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BUTLER NEWS
The Following is a Copy of a Letter from the CRI (Carpet and Rug Institute) responding to the Questions and Concerns Regarding the SOA (Seal of Approval) Testing.
What prompted the CRI to create the SOA program?
Over the last 10 years or so, the carpet industry witnessed a steady erosion of the floor covering
market. As it came to grips with the reasons behind it, the CRI started working diligently to put
tabs on the reasons to avoid or remedy them in the future. Previous beliefs were based on
surveys of carpet retailers who consistently cited installation as the industry's number one
problem. Consumer market surveys were used and the number one issue we found with carpet
as to why people were de-selecting it, was a cleaning and maintenance issue. "You can't clean
and maintain carpet" was the overwhelming sentiment.
Of course, we knew that carpet could easily be cleaned and maintained, but something was out
there permeating that prevailing thought. What was discovered through some preliminary testing
was bad cleaning products. In fact, most cleaning product manufacturers didn't even realize
their products not only didn't clean very well, but left residues behind causing rapid resoiling.
Our initial tests of products purchased off the supermarket shelf and at local distributors showed
less than a handful of two dozen tested better than water. The protocol that was put together
has literally raised that segment of the industry by leaps and bounds. Products were
reformulated and today we know of over 100 that have been tested and can proudly say they
clean carpet.
We expanded the SOA program to include extractors once NASA's XRF technology became available and, again, we have been able to distinguish good cleaning products.
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?
The protocol that is in place is indicative of what transpires in the cleaning and restoration field.
And not only does it replicate these conditions, but it is a protocol that is repeatable, a critical
factor in any pass/fail procedure. From the beginning, we realized the need to have soil in
particulate sizes that represent the broad spectrum of soil types. Wehad a major vacuum
cleaner manufacturer gather soil samples from across the country and then analyzed them for
particulate size and individual characteristics. There is not a perfect soil type, but what we have
for this standard is representative of a wide variety of them.
How does it benefit the machine manufacturer?
Bottom line, professional cleaners and the consumers they serve are the primary beneficiaries
of the CRI SOA chemical and equipment testing programs. For the machine manufacturer, the
SOA Program is a tool to back up the marketing claims you make about your equipment. We
have also found that many manufacturers have used the SOA testing as a way to enhance their
research and development in order to make better equipment. This is a win-win for everyone.
How does it benefit our customer?
Again, it backs up any marketing claims you make about your machine, but it also ensures to
your customer that the product they are using has been tested and is certified. Some of the mills
have independently started tying portions of their warranties to the use of SOA certified
products, so being certified would enable your customers to meet those requirements.
Why would truckmount machines need to be tested when portable extractors have earned the SOA?
Aside from having the equipment eligible to meet warranty requirements by some of the carpet
manufacturers, equipment should be tested as a way to certify that it removes soil, does not
leave behind too much residual moisture and does not damage the carpet.
Have any truckmount machines been tested and failed?
No, but not all of them have tested out initially at the levels they are currently listed on the
website. In other words, some truck mounts initially tested at the bronze level and by making
enhanced modifications to the truck mount unit or cleaning process, were able to resubmit their
machines and earn the higher levels.
Are there any written guidelines available, which state the required specifications for equipment that is to be tested?
No, we test equipment that is submitted by the manufacturer as is. The pass/fail criteria are the
same for all machines in the extractor portion of the SOA. We follow recommended procedures.
Some examples would include: wand design, spray pattern of jets, single or multi jet wands, water temperatures, pressure ratings, airflow requirements, etc.
We recognize that all of these examples may make a difference, but we test the equipment as it
is submitted to the lab.
What is the benefit of the Space Foundation Certification to the machine manufacturer?
It is a marketing opportunity for those who choose to pay the Space Foundation a set fee to use
the tag in their marketing efforts. Surveys show that NASA resonates well with the general
public and the fact XRF is a NASA technology that has been transferred into a commercial use
has provided this opportunity.
What is the benefit of the Space Foundation Certification to our customer?
Again, the Space Foundation seal is more about a marketing opportunity. The ability to display
the Space Seal is a way for your customers to differentiate themselves from competitors in the
marketplace with a symbol that is universally recognized and carries weight with the consumer.
Do we need to test just the basic machine or every variation thereof?
We are currently working diligently on putting into place parameters that would work to certify
machines that are no longer in production by manufacturers. Typically, manufacturers of truck
mounts units will not need to test each of their variations unless there are significant variations
in the equipment. For example, if a truck mount unit has passed the test and a similar truck
mount unit has been enhanced, the enhanced specifications/features would be reviewed by an
independent Review Board. The similar enhanced unit could obtain SOA certification based on
the judicious decision of the Review Board. Certainly various wand designs affect performance
and we are currently looking at ways to test wands on their own merit and include it in the SOA
program.
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?
Again, we are looking into a wand certification program that would handle such a scenario.
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?
They would if there were not significant variances that would lower the unit's performance.
If not, would individuals and companies have the opportunity to test their existing machines in order to be in compliance?
The opportunity to test equipment is always open to individuals and/or companies.
If so, will the individual or company need to pay the same fees as a manufacturer to have their machines tested?
Yes.
Has the CRI set an age limit on the age of machines that can be tested?
No.
What will the manufacturer need to do each year to remain in compliance?
Pay a small annual renewal fee. GRI member fee is $50. A non-GRI member is $75.
Upon manufacturers receiving the CRI SOA or Space Foundation Certification, will all their machines in use, prior to the approval, be automatically grand fathered?
All the machines of that specific model that receives certification will be certified.
Where are the independent CRI testing laboratories located?
At the present time, the testing lab is located in Dalton, Georgia. The GRI Board has dictated
that all programs should be supported by at least two labs with Professional Testing to receive a
three-year exclusive due to their huge investment in R&D. to date, no other labs have
expressed interested in this program.
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?
Once the manufacturer gets a specific model certified irrespective of where they are sold,
shipped or used, they will be certified. Generally, it is the equipment manufacturer that submits
equipment to be certified and not the customer and/or companies.
Will the testing conditions in each individual laboratory be identical?
Currently there is just one lab certified. This lab is audited on an annual basis by a professional
quality assurance company which assesses the operating procedures and conditions as per an
approved test protocol. If, and when, another lab comes on board for testing, the testing
conditions will be identical.
What will an individual or company need to do each year to remain in compliance and are there any annual fees?
The annual fees are for the manufacturer of the equipment, not the owner.
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?
We are currently working on a wand certification program that would deal with this scenario.
This program might encompass a nominal fee. If you interchange approved wands, the machine
will retain its certification.
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?
Certification goes to the model that the manufacturer produces. If a customer opts to change
devices such as wand, they can notify CRI's Review Board and have the changes certified if
they meet the criteria for approval.
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?
As with any major testing and certification program, every day inspection of certified equipment
in the field would be cost prohibited. It is critical for the owner to be honest and for CRI to have
trust in the decision by the owner that the modified machine will perform at least to the
certification level identified in the original SOA certification approval.
If CRI obtain excessive complaints, over a period of time, from consumers of SOA certified
equipment cleaning performance, this policy as stated may require modifications.
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?
Requests can always be made to test.
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?
Yes, the testing lab uses the same water supply and water temperature to each truck mount
being tested. Each test is performed with the truck mount water temperature specified and set
by the unit owner.
After a machine has been approved how long does the SOA remain in effect?
The approval is perennial as long as the annual renewal fee is paid and no maior changes are
made to equipment that might reduce the cleaning performance.
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?
Through an audit system that is currently being discussed within the CRI Cleaning &
Maintenance Issues Management Team.
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?
All claims regarding carpet physical performance should be directed to the manufacturer of the
carpet. As an example, a claim against the cleanability of a carpet would be addressed by the
manufacturer of that individual carpet.
The Service Provider that performed the cleaning using a SOA certified truck mount unit should
address a claim against the quality of cleaning.
CRI provides the SOA certification based on performance data generated in a testing lab using
the operating settings as per the owner of that equipment or cleaning system. No warrant
contract is offered, or implied, indicating the level of cleaning performance in the field.
We read that 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 of or relating 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?
Your basic question is "why obtain a SOA certification since CRI does not cover everyone's
potential liability."
The SOA certification provides the equipment manufacturer with a listing on CRl's website that
his equipment has the features of cleaning carpets at the bronze, silver or gold level. The
certification level of performance is issued by an non-profit carpet trade association based on a
peer-reviewed test protocol performed by an independent testing lab.
This information is public and may be used by an SOA approved service provider.
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?
That's not a question for CRI to answer.
Sincerely,
Wemer H. Braun, President
Carpet and Rug Institute
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