FAQs

For more information about pool and spa safety and the Virginia Graeme Baker Pool & Spa Safety Act, read our Frequently Asked Questions (FAQs).

FAQs image

These FAQs are unofficial descriptions and interpretations of various features of the Virginia Graeme Baker Pool & Spa Safety Act (P&SS Act). They are presented by topic and cover pool and spa safety issues and the P&SS Act.

The FAQs were prepared by CPSC staff, have not been reviewed or approved by, and may not necessarily reflect the views of, the Commission and may be subject to change by the Commission.

Sections

* For the purpose of these FAQs and in order to be consistent with the latest industry terminology, the word “drain” has been updated with the term “suction outlet.” Therefore, suction outlet cover, drain cover and grate are synonymous.

General Compliance

Suction Outlet Covers/Drain Covers/Grates

Unblockable Suction Outlets or Drains

Secondary or Backup Systems or Devices

A pool owner installed an emergency shut-off switch for an indoor pool which is gravity fed. The existing covers are 18″ x 18″ with a 24″ diagonal. Would new suction outlet covers be required?

Sumps

Flow Rates

Other Features

Recalls

What are the details of the May 26, 2011 recall of drain or suction outlet covers ?

General Compliance

What are public pool and spa owners/operators obligated to do to comply with the Virginia Graeme Baker Pool & Spa Safety Act?
As of December 19, 2008, all operating public pools and spas must have suction outlet covers that meet the ANSI/ASME A112.19.8 (2007) standard or any successor standard on every suction outlet. On July 27, 2011, the Commission unanimously approved ANSI/APSP 16-2011 as the successor suction outlet cover standard which pool operators need to follow to comply with the P&SS Act. In addition, if the pool has a single main drain or suction outlet (other than an unblockable suction outlet), the operator must install a second anti-entrapment device or system, which can be an automatic pump shut-off system, gravity drainage system, Safety Vacuum Release System (SVRS) or a suction-limiting vent system; or the operator can disable the drain taking into consideration the pool’s filtration system and the regulations within the particular jurisdiction.

A pool may have more than one suction outlet, but multiple suction outlets are not a requirement of the law. If a pool has dual or multiple suction outlets (per pump) that are separated by at least three feet, or located on different planes, it may be exempt from the secondary backup device or system requirement.

An unblockable suction outlet is defined in the P&SS Act as “a drain of any size and shape that a human body cannot sufficiently block to create a suction entrapment hazard.”

Last updated: January 2012
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Where can I find CPSC’s interpretation of the law?
CPSC staff has issued technical and legal interpretations for Section 1404 of the P&SS Act, which applies to all public pools and spas in the U.S. and its territories. The Act and related documents are available on CPSC’s Pool Safely website: www.poolsafely.gov/pool-spa-safety-act/; Staff Interpretations and Guidelines can be found here: www.poolsafely.gov/pool-spa-safety-act/interpretations-guidelines/.

Last updated: January 2012
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Which types of pools and spas pose the greatest danger of entrapment and evisceration to consumers?
Pools designed specifically for young children, such as shallow wading/kiddie pools, with easily accessible suction outlets; in-ground spas that have flat suction outlet grates; and single suction outlet systems.

Last updated: January 2012
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What should I do if my state or county department of health does not allow me to disable my suction outlets or use a particular suction outlet cover?
Affected pool and spa owners/operators need to be in compliance with the federal safety requirements. If you believe that state or local laws make it impossible for you to comply with the federal law, please contact CPSC for guidance at PoolSafely@cpsc.gov.

Last updated: January 2009
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Who qualifies as a “trained or certified professional”?
CPSC staff recommends contacting state or local officials to determine who is qualified in your area. Experts, such as a professional engineer (PE) or similar registered design professional (RDP), should be formally licensed or certified as a business and carry some level of insurance or similar protection.

Last updated: January 2009
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Who can enforce the Act?
The Consumer Product Safety Commission and State Attorneys General are empowered to enforce the P&SS Act.

Last updated: January 2009
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Suction Outlet Covers/Drain Covers/Grates

What is the approved standard for all pool and spa suction outlet covers?
The P&SS Act requires each swimming pool or spa suction outlet cover manufactured, distributed, or entered into commerce in the United States and its territories to conform to the ANSI/ASME A112.19.8 performance standard, or a successor standard approved by the Commission.

In July 2011, the Commission voted unanimously to approve ANSI/APSP-16 2011 as the successor standard to the ANSI/ASME A112.19.8 (2007) suction outlet cover standard mandated by the P&SS Act. The Commission determined the new standard, ANSI/APSP-16 2011, was in the public interest, and incorporated this standard into its regulations. Effective September 6, 2011, suction outlet covers manufactured, distributed, or entered into commerce in the U.S. and its territories must conform to the requirements of ANSI/APSP-16 2011. Note that ANSI/APSP-16 2011 is virtually identical to ANSI/ASME A112.19.8 and its two addenda.

Last updated: January 2012
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What is the definition of an “unblockable drain”? What is CPSC’s ruling on the interpretation of an unblockable drain or suction outlet?
The P&SS Act defines an “unblockable drain” as “a drain of any size and shape that a human body cannot sufficiently block to create a suction entrapment hazard.”

In April 2010, the Commission issued a rule regarding the interpretation of an unblockable drain (or suction outlet) which had permitted a drain cover of certain specifications to be used to convert a blockable suction outlet into an unblockable suction outlet. In September 2011, the Commission revoked the April 2010 interpretation of an unblockable drain. As a result of the revocation, an unblockable suction outlet cover can no longer be used to convert a blockable suction outlet to an unblockable suction outlet. A single suction outlet of a blockable size must be equipped with a secondary anti-entrapment device or system.

Public pool or spa operators who had an unblockable sized drain cover installed over a blockable sized drain/suction outlet do not need to remove or replace the cover. Operators will need to add one of the approved secondary anti-entrapment devices or systems to be in compliance with the current interpretation.

The Commission has set a compliance date of May 28, 2012, to allow time for firms that require modifications as a result of this revocation to bring their pools and spas into compliance with the statute as written. The Commission invites written comments regarding the ability of those who have installed compliant unblockable drain covers as described in 16 CFR 1450.2(b) to come into compliance by May 28, 2012. Comments will be reviewed by the Commission in order to determine whether or not to change the current compliance date of May 28, 2012. To view the Federal Register notice, see: http://www.cpsc.gov/businfo/frnotices/fr12/vgbunblockable.pdf

Last updated: January 2012
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What is the proper marking on a compliant suction outlet cover?
Suction outlet covers made during the summer of 2008 were marked with the ASME symbol and/or with “ASME/ANSI A112.19.8 (2007).” During the late summer and early fall of 2008, no specific marking was placed on suction outlet covers manufactured in compliance with the standard. Many suction outlet covers manufactured since November 12, 2008, have a “VGB 2008″ marking.

The minimum marking requirements for suction outlet covers have not changed in the successor standard. Covers should indicate:
Type of Use (single or multiple suction outlet)
GPM (gallons per minute)
Type of Fitting
Fitting Life
Wall or Floor Mounting
Model Name/Number

You should ensure that you are using certified suction outlet covers. If there is no mark or you are otherwise in doubt, contact the manufacturer and ask for a copy of the Certificate of Compliance. Also keep a record of where and when you purchased the suction outlet cover.

Last updated: January 2012
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Who is approving new suction outlet cover designs?
Third-party testing and certification is being conducted by Underwriters Laboratories (UL), the National Sanitation Foundation International (NSF) and the International Association of Plumbing and Mechanical Officials Testing and Services, LLC d/b/a IAPMO R&T Lab (IAPMO).

Last updated: January 2009
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Are maintenance drains or suction outlets subject to the Virginia Graeme Baker Pool & Spa Safety Act?
Yes. Suction outlets that are opened only during maintenance and used to empty the pool are still considered submerged suction outlets. These types of suction outlets require a Virginia Graeme Baker Pool & Spa Safety Act compliant suction outlet cover, but they do not require a secondary anti-entrapment backup system. Maintenance suction outlets are not to be in use when swimmers are in the pool.

Last updated: June 2010
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How do I determine if my pool has multiple suction outlets?
Multiple suction outlets consist of, at a minimum, two fully-submerged suction outlets per pump per pool, with suction outlet cover/grate centers at least three feet apart (measured center to center), or located on different planes. While no maximum separation length is noted in the P&SS Act, the connections between the outlets and the pump are important for proper operation. The connections should be certified by a Registered Design Professional and inspected by a licensed inspector to ensure hydraulic balance between the outlets and the main suction line to the pump.

Note: Some systems may not be hydraulically balanced and others may include multiple suction outlets on a pump that is used for more than one pool. It is highly recommended that a professional engineer or egistered design professional be consulted on the design/certification of any multiple suction outlet system.

Last updated: June 2010
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Are equalizer lines in public pools subject to the Virginia Graeme Baker Pool & Spa Safety Act?
Yes. Skimmer equalizer lines are submerged suction outlets and must either be covered with a compliant suction outlet cover or plugged. CPSC staff does not consider equalizer lines to be main drains. The intended function is not as a drain but rather to prevent air from entering the suction line if the water level in the pool falls below the skimmer opening. With proper maintenance (maintaining water level and clearing baskets), an equalizer line does not present the hazard addressed by the P&SS Act. Existing equalizer lines do not need to be split.

Last updated: June 2010
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Is a skimmer with or without an equalizer considered a suction outlet for purposes of determining a cover’s capacity to handle the pump system flow?
No. The skimmer is intended to clog. The equalizer, if present, operates only when the skimmer is not functioning, so CPSC staff does not consider it as part of a “multiple suction outlet system.” Since there are so many different ways to consider/set the system from a percentage of flow point of view (% main suction outlet + % skimmer), CPSC staff considers ‘system flow’ to be flow through the suction outlet (s) only.

Any additional suction outlets (such as skimmers) add some safety factor as they take some of the flow and thus reduce the flow required at the other suction outlet(s). If the skimmers become inoperable, the system is still protected by having appropriately rated suction outlet covers in place. If the scenario should be reversed (main suction outlet(s) inoperable), it is not significant since the skimmers should handle some of the flow and they do not present the same hazard as submerged suction outlets.

Last updated: June 2010
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My indoor public pool has two suction outlets about 18 inches apart. Do I still need to install new suction outlet covers?
Yes, all suction outlet covers in public pools or spas must be compliant with the ANSI/ASME A112.19.8 (2007) standard or the new successor standard, ANSI/APSP-16 2011. If they are not located on separate planes, a second anti-entrapment system will be needed since the suction outlets are less than three feet apart, as measured from the center of each suction outlet.

Last updated: January 2012
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Do inaccessible suction outlets require Virginia Graeme Baker Pool & Spa Safety Act compliant covers?
No. Suction outlets that are not readily accessed by the swimming public (i.e., collector tanks, surge tanks) are not subject to the P&SS Act.

Last updated: June 2010
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If I have a gravity drain outlet system, am I required to have a Virginia Graeme Baker Pool & Spa Safety Act compliant suction outlet cover?
Yes. However, pools with gravity suction outlet systems are not required to have a second anti-entrapment system, so ensuring that the existing suction outlet covers are compliant with the ASME/ANSI A112.19.8-2007 standard or ANSI/APSP-16 2011 standard, or replacing them with compliant suction outlet covers, is all that is required.

Last updated: January 2009
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My public spa has three or four suction outlet covers, all in a small foot well. What do I need to do to comply?
The suction outlet cover requirement of the P&SS Act applies to these types of public spas. They should have compliant suction outlet covers and a second anti-entrapment system if the suction outlets are less than three feet apart as measured from the center of each suction outlet and are not located on different planes.

Last updated: June 2010
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What should I do if my pool’s suction outlet requires a field-fabricated suction outlet cover but none is available? (For example, a pool with a single L-shaped suction outlet that is half on the pool bottom and half on the wall.)
Certain suction outlets will require a field-fabricated cover. Pool owners/operators should either find a manufacturer who will build a custom-made compliant suction outlet cover or the pool should be re-built to have dual suction outlets.

Last updated: November 2011
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I have a field-fabricated, unblockable suction outlet cover that I believe meets the required standard. Am I required to order a new cover?
No. A field-fabricated suction outlet cover may continue to be used where it is installed over a similarly sized sump and a professional engineer (PE) certifies that it meets the requirements of the ANSI/ASME A112.19.8 (2007) standard or the new successor standard, ANSI/APSP-16 2011. This certification should include flow rates, UV exposure, and durability. The PE must document that the suction outlet cover meets the requirements of the standard and provide a copy of the certificate of compliance to the pool owner/operator.

Last updated: January 2012
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What should I do if a suction outlet cover/grate is loose or missing?
If the cover/grate is loose or missing from the suction outlet, then the pool must be closed immediately.

Last updated: January 2012
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What should I do if just a screw is missing from my cover/grate?
Unless the cover/grate was certified to be compliant with the screw missing, then the pool must be closed immediately until the cover/grate is repaired. All of the components that were present when the flow rating for the cover/grate was determined must be present and functioning in order for the cover/grate to be in compliance with the Act.

Last updated: January 2012
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Unblockable Suction Outlets or Drains

See Question 8 for a definition of unblockable drain cover and CPSC’smost recent interpretation of an unblockable drain cover.

Last updated: January 2012
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Who is affected by the revocation?
A facility subject to the P&SS Act that used a large, unblockable cover/grate over a single blockable suction outlet will now need to have a secondary system installed in order to be in compliance with the law. In other words, a facility with a large unblockable cover installed over a smaller blockable suction outlet must install a secondary or backup anti-entrapment system to be compliant with the P&SS Act.

Last updated: January 2012
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What if my facility uses a single, unblockable cover over an equally large suction outlet?
Your facility is not affected by the revocation.

Last updated: January 2012
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What if my facility uses a multiple suction outlet system and incorporates an unblockable cover over smaller suction outlets?
Facilities with multiple suction outlets per pump, with covers/grates at least three feet apart as measured center to center, are not affected by the revocation. The revocation affects pools and/or spas with multiple outlets that are less than three feet apart from center to center, or those with single suction outlets or single main drains.

Last updated: January 2012
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Does this revocation have an effect on smaller suction outlet cover/grates?
Suction outlet covers/grates that were not labeled or sold as unblockable are not affected in any way.

Last updated: January 2012
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Do covers affected by the revocation have to be removed or replaced?
No. Retrofited unblockable suction outlet covers do not need to be removed from facilities that installed them on small single suction outlets as a result of the revocation. However, pools and spas that have a single suction outlet where a large, unblockable cover/grate was placed over a smaller suction outlet must now install one of the recognized secondary anti-entrapment systems or devices. The Commission decision simply reverts back to the statutory requirement that directs pool and spa operators to add a secondary anti-entrapment system or device under these conditions.

Last updated: January 2012
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Secondary or Backup Systems or Devices

A pool owner installed an emergency shut-off switch for an indoor pool which is gravity fed. The existing covers are 18″ x 18″ with a 24″ diagonal. Would new suction outlet covers be required?
Anti-entrapment suction outlet covers compliant with the ASME/ANSI A112.19.8 (2007) or ANSI/APSP-16 2011 standards are required on all public pool and spa suction outlets, including gravity systems. A gravity suction outlet system qualifies as a secondary anti-entrapment system, so no additional system or backup is required.

Last updated: January 2011
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Sumps

What is CPSC’s position regarding sumps and the ASME/ANSI A112.19.8 (2007) or ANSI/APSP-16 2011 standard?
CPSC staff recognizes and supports the technical requirement of the ASME/ANSI A112.19.8 (2007) standard and its successor standard, ANSI/APSP-16 2011, which calls for field-built sumps to have the suction piping separated from the bottom of the cover by a distance equal to or greater than 1.5 times the diameter of the suction piping. However, the P&SS Act does not require pool owners/operators to replace their sump. In order to be compliant with ANSI/APSP-16 2011, a new compliant suction outlet cover must be safely secured onto a pre-existing sump. If a professional engineer (PE) determines that additional engineering work needs to be done to the sump to bring it into compliance with the standard and ensure a secure connection with a new cover, then that work should be carried out by a licensed professional. Finally, if a PE determines that a new suction outlet cover cannot be safely placed on a pre-existing sump, then the sump should be removed and replaced with a new, compliant sump that is compatible with the compliant suction outlet covers.

Last updated: January 2012
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If I need to modify my sump to accept a new replacement cover, do I need a professional engineer or a licensed professional to approve this new cover?
Yes, if the modification increases the flow/velocity through the rated suction outlet cover or it will substantially affect the sump structure. If the sump needs substantial modification to accept the new P&SS Act compliant cover, then this would be considered a “field fabricated” sump and would require either the approval of a professional engineer or registered design professional, or documentation from the cover manufacturer indicating that the flow rate and velocity through the cover are appropriate for the field modified sump.

Modifications that may affect the connection between the cover and the sump, such as re-drilling holes, which is allowed by the ASME/ANSI A112.19.8 (2007) and its successor ANSI/APSP 16-2011 standard under certain conditions, must follow cover and sump manufacturer procedures and recommendations. A registered design professional must certify the cover installation when modifications are required outside of those procedures.

Last updated: January 2012
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Flow Rates

How do I calculate flow for suction outlet covers in a multiple suction outlet system?
CPSC staff, consistent with the ASME/ANSI A112.19.8 (2007) and its successor standard, ANSI/APSP-16 2011, recommends using the multiple suction outlet calculation outlined below.

For multiple suction outlet systems, 100% system flow is maintained when each suction outlet cover is flow rated with any one suction outlet completely blocked. This is a packaging/instructional requirement of the ASME/ANSI A112.19.8 (2007) standard and its successor standard, ANSI/APSP-16 2011, and is also referenced in the ANSI/APSP-7 Entrapment Avoidance standard which was recently adopted into the International Code Council (“ICC”) building codes. Many states have adopted the International Building Code/International Residential Code (“IBC/IRC”). The Pool & Spa Safety Act (P&SS Act) requires compliance to the ASME/ANSI A112.19.8 (2007) and its successor standard ANSI/APSP-16 2011.

Accordingly, the following flow calculations should be treated as guidance from CPSC technical staff consistent with the packaging requirements of the ASME/ANSI or ANSI/APSP standards in order to further the goal of the P&SS Act to provide alternatives to single suction outlet systems and reduce the suction outlet entrapment hazard in pools and spas. Although not specifically referenced in the P&SS Act, building codes and industry standards provide important safety guidance that should be followed by the pool and spa industry.

The general concept to calculate flow for multiple suction outlets is to assume one suction outlet is blocked so the total flow through the remaining open suction outlet covers meets the system requirements. The total flow must also be hydraulically balanced, such that flow is distributed equally among the unblocked suction outlet covers.

Assuming one suction outlet is blocked, the ASME/ANSI A112.19.8 (2007)- or ANSI/APSP-16 2011 rated flow through each unblocked suction outlet cover is at least:

Two suction outlets (one blocked) = each suction outlet rated at total system flow

Three suction outlets (one blocked) = each suction outlet rated at 1/2 total system flow

Four suction outlets (one blocked) = each suction outlet rated at 1/3 total system flow

# of suction outlets (one blocked) = each suction outlet rated at total system flow/(# of open suction outlets)

For one suction outlet, the rating of the cover/grate must be equal to or greater than the maximum system flow. If it is blockable, an additional secondary anti-entrapment device or system is required to be installed. If the single suction outlet is an unblockable suction outlet as defined in the P&SS Act, no further action is required.

Consult a Professional Engineer to determine the flow and balance of specific multiple suction outlet systems.

Last updated: January 2012
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Approved flow rates are determined by the suction outlet cover manufacturers, but some minimum standards set by states require that the water velocity through covers not exceed 1.5 fps (feet per second) with one suction outlet 100% blocked. How do you rectify this issue?
Suction outlet cover ratings are based on allowable flow in gallons per minute (gpm) and tested in the laboratory under conditions to determine maximum allowable flow rate, which can result in velocities through the open area of the cover that are greater than 1.5 fps. Alignment of the flow-ratings of the covers with state requirements may require adjustments to the flow rating of the cover. Because the drain cover or suction outlet cover requirements of the P&SS Act preempt state law, state officials may need to evaluate their code requirements in light of the mandatory drain cover requirements in the P&SS Act.

Last updated: January 2012
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Is design flow or maximum flow used to apply a P&SS Act compliant suction outlet cover to a pump system?
The maximum flow rate that the circulation system is capable of producing should be used to determine the flow rating for the outlet cover(s). When determining the maximum system flow rate, all of the valves which can restrict or impede the flow of water through the suction outlet(s) should be set to maximize the flow of water through the suction outlet(s). All other restrictions, including the filter, should be removed.

Last updated: January 2012
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Other Features

Do hydrostatic valves require a P&SS Act compliant suction outlet cover?
No. A hydrostatic valve is not a submerged suction outlet, but rather it acts as an inlet when the hydrostatic valve operates. The cover for a sump with only a hydrostatic valve does not need to be P&SS Act compliant.

Last updated: January 2012
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Are spray/splash pads and interactive recreational fountains subject to the P&SS Act?
There are numerous ways to construct spray/splash pads. Assuming there is no direct suction on the outlets for spray/splash pads, the pads drain via gravity on a slightly sloped surface to a tank where the water is then pulled via a pump and sprayed back. Generally, the outlets are not submerged, or if they are submerged it is minimal. Spray/splash pads with no direct suction on the outlets are not subject to the P&SS Act.

Last updated: June 2010
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Are whirlpool bathtubs located in hotel rooms subject to the P&SS Act?
No. Bathtub appliances are not subject to the P&SS Act. Hot tubs and spas are by definition included within the scope of the P&SS Act. If a structure is a hot tub, spa, or portable spa whose suction outlets are addressed by ASME/ANSI A112.19.8 (2007), or its successor standard, ANSI/APSP-16 2011, the structure is included in the definition of “swimming pool or spa” under the P&SS Act. If the appliance or structure in question is one whose suction outlet requirements are addressed by ASME A112.19.7 (2006), “Hydromassage Bathtub Appliances,” neither the appliance nor the suction outlet cover/grate are within the scope of the P&SS Act.

Last updated: January 2012
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Are baptismal fonts in churches covered by the Pool & Spa Safety Act?
No. The P&SS Act defines a swimming pool or spa as “any outdoor or indoor structure intended for swimming or recreational bathing…” A baptismal font in a church does not meet the definition of a “swimming pool or spa” under the P&SS Act because it is not “intended for swimming or recreational bathing.”

Last updated: June 2010
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Are physical therapy pools considered to be public under the Act?
It depends. Therapy pools are not specifically defined under section 1404(c)(2) of the P&SS Act, but a therapy pool may be considered a public pool depending on its accessibility to the public generally.

Last updated: January 2009
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Recalls

What are the details of the May 26, 2011 recall of drain or suction outlet covers?
CPSC has published a list of answers to frequently asked questions regarding the May 26, 2011 recall of drain or suction outlet covers by eight manufacturers. Read the FAQs here and the press release here.

Last updated: January 2012
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Seven-year-old Virginia Graeme Baker’s tragic death inspired her family to advocate for pool and spa safety and moved Congress to act to prevent entrapments.
Read more about her story.

Find the most up to date requirements for the Virginia Graeme Baker Pool and Spa Safety Act.

FAQs

Sections

General Compliance

Suction Outlet Covers/Drain Covers/Grates

Unblockable Suction Outlets or Drains

Secondary or Backup Systems or Devices

Sumps

Flow Rates

Other Features

Recalls

General Compliance

Suction Outlet Covers/Drain Covers/Grates

Unblockable Suction Outlets or Drains

Secondary or Backup Systems or Devices

Sumps

Flow Rates

Other Features

Recalls

Who is Virginia Graeme Baker?

The Pool and Spa Safety Act: Staff interpretation and updates

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