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Tim Fisher
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PPI Group
Comment 01
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Preface
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Introduction
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Index
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Batch Release Tests
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Table A2
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14
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Technical
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Table A2 Batch Release Tests at Performance , Clause 9 and Appendix D both require 100% Testing.
Many brands of emergency shower and eye / eyeface wash units certified and sold into the Australian market are sold in component form. Their designs are such that they are delivered in a modular format That is, there is usually minimal assembly of the unit undertaken by the manufacturer, leaving the installer to complete the assembly, test and verify onsite.
This in most cases has been done to minimise the external packaging footprint for global and local distribution as well as additionally removing unnecessary labour from the manufacturing process. As an example please refer to the Broen video in the following link:
https://www.youtube.com/watch?v=Sdkx2KITXb4
Some manufacturers / suppliers choose to remain fabricating their assemblies with intensive welding procedures and associated costs with such labour intensive practices. Some assemblies may be broken down to partly assembled components requiring final assembly, test and verification at point of installation. Refer to attached Installation guide from Enware.
Once again such a requirement of 100% testing for both Performance and Watertightness Determination in this product category is inconsistent with that prescribed for Watermark Certified residential showers in AS/NZS3662 which require a Frequency of "1 per manufacturing batch....."
Performance theoretically may be verified through Design Freeze process of a suitably certified manufacturer.
The provision of 100% testing for Determination of Watertightness then becomes questionable as to the true intent of such application and potentially may have significant impact on product design and costs.
Given that AS4775 and ANSI Z 358.1 identifies assembly of product in the field and that products are to be installed and commissioned for the most part minimises the risk that such a 100% determination of watertightness and performance is attempting to address.
Many brands of emergency shower and eye / eyeface wash units certified and sold into the Australian market are sold in component form. Their designs are such that they are delivered in a modular format That is, there is usually minimal assembly of the unit undertaken by the manufacturer, leaving the installer to complete the assembly, test and verify onsite.
This in most cases has been done to minimise the external packaging footprint for global and local distribution as well as additionally removing unnecessary labour from the manufacturing process. As an example please refer to the Broen video in the following link:
https://www.youtube.com/watch?v=Sdkx2KITXb4
Some manufacturers / suppliers choose to remain fabricating their assemblies with intensive welding procedures and associated costs with such labour intensive practices. Some assemblies may be broken down to partly assembled components requiring final assembly, test and verification at point of installation. Refer to attached Installation guide from Enware.
Once again such a requirement of 100% testing for both Performance and Watertightness Determination in this product category is inconsistent with that prescribed for Watermark Certified residential showers in AS/NZS3662 which require a Frequency of "1 per manufacturing batch....."
Performance theoretically may be verified through Design Freeze process of a suitably certified manufacturer.
The provision of 100% testing for Determination of Watertightness then becomes questionable as to the true intent of such application and potentially may have significant impact on product design and costs.
Given that AS4775 and ANSI Z 358.1 identifies assembly of product in the field and that products are to be installed and commissioned for the most part minimises the risk that such a 100% determination of watertightness and performance is attempting to address.
Proposed change
Change the Frequency to read "1 per manufacturing Batch."