achieved and UL will adopt the amended proposals in Appendix B and revise UL 1123 accordingly. If you wish to change your vote in light of the dispositions/actions or the proposed changes, please respond to us in writing or via E-mail to Betty.C.McKayus.ul.com by February 16, 2004. If we do not hear from you by the proposed date, your original vote will be maintained. You have the right to appeal this action on a procedural basis through ULs Appeals Process. If you wish to appeal, please respond by February 16, 2004. Guidelines on how to register an appeal can be obtained on http:/ulstandardsinfonet.ul.com or by contacting the STP Secretary. Appendix C contains a UL 1180 draft Rearming Kit proposal which is included as a Document for Comment. You are requested to send in comments on the draft to the STP Secretary by February 16, 2004. In regard to the new proposals in Appendices D, E, and F, if you are a voting member of the STP, complete the attached ballots with your vote on the proposals. Please note that all negative ballots must be accompanied by supporting written reasons and, where possible, proposals for a solution to the problem raised. STP members may submit comments on the UL 1177 proposals in Appendix G since voting on this standard is not required. Impact statements and effective dates information are not subject to letter ballot. Therefore, comments regarding impact statements and effective dates may be made and should be sent to the STP Secretary separate from the letter ballot. Subscribers and other interested parties: The matrix in Appendix A contains all the comments that were received on proposals in the February 22, 2002 bulletin and the April 15, 2003 bulletin and provides the comment dispositions agreed upon by those attending the STP meeting. If the STP concurs with the disposition/actions, then consensus will be achieved and UL will adopt the amended proposals in Appendix B and revise UL 1123 accordingly. You have the right to appeal this action on a procedural basis through ULs Appeals Process. If you wish to appeal, please respond by February 16, 2004. Guidelines on how to register an appeal can be obtained on http:/ulstandardsinfonet.ul.com or by contacting the STP Secretary. Appendix C contains a UL 1180 draft Rearming Kit proposal which is included as a Document for Comment. You are requested to send in comments on the draft to the STP Secretary by February 16, 2004. If you are a subscriber or other interested party, you are requested to send comments on the proposed requirements in Appendices D, E, F and G, impact statements, and proposed effective dates to the STP Secretary. The STP member ballot should not be used to submit your comments. JANUARY 14, 2004SUBJECT 1123-3- Copyright Underwriters Laboratories Inc. Provided by IHS under license with ULLicensee=North Carolina State University/5618801100 Not for Resale, 10/16/2006 02:13:42 MDTNo reproduction or networking permitted without license from IHS -,-,- Comments should be made in writing and may be sent by fax to 919-547-6180 or by mail to the attention of Betty McKay at ULs RTP office. Comments may also be sent via E-mail to Betty.C.McKayus.ul.com. Please reference all correspondence to Subject 1123. Note all comments received are public and may be circulated to others. If you respond by fax or E-mail, please include your full name and company name and address to ensure a reply. STP BALLOTS AND ALL COMMENTS DUE: FEBRUARY 16, 2004 Attached as Appendix A is the disposition table for comments received on proposals that were included in the 2/22/02 STP meeting report and the 4/15/03 STP proposal bulletin. Attached as Appendix B are amended proposals for UL 1123 that were proposed in the 4/15/03 PFD STP bulletin and have been amended in light of comments received and the disposition determined by the STP. Attached as Appendix C for your review and comment is a Document for Comment regarding draft UL 1180 Rearming Kit requirements. Attached as Appendix D for your review and comment are new proposed requirements for UL 1123. Attached as Appendix E for your review and comment are new proposed requirements for UL 1180. Attached as Appendix F for your review and comment are new proposed requirements for UL 1191. Attached as Appendix G for your review and comment are new proposed requirements for UL 1177. Attached as Appendix H for your review and comment are ULs impact statements and proposed effective dates. Attached as Appendix I are STP ballots. Attached as Appendix J is information regarding Working Groups. Attached as Appendix K is a list of those who attended the meeting. Questions regarding interpretation of requirements should be directed to the responsible UL Staff. Please note that proposed requirements are of a tentative and early nature and are for review and comment only. Current requirements are to be used to judge a product until these requirements are published in fi nal form. * * * * * * The following report is not intended to be a verbatim transcript of the discussion at the meeting, but is intended to record the signifi cant features of those discussions. MEETING CALL TO ORDER, ANNOUNCEMENTS, INVITATION OF MEMBERS, GUESTS, OBSERVERS JANUARY 14, 2004SUBJECT 1123-4- Copyright Underwriters Laboratories Inc. Provided by IHS under license with ULLicensee=North Carolina State University/5618801100 Not for Resale, 10/16/2006 02:13:42 MDTNo reproduction or networking permitted without license from IHS -,-,- Dan Ryan, Chair of the Standards Technical Panel for Personal Flotation Devices, called the meeting to order at 8:00 A.M. The Chair introduced himself and welcomed PFD STP members, guests, and observers. The Chair then asked all attendees to introduce themselves. A roster was circulated for members to review for accuracy and initial, indicating their presence at the meeting. A separate attendance table with contact information was circulated for guests and observers. ADDITIONS OR CORRECTIONS TO THE AGENDA The following additions were made to the agenda: a) STP member, Captain Jeffrey Lantz, requested that the USCG be able to present a power point presentation on Risk Based Analysis if time permits; and b) A discussion item regarding Labels for High Speed Devices was added as New Business. ANNOUNCEMENTS FROM THE SECRETARY a) ULs New ANSI STP Regulations Betty McKay, PFD STP Secretary, distributed copies of a power point presentation, Regulations Governing UL Standards Technical Panels. The power point presentation was viewed and questions answered. The Secretary explained that the ANSI method of standards development for PFD standards is now the Accredited Organization Method (AOM). b) STP Balance The current balance of this STP is 28 percent User, 45 percent Producer, and 28 percent General Interest. ULs goal is equal interest participation. Members were encouraged to provide names of potential general interest and user members to help achieve this goal. It was noted that currently the Producer category is not open for additional members. DISCUSSION OF EACH STP PROPOSAL / DISCUSSION ITEM The Chair opened the fl oor to STP representatives for presentation of proposals as outlined in the November 11, 2003 STP meeting agenda. 1. EXCESS BODY STRAP LENGTH (UL 1123) DISCUSSION UL explained that the intent of the proposed change in the construction requirements for excess body strap length is to accommodate people with a large belly. At issue is the current excess body strap chest requirements do not fi t with the current body strap waist requirements. UL proposed in paragraphs 12.1 and 12.2 to delete chest so that test subjects will not be chosen based on maximum chest size and to add waist so that test subjects may be chosen based on maximum waist size. An STP representative noted not only seeing evidence in the fi eld of this problem but also he has seen that the issue could go the other way where the concern is excess body strap requirements for a user with a large chest size and a small waist. It was suggested that the proposal be amended to refl ect that the test subject with the largest chest size or waist size successfully be tested. The proposal was amended to keep chest and to add or waist. The STP supported moving the amended proposal forward to letter ballot. RATIONALE For determining the excess body strap length, test subjects should be chosen based on maximum waist size or maximum chest size. JANUARY 14, 2004SUBJECT 1123-5- Copyright Underwriters Laboratories Inc. Provided by IHS under license with ULLicensee=North Carolina State University/5618801100 Not for Resale, 10/16/2006 02:13:42 MDTNo reproduction or networking permitted without license from IHS -,-,- 2. TOLERANCES TO THE WEIGHT RANGE AND CHEST SIZE FOR SELECTION OF TEST SUBJECTS (UL 1123) DISCUSSION UL stated that this proposal will provide more efficient testing by allowing for the changing weight and size of infant/child/youth test subjects. UL further explained that a tolerance for weight and chest size is appropriate for the 0-80 pounds weight group. The STP supported this proposal and it was moved forward to letter ballot. RATIONALE In order to provide fl exibility in the selection of test subjects for youth, child, and infant devices, it is proposed there be a tolerance at the extremes of weight range of ±1 lb, and ±1 inch for chest size. 3. WATER ENTRY TEST SPECIFICATIONS (UL 1123) DISCUSSION UL explained that this proposal is intended to improve test safety. This proposal changes the water entry jump test requirements from specifying that for tests over three feet the test subject enters the water hands above the head with arms extended to holding onto the device during water entry. Another STP member questioned the deleting of this water entry requirement because of the concern that the personal fl otation device may pop off when not holding onto the device during the water entry in the fi eld. The USCG stated that the device should stay on during water entry. It was noted that the proposed changes to the UL 1123 water entry test aligns the requirements with UL 1180. A majority of STP members present supported moving this proposal forward to letter ballot. RATIONALE The proposed revisions will improve the safety of the test procedures. 3 meter jump should be performed feet fi rst, hands holding onto device during water entry. For Type II devices, to evaluate whether the device remains in its intended position after a jump, an additional 1 m jump with hands over head with arms extended should be performed. 4. SHIFTING/BUNCHING OF INTERNAL MATERIAL TEST (UL 1123) DISCUSSION UL presented a proposal to add a test for shifting/bunching of foam in a PFD in an attempt to eliminate a problem that has been encountered in the fi eld. An