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BUTLER NEWS
The Following is a Copy of a Letter Sent to the CRI
(Carpet and Rug Institute) with Questions and Concerns
Regarding the SOA (Seal of Approval) Testing.
Over the last year, many of our customers and cleaning and restoration associates have asked what is our position regarding the CRI SOA (Carpet and Rug Institute Seal of Approval), and whether or not our company would be participating in the equipment and product testing. They also expressed many of their questions and concerns.
We are hopeful that the CRI will be able to answer the questions and concerns listed below, so that we will have accurate information to make an informative decision regarding the testing and to provide our customers with some definitive answers.
What prompted the CRI to create the SOA program?
Does the CRI laboratory conditions accurately duplicate what transpires in the cleaning and restoration field with thousands of companies, using multiple of thousands of cleaning machines that are cleaning millions of square yards of different carpet each day?
How does it benefit the machine manufacturer?
How does it benefit our customer?
Why would truckmount machines need to be tested when portable extractors have earned the SOA?
Have any truckmount machines been tested and failed?
And if so, for what reasons?
Are there any written guidelines available, which state the required specifications for equipment that is to be tested?
Some examples would include: wand design, spray pattern of jets, single or multi jet wands, water temperatures, pressure ratings, airflow requirements, etc.
What is the benefit of the Space Foundation Certification to the machine manufacturer?
What is the benefit of the Space Foundation Certification to our customer?
Do we need to test just the basic machine or every variation thereof?
If a machine is designed for more than a single wand, does the machine have to be tested with each of the possible wand combinations to be in compliance?
If we were to own an original Butler System that was 25 years old or older, installed in its original vehicle and it received a CRI SOA, then would all newer Butler Systems also be automatically approved?
If not, would individuals and companies have the opportunity to test their existing machines in order to be in compliance?
If so, will the individual or company need to pay the same fees as a manufacturer to have their machines tested?
Has the CRI set an age limit on the age of machines that can be tested?
What will the manufacturer need to do each year to remain in compliance?
Upon manufacturers receiving the CRI SOA or Space Foundation Certification, will all their machines in use, prior to the approval, be automatically grand fathered?
If not, we will have thousands of unhappy customers, who will be in the unfortunate position of owning a considerably devalued machine, and will have the burden of an expensive replacement if they want to be in compliance.
Where are the independent CRI testing laboratories located?
Will the locations for the independent laboratories be feasible for our customers and companies that are located throughout the United States, including Alaska and Hawaii, or international businesses and the US federal government around the world?
Will the testing conditions in each individual laboratory be identical?
What will an individual or company need to do each year to remain in compliance and are there any annual fees?
Will there be any additional charges, if we, or our customers, were to use more than one size and/or type of floor wand, and if so, at what cost?
If a customer changes the manufacturer's recommended settings on the machine ie: RPM, pressure, vacuum, water temperature, etc. how does that affect the compliance?
If a customer does not use the manufacturer's wand, cleaning tool and/or hoses, or change the length or diameter of the hoses, etc. that was part of the CRI SOA for the manufacturer's machine, how will that affect the machine's compliance?
If someone were to repair, replace or modify a vacuum blower, wand, hoses or any accessory or part to a CRI approved cleaning machine, will it need to be retested?
Will manufacturers and/or distributors have the opportunity to be authorized to individually test their newly manufactured machines or their customers used machines for compliance?
Will a manufacturer be required to retest a machine based on for example: a component manufacturing change of equal performance or a larger vacuum/blower, high pressure pump upgrade, etc.?
Do all CRI approved machines and cleaning products tested at the CRI laboratory use the same water supply and water temperatures, and if so, what affect will the water and water temperatures in various regions of the country have on the machine's performance or the cleaning products effectiveness?
After a machine has been approved how long does the SOA remain in effect?
How does the CRI plan to monitor the performance of an approved machine after it has been in service to be certain the machine is still in compliance?
As a manufacturer it’s been our experience that every machine's performance relies on the operator's experience and the machine's performed maintenance.
A machine that is CRI approved may be out of compliance in a very short period of time, due to poor maintenance (ie: dirty filters, worn and/or misaligned jet(s), etc), the use of improper cleaning procedures, tools, cleaning agents, spotting agents, water, water temperatures, water pressures, airflow, clogged filters, etc., etc.
On the other hand, a 25-year-old machine can perform as well, or better, than a new machine based on how well the machine has been maintained and the care and experience of the operator.
Who is ultimately liable for any claims if the cleaning technician uses a CRI approved machine, CRI approved cleaning products and is IICRC certified or none of the preceding or any combination herein? Is it the CRI, the IICRC, the carpet manufacturer, wholesaler, retailer, installer, homeowner, the manufacturer of the carpet cleaning machine, their distributor, the manufacturer of cleaning products, their distributor, the carpet cleaning company, the carpet cleaning company owner(s), the carpet cleaning company technician, his/her assistant or all or some of the above?
We read that the CRI expressly disclaims any warranty or representation that the Program's test criteria have been or will be approved, sanctioned, followed or authorized by any government agency. In no event shall CRI be liable to the manufacturer for any indirect, special or consequential damages or lost profits arising out of or related to (CRI) agreement or the performance of breach thereof, even if CRI has been advised of the possibility thereof.
Why be tested if the above is true?
What is the specific liability of the manufacturer, distributor or our customer of both a CRI SOA machine and a non-compliant machine in the above question?
It is our opinion that it would be more beneficial for the carpet and rug manufacturers and the cleaning and restoration industry, if more emphasis were placed on recommending stringent specifications for cleaning machines, machine maintenance and cleaning products, as well as, cleaning procedures and operator training.
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