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 Spa.

And now that the Consumer Product Safety Commission is proactively enforcing the law, it’s critical that pool professionals get compliance right.

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 well.

“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 shut-off.”

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 compliance.

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 skimmer equalizers.

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 them.”

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 outlet.

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 above.

“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 added.

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 VGB-compliant cover.

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 VGB.

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 be replaced.

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 problem.”

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 specified dimensions.

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 not addressed.

“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 off.

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.