The Virginia Graeme Baker Pool & Spa Safety Act (A112.19.8-2007) is now in effect. This is a new federal law that is designed to make pool drains safer. First off, it applies to all new drain covers sold -- commercial or residential. All approved covers will have "(ASME/ANSI A112.19.8-2007)" stamped on the exposed side of the cover. Secondly, the law also has more stringent criteria for commercial pools (this includes apartment, condominum, and home owner association pools). Basically the law requires some sort of back up safety device called a Safety Vacuum Release System (SVRS).

This back up device can be either a large "unblockable" drain, a second drain three feet or more away from the first drain, or it can be a SVRS device that senses a possible entrapment and either shuts off the pump or vents the suction line. There are several of these add-on SVRS devices. The Hayward Stratum both momentarilly shuts off the pump and vents the suction line to eliminate any residual suction. The VacAlert vents the line until it is manually reset, but the pump stays on (this could cause the pump to run dry). The Stingil and the Intelliflo VS=SVRS both shut off the pump if they sense an entrapment possibility.

There is much confusion regarding local implementation of this law. Local health and building departments have much latitude here. Be sure to contact them before making any expensive changes. Some localities such as Los Angeles County require you to drain the pool, so that they can inspect the cover and drain to make sure that it is compliant. Several proactive companies hired scuba divers to replace covers. These pools may now need to be drained and inspected.

Be sure to ask about inspection fees too. There is currently very little money dedicated to enforcement and localities are paying for it out of the inspection fees they charge.

Since enforcement will likely be hit and miss, much of compliance is left up to the property management company. Just as companies buy insurance to protect themselves against liability, an SVRS is also good liability insurance. The loss of a life in a pool that lacks this extra layer of protection would be disasterous in terms of the human loss and it could mean financial ruin for the property management companies and owners who are responsible.

SCE rebate form

Here is a link for Southern California Edison's two-speed and variable-speed pump rebates: http://www.sce.com/NR/rdonlyres/61A34CB4-441C-47BC-8994-A5350C20BD6A/0/2008_HEERApplication.pdf

Controversy over Title 20 and 3/4 hp pumps

The Independent Pool and Spa Service Association (IPSA) studied the effect of Title 20 on the use of 3/4 hp pumps. IPSA argues that this intermediate size of pump remains a practical and energy efficient option, and, as a result, should be exempt from the two-speed requirement.

Given IPSA's reluctance to embrace Title 20, their findings must be viewed with some suspicion. Nevertheless, the study makes an interesting and reasonable sounding claim. Theirs is a point that deserves further consideration and an independent study.

IPSA's study and conclusions can be found here: http://www.energy.ca.gov/appliances/2008rulemaking/2008-AAER-1B/public_comments/Residential_Pool_Pumps_and_Portable_Electric_Spas/IPSSA_Residential_Pool_Pump_Measure_Revision_TN-47889.PDF

Title 20 comments and replies

The May 15, 2008 California Energy Commission Energy Efficiency workshop solicited comments from those working in the pool industry. Here is a summary of comments and replies compiled by PG&E.

http://www.energy.ca.gov/appliances/2008rulemaking/documents/2008-05-15_workshop/comments/PGE_Response_to_Comments_regarding_Pool_Pumps.pdf

Link to proposed revisions

Here is a link to the proposed Title 20 revisions on the CEC website: http://www.energy.ca.gov/appliances/2008rulemaking/documents/2008-05-15_workshop/other/PGE_Proposal_Informaiton_Template_for_Residential_Pool_Pump_Measure_Revisions.pdf

Proposed revisions to Title 20

At a May 15, 2008 California Energy Commission (CEC) workshop, representatives of Pacific Gas and Electric Company (PG&E) proposed some revisions the the wording of Title 20 as it applies to residential pool filtration pumps. The intent of these revisions is to clarify, given the benefit of multiple interpretations, the original motive behind the drafting of Title 20.



First, the PG&E team proposes that the wording be changed so that Title 20 explicitly includes replacement motors (as well as entire pumps). In my reading, the current wording already makes this clear, but some have argued that the wording is ambiguous.



Second, the PG&E proposal recognizes that the current two speed timer requirement is, in retrospect, misguided. As the proposed revisions make clear, a two speed timer should only be required when a two speed pump is used. The revisions acknowledge that there are approved cases where a two speed pump, and hence a two speed controler would not be used. For instance, a small single speed pump (of less than 1 hp) would require a timer capable of operating only the one speed pump that it is used with. Additionally, some pools can use multi-speed pumps. These pumps require a compatible multi speed capable controller. The proposed revisions reflect this real world nuance.



I applaud the proposed revisions. I believe that the clarification they would provide would prove useful in getting more contractors and homeowners to follow what I believe is best practice and conform to the intent of the law.