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Proposed Federal Rule for Floor Slip Resistance

The U.S. federal government’s Consumer Product Safety Commission (CPSC) is considering a petition requesting rule making to require that manufacturers of floor coverings, floor coverings with coatings, and treated floor coverings label their products’ slip resistance in accordance with an ANSI/National Floor Safety Institute (NFSI) standard, B101.5. (NFSI, Safety Direct America and others offer for-fee testing of the types that would be required under their proposed requirement.) The CPSC invites comments concerning the petition by Monday, February 1, 2016. Information is at www.regulations.gov under docket number CPSC-2015-0033.

The standard requires both static (SCOF) and dynamic coefficient of friction (DCOF) testing, the latter using the BOT-3000E tribometer. Prescribed graphics on the product package would be required showing how the test results compare with the standard’s safety criteria for each (static and dynamic). It’s not clear who owns the copyright or trademarks of these graphics. It’s also not required to state that the tests are wet rather than dry.

Static friction applies to pedestrians who are standing still, while dynamic friction applies to a walking pedestrian. Presumably if a flooring product fails to satisfy both static and dynamic criteria, the buyer’s conclusion would be obvious. If it satisfies both criteria, the user would be reassured. It’s not made clear what conclusion is appropriate when a product satisfies one of the safety criteria but not the other.

Here are some comments on this proposed rule making:

1. Most of the world successfully relies solely on dynamic friction tests to assess pedestrian slip risk. Requiring both static and dynamic for the proposed label might be overkill and confuse the consumer, leading to purchase of flooring inappropriate for its intended use.

2. The Application section in ANSI B101.1 says that it does not apply to mechanically polished tile such as polished porcelain, marble, granite, etc. There is no alternative given as to how this would be treated on the proposed labels. (Owners of the BOT-3000E digital tribometer might be surprised to learn that though it can measure static friction, it is not approved by NFSI for this use under ANSI B101.1.)

3. The label would apply only to wet slip resistance of the flooring as it leaves the factory, rather than giving any information about whether the slip resistance lasts more than a few weeks under real-world conditions. McDonalds Restaurants and others have found that some flooring can lose slip resistance under wear, sometimes in just a few weeks. McDonalds devised the Sustainable Slip Resistance test to address this problem.

4. Any use of test results on a label should specify whether they are wet or dry results. Areas that are normally clean and dry in use might not require good wet slip resistance.

5. The label itself should be in the public domain, without a copyright by any organization except perhaps the CPSC.

6. The safety standard is “one size fits all,” with no consideration as to whether the flooring will be used for a ramp, stairs, swimming pool deck, kitchen, shower, laundry room, food court, etc. More detailed standards based on use of the area, and dynamic friction, exist and are shown at https://safetydirectamerica.com/improving-the-worlds-most-sophisticated-floor-slip-resistance-testing-standards/.

7. The label apparently would be appropriate for only indoor flooring, but the present version doesn’t state that.

8. Some of the test methods for static friction under NFSI B101.1 can be influenced by human factors that may affect the results to the detriment of the consumer.

9. The rule does not help consumers to comply with the 2012 International Building Code, which (by reference to ANSI A137.1) specifies a different dynamic test method to assess wet slip resistance. However, ANSI B101.3 is based on better safety research than is A137.1.

Giving consumers information on wet slip resistance of flooring is a good idea and long overdue, but the devil is in the details.

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