CPSC 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 information includes:

• 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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