Gentlemen,
Sorry in the delay in responding to this, I have only
recently returned to office. I am sending this email at the request of
Chris Sheppard, of System Components Corporation, and would like to make the
following response to the noted comments for FL8700-R2.
QAI has reviewed the information in the response from
Ted Berman and Associates, and requests that the application not be deferred,
but be granted a conditional listing. This conditional listing would be
based on the following actions and response to the below noted comments:
Comment
1. The
independence of the validator from the entity verifying the installation
instructions. 2. The validator is not a Professional Engineer and the
technical validation requires certification of compliance with the Florida PE
administrative code.
Response: The application will be updated immediately
as noted by Ted Berman and Associates with the following actions.
Installation Instructions will be noted as reviewed by FL PE Chris Bowness, who has worked with extensively with this product,
and has confirmed the installation instructions as accurate. Upon update
to include Chris Bowness as the reviewer of the
installation instructions, this approval will be revalidated by Quality
Auditing Institute as an administrative validation.
Comment 2.
Evaluation report specifies exposure limitation in excess of 30 days
without conducting enhanced accelerated weathering specified in TAS 110
footnotes of sections 9, 10, 11 and 17. Use as a tile underlayment requires
compliance with TAS 103 or TAS 104. The Intertek
report 3071726-001 dated 9/29/05 does not confirm full compliance with TAS 104
as the report omits some of the testing specified in TAS 104 for polyester or
polypropylene reinforced membranes. *Limit exposure to 30 days and do not allow
use as a tile underlayment in the HVHZ. Else, indicate not for use in the
HVHZ.
Response: A 30 Day Exposure limitation will be
included during update of FL8700. Limitation will be noted in: Limit of
Use, section “Other” during update in response to Comment 1 above.
Regarding additional comments in Public Comment 2, the evaluation conducted by
Chris Bowness, P.E. and validated by QAI, outlined
TAS 104 compliance of the FelTex and ProTex products through testing outlined in QAI report
RJ1814E-1 dated 4/30/2013 and Intertek test report
3071726-001 dated 9/29/05. No reference in the evaluation conducted by
Chris Bowness inferred compliance to TAS 104 based on
the noted Intertek test report solely. As such,
QAI requests this comment withdrawn as the noted evaluation indicates
compliance to TAS 104 based on additional information reviewed by Chris Bowness, which are not noted in the public comment.
I will be available to discuss during the POC October
3rd to move this application
for conditional approval if the above is acceptable and look forward to your
response to the above.
Thanks,
Matt Lansdowne, P.Eng.,
M.Sc.
Business Manager – Building Products
Office: 604-527-8378
Cell: 604-358-4278