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Question and Answers about Wisconsin
implementation of federal swimming pool anti-entrapment rules resulting
from the Virginia Graeme Baker Act 1. What is the "Virginia Graeme Baker Act?" Seven-year-old Virginia Graeme Baker, granddaughter of former federal Secretary of State James Baker, drowned by entrapment in 2002, pinned under water by the suction force at the drain of a hot tub. The 2007 federal law called the "Virginia Graeme Baker Act' (VGBA) requires protection from suction entrapment. The Consumer Product Safety Commission (CPSC) created rules that go into effect on December 19, 2008, that mandate certain standards for swimming pool or water attraction circulation systems. You can read part of the rule requirements below*. 2. What swimming pools and persons in Wisconsin must comply with the Virginia Graeme Baker Act? The CPSC rules apply to all public pools and pool grate manufacturers, pool maintenance persons, pool manufacturers and pool equipment retailers in the United States. All grates replaced in all pools, public and private, after December 19, 2008 must be listed to comply with the ASME/ANSI A112.19.8-2007. In addition, the rules require public pool owners to install the VGBA-compliant grates or covers in place of existing covers or grates. Only public pools are required by the act to have additional suction entrapment prevention methods included in the pool construction or devices installed in the circulation system. Some existing public swimming pools or water attractions in Wisconsin may only need to modify the pool by changing all of the suction outlet covers and grates. The Department of Commerce, Safety and Buildings Division (S&B), has jurisdiction over public swimming pool and water attraction construction standards. S&B is involved in the alteration of existing pools and does plan review and inspection for modifications of existing pools. Suction outlet grate and cover replacements and additional modifications to comply with VGBA are modifications to an existing public swimming pool or water attraction and require review. Comm 90, Design and Construction of Public Swimming Pools and Water Attractions, PDF file, contains the requirements for the construction of public swimming pools and water attractions. 2A. Is it possible for the Department of Commerce to give me an extension for compliance? No, only the CPSC has the ability to give additional time to comply with their rule. 3. What type of suction outlets exist in the Comm 90 code? The outlets types are: main drains, equalizer outlets serving skimmers, suction outlets (wall or floor), feature pump outlets, and water agitation suction outlets. 4. Do suction outlets in all pools need new grates or covers? Yes, according to federal rules unless a Wisconsin licensed engineer or architect provides documentation to S&B that existing drain covers/grates and sumps comply with the ASME/ANSI standard. 5. Must suction grates that are inaccessible to patrons be modified to comply with VGBA? No, if the suction grates are permanently installed to prohibit any contact with pool patrons, modifications are not necessary. F. Do all of the suction outlet covers or grates in a pool need to meet the ASME/ANSI standard? Yes, all suction outlet grates or covers installed in pools and water attractions must meet the ASME/ANSI standard. Manufactured grates and covers must be listed by a nationally-recognized listing agency to meet the ASME/ANSI A112.19.8-2007 standard (the version adopted by the Comm 90 2009 code). National agencies at this time that are listing grates include International Association of Plumbing and Mechanical Officials (IAPMO) and National Sanitation Foundation (NSF). The CPSC has an online list of manufacturers of compliant grates or covers. http://www.cpsc.gov/BUSINFO/draincman.html#drain The ASME/ANSI standard provides for the option of a “Registered Design Professional” to design the suction outlet (grate and sump). If a Wisconsin licensed engineer or architect designs a sump and cover or grate, the design professional must fully address the considerations in the standard, including: • 1.5 ft/sec of flow through the open area of the cover/grate • Unblockable configuration of the grate • Cover/grate loadings • Durability • Hair, finger and limb entrapment issues • Cover/grate secondary layer of protection related to sump design • Features particular to the site • Wisconsin Comm 90 code requirements 6. How do I recognize a compliant grate/cover? Except for those suction outlets designed by a Wisconsin licensed engineer or architect, only grates listed by a nationally recognized agency may be used. The ASME/ANSI standard requires that each listed grate or cover be stamped with the following information: • The usage of the grate - “For Single or Multiple Drain Use,” “For Single Drain Use,” or “For Multiple Drain Use Only” • The maximum flow rate • The type of fitting - “Venturi Outlet,” “Swim Jet Combination Fitting” or “Submerged Suction Outlet” • The lifetime of the fitting - “Life: ___ Years” • Installation location - “Wall Only,” “Floor Only,” or “Wall or Floor” • Manufacturer’s name or registered trademark • Model designation The CPSC recently has issued a determination that each grate be stamped “VGB 2008”. 7. What does Comm 90 require for main drains? The new 2009 code requires a main drain for the pool, but it does not require that main drain function. In other words, reverse flow pools without a functioning main drain are currently permitted in the code. See Comm 90.11(6)(a) for the requirements for main drains. For public swimming pools, a single main drain is code compliant; for water attractions unblockable drains are necessary in the 2008 version of the code. The new 2009 code will require that all basins are provided with a suction outlet in the lowest point of the basin the floor or the wall. This means that a main drain outlet is required for all pools; however a drain with a modulating valve would be considered a suction outlet in this situation. See the revised 2009 Comm 90.14(13)(c)1.a. See the alternate pool approval on the S&B WebSite for additional options for pools licensed by the Department of Health Services prior to December 19, 2008. 8. What about projects currently under construction? If a public swimming pool or water attraction project has not been licensed by the Wisconsin Department of Health Services and has not undergone the final inspection by S&B staff, a revision to the previously-approved plan may be submitted to S&B for review. 9. What code requirements are impacted by the Virginia Graeme Baker Act? The 2009 Comm 90 has requirements for: • 1.5 ft/second maximum velocity through suction grates. • 1.5 pipe diameters minimum from the bottom of the suction grate to the suction outlet pipe opening(s). • All equipment within the scope of NSF 50 must be listed by an acceptable listing agency to meet ANSI/NSF 50 or equivalent • Two main drains or one main drain with length or width of at least 36 inches is required for every basin of water. • Comm 90 has adopted the ASME/ANSI A112.19.8 standard and installations must comply with this standard and all Comm 90 requirements. 10. When making changes to comply with the Virginia Graeme Baker Act, what parts of the pool need to be reconstructed or remodeled to comply with the 2009 version of Comm 90*? *See the alternate pool approval or any published alternate grate product approvals for more options for existing pools. Grate Replacements If one of the following conditions (1 or 2) are met, the grate is deemed in compliance with VGBA: 1. a. The grate is listed by a nationally-recognized testing agency as complying with ANSI/ASME A112.19.8. b. The calculated peak flow rate of the circulation system must be less than the acceptable flow rate of the grate. c. The grate must be installed in accordance with the manufacturer’s recommendations. 2. A Wisconsin licensed engineer or architect designs the suction outlet (grate and sump combination) to comply with the ASME/ANSI standard and the Wisconsin Administrative Code. 3. Option for gravity drains, only. a. The grate is listed. b. The calculated velocity through the grate is 1.5 fps or less. The rate is calculated using the difference in elevation from the activating level of the modulating valve (or the design operational level where there is no modulating valve) to the gutter weir level. The pool designer must provide calculations indicating that the grate is capable of the flow rate at a maximum of 1.5 ft per second and certify that the distance from the grate to the pipe complies with the code requirement. Sump modification If a sump is modified, the separation distances between suction grates and distance from bottom of grate to top of suction pipe must comply with the current Comm 90. If no piping is being replaced downstream of the sump, no further system modification is required to comply with Comm 90. VGBA does require that one of the options for blockable drains be utilized. 11. When is Safety and Buildings Division pool plan review and approval required prior to installation? Plan review is required for any modification to a pool that’s being modified to comply with the VGBA Any new construction, modification or alteration of an existing pool necessitates the review and approval by S&B. This requirement is found in Chapter 145 of the Wisconsin Statutes. 12. How will department plan review be conducted for modifications involving the Virginia Graeme Baker Act? For plan submittal involving VGBA modifications, the submitter has two options. Option One. The first option is to submit the plan via the current plan review appointment process. This is done by mailing plans in or faxing the application to the office and an appointment will be made. The plans must be in the office at least two days prior to the appointment date. This process must be used when the plan involves modifications to the pool in addition to the VGBA. Option Two. The second option is a more expedited process and can be used for modifications to the pool when only involving the VGBA. There will be no appointment made for these types of reviews. This method of review will be available only until December. 31, 2009. This process will work as follows: A. A complete application (SBD-9808), plans, calculations, etc., are faxed from the to the S&B plan review office. The fax number is 877-840-9172. All plans and accompanying information, must be on 8.5 inch by 11 inch paper. The faxed drawings must bear the engineer/architect sealing stamp and signature. B. The submitting engineer/architect will be invoiced for the plan review fee. The plan review fee applies to all plans regardless of outcome. C. S&B will enter the information into their database and the reviews will be processed on a first-come first-serve basis. D. If approval is granted, an approval letter will be faxed back to the submitting party at which time the installation may commence. The appropriate inspector will be emailed that the project has been approved. E. The supervising professional is responsible to contact the appropriate inspector when the installation is in the rough-in stage (if the pool shell is being disturbed) and at the final stage for inspection. F. Modifications to existing pools that include only VGBA-required changes should be submitted to the La Crosse office: La Crosse reviewers are Jerry Swim, 608-789-7892; Charles Bratz, 608-789-7893; and Doug Erler, 608-789-4690. You may also contact Glen Jones in Madison, 608-267-5265, if unable to reach any of those three. For the expedited method of review, it will not be necessary for the designer to submit original stamped drawings to the division after approval has been granted. 13. What is the cost of plan review for these modifications? The plan review and inspection fees for public swimming pools are shown in Comm 2.68. Most plans will have the following fees: $750 when S&B performs the plan review and inspections. Where the S&B does not perform the inspections, the S&B fee for review is $300. Inspection includes one rough-in inspection and one final inspection. (Important - See Question 14.) There are contracted inspectors in some areas of Wisconsin who charge for rough-in and final inspections. See this map to identify the inspector in the location of the pool. 14. Will a rough-in and a final inspection be required? Two inspections may not be necessary in all installations. Where S&B is performing inspections, when a successful final inspection is completed as a first inspection, S&B will refund the cost of one inspection ($150). 15. If the circulation rate/turnover time is not compliant with the current version of Comm 90, do I need to change the circulation rate/turnover time? No, if no piping is being replaced. No, if the only piping being installed is within the existing sump. No, if the only piping replaced is the piping installed to add a second main drain. Yes, if more modification is proposed that replaces more than 10 feet of the circulation piping serving a pool. Yes, if the pool was installed after April 1, 1994 without departmental approval. 16. Does newly installed piping or equipment need to be sized so as to be compliant with the current Comm 90? Yes, whatever piping or equipment is installed must comply with the current code. 17. As a Wisconsin licensed engineer or architect, may I certify that a separation distance from the bottom of the grate to the outlet pipe opening is acceptable even though it is less than the code requirement of 1.5 pipe diameters? No. The code requires the 1.5 pipe diameters from the bottom of the grate to the top of the suction outlet pipe opening.* *See the answer concerning grates or covers and alternate product approvals and the VGBA alternate pool approval for more options. 18. May a flow meter reading be used to document the flow rate of a system? Yes. A functioning flow meter that is installed in accordance with the manufacturer’s recommendations may be used to document flow rate in an existing system. An inspector may require the flow meter to be cleaned in order to substantiate an existing flow meter reading. 19. In gravity drainage systems, if a grate is replaced, does additional modification to the gravity drain sumps need to be performed to comply with VGBA? Sometimes. The design engineer must make this determination taking the manufacturer’s installation instructions, velocity through the grate and the configuration of the existing sump into account. See question #10. *For this question, existing pools are defined as pools licensed prior to the 2009 code implementation date and water attractions licensed prior to February 1, 2005. 20. If a grate is replaced in a gravity system, does the grate replacement need to comply with the manufacturer’s recommendations in regards to separation from the suction outlet pipe to the bottom of the grate? Yes, all grate installations must comply with the manufacturer’s recommendations. 21. What are the conditions where the suction outlet separation must be made compliant with the 2009 Comm 90 code?* When the shell of the pool or water attraction is being disturbed or excavated. *See the alternate pool approval for more options for existing pools. 22. Are there requirements for the distance from the sump structure to the openings in the suction pipe? The installation of all suction pipe openings should allow the free flow of water. 23. May a main drain suction outlet be abandoned in order to comply with the Virginia Graeme Baker Act? No, the 2009 code requires a suction outlet in the lowest point of the wall or floor. (If the pool designer submits an alternate pool or petition for variance, each submission will be considered on specific site conditions.) 24. May the equalizer pipes be eliminated in a basin in order to comply with the Virginia Graeme Baker Act? Except as permitted in the alternate pool approval, no, the NSF 50 standard requires that equalizer pipes be installed to serve skimmers. S&B has approved an alternate pool where the skimmer equalizer pipes could be abandoned. *See the alternate pool approval for more options for existing pools. 25. Do Splash Pads (Interactive Play Attractions) need to comply with the Virginia Graeme Baker Act? No, splash pads have no standing water and are served by gravity systems. 26. What circulation system conditions are used in determining the flow through grates or covers? Flow through the grates is dependent on the open area of the grate and the capacity of the pump and piping system. The working capacity of the pump is based on the design of the pump and the calculated total dynamic head of the system. The following information for determining total dynamic head must be included in plan submittals for VGBA compliance: Total dynamic head (TDH) is determined with: A. The pump curve B. The elevation difference between the pump and the basin’s water elevation C. Friction loss through permanently-affixed fittings and pipe Permanently-affixed includes inlet eyeball fittings that are anchored to the pool, but not those that are removable without tools. Permanently-affixed also includes weir plates or other immovable flow restrictors. D. Friction loss through any clean filtration devices or heating equipment. 27. May a Wisconsin licensed engineer or architect verify the flow through the cover or grate without providing the pump curve and TDH calculations? Yes, the engineer or architect may provide other documentation for peak flow calculations. 28. May valve settings be included in the TDH calculation? If a valve has a friction loss based on a permanent setting, it may be included in the calculation. If the valve’s setting may be changed by the owner or pool operator it may not be included in the calculations. 29. How high may drain covers protrude from the floor of a public swimming pool or water attraction? The ANSI/ASME standard permits the cover/grate to extend to a height of two inches. The drain covers in shallow water (less than 32 inches of depth) must be installed so that the covers do not pose a tripping hazard. This may be accomplished by installing a compliant cover that does not protrude into the basin (less than ½ inch), installing a play feature to prohibit foot path over the grate or installing a grate that is flush with the floor. 30. Q&A removed 31. Does a drain that’s only used for draining a pool need to comply with the Virginia Graeme Baker Act? No. 32. Where a single main drain has a hydrostatic relief valve, can a Safety Vacuum Relief System (SVRS) be installed as an alternative to installing a second main drain? If yes, is there any restriction if a hydrostatic relief is installed? The ASME A112.19.17-2002 standard states that the SVRS can’t be used with a hydrostatic relief valve. The ASTM standard for SVRS doesn’t mention hydrostatic relief valves. The CPSC advice is that the SVRS manufacturer’s instructions be followed and any restrictions on use should be acknowledged by the manufacturer. Plans submitted, that intend to use the SVRS in a system with a hydrostatic relief valve must be accompanied by the manufacturer’s installation instructions that specify that the use of the SVRS is compatible with a hydrostatic valve. 33. A hot tub has two main drains allocated on two planes. They are located with less than 3 feet separation. Does a two plane main drain configuration meet the definition of an unblockable drain for the CPSC? The CPSC determination is: Locating outlets on different planes is acceptable proving the outlets (or foot well) cannot be simultaneously blocked. 34. Can an approved cover/grate be installed over a sump that is smaller than is the sump depicted on the manufacturer’s installation instructions? The CPSC states that the cover manufacture should be consulted. The installation instructions must include instructions and/or sump requirements. 35. In recirculation systems where the filters have multiport valves which could allow the system to be used bypassing the filters, does the filter need to be bypassed to calculate the peak flow rate? The CPSC response is: Yes, the maximum flow rate of the circulation system should be used to determine the flow rating for the outlet cover(s) needed which would include removal of all restrictions (including the filter). 36. When measuring the minimum distance of one and a half pipe diameters from the top of the pipe to the bottom of the grate on a sump where the grate is domed, can the highest point of the domed portion be used in the calculation? No. The measurement should be at the point of the suction pipe outlet to the bottom of the grate directly above the suction pipe. 37. May a design submitted to the department include options for different grate/sump configurations? Yes, modification plans for a pool having only one drain system may include a maximum of three design options for the grate/sump system. Examples include: - Grate change only - Grate change with diverter plate in sump - Grate change with piping changes in sump - Grate change with new sump However, modification plans for a pool having multiple drain systems (e.g. recirculation drain plus feature drain systems) are allowed only one design option per suction outlet (sump and grate combination). 38. What grate capacities are required when the sump is existing and will not be replaced? The maximum flow rate that can be produced by the pump/system may not exceed the manufacturer’s rated flow rate for the grate. If the grate meets the pump/system maximum flow rate, flow velocity is not a consideration. 39. On existing pools, when a sump is replaced, does the grate need to be designed for a flow velocity of 1.5 feet per second? Yes. The grate must be capable of passing the circulation flow at a velocity that doesn’t exceed 1.5 feet per second. The grate may exceed the 1.5 feet per second for the system maximum flow rate, but may not exceed the manufacturer’s velocity rating for the grate. Note: This document is made available for Wisconsin Public Swimming Pool and Water Attraction owners and designers as the current understanding of the federal Consumer Product Safety Commission rules. Further clarification and interpretations will be made available as necessary. More information is available from the Consumer Product Safety Commission’s publication. The CPSC has a Question & Answer site: http://www.aquaticsintl.com/poolsafety/08safety_faq.html *Part of the CPSC rule requirements read: “Section 1404, Part (b) DRAIN COVER STANDARD. -Effective 1 year after the date of enactment of this title, each swimming pool or spa drain cover manufactured, distributed or entered into commerce in the United States shall conform to the entrapment protection standards of the ASME/ANSI A112.19.8 performance standard, or any successor standard regulating such swimming pool or drain cover.” And for public pools: “Section 1404, Part (c) PUBLIC POOLS – (1) REQUIRED EQUIPMENT (A) IN GENERAL – Beginning 1 year after the date of enactment of this title – (i) each public pool and spa in the United States shall be equipped with anti-entrapment devices or systems that comply with the ASME/ANSI A112.19.8 performance standard, or any successor standard; and (ii) each public pool and spa in the United States with a single main drain other than an unblockable drain shall be equipped, at a minimum, with 1 or more of the following devices or systems designed to prevent entrapment by pool or spa drains that meets the requirements of subparagraph (B):” (I) SAFETY VACUUM RELEASE SYSTEM (II) SUCTION-LIMITING VENT SYSTEM (III) GRAVITY DRAINAGE SYSTEM (IV) AUTOMATIC PUMP SHUT-OFF SYSTEM (V) DRAIN DISABLEMENT (VI) OTHER SYSTEMS (as determined by the CPSC) “(B) APPLICABLE STANDARDS. – Any device or system described in subparagraph (A)(ii) shall meet the requirements of any ASME/ANSI or ASTM performance standard if there is such a standard for such a device or system, or any applicable consumer product safety standard.” County Web sites || City/Town/Village Web sites || State Portal || Build Your Business Email this page's manager, Todd Taylor, ttaylor@commerce.state.wi.us or 608-267-3606 The Department of Commerce Safety and Buildings Division is an equal opportunity service provider and employer. If you need assistance to access services or need material in an alternate format, please contact us, 608-266-3151, TDD Relay dial 711 in Wisconsin or 800-947-3529, or ttaylor@commerce.state.wi.us |
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