The Virginia Graeme Baker Pool and Spa Safety Act isn’t merely about drain covers.
It’s true that this crucial component is the first line of
defense for people who could come into contact with a suction
outlet. But complying with the law involves much more than merely
installing lids stamped VGB 2008.
“[Some professionals] just go out and buy VGB-compliant
covers that have a visible stamp on the top and put them in without
doing any of the rest. But you can’t do that,” says
Steve Barnes, chairman of APSP’s Technical Committee and safety and
compliance manager with Sanford, N.C.-based Pentair Water Pool and
And now that the Consumer Product Safety Commission is proactively
enforcing the law, it’s critical that pool professionals get
To that end, the Association of Pool and Spa Professionals
developed a flow chart for service technicians, builders and others
to take on-site. The document, sold by APSP, is actually used to
make sure a pool or spa complies with ANSI/APSP-7 Standard for
Suction Entrapment Avoidance. But it functions for the VGB Act as
“If you comply with this, you’re in compliance with VGB
without exception,” Barnes says. “The only thing
that’s missing from this that VGB allows is an automatic pump
The chart outlines the steps involved in examining public pools and
spas, and serves as documentation to show the condition of the pool
when last seen by a professional.
Here, we break the process down into five steps, not necessarily
correlating with the sequence in the flow chart. Follow this guide
for using the form to inspect pools for VGB and ANSI/APSP-7
Fill out enough forms.
The opening page of APSP’s “Appendix B: Field Checklist
for Identifying Suction Entrapment Hazards” contains blanks
for basic information about the pool — owner information,
name of the professional performing the assessment, the pump
involved and any actions taken.
APSP officials recommend filling out one of these forms for each
pump on the system that is connected to suction outlets.
“Each pump could have its own range of problems —
screws, flow rates,” Barnes says. “A lot of these pools
have two, three, four pumps, and each pump has to be
addressed.” Pumps that pull from skimmers, gutters or
non-accessible vanishing-edge catch basins don’t need to be
addressed. If a catch basin may be accessed, however, it qualifies
as a pool and must be checked.
Also fill out the box titled “Cover/Grate Audit” on the
back flap. This will ask for information about the pump, pool
volume, filter, system flow, total dynamic head, drain covers and
other essential information about the system.
The pool owner or operator should sign it, as should the
professional evaluator. “Now, if the CPSC comes in and says,
‘Are you in compliance?’ they can hand them
this,” Barnes says. “That should go a long way toward
showing due diligence and compliance.”
In addition, this can help protect the professional who is
evaluating the pool in case someone else alters the system later
and legal questions arise.
Identify each outlet and its pump(s) and flow.
To follow the flow chart, begin at the box marked “Start
Here,” and follow the arrows. The first question asks if the
pool has fully submerged suction outlets in the floor, walls or
If the answer is yes, users then are asked to identify how many
pumps pull from that outlet. “In many cases, especially in
public pools, you have a great big sump — as big as a door
– and you might have two or three pipes coming in,”
Barnes says. “Each one of those pipes may go into its own
pump, yet the suction outlet has to protect all of
Larger commercial pools, such as university and YMCA installations,
should have engineered plumbing schematics to help you see the
connection. In the case of smaller public pools, such as those
found at hotels or in apartment complexes, professionals may have
to perform tests to determine how many pumps draw from the
For each drain, calculate the highest potential flow by adding the
maximum system flow, in gallons per minute, of each pump hooked up
to the outlet. The last page offers a guide for calculating this.
You can use pressure and vacuum gauge readings, or simply add up
the manufacturer-specified maximum flow rate.
“The main thing we have to know is how much water are we
putting through the pumps,” Barnes says.
Next, make sure the outlet cover is rated for that maximum flow or
higher. If not, it will have to be replaced.
Make sure you have a true dual-drain system.
In examining the plumbing, you also need to make sure you have a
true dual-drain system.
After compliant drain covers, dual outlets are named as the most
important line of defense against entrapment.
In the absence of a dual-drain system, professionals must split the
drains or add a back-up device. These include safety vacuum release
systems or engineered vent systems. The professional also can
convert the single outlet into a gravity-flow system, turn it into
a return inlet, or permanently disable the outlet.
Of course, if there is only one drain in the whole pool, it’s
a single-drain system. In this case, you must determine whether the
single outlet is unblockable as defined by ASME A112.19.8-2008a or
certified by a registered design professional.
The CPSC is currently finalizing its definition of an unblockable
drain. Its draft definition states that an unblockable drain is one
measuring at least 18-by-23 inches, or 29 inches on the diagonal.
These have been deemed the minimum dimensions for ensuring that 90
percent of adult males cannot block the drain. In determining the
finalized definition, the CPSC will consider comments from the
industry and safety advocates, some of whom believe that drains
should be larger to be deemed unblockable, and others who think the
dimensions are currently too broad and would like to see more
language stipulating the amount of open space that must be
available around what CPSC calls the 90th percentile man, meaning
he is larger than 90 percent of adult males.
If you see more than one drain in the pool, that doesn’t
necessarily mean the pool has a dual-drain system. Many still
believe the term dual drain refers to the pool, but in fact it
refers to the pump. In order for the system to be effective, each
pump must be connected to two drains. The plumbing schematic should
be checked to confirm that this is the case. If no such drawings
are available, professionals can perform a simple test.
Turn the pumps on and make sure that suction is pulling through
both drains. You can do this by placing a rubber mat on one of the
drains and seeing if, once the pumps are turned on, it clings to
the drain to indicate suction. If it does, then a vacuum was
created on that drain, meaning the pool actually has two
single-drain systems, each of which must be addressed as outlined
“The cautionary note here is that, if it’s not a VGB
cover and it is a single drain, [this test] is probably going to
break [the cover],” Barnes says. “So [professionals
should] be careful when doing this.”
You must also make sure the drains are at least three feet apart
from center to center. If not, then the outlets are considered
close enough where both can be blocked by one body. The drains will
either have to be moved farther apart, or a back-up system must be
But drains also can be too far apart. If this is the case, the pump
will not be able to draw from both drains, or at least not equally.
If one is blocked, then the other may not be able to pull water
into the system. There are no parameters specifying the farthest
distance. If they are more than eight feet apart, however, use the
same test outlined above to make sure that, when the pump is turned
on, the mat will not cling to either drain.
In addition to unblockable drains, there are other types of outlets
that can be used alone. Skimmer equalizer lines, swim jets (which
function as combination outlet/inlets) and venturi systems (which
aren’t connected to a pump) are all allowed to be single
— as long as the flow rate is appropriate and they have a
Make sure each individual outlet is compliant.
APSP’s flow chart goes through a list of questions about each
outlet to make sure they are compliant with ANSI/APSP-7 and
After establishing that the flow through each drain falls within
the parameters provided by the drain-cover manufacturer, there are
other areas to check.
Make sure that each cover has a VGB 2008 or ASME/ANSI
A112.19.8-2007 stamp, and that the cover falls within the VGB 2008
service life. Note when the drain cover was installed and record
that date. If the drain has exceeded its service life, it needs to
Assess each cover to make sure there is no damage. The plastic on
the surface should not be broken or degraded, as this could create
a potentially hazardous opening in the drain. If this is a problem,
the cover must be replaced.
Make sure that each cover is secured with hardware specified or
supplied by the manufacturer or, in the case of a field-fabricated
sump, a registered design professional. It is not enough to tug and
pull on the drain cover to make sure it stays in place. Further,
check that the screws used are correct for the threads.
“If you’re buying a cover that has stainless steel
machine screws that are designed to go into brass nuts, and you try
to connect that just [to] a plastic frame, it’s not going to
work,” Barnes says. “And if they used some other
hardware, from a hardware store, then we have a
In the case of field-fabricated sumps, determine whether it falls
within the parameters laid out by the cover manufacturer. Measure
the distance between the pipe and the cover’s underside, and
between the edge of the frame and the sump bottom, and any other
Check the vacuum line.
While not named in VGB, vacuum outlets are covered in ANSI/APSP-7,
because the organization believes these outlets can be a hazard if
“They do not meet the definition of a suction outlet, but
they clearly are suction fittings, and water goes through
them,” Barnes says. “But if you put a drain cover on
it, you can’t use it as a vac fitting, so it’s beyond
the scope of the VGB Act as written by Congress.”
APSP has requested that CPSC consider vacuum outlets in its
interpretation of VGB.
To address this, ANSI/APSP-7 specifies that vacuum outlets be
outfitted with a vacuum port fitting, which automatically closes
and latches so it can’t be opened without a tool. “If
there’s no hose connected and no vacuum being used, then
it’s closed and shut,” Barnes says.
If the pump’s running, even a tool can’t remove this
cover. “So if the pump is running and a kid were trying to
open it, they can’t do it,” Barnes says.
If the vac line won’t be used, it can be permanently blocked
For additional protection, ANSI/APSP-7 also requires that a valve
be installed at the equipment pad to close when the vacuum line
isn’t being used.