National Floor Safety Institute (NFSI) Provides Rebuttal to the Consumer Specialty Products Association (CSPA) Advocacy Group Study
I, along with respected members of the safety community, found the recent release of the Consumer Specialty Products Association CSPA study entitled, “Measuring the Slip Resistance of Wet Floors” troubling and perplexing at the same time, as it represents outdated, erroneous and very old information from a floor-finish makers’ advocacy group.
This attack by the CSPA on portable walkway testers dates back to an earlier ambush (Circa 2004-05) on the position of the National Floor Safety Institute (NFSI) during a public hearing between the NFSI and the Consumer Product Safety Commission (CPSC).
Although the CSPA claims this paper - “Measuring the Slip Resistance of Wet Floors” - is new, it is most certainly not new, or even accurate. Most of the content dates to 2004-2005, and February 2010. Then, as now, the information does not reflect the body of knowledge and majority opinions of those in the field of safety and health.
By their own words, “The Consumer Specialty Products Association (CSPA) is the premier trade association representing the interests of companies engaged in the manufacture, formulation, distribution and sale of more than $100 billion annually in [cleaning chemicals, floor finishes and related products.]” Brackets are ours. In addition, the paper’s authors have enjoyed rather distinguished careers as lab technicians for leading floor finish manufacturers.
CSPA authors claim the traction qualities of wet floors cannot be properly tested, and that the five portable test devices examined have technical flaws making them unreliable.
However, the “scientific” study presented as evidence by CSPA is deeply flawed, and a rehash of old “information” that has been refuted by better studies and data.
Shortly after the first publication of this old information in 2004, the NFSI rebutted its specious claims in a November 29th, 2004 article entitled “NFSI and CSPA Face Off on Floor Safety” published in a major trade outlet.
The CSPA’s second publication of this “info” dates to 2010, and in response, the NFSI again issued a straightforward rebuttal: “Who is the CSPA and Why Are They Attacking the NFSI.”
With the third most recent release of this report, one can only speculate as to the motives of the product advocacy-group, CSPA. Perhaps they think that if they allow enough time between releases that readers will actually think it’s news!
Most astounding, and frankly embarrassing for the report’s authors, are the copious errors in this older report; derived largely from an attempt to compare five dissimilar portable slip resistance test devices which each measure different forms of slip resistance – making it an “apples to oranges” comparison at best.
A brief list of technical errors includes:
1. Section 2.1.2 of the paper claims the English XL is a dynamic testing device (measuring Dynamic Coefficient of Friction or DCOF) when it is not. The XL belongs to a family of tribometers (slip resistance testers) known as VIT’s or Variable Incidence Tribometers. The XL measures a form of slip resistance called the “Slip Index” which is clearly stated on the devices “scale” - and not DCOF. This is clearly stated by its inventor, Bill English (deceased), in his books, as well as in the manufacturer’s (XLT, Inc.’s) operating manual which emphatically states: "The XL does not measure forces…its output can't be DCOF…" and "…it is not measuring dynamic or static COF on wet surfaces, it is measuring slip resistance". Thus, the XL can only measure SCOF dry and the stated "slip resistance index" when wet.
2. Section 2.1.3 of the paper states that the Brungraber Mk. II measures DCOF which again is incorrect. The Brungraber Mk. II measures TCOF or Transitional Coefficient of Friction and not DCOF, a fact widely understood within the floor safety industry.
3. Section 4.2.2 of the paper cites the ASTM F1679-00 standard along with the ASTM F1677 standard (cited in section 4.2.3) as authoritative. Both of these standards were withdrawn by the ASTM in 2006, and for the past 7 years have not been recognized test methods.
4. Section 5.0 of the paper attempts to compare test results of five different tribometers when (as noted above) no two actually measure the same form of slip resistance, and therefore do not have comparable scales of measurement. For example:
The English XL measures the Slip Index (apples) while the Brungraber Mk. II measures TCOF (oranges). The British Pendulum measures DCOF (yet a different fruit) while the UWT measures SCOF (yet another disconnect). You get the point!
In short, it would appear the authors are either ill-informed, and lack technical knowledge of the field of tribometry - or they are simply seeking to mislead the reader.
Furthermore, the cited NFSI “Universal Walkway Tester” (UWT) has not been in production for nearly 8 years, and has been replaced by the BOT-3000 and the BOT-3000e, both of which are manufactured and sold by Reagan Scientific, Inc.
5. On Page 15 of the paper, the authors state they used a Neolite sensor to measure dry COF with the UWT. The UWT explicitly calls for the use of a leather sensor and not Neolite when measuring dry surfaces - something even a novice operator would know.
Neolite is a hard rubber-like compound which when used on dry surfaces will produce artificially higher readings than that of leather. Again, the authors either did not know how to properly use a UWT, or - they are seeking to mislead the reader.
6. Page 16 Figure 9 was probably the case because the device was being operated by an incompetent person.
CSPA is Peddling Junk Science
Then and now, the content of this paper is full of inaccuracies, technical errors, and, frankly, nonsense. In the legal system, this type of “evidence” is referred to as “Junk Science.”
Sound Science Prevails
Then, as now, it is urgent to properly address the growing slip-and-fall problem faced by many users of commercial floor finishes - with sound, well-vetted science.
The field and science of walkway safety has advanced considerably since the first publication of these fallacious and misleading arguments.
In 2006, the ANSI B101 committee was formed and issued a series of five new standards. The ANSI B101 committee is comprised of 28 members representing various industries or governmental agencies such as OSHA, the CDC, or the Department of Defense (DOD).
All ANSI B101 standards for measuring COF do so under wet conditions because wet testing has gained the support of independent researchers worldwide.
Last year, the ceramic tile industry abandoned their dry test method (ASTM C-1028) for a new wet DCOF test method (ANSI A137.1) which is nearly identical to that of the ANSI/NFSI B101.3-2012 standard that was adopted by the polished concrete industry.
The only industry which still clings to a dry test method and shuns the established, scientific soundness of a wet test method, is the American floor finish industry.
Times have changed, but manufacturers of commercial floor polishes and their Washington D.C. based-lobbyist group (CSPA) have not.
Slips and falls are a leading cause of injury in the U.S. and top the list of reasons for seeking emergency room visits. This year more than 24,000 American’s will lose their lives as a result of an accidental fall, many of which take place on retail floors.
With this in mind, we sincerely hope the CSPA will take notice of the cause and effect relationship between poorly-maintained commercial floor finishes and slips and falls, and abandon their outdated and erroneous views.
People slip and fall most often on wet, poorly maintained floors, which is why the safety community unreservedly supports testing of traction on wet floor surfaces.
Russell J. Kendzior, President, NFSI
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