(5/6/2025) PoolPal USA Inc: In response to the complainant in the Incident Description: “NON compliant VGBA adaption devices being sold on amazon by a company to circumvent ANSI/AMSE testing requirements”: our product is NOT a main drain adapter, therefore, UL can’t and won’t test it for VGBA, since it’s NOT subject to that testing. This is a nuisance complaint from an associate of a competitor.
1. The information is inaccurate because: (A) In approximately late 2014 to early 2015, we contacted Underwriters Laboratories (UL) to have them test the Main Drain Adapter for ANSI/ASME certification and had extensive communications with them regarding this product. They determined thru those communications that they could not do any type of certification as it relates to the federal Virginia Graeme Baker Pool and Spa Act (VGBA) requirements, as they determined that the product was NOT a pool main drain cover, but rather “a transitional adapter,” not subject to that testing. They did, however, suggest that we “could” do a series of tests to certify that specific brands of VGBA compliant pool main drain covers were compatible with our product. The list of suggested testing that could be done was relatively simple and could be done in-house, therefore, we conducted in-house testing. The results of the in-house testing exceeded all perimeters of industry standards as we understand them, the results of which can be produced, along with video recordings of testing examples. The tests included: pull out tests of our product from main drains/grates; main drain cover pull-off tests, using various brands of main drain covers; UV comparative tests; crush tests; and we further calculated major brands of main drain covers’ area of flow thru each brands cover, and calculated and compared the area of flow of our product to ensure that our product did not restrict flow. Also, we contacted a licensed Professional Engineer to conduct Flow Rate calculations on the MDA, attached; AND
(B) According to the US Consumer Protection Safety Commission’s own website, all references to VGBA seem to be specifically in regard to commercial only, and not residential, swimming pools and spa. Our MDA is ONLY recommended for residential use, although our testing and engineering have shown that it would still meet or exceed VGBA requirements.
2. Although our MDA is NOT subject to this testing, our in-house testing and results, as well as testing and results from a Professional Engineer, and documentation is attached. On the US Consumer Protection Safety Commission’s website, they reference “Field Fabricated Main Drains” as “legal”. We believe that our product falls in that category and we have taken appropriate measures testing and have professionally engineered calculations to support the legal use of our product. Video testing is available upon request. https://www.poolsafely.gov/wp-content/uploads/2016/08/Pool-Safely-FAQ.pdf Virginia Graeme Baker Pool & Spa Safety Act (P&SS Act) FAQ Q: What are public pool and spa owners/operators obligated to do to comply with the Virginia Graeme Baker Pool & Spa Safety Act (P&SS Act)? A: As of December 19, 2008, all operating public pools and spas must have drain covers that meet the ANSI/ASME A112.19.8-2007 standard on every drain/grate. In addition, if the pool has a single main drain (other than an unblockable drain), the operator must either disable the drain or install a second anti-entrapment device or system. This can take the form of an automatic shut-off system, gravity drainage system, Safety Vacuum Release System (SVRS) or suction-limiting vent system. A pool may have more than one single main drain. If a pool has dual or multiple main drains more than 3 feet apart, it may be exempt from this second requirement. Pools and spas with single main drains that are unblockable are also exempt from this requirement. (Last Updated: January 30, 2009) https://standards.globalspec.com/std/1248903/ASME%20A112.19.8 Field Fabricated Outlets. All nonmanufactured suction outlets constructed in the field with individual components shall be considered as “Field Fabricated Outlets.”
In sections of the US Consumer Protection Safety Commission’s website, they discuss the dangers of missing main drain covers. Our product (engineered and tested) gives the opportunity to attach a VGBA compliant main drain cover in the field where it might not otherwise be possible. Attached documents and below bullet points are included for additional evidence.
• In approximately late 2014 to early 2015, we contacted Underwriters Laboratories (UL) to have them test the Main Drain Adapter for ANSI/ASME certification and had extensive communications with them regarding this product. They determined thru those communications that they could not do any type of certification as it relates to the federal Virginia Graeme Baker Pool and Spa Act (VGBA) requirements, as they determined that the product was NOT a pool main drain cover, but rather “a transitional adapter,” not subject to that testing. They did, however, suggest that we “could” do a series of tests to certify that specific brands of VGBA compliant pool main drain covers were compatible with our product. The list of suggested testing that could be done was relatively simple and could be done in-house, therefore, we conducted in-house testing. The results of the in-house testing exceeded all perimeters of industry standards as we understand them.
• Based on our conversations with UL, it is our understanding that all products do not require ANSI/ASME certification, but we have done both in-house and third-party testing and evaluation of the specific product named in this complaint.
• Approximately 2015, we contracted a local engineering firm to calculate the Flow Rate of our product. The Flow Rates far exceeded acceptable rates and far exceeded VGBA pool main drain cover Flow Rates. Please find attached a copy of [REDACTED] licensed credentials and his Flow Rate chart of results, the engineer who did the calculations.
• Approximately 2014-2015, although it was not suggested by UL, we took several of the major brand main drain covers and calculated the open areas of the cover and determined by those calculations, that every main drain covers significantly reduces Flow Rates in comparison to the Flow Rate of the MDA. Further, pipes generally used in swimming pools have a lesser Flow Rate than the MDA. Please find attached a copy of a [REDACTED] Main Drain Cover for Flow Rate comparison, as well as a Water Flow chart of standard PVC plumbing that we used in our study, dated 11/10/2014.
• Approximately 2014-2015, we performed testing to determine how many force-pounds would be required to detach several of the most common brands of VGBA pool main drain covers. All covers exceeded the accepted industry standards. Upon receipt of this non-injury complaint, we attempted to recover our records of this test. Due to Hurricane Helene in October 2024, many of our archived records were lost in the flooding (both our home and business sustained multiple feet of water from this flood). We retested and attached are some of the test results (they are reflective of similar results we had originally) and will keep the results electronically to prevent any record loss in the future.
• We performed retesting to determine how much force-pounds would be required to detach our MDA from a pool main drain pot. It took 188 lbs. of pulling force to remove the MDA from a main drain grate frame.
• Approximately 2014-2015, we performed a product crush test. The results exceeded acceptable industry standards. Once again, our documentation was destroyed, and we will retest.
• Approximately 2014-present, we are still in the process of performing UV testing. We initially made a batch of control MDA’s in which no UV additive was present. Our standard MDA for sale contains UV additive in the plastic. On an ongoing basis, we are comparing and contrasting UV present MDA’s versus control MDA’s (no UV additive). The control MDA’s have significant yellowing compared to UV present MDA’s. A 10-year-old MDA still performs similarly to previous testing. We recommend a 5-Year-Life span for our Main Drain Adapter, irrespective of it’s 10-year performance.
• We tested our MDA in use with a Custom Molded Products (CMP) 25507-0XX-10 main drain cover, which resulted only in the failure of the CMP main drain cover at 321 lbs. The 1” MDA screws did NOT fail. The MDA screws show no sign of stress. Conclusion: the MDA significantly outperforms the main drain cover.
• We tested our MDA in use with a Custom Molded Products (CMP) 25507-0XX-10 main drain cover, in which at 158.9 lbs., the 3/4” MDA screws pulled out of the MDA; the main drain cover did not fail. Conclusion: the MDA significantly outperforms the minimum standards for a main drain cover pull out.
• We tested our MDA in use with a Waterway main drain cover, which resulted only in the failure of the main drain cover at 130.7 lbs. The 3/4” MDA screws did NOT fail. The MDA screws show no sign of stress. Conclusion: the MDA significantly outperforms the main drain cover.
• We tested our MDA in use with a Waterway main drain cover, which resulted only in the failure of the main drain cover at 188 lbs. The 1” MDA screws did NOT fail. The MDA screws show no sign of stress. Conclusion: the MDA significantly outperforms the main drain cover.
• The MDA attachment thumbscrews show signs of stress (plastic only) at approximately 275 lbs.
On this complaint filed on March 4, 2025, we noted the complainant, who is a well-known entity to us. He has a business relationship with one of our major competitors ([REDACTED]), with whom we have had to take legal action against, due to defamation. Please refer to a copy of his website (redacted) which he lists [REDACTED] as one of his “Trusted Partners and Vendors” in business, a copy of his webpage is redacted. We believe that this entire complaint itself is retaliatory, and not legitimate. The Consumer Protection Agency should not be used as a tool to attack competitors, and we ask that they investigate this complainant, and take any legal action possible on this fraudulent filing. Further, we have no reason to believe this individual has even purchased this product.
As one can see, from the beginning, we have always strived to do our Due Diligence regarding testing our products, and particularly our Main Drain Adapter. Prior to selling the product, we reached out to UL for consultation and/or testing, as well as to a licensed Professional Engineer for Flow Rates, in addition to performing in-house testing, as suggested by UL, which we continue to do to date.