There are many public pool facilities that have not replaced their existing drain covers, as required by the Virginia Graeme Baker Act (VGB Act). The reason: the size of the drain cover. Large covers commonly referred to as unblockable covers. The ASME/ANSI A112.19.8 indentifies unblockable as 18” X 23” or 29” diagonal measure or larger. The CPSC clouded the issue of unblockable covers in their staff draft technical guide.
“The Consumer Product Safety Commission staff (“CPSC staff” or “staff”) has interpreted this definition to include a drain coupled with a drain cover of specific dimensions (an “unblockable drain cover”) that meets the requirements specified in ASME/ANSI A112.19.8.”
The crucial phrase in this paragraph is: “that meets the requirements specified in ASME/ANSI A112.19.8.”
This phrase clearly states that covers must meet the ASME/ANSI A112.19.8. The ASME/ANSI A112.19.8 requires drain covers to be tested and approved for body entrapment, limb entrapment, finger entrapment, hair entrapment (entanglement) and evisceration/disembowelment. Existing drain covers may meet all of these provisions but they were not tested thus the manufacturers of these covers will not retroactively certify them.
The State of Michigan Department of Environmental Quality (DEQ) and Pool Safety Consultants of Michigan (PSCM) interpret the VGB Act to require replacement of ALL existing drain grates/covers REGARDLESS of size with ASME/ANSI A112.19.8-2008 approved grates/covers. *
I believe the CPSC should clarify this for the public with a statement such as:
1) All covers must be replaced, regardless of size, with covers having the ASME/ANSI A112.19.8. 2008 stamp or logo
2) If the covers do not have the ASME/ANSI A112.19.8. 2008 stamp or logo they must be replaced, regardless of size.
Finger or limb entrapments are real dangers in older drain covers. We have removed drain covers that appear safe but discovered the grate bars slide on the cross members. This changes the spacing between the bars which could allow a finger or even a hand to be entrapped.
PSCM encourages public pool owners with large unblockable drains to replace them with approved drain covers.
*An existing drain cover can be individually tested to meet all the provisions of the ASME/ANSI A112.19.8-2008 and then be approved/sealed by a Licensed Professional Engineer.