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The ANSI name lends credence to standards activities. The ANSI name indicates to the
public that a standards developer has followed the stringent steps necessary to create
and maintain trustworthy, scientific standards that the public may have confidence in.
Alternatively, the ANSI name may be used to make it appear that these things have
been done. For example, CRI publicly and with no retraction claims to already have
ANSI accreditation for its vacuum cleaner testing program:
3DUWRI$16,¶VPLVVLRQLV³VDIHJXDUGLQJWKHLQWHJULW\RIWKHYROXQWDU\VWDQGDUGL]DWLRQ
V\VWHP´ ConsidHULQJ&5,¶VGLVUHJDUGfor the ANSI brand name, as indicated by using
erroneous claims to gain credibility, and considering CR,¶VODFNRI evidence supporting
their standards RU$16,¶V, we H[SHFWWKDW$16,¶VRSLQLRQRIWKLVSURJUDPLVWKDW&5,KDV
not fulfilled the requisites in ISO/IEC Guide 65, General requirements for bodies
operating product certification systems, First Edition 1996.
Specific examples of CRI failures to fulfill the criteria in Guide 65 and other relevant
guides and standards, include but are not limited to:
I. ISO/IEC Guide 65, 4.1.3, states that the criteria against which the products
are evaluated shall be those outlined in specified standards, suitable per
ISO/IEC Guide 7, which has been revised into ISO/IEC 17007-2009. CRI fails
to meet Guide 7 and 17007 criteria in numerous ways.
A. Guide 7, 4.4 and ISO/IEC 17007, 5.2.2 state that a standard should result
in accurate and uniform interpretations, and that parties using a standard
should be able to derive a common understanding of its meaning and
intent.
1. CRI has supplied no document that is labeled D³VWDQGDUG´
ThHUHDUH³VWDQGDUGWHVWPHWKRGV´ and there is a list of
³FULWHULD´LQFRUSRUDWLQJWKRVHWHVWPHWKRGV
2. There are various web site pages marketing the program, each
with different language that implies different meanings. If the
YDULRXVZHESDJHVDUHWDNHQWRJHWKHUWREHWKH³VWDQGDUG´
accurate and uniform interpretations are impossible. Some
examples of lack of clarity:
2
a. OQHSDJHGHVFULEHVWKH³WRXJKVWDQGDUGV´DQGGHOLQHDWHV
two categories IRUSURJUDPLQYROYHPHQW³JHQHUDO
SXUSRVH´DQG³ORZSLOH´$QRWKHUSDJHGHVFULEHVWKRVH
WZRFDWHJRULHVDV³KRXVHKROG´DQG³FRPPHUFLDO´<HW
another page lists products that have passed ³KRXVHKROG´
³FRPPHUFLDO´DQG³KRXVHKROGDQGFRPPHUFLDO´ tests.
The categories are inconsistent and definitions unknown.
b. Meanwhile, in one place it is stated that carpet samples
XVHGIRUVRLOUHPRYDOWHVWVDUH³HLWKHUR]V\
FRPPHUFLDOFXWSLOHFDUSHWRUR]V\ORRSSLOHFDUSHW´
Yet another page lists four carpet samples in the testing,
but GRHVQ¶WLQGLFDWHWKDWWKHUHLVDchoice between them
for participating manufacturers. And still yet another
page lists three potential samples with a choice. Anyone
looking at this program as presented would not be able to
discern what was actually tested. Further, approved
products are not differentiated by what carpet they were
tested with and for what purpose. This makes any
performance rankings incomparable. ISO/IEC 17007 4.5
Principle 4 requires comparability.
3. The vacuum cleaner testing program incorporates the name
µGreen Label¶. The carpet testing program also uses the name
µGreen Label¶%XWRQO\WKH carpet testing programs are within
the scope of &5,¶V current ANSI accreditation. The use of the
same name for both scopes is misleading and obscures the
meaning and intent.
4. &5,FODLPVWKDW³WKHHQWU\OHYHORI%URQ]H(in the new testing
program) requires a 10 percent improvement of soil removal
over the Green Label program and the standards are even higher
3
texture from cleaning processes, as the loop pile would be
YLUWXDOO\EXOOHWSURRILQWKLVUHJDUG´ In other words,
items submitted for testing in one category would all pass
unless the test was specifically changed to fail a number
of them. This is unreasonable. If an efficacy test is
performed on loop pile carpet, the texture retention test
should also be performed on loop pile carpet.
b. This testing is especially unreasonable given the base
quality of the carpet samples used. Despite a relatively
high market share due to its low price point, the former
CEO of Shaw Industries admits that this quality of carpet
LV³JXDUDQWHHGWRZDONRXWLQIRXUZHHNV´Appendix N)
To deliberately create a test for the purpose of showing
texture damage to a carpet sample by a cleaning process,
when that carpet sample would be damaged by walking
on it for a month anyway, amounts to shifting warranty
blame inappropriately. It also amounts to a commercial
interest in the certification process by voting
CRI members who have included the CRI SOA into their
warranties, which violates Guide 7, 4.2.m.
2. The CRI Seal of Approval has become a market requirement in
several arenas, as it has been incorporated into warranties,
various pieces of legislation and national standards.
a. There is pressure on manufacturers of products to
enJLQHHU³WRWKHWHVWV´ZKLFK retards technological
developments (especially in the commercial arena).
5
they were in before they were vacuumed. This is because
³&KDQJHVLQWKHGLVWULEXWLRQRIWKHFRPSRXQGVFKDQJLQJWKH
measured amount, in (conjunction) with variation in carpet
fiber to detector distance is believed to be the largest source of
YDULDWLRQLQWKLVWHVW´Appendix C)
a. Returning yarns back to their original positions is
technically impossible without exacting study.
b. Nevertheless, a technician brushes the yarns with a rake
in order to attempt to return the yarns back to a
³XQLIRUPVPRRWKDSSHDUDQFH´Appendix B, 6.8) There
is no definition of what FRQVWLWXWHVD³XQLIRUPVPRRWK
DSSHDUDQFH´ there is no proscribed number of brush
strokes;; there is no monitored pressure or speed. The
technician goes through inconsistent and subjective but
token motions in an attempt to do the impossible. ³7KH
XRF peak intensity drops as the inverse square of the
distance from the fiber to the detector;; hence, it is
important that the samples be brushed or combed before
they are scanned to maintain a constant position. «I)t is
essential that pile orientation and its distance relative to
WKHVHQVRUEHPDLQWDLQHG´ibid., 12.2.8) Being so
essential, a non-subjective method should be employed
for correction.
3. In calibrating the equipment for the soil removal testing, one is
directed to raise the carpet sample up with shims until it
³DOPRVW´WRXFKHVWKHQRVHSLHFHRIWKH;5)XQLW(ibid., A1.1.4)
³$OPRVW´LVQRWDGHILQHGWHUP. One is directed to accept the
³DOPRVW´KHLJKWLIWKHUHDUH³QR´HOHPHQWVIURPWKHEDFNLQJ
detected in the sample, but if there are, one must incrementally
7
lower the sample until the amount of backing elements is
³QHJOLJLEOH´ ³1HJOLJLEOH´LVDOVRXQGHILQHGDQGthus creates
another point of subjectivity in the method.
Because this testing attempts to measure trace quantities,
QXPEHUVUHSUHVHQWHGE\³DOPRVW´DQG³QHJOLJLEOH´DUHPRUH
VLJQLILFDQWWKDQWKH\PLJKWVHHP)RULQVWDQFHD³QHJOLJLEOH´
amount of strontium found in the backing as is allowed in the
calibration would add to the strontium used in the test soil, thus
adding error to calculations and causing false positives.
E. Guide 7, 5.3 states that standards should be written in such a way that
variants are clearly defined and indentified. CRI has failed to do this.
1. &5,¶V%ronze, Silver, and Gold categories are described as based
on quantitative analysis. However, with all the issues involved
with the soil removal efficacy testing using XRF, these categories
are qualitative, misleading and unclear--until proper validation
and other method requirements have been proven. (Appendix
D)
2. Passing variants are listed one way on the CRI web site, but are
confusingly stated as tested in different ways elsewhere on their
site. Please refer to I.A.2.a and I.A.2.b above.
F. Guide 7, 6.1 states that test methods should be consistent with the purpose
of the standard. At least one of the specified test methods for conformity
assessment, Standard Test Method for Evaluation of Solid Particulate
Removal Effectiveness Using X-Ray Fluorescence Techniques for
Evaluating Cleaning Effectiveness of Residential/Commercial and
Central Vacuum Cleaners (Appendix B), has not been shown to be
relevant to the purpose of the standard. It has not been shown to be
8
correlated to real-world dirt removal, or to another laboratory test method
that has.
1. 7KHWHVWPHWKRGVWDWHV³7KLVWHVWPHWKRGLVQRWEDVHGRQKRPH
cleaning tests. There is no established correlation between field
and laboratory results. However it is reasonable to assume that
in most cases, a vacuum that performs well in the laboratory will
SHUIRUPZHOOLQDFWXDOXVH´ibid., 5.4.)
a. It is not reasonable to assume a correlation.
b. Again, this test method is replete with issues that make
validating and correlating paramount before any
assumptions should be allowed. Please refer to Appendix
D.
2. CRI has not provided any proper correlation or validation
materials to show that their tests function as stated and that
they are relevant to real-world experience. This test method has
not been shown to be consistent with the purpose of the
standard, as required in 6.1.
3. Further, ISO/IEC 17007, 5.4.8, specifies that test methods
³follow metrological principles concerning validation,
measurement traceability, and estimation of measurement
uncertainty GHVFULEHGLQ,62,(&&ODXVH´&5,
test methods (Appendices A, B, and E) do not. None of this
information exists or is available, despite private and public
requests, and despite a public CRI response to the contrary
(Appendix F). When validation is discussed, inappropriate,
incomplete and misleading studies are referred to. Robust
9
protocol in place to consider such errors. The low, outlying
score would bring down the average and thus create a false
ranking that makes the results incomparable.
H. *XLGHVWDWHVWKDW³:KHUHWHVWHTXLSPHQWLVRQO\DYDLODEOHIURPRne
VRXUFH«WKHVWDQGDUGVKRXOGLQFOXGHVXFKVSHFLILFDWLRQVIRUWKH
equipment as to ensure that comparable testing can be conducted by all
LQYROYHGSDUWLHV´ISO/IEC 17007, 5.2.4 states that test methods should be
³H[SUHVVHGLQVXFKDZD\WKDWDQ\LQWHUHVted party may carry out the
WHVWLQJ´ Any interested party may not carry out the testing.
1. The CRI standard, which in the absence of any such named
document is taken to mean the various criteria and testing
protocols/methods, does not provide enough information to
HQVXUHFRPSDUDEOHWHVWLQJE\³DOOLQYROYHGSDUWLHV´0LVVLQJfor
example, are:
a. what calculations are performed by software
b. how results are derived from raw data
2. CRI publicly states that no one besides their contractor,
Professional Testing Laboratory, has shown interest in doing the
testing. (Appendix F) This statement is untrue.
a. On one hand, CRI states that others are using the
technology for testing. (Appendix I)
b. Yet others, such as Racine Industries, have expressed
interest but have been denied the ability to perform the
testing. (Appendix Q) CRI disallows certain parties from
performing the testing, with the justification that this
11
1. CRI confuses the terms accuracy and precision and seemingly
uses them interchangeably. (Appendix K, 1 and 2)
2. CRI confuses the definitions of identification and quantification.
(Appendix K, 3)
3. CRI uses aQHQWLUHO\GLIIHUHQWWHVW¶Vaccuracy numbers in their
marketing and given technical information as their own.
(Appendix K, 4) They seem to assume that because a piece of
test equipment had a certain level of accuracy in identifying
elements in one kind of test method, that their related piece of
equipment will work how they wish an SOA test, and to the
same level of accuracy and precision.
4. Section 5.4.1 of ISO/IEC 17007 asks for what is acceptable in
terms of uncertainty of measurement, accuracy, reproducibility,
and repeatability. CRI has not been able to produce this
information. Despite the above precision and accuracy
references in 1, 2, and 3 above, no statements about precision
and accuracy may scientifically be made (Appendix B, page 8),
due to lack of information.
III. ISO/IEC Guide 65, Section 6, requires a certification body to give due notice
RIDQ\FKDQJHVLWLQWHQGVWRPDNHLQLWVFHUWLILFDWLRQUHTXLUHPHQWVDQG³VKDOO
take account of views expressed by interested parties before deciding on the
SUHFLVHIRUPDQGHIIHFWLYHGDWHRIWKHFKDQJHV´WREHSXEOLVKHG&5,KDVQRW
met these requirements.
A. CRI does not procedurally give an opportunity for interested parties or
concerned stakeholders outside the CRI to comment on or to be informed
on certification requirement changes.
13
2. Seal of Approval test procedures are changed without notice to
customers. Based on criteria posted on the CRI web site, Racine
Industries participated in an SOA conformance test;; the
equipment submitted was expected to pass easily. However,
when we received our report (excerpt, Appendix S), we noted
that the original sample specification had been crossed out and
replaced with a handwritten new specification. The specified
carpet sample for testing was replaced with another, without
consulting us. The result being that the equipment was failed.
If we had been consulted, we would have refused the test and
would have avoided being invoiced for a test we did not order.
Following Guide 65, Sections 4 and 6 may have prevented this.
[It is unknown if equipment tested before this specification
change occurred has been retested so that it would be more
comparable to more current conformance assessments;; if not,
there are further ISO/IEC 17007 4.5 issues.]
B. CRI also neglects to give due notice to committee members who vote on
related matters. For example, meeting agendas are sometimes sent just
before a meeting and contain little if any detail to review (Appendix H).
Certification-related topics are frequently voted on quickly with no
VXSSRUWLQJGDWDJLYHQWRUHYLHZ³,ZRQ¶WERUH\RXZLWKWKHGHWDLOV´LVa
sentence heard at many meetings.
14
IV. ISO/IEC 17007, 5.2.11, requires the use of SI units for measurements. CRI is
inconsistent in this regard. See test methods at Appendices A, B, and E.
V. ISO/IEC Guide 65, 4.2.p requires a certifying body to have policies and
procedures in place for handling certification-related issues received from any
SDUW\6LPLODUO\*XLGHPVWLSXODWHVWKDWDFHUWLI\LQJERG\¶VTuality
PDQXDOVKDOOFRQWDLQRUUHIHUWR³WKHSROLF\DQGSURFHGXUHIRUGHDOLQJZLWK
DSSHDOVFRPSODLQWVDQGGLVSXWHV´:KLOH&5,UHSHDWHGO\UHIHUHQFHVD3ROLF\
and Procedure Manual in their Carpet and Rug Institute Quality Manual and
cites it as part of their Quality System (and likely has submitted this document
to ANSI for approval), CRI also states that there is no Policy and Procedure
Manual available. (Appendix L) Denying the existence of and therefore
access to a Policy and Procedures Manual prevents due process and violates
the purpose and intent of numerous requisites in Guide 65.
VI. ISO/IEC Guide 65, 7.2 requires that a certification body keep a record of all
appeals, complaints and disputes and remedial actions relative to
certification, to take appropriate subsequent action, and to document the
action taken and its effectiveness. CRI denies, ignores or is otherwise unable
to provide evidence of serious questions regarding the testing program.
A. $QH[DPSOHRI&5,¶Vresponse to a question asking if a letter existed that
contained serious technical questions regarding some of the SOA test
PHWKRGVWKH&5,UHVSRQVHZDV³1RWWRWKHEHVWRIP\NQRZOHGJHEXW,
FDQ¶WUHVSRQGWRUXPRUVDQ\ZD\´Appendix O)
B. A draft version of A Discussion Regarding a Novel Method: the Use of X-
Ray Fluorescence for Quantitative Analysis of Elements in Carpet
(Appendix D) was sent to CRI March 25, 2010. (Appendix P) There was
no response from CRI;; that is, there was no response until the paper was
finalized and made public several months later. The response finally
elicited from CRI consisted of a dismissive press release, which included
15
no offer of remedial action or other attempt to work with the testing
problems (see their non-substantive public response at Appendix F). As is
required in Guide 65, 7.2, has CRI documented the ignoring of the
Discussion paper until it was published, and does the record reflect how
they voted to not respond further after their press release and how
effective their response has been? These actions and inactions cannot be
GHHPHG³DSSURSULDWHVXEVHTXHQWDFWLRQ´
VII. ISO/IEC Guide 65, 4.2m and 4.2n require that those involved be free from
commercial, financial, and other influential pressures. Guide 65, 4.4 refers to
conflict of interest in subcontracting.
A. CRI owns a major piece of prohibitively expensive testing equipment that
a CRI contractor uses to perform testing for CRI. CRI has a vested interest
in the use of this equipment, and thus cannot be considered independent
from its testing contractor.
B. This contractor is also a voting CRI committee member;; this contractor
controls the access and translation of (self-generated) technical data and
therefore has strong influence regarding committee voting on certification
program issues.
Conclusion
Participation in CRI programs or attending CRI meetings does not equal confidence in
the testing²numerous manufacturers feel forced to participate because of market and
legal pressures such as warranty requirements, legislation, and other standards and
procurement specifications that have agreed to incorporate a CRI approval as a
prerequisite. According to the National Institute of Standards and Technology,
voluntary consensus standards may be rendered mandatory when referenced in
regulations or procurement specifications, and may be rendered quasi-mandatory due
to conditions in the marketplace. (Appendix R) These qualifications apply here, and in
effect render the CRI SOA programs non-voluntary for manufacturers who desire to
16
continue selling their products. These pressures keep stakeholders paying for testing
when they otherwise might not be, and keep stakeholders interested in seeing rigor in
the standards process: livelihoods are at stake. Interest, presence at meetings, and
program participation do not indicate that a stakeholder condones or endorses the
process or outcome, or is otherwise in consensus with CRI.
The outlined examples of issues above indicate that much work still needs to be
attempted and accomplished. However, CRI is not interested in pausing and doing the
scientific work required first;; they have instead chosen to garner popular support rather
than factual data to further their program acceptance. 7KLV³IODZHGWHVWLQJLVEHWWHU
WKDQQRWHVWLQJ´SRVLWLRQKDVSXWDTXHVWLRQDEOH product ranking scheme into the
marketplace, with no successful method validation studies behind it, no passing peer
review by independent experts in the specialized lab technology utilized, and no public
due process used.
Sincerely,
Deborah Lema
Research and Education
Racine Industries, Inc.
Cc:
Reinaldo Figueiredo, Senior Program Director, Product Certification Accreditation at ANSI
Nikki Jackson, Program Manager, Product Certification Accreditation at ANSI
Shahin Moinian, Chair, ANSI Accreditation Committee for Product Certifiers
Ken McIntosh, Senior Technical Director at CRI
Pat Jennings, Technical Manager and Seal of Approval Coordinator at CRI
17
APPENDICES
Note: ISO/IEC Guide 65, General requirements for bodies operating product
certification systems, as well as related and incorporated guides and standards referred
to above and more, are available at www.ansi.org.
Appendix A
CRI TM 114: Standard Laboratory Test Practice (f)or Measurement (o)f Surface
Appearance Change (o)f Textile Floor Covering (a)s (a) Result (o)f (t)he Vacuuming
Process.
http://www.carpet-rug.org/technical_bulletins/1003_Test_Method_114.pdf
Also perhaps of interest, Assessment of Carpet Appearance Change using the CRI
Reference Scales: http://www.carpet-
rug.org/technical_bulletins/0307_CRI_TM_101.pdf
Appendix B
CRI TM 112: Standard Test Method for Evaluation of Solid Particulate Removal
Effectiveness Using X-Ray Fluorescence Techniques for Evaluating Cleaning
Effectiveness of Residential/Commercial and Central Vacuum Cleaners.
http://www.carpet-rug.org/technical_bulletins/1003_Test_Method_112.pdf
18
Appendix C
Asbury, G, and Shannon, RF, Quantification of (f)oreign (c)ontaminant from flooring
surface through XRF (t)echnology. Attached separately.
Relevant excerpt:
³«7KHUHLVDJHRPHWULFIDFWRUDVVRFLDWHGZLWKWKHGHVLJQRIWKHLQVWUXPHQWWKDW
decre(a)ses the signal as the source is moved farther from the instrument. Hence it is
critical to present the carpet fibers in the same pos(i)tion each time it is scanned. The
FDUSHWPXVWEHEUXVKHGWRUHPRYHPDWWLQJDQGVWDQGWKHFDUSHWILEHUVXS´Page 6,
Discussion of Errors)
Appendix D
Lema, D, A Discussion Regarding a Novel Method: The Use of X-Ray Fluorescence for
Quantitative Analysis of Elements in Carpet.
Appendix E
CRI TM 115: Standard Laboratory Test Practice (f)or Determining the Power Use
Effectiveness of Residential and Commercial Vacuum Cleaners.
http://www.carpet-rug.org/technical_bulletins/1003_Test_Method_115.pdf
CRI TM 113: Standard Laboratory Practice (f)or Quantifying Respirable Particulate
Emissions Generated by Residential/Commercial Vacuums and Central Vacuum
Systems.
http://www.carpet-rug.org/technical_bulletins/1003_Test_Method_113.pdf
19
Appendix F
"There is nothing [in the document] that has not been addressed either before or since
the SOA program was introduced at NASA's John F. Kennedy Space Center in the Fall of
2004(*)," Braun said. "It is disappointing to see questions listed as unanswered when
we have, in fact, answered Racine Industries on multiple occasions in writing."
http://www.scrt.org/news/73-cri-defends-validity-of-seal-of-approval-testing
([DPSOHVRIKRZ&5,DGGUHVVHV5DFLQH,QGXVWULHV¶FRQFHUQVin the above press release
include:
1. Having been asked for method validation studies, CRI replies that one has been
done but is in the peer review process (and is therefore unavailable). That is the
same response we have heard for years:
-----Original Message-----
From: Carey.Mitchell@shawinc.com
Sent: Friday, November 07, 2008 12:17 PM
To: Debbie Lema
Subject: Re: Encapsulation Study
The copyright is held by CIRI;; don't know the status of publication
**********************************************************
Privileged and/or confidential information may be contained in this message. If you are
not the addressee indicated in this message (or are not responsible for delivery of this
message to that person) , you may not copy or deliver this message to anyone. In such
case, you should destroy this message and notify the sender by reply e-mail.
If you or your employer do not consent to Internet e-mail for messages of this kind,
please advise the sender.
20
Shaw Industries does not provide or endorse any opinions, conclusions or other
information in this message that do not relate to the official business of the company or
its subsidiaries.
**********************************************************
-----Original Message-----
From: ss60@umd.edu [mailto:ss60@umd.edu]
Sent: Friday, November 07, 2008 8:21 PM
To: Debbie Lema
Cc: jim@janitronicsinc.com
Subject: Re: Shaw and CIRI Encapsulation Study- Paper.
Debbie Lema, Host/Racine Industries:
D:- are you referring to the separate paper Carey M presented at UNLV in 2007? If so,
pls. provide the full title from PowPt as the actual reference, clarity.
Note however that the detailed, full text CIRI 2007 papers have not [yet] been published
or made available. We have been looking for an approp. peer reviewed research journal
capable of reviewing and publishing the lengthy 2007 papers, as such.
I have finally made progress this year toward that goal...
In any event I do not have them;; assume that Jim Harris Sr, CIRI HQ and/or the CIRI
conf. proceedings reviewers do so. It's Jim Harris' to reply and determine their public
sale;; [we can discuss access and their distribution].
Did receive "Fritz@CRI" PowPt and DVDs for post-election read.
Steve Spivak.
[No further response from Jim Harris.]
21
2. CRI provides pictures of some of the designer soils used in the testing and
collected dirt as evidence of validation. However, these pictures contain little
useful information (e.g. numerical data comparing micron size) and have no
relevance to a measurement method validation.
3. CRI has recently provided some pages of undefined and untraceable numbers as
evidence of correlations between tests. These numbers are useless in this offered
form, but moreover appear to indicate a lack of correlation.
*Correction: the program introduction at the Kennedy Space Center happened in 2005.
Appendix G
http://realdirtoncri.wordpress.com/
A sample quote, illustrating the exclusion of a main stakeholder type by CRI:
³7KHUHDVRQWKLVEORJFDPHDERXWEHJDQZLWKWKHFRPSOHWHODFNRIGLDORJXHEHWZHHQ&5,
and residential professional cleaners. Cleaners¶ complaints and criticisms were being
brushed aside, articles by authorities in our industry completely ignored, and even
officially filed complaints ZULWWHQRIIDVDIHZLVRODWHGXQKDSS\SDUWLHV´
Appendix H
1. An example of a one-day notice of meeting agenda, amounting to about four or five
business hours for preparation, accompanied by review material for only two of ten
WRSLFVGDWHVHPSKDVL]HG7KLVGRHVQRWFRQVWLWXWH³GXHQRWLFH´DVUHTXLUHGLQ*XLGH
65:
22
If you have additional agenda items, please let me know ASAP.
Ken McIntosh
To sign up for CRI's newsletter, subscribe on our website at: www.carpet-
rug.org/newsroom.cfm#subscribe
To sign up for CRI's blog, subscribe at: www.criblog.org
****************************
This e-mail and any files transmitted with it are confidential and intended solely for the
use of the individual or entity to whom they are addressed. If you have received this e-
mail in error please notify the originator of the message. Any views expressed in this
message are those of the individual sender, except where the sender specifies and with
authority, states them to be the views of The Carpet and Rug Institute.
****************************
2. Below is an email example of how certification requirement changes may be
completed at CRI. The email gives committee members less than one business day to
UHVHDUFKDQGFRPPHQWXSRQDWHFKQLFDOWHVWFKDQJHWKDWZDVDOUHDG\³VXJJHVWHGDQG
DSSURYHG´E\WKHcommittee chairman.
----- Original Message -----
From: "Ken McIntosh" <kmcintosh@carpet-rug.org>
To: (Relevant Committee, addresses deleted)
Sent: Friday, October 12, 2007 1:32 PM
23
To sign up for CRI's newsletter, subscribe on our website at:
www.carpet-rug.org/newsroom.cfm#subscribe
****************************
This e-mail and any files transmitted with it are confidential and intended solely for the
use of the individual or entity to whom they are addressed.
If you have received this e-mail in error please notify the originator of the message. Any
views expressed in this message are those of the individual sender, except where the
sender specifies and with authority, states them to be the views of The Carpet and Rug
Institute.
****************************
Appendix I
The following excerpts are from one CRI lobbying effort to have their programs written
in as legislative requirements:
³7KHWHVWPHWKRGVXVHGLQWKHSURJUDPDUHLQWKHSXEOLFGRPDLQDQGFDQbe and are
currently being performed by other private labs, including several vacuum cleaners
PDQXIDFWXUHUV¶ODEV´Page 4)
³9DFXXPPDQXIDFWXUHUVKDYHUHTXHVWHGWREHDOORZHGWRFRQGXFWWKHLURZQWHVWLQJIRU
certification purposes;; however, the program¶VFUHGLELOLW\UHVWVRQWKLUG-party testing
DQGWKLVIRXQGDWLRQRIFUHGLELOLW\FDQQRWEHFRPSURPLVHG´3DJH
https://greencleaning.ny.gov/Docs/NewCleaningTechnology.rtf
25
Appendix J
Below are examples of CRI statements and answers that show the lack of necessary
technical expertise or desire to communicate the information that members, other
stakeholders, and the public need to make business decisions and/or provide input,
perform, or vote on certification matters.
1. Question : Why does the carpet sample being tested need to be brushed so that the
readings are more accurate if the readings detect all the soil through the fibers?
CRI Answer: The carpet is groomed just like the IICRC S100 standard. It is part of the
cleaning process. RQOLQHVWDNHKROGHUV¶³+RW6HDW´4 $LQWHUYLHZZLWK&5,
president Werner Braun, available at www.mikeysboard.com)
[The correct answer would have been that ³WKHUHLVDJHRPHWULFIDFWRUDVVRFLDWHGZLWK
the design of the instrument that decreases the signal as the source is moved farther
from the instrument. Hence it is critical to present the carpet fibers in the same position
HDFKWLPHLWLVVFDQQHG7KHFDUSHWPXVWEHEUXVKHG«´ (Appendix C)]
2. Question: Because questions of fairness to differing equipment and methods have
arisen, why does not CRI publish at least the basics of their test protocol(s)?
CRI Answer: Primarily because it is based on years of research and data that is not
easily digested. ³+RW6HDW´4 $LQWHUYLHZZLWK&5,SUHVLGHQW:HUQHU%UDXQ
available at www.mikeysboard.com)
[CRI also stated in the same interview WKDW³7KHWHVWLQJSURWRFROVDUHDYDLODEOHWR
DQ\RQHZKRZDQWVWKHPWKURXJKWKHODE<RXFDQJHWWKHPDVGHWDLOHGDV\RXOLNH´
However, those contacting the lab for detailed protocols have been told there is no
written protocol available from them. (Reference below at Appendix K.)]
26
3. Question: Why are there no water-soluble soils included in the test, when water is
used to suspend soils?
CRI Answer: Initially, research was done on a variety of soiling compounds and a
water soluble one was included. What we found during the early research was that it
was removed essentially by everything and did not offer us any manner to
differentiate in the testing, so it was replaced. ³+RW6HDW´4 $LQWHUYLHZZLWK
CRI president Werner Braun, available at www.mikeysboard.com)
[The correct answer would not have been that it was removed essentially by everything,
but that³We beliHYHWKDWWKHµWRSOD\HUVRIVRLOXVXDOO\KDYHDOOWKHZDWHU-soluble
components washed out, however it could be argued that table salt (NaCl) would be a
common particle found in carpets. Chemically Potassium Bromide, (KBr) is similar to
WDEOHVDOW¶ At most, only 62% of KBr was removed in trials. µ«The KBr percent removed
after chemical extraction is two percent less than after it was vacuumed. This of course
cannot be, and is likely due to a wicking of the KBr to the fiber tips. This wicking
problem is why in future testing KBr is not used.¶´ (Appendix C)]
4. ³:LWKVWDQGDUGL]HGSURWRFROWKHWHVWLQJODEFDQPHDVXUHWKHDPRXQWRIVRLODSSOLHG
to a carpet sample, clean the sample with a vacuum or extractor and quantify the precise
DPRXQWRIVRLOUHPRYHGIURPWKHFDUSHWGRZQWRIRXUGHFLPDOSRLQWV´(CRI Press
Release)
[Quantification and precision are in question in this test. Marketing the test as accurate
RUSUHFLVHWR³IRXUGHFLPDOSODFHV´LVIDOODFLRXVAs stated previously, no statement
about precision may be made (Appendix B), and XRF experts question that the test is
quantitative rather than qualitative (Appendix D))XUWKHUWKH³IRXUGHFLPDOSODFHV´
comes from a different test method not used in the SOA program (CRI Press Release).
27
Appendix K
From: lisa smith [mailto:truckmountgirl@gmail.com]
Sent: Monday, February 26, 2007 1:58 PM
To: Debbie Lema
Subject: Re: CRI
Hi Debbie,
I called and talked to Lloyd Cooper at the lab. He said there is no WRITTEN protocol
available, that you would have to get that from CRI. He also said quite a bit more that
was interesting. Too much to type for me, so give me a call @ (number deleted) and I'll
fill you in. You can call in the evening too, it's a home office.
Take care,
Lisa
Appendix L
From: Deborah Lema [mailto:dlema@hostdry.com]
Sent: Wednesday, August 25, 2010 10:05 AM
To: Ken McIntosh
Subject: Polcies/procedures
Hi Ken,
Will you please send me the CRI policies/procedures?
Thanks,
Debbie
28
Thanks Louise!
It looks like the procedures are separate, in the by-laws? May I have those too please?
Thanks some more,
Debbie
From: Louise Dobbs [mailto:ldobbs@carpet-rug.org]
Sent: Thursday, August 26, 2010 1:38 PM
To: Deborah Lema
Subject: RE: Polcies/procedures
Requested document attached.
From: Deborah Lema [mailto:dlema@hostdry.com]
Sent: Thursday, August 26, 2010 4:31 PM
To: Louise Dobbs
Subject: RE: Polcies/procedures
3OHDVHGRQ¶WEHDQQR\HGZLWKPH May I please have the CRI quality manual as well?
The documents keep referring elsewhere;; sorry!
Debbie
From: Louise Dobbs [mailto:ldobbs@carpet-rug.org]
Sent: Friday, August 27, 2010 8:16 AM
To: Deborah Lema
Subject: RE: Polcies/procedures
Requested document attached.
30
Item 9, MINUTES, Cleaning and Maintenance Issues Management Team, Meeting of
July 15, 2010:
³C & M IMT Response to Host Press Release and Close the Issues of
Responses to Host Press Release ± Ken McIntosh ± The C&M IMT draft Response
[immediately below in italics] to the Host Press Release was presented for review and
discussion. Motion made and seconded to accept. Vote taken 12 Ayes, 1 Nay. Ken
McIntosh made a recommendation that based on the number of responses made public
relative to the HOST Press Release that carpet related industry groups cease and desist
from issuing any additional responses. A motion was made and seconded for the carpet
related industry to consider not issuing any additional responses to this particular Host
Press Release. Vote taken 13 Ayes, 3 Abstentions.´
New 7-7-10 Proposed Draft
Draft response from CRI Cleaning and Maintenance Issues Management Team
The CRI Seal of Approval program was developed over several years in what was then
viewed as a very slow, methodical process. At several significant stages, input was
sought from external scientists to ensure that our direction was valid. Input was
received numerous times from Dr. Michael Berry, retired US EPA scientist and
research professor, Dr. Alan Hedge of Cornell University, and Dr. Barry Ryan of the
Emory University School of Medicine. [Note: None of whom are XRF experts.]
It is interesting to note that during the development of the SOA program, Racine
Industries personnel were members of the committee and were routinely involved in
the discussions, the approval process, and the votes. No concerns, like those raised in
the new white paper by Racine Industries, surfaced during the process. [Note: this
statement is misleading and incorrect. CRI apparently has kept no records of concerns.]
Racine CEO, Fritz Rench, in 2009, the C&M IMT listened to a presentation on his
perceived problems with the XRF test method. [Note: presentation was in 2008.] The
issues he raised were found at the time to be due to misinterpretations and a general
lack of understanding. Each of his issues was addressed in the meeting and later in
writing. [Note: some of his issues were indeed addressed, and addressed poorly,
incompletely, or dismissively. This document is available for viewing if desired by
ANSI;; it is largely without technical relevance.] For instance, the claim that the test
protocol was not available to Racine is preposterous, because, as the protocol was
developed and adapted over the years, it was routinely distributed to the entire group,
which included Racine personnel. [Note: CRI has been repeatedly confused by the term
³SURWRFRO´:KDWZDVDYDLODEOHZDVDOLVWRIFULWHULDIRUSDVVLQJEXWQRWHVWLQJSURWRFRO
Please refer to Appendix J.2 and Appendix K, showing the lack of availability of a
protocol to review.] The collective judgment of this committee is that the Racine white
paper appears primarily to be a reflection of dissatisfaction with a concept that does
not favor a particular product.
It is also instructive to note that the update of the Institute of Inspections, Cleaning,
and Restoration Certification (IICRC) S-100 Cleaning Standard is currently stalled due
to an appeal by Racine Industries. Since this is an ANSI standard, [Note: draft
standard] the process is clearly defined and the rules for achieving consensus are quite
stringent. Racine Industries personnel served on the IICRC committee throughout the
process, and apparently no issues were raised. [Note: Untrue, but also irrelevant.]
Now, the IICRC has been presented with a 100 page appeal questioning the standard ±
similar to the situation with CRI's SOA program. This pattern suggests a company
with some personnel that are not working for the betterment of the carpet industry
when given the opportunity to fully participate but to discredit the hard work of other
industry members after the fact while offering no better alternatives. [Note: Rather
than answer with substance, CRI attempts to discredit legitimate requests for
information, transparency and scientific diligence.]
The focus in recent years on the indoor environment has brought attention to the value
of identifying cleaning methods and systems capable of maintaining carpets relative to
high quality indoor environments. While &5,¶V62$SURJUDPVDQGWHVWPHWKRGVDUH
33
always available for improvement, they are fair ± they reasonably replicate real
world performance. [Note: how?] These programs utilize the best knowledge in the
industry today. The C&M IMT members are confident that the various CRI Seal of
Approval programs have contributed significantly to measurable improvements in
cleaning equipment, cleaning agents, and systems and have advanced the science of
cleaning. [Note: how?]
Appendix N
³No less a carpet man than Bob Shaw once stated iQIURQWRIRYHUUHWDLOHUVµMy 28-
ounce Stainmaster carpet is guaranteed to walk out in four weeks.¶´ >³:DONRXW´LV
industry jargon for losing texture appearance via foot traffic or, more simply, getting
frizzy from walking on it.]
http://www.fcnews.net/index.php/2010/06/salesmanship-the-lost-carpet-fiber/
Appendix O
http://www.talkfloor.com/TalkFloorTVSegments.aspx?psGroupID=253
Appendix P
Ken, Lee...
34
You are first class gentlemen. It's in that spirit I'm sharing
Debbie Lema's Draft Discussion re SOA testing of cleaning systems
ala XRF et al. She started it a couple of years ago. Then I stopped it,
only to ask her to re-start recently. She finished last week.
This material is not what was shared at the IMT session, Oct ' 08.
As noted then, I don't know anything about XRF technology.
My expertise is carpet performance relative to traffic and soil,
and some of the strategies and tactics re what to do about it.
A handful of people have received copies since Monday,
requesting their comments. The PR-strategy-survival world
is going to scream when they find out this draft has been sent
to you. But I just can't operate any other way.
For us this issue is about survival, not about personalities or agendas.
Best regards,
f
Appendix Q
The following series of emails contradicts the repeated CRI position that no one besides
their contractor, Professional Testing Laboratories, has indicated an interest in pursuing
the acquisition of XRF technology.
After KeyMaster copied CRI in on these emails indicating our interest in the XRF
equipment, subsequent repeated calls to KeyMaster (now Bruker) went unreturned.
The XRF equipment specified by CRI is not available to everyone.
35
----- Original Message -----
From: Deborah R. Lema
To: lstarks@keymastertech.com
Sent: Wednesday, July 27, 2005 4:52 PM
Subject: XRF Research
Hi Lloyd,
Per your request this afternoon, I am emailing to give you my email
address so that you may respond with quotes for us. Thanks in advance
for putting that together.
Regarding the NASA habitat research, I've been pondering a bit and think
our product-- at least our method-- would be a brilliant solution for
surface cleaning in such situations. How can I help you in the research
of this idea, with or without XRF? As I said on the phone, we like to
share information here, so please count us as a resource.
I will serve as your contact at this juncture, and here is my info:
Deborah R. Lema
Research and Education Associate
Racine Industries, Inc.
dlema@hostdry.com
800-558-9439
262-637-4491
FAX 262-637-0505
1405 16th Street
PO Box 1648
Racine, WI 53401
http://www.hostcarpetcleaning.com
36
Thanks again, Lloyd.
~Debbie
-------- Original Message --------
Subject: Re: XRF Research
Date:
Wed, 27 Jul 2005 17:24:27 -0400
From:
Lloyd Starks <ls_chemco@msn.com>
To:
Deborah R. Lema <dlema@hostdry.com>
References:
<42E7F3F6.3050005@hostdry.com>
Thanks Debbie!
Lloyd
-------- Original Message --------
Subject: Fw: XRF research:
Date: Tue, 2 Aug 2005 13:03:36 -0400
From: Lloyd Starks <ls_chemco@msn.com>
To: dlema <dlema@hostdry.com>
Debbie,
Let me know if you receive this!
Lloyd
----- Original Message -----
*From:* Lloyd Starks <mailto:ls_chemco@msn.com>
*To:* dlema@hostdry.com <mailto:dlema@hostdry.com>
*Cc:* kmcintosh <mailto:kmcintosh@carpet-rug.org> ;; John Landefeld
<mailto:jlandefeld@keymastertech.com>
37
KTI TRACER III XRF instrument $35,000.00
KTI TRACER III V XRF instrument $45,000.00
Debra, I look forward to working with you to address your needs.
Regards
Lloyd Starks
KeyMaster Technologies, Inc
www.keymastertech.com
(706) 270 0841
-------- Original Message --------
Subject: RE: XRF research:
Date:
Tue, 2 Aug 2005 14:35:23 -0400
From:
Ken McIntosh <kmcintosh@carpet-rug.org>
To:
Lloyd Starks <ls_chemco@msn.com>, <dlema@hostdry.com>
CC:
John Landefeld <jlandefeld@keymastertech.com>, Werner Braun
<wbraun@carpet-rug.org>, Joan Seelaus <jseelaus@carpet-rug.org>
Lloyd,
I believe you have composed several viable and interesting options for Host to consider.
CRI will be glad to offer suggestions and be available at any time to move the XRF
testing technology forward in the carpet related industries.
Kmc
[Silence from equipment manufacturer after this;; no returned calls.]
39
Appendix R
http://gsi.nist.gov/global/docs/USGuide_DocStds_2001.pdf, page 17.
0RUHFRQVLGHUDWLRQVDERXWZKDWGHILQHVD³9ROXQWDU\FRQVHQVXVVWDQGDUG´UHODWLYHWR
"Non-consensus standards," "Industry standards," "Company standards," or "de facto
standards," which are developed in the private sector but not in the full consensus
process:
http://www.whitehouse.gov/omb/circulars_a119/#3.
Appendix S
40