UL 1776
Important Changes in the Standard
by Gary Weidner
S
tandards may seem like a sleepy
subject, but a number of things have happened since Cleaner Times last published
an article on the UL 1776 pressure washer
safety standard. It’s not easy for everyone
in the pressure washer industry to keep current of changes, because the standard is 202
pages long, and a printed version costs
$560—and that’s just an as-of-the-moment
copy. A three-year subscription to receive
bulletins, revisions, and any new issues will
set you back $1,115. (Electronic PDF-versions
cost approximately one-half those amounts.)
Changes Within the Standard
When discussing the safety standard, it’s
important to keep in mind that the standard
does not concern itself with the quality,
durability, or performance of a pressure
washer, unless an aspect of one of those has
to do with safety. Regarding performance,
for example, the gpm water flow through
a pressure washer is seldom measured
by a safety testing lab.
In part, UL 1776 is difficult to navigate
because it remains bloated with irrelevant requirements. One of my personal
favorites is a paragraph specifying requirements for fuel lines “larger than threeinch nominal pipe size.” Nonetheless,
slow but steady progress is being made.
The Third Edition replaced the Second
Edition of the standard in June 2002. It was
re-issued as an American National Standard in June 2003, and re-issued again with
16 • March 2004 • CleanerTimes
revisions in August 2003. These are some
changes made over the last couple of years:
Relief valves—An unrealistic requirement was revised; also, manufacturers
now are clearly allowed to omit the relief
valve if no unsafe conditions can result.
Low temperature tests—Options for
relaxed requirements are now available.
Formerly, plastics had to be impact tested at -31°F.
Water spray test—The old UL water
spray test is being phased out. In its place,
the Canadian approach of spraying the
machine with its own wand is being
phased in.
Wand length—A machine formerly required
to be equipped with a 36-inch wand may now
have a wand 29.5 inches long.
Meanwhile, a steady stream of minor
revisions indicates that more and more manufacturers are using the standard. The
misconception that getting a change made
to the standard is next to impossible, or that
it takes years to accomplish, is fading.
The change in minimum wand length
mentioned above is a good example. A single individual presented the proposed
change together with a rationale and supporting information, and the standard
was revised within a matter of months.
Changes Outside the Standard
The American National Standards
Institute (ANSI) now requires a Standards
Developing Organization (SDO) to follow
one of two specific methods in
developing and maintaining standards. Like many SDOs, UL considers the so-called “canvass
method” burdensome, and has chosen the “consensus method.” The
consensus method requires UL to
establish a decision-making committee for each standard. UL calls
the committee a Standards Technical Panel (STP).
Each STP must be composed
of a cross-section of interested
parties. The STP that UL has established for the 1776 standard consists of five manufacturers, three
UL staff (two are the non-voting
chairman and secretary), one enduser, one parts wholesaler, one
consultant, and two trade associations. UL would be delighted if
some distributors and contract
cleaners would also join the panel.
UL has been gradually assigning each of its standards to “Primary
Designated Engineers” (PDEs).
The PDE, who is the UL technical
member of each STP, is now the UL
internal “clearinghouse” for matters related to the standard. The
PDE seeks out feedback and represents UL in outside events such
as seminars and industry meetings.
Questions about the standard, such
as requests for interpretations, are
directed to the PDE.
Aside from generating a lot of
acronyms, have there been beneficial results from all this activity?
Yes. Bearing in mind that the 1776
STP was only formed in late 2001
and the PDE emphasis is much
newer than that, the standards
development process has become
more organized and open, and it’s
easier to get questions answered
and get things done.
What’s Coming
There is a massive world-wide
push to “harmonize” standards
among nations. The distant goal
for each type of product is “one
standard, one set of tests, good
anywhere.” Both ANSI and
much of U.S. industry are putting
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tremendous pressure on UL to
harmonize its standards with those
of the International Electrotechnical
Commission (IEC).
Does harmonization mean discarding all the work that went into
UL 1776? Not at all. The first step
of harmonizing a standard is to
rewrite it, following the IEC format
and using as much of the IEC content as does not conflict with the
present standard. Every requirement in the present standard that
differs from the IEC version appears
in the new harmonized standard as
a “National Difference.”
It’s true that if every country’s
version of an IEC standard contains
a bunch of National Differences,
then, in fact, all the standards are
still different. The rationale is that
we have to start somehow on unifying standards, and this is the
logical way to proceed. ANSI’s
“National Standards Strategy for the
United States” and UL’s own fiveyear plans strongly reflect the push
in this direction.
Where is UL 1776 at in this process? A working group of volunteers is presently drafting the new
version, which will be designated
UL 60335-2-79. This is a huge
amount of work, and it will take a
considerable while to complete.
The drafters must take extreme
care while rewriting the standard
not to alter or omit any requirements unique to the U.S.
Do we really need to do all this?
As reported in the July 2001 issue
of Cleaner Times, there are three
options regarding UL 1776:
1. Do nothing. The shortcomings
of the present standard have been
a source of headaches for manufacturers, suppliers, distributors, and
users. That situation can only get
worse as the need for safety certification becomes more widespread,
so this is not a good choice.
2. Rework the standard. We’re
talking about a major overhaul. A
disadvantage is that if the standard is later harmonized with those
of other countries, much of the
work will have to be repeated.
3. Harmonize the standard. We
might as well face up to it and get
on with it. It’s happening all around
us, in virtually every industry.
Once the standard has been harmonized, any defective requirements that carried over can be
addressed.
Meanwhile, on the domestic
front, what’s needed is some cooperation among the four testing labs
recognized to certify pressure
washers to UL 1776. OSHA, the
agency that authorizes testing labs,
does not require them to cooperate
or accept each others’ results, and
they frequently don’t.
To get maximum value from
the safety certification system, a
manufacturer needs to be able to,
say, take a machine to one lab for
certification but request that the certification include a trigger gun
already certified by a second lab.
The first lab could request from
the second lab the actual test record
for the trigger gun, to ascertain
whether everything had been done
properly.
The Cleaning Equipment Trade
Association could serve to broker
a memorandum of understanding
among the labs. The memorandum
would spell out a mechanism for
mutual acceptance of test data.
What’s the bottom line on all this?
Back to the trigger gun for an
example: a manufacturer could
simply and easily include a number of already-certified trigger
guns in a machine certification
file. Servicing distributors would
then have the option of using any
of those guns for replacement
without violating the machine’s
certification.
Whatever the course of events,
UL 1776 will hopefully morph into
a form that is more and more useful and effective.
Gary Weidner is an independent consultant and a contributing editor to
Cleaner Times. CT
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