Rules on Conformity to Certification Requirements
The U.S. Consumer Product Safety Commission (CPSC) recently published
a final rule as part of its Federal Register, 73 Fed. Reg. 68328
that addresses the conformity certification required for consumer
products, including architectural glass used in hazardous locations,
which are subject to safety rules under CPSC jurisdiction (CLICK
HERE to read the rule). In its ruling, the CPSC addressed a
number of areas including how the certificate will need to be filed,
including electronic formats, and the information that must be included
in the certificate.
As a result of numerous requests and comments regarding the need
to have a means for electronic certificates as an alternative to
paper certificates, the CPSC now allows certifications to accompany
the product and be furnished to distributors and retailers electronically.
"In my opinion, the CPSC regulation changes seem to bring
the certification requirements for safety glazing officially into
the modern age. The new regulations formally allow for use of an
electronic certificate for safety glazing," says Julie Schimmelpenningh,
architectural applications manager with Solutia Inc., who is also
actively involved with a number of industry organizations focused
on safety glazing, including the Glazing Industry Code Committee
(GICC), the Accredited Standards Committee (ASC) Z97 and the Glass
Association of North America (GANA). "In the past the glazing
used in doors and door leaves as outlined in CPSC 16 CFR 1201, or
safety glazing required in hazardous locations as defined in the
model building codes, either had to have a permanent mark on the
glazing indicating performance compliance to CSPC 16 CFR 1201 or
a paper certificate that went along with the glazing. Now, with
this regulation change, the documentation may be electronic."
Another change brought forth by the regulation is the amount of
information that must be included on the certificate. The required
- Identification of the product covered by the certificate;
- Citation to each CPSC product safety regulation to which the
product is being certified;
- Identification of the importer or domestic manufacturer, including
the importer or domestic manufacturer's name, full mailing address
and telephone number;
- Contact information for the individual maintaining records of
test results, including name, e-mail address, full mailing address
and telephone number;
- Date (month and year at a minimum) and place (including city
and country or administrative region) where the product was manufactured;
- Date and place (including city and country or administrative
region) where the product was tested for compliance with the regulation(s)
cited above; and
- Identification of any third-party laboratory on whose testing
the certificate depends, including name, full mailing address
and telephone number of the laboratory.
Another regulation change involves accessibility to the certificates
by both the customers and CPSC.
"What this means to the glazing industry is potentially the
development of a transparent tracking and certification system and
access to those records for any glazing deemed as a 'safety' product.
This may mean the development of online access or some other form
of data acquisition that can be designated to allow review as necessary
for the products that are sold as safety glazing," Schimmelpenningh
says. "This regulation went into practice effective immediately
on November 8, 2008."
Schimmelpenningh says a number of industry organizations are distributing
this information to their members and asking for feedback and comments.
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