Hot Spring Spas of California has lost it's UL
listing
due to fires and not building spas to the ANSI UL standards for safety.
After the spas that caught fire with the 240 heaters on the tiny
Lainge
circulation pump, UL performed an investigation and discovered that the
design does not follow the UL safety instructions in regards to
installing an electric heater in a portable spa.
There are several design issues that contributed to the UL taking the
UL listing away from Hot Spring spas.
If you own a Hot Spring Spa with a UL sticker on it and it has a
240 heater, you need to contact the manufacturer for a recall and to
have the spa built to UL standards or have them give you your money
back. The UL listing is voided by the design errors on the spas
that can cause heater chamber over heat under normal operation.
According to the ANSI UL safety rules the heater exit temperature
cannot
exceed 122 degrees F. The normal operating temperatures of this
"No-Fault" heater is much higher than that.
According to spa designers the small circulation pump used does not
move the water fast enough through the heater to keep the water from
exceeding UL standards.
If you own a 120 V version, you must never covert it to 240 volts,
because of the possible scalding and fire hazards.
For every year that Hot Spring spas has had a "listing" it has
been "proud" to be "UL listed".
After they put in 240 V on that 120V heater, the spas started having
safety issues and continual heater problems, because you cannot put
240 Volts and 6,000 Watts on a heater connected to any of the Lainge
circulation pumps. It is against the UL and NSPI/ANSI.
Finally UL listened to me after the spas caught fire. I have been
telling the Watkins company about this for years, but they never
listened to me. I complained to the FTC and the US CPSC to no avail,
until the spas started catching on fire.
Read these two pages from the Hot Spring Owner's Manual.
You will notice that before UL investigated Hot Spring the manual shows
a UL listing on the back page. After the UL investigation, they show
ETL listing.
Unfortunately ETL was not advised by me of the ANSI and UL safety
issues of Hot Spring. Hot Spring spas are not safe to own. That is a
fact.
http://www.spashopperguide.com/Page60UL_03.pdf
http://www.spashopperguide.com/Page64_2004.pdf
Here Again is my letter to the UL and US Government Consumer Product
Safety Commission"
From: "Information Center" Date: Mon Jun 16, 2003 11:36:00 AM
America/Denver To: Subject: Report a product to UL
Hello, Thank you for contacting the U.S. Consumer Product Safety
Commission (CPSC). CPSC is an independent federal regulatory agency
that protects the public from the unreasonable risk of injury or death
from 15,000 products under our jurisdiction. CPSC would be interested
in filing a report regarding your safety concerns in reference to the
hot tub described below. Please contact our toll-free hotline at
1-800-638-2772, Monday - Friday, 8:30am to 5:00pm, Eastern Standard
Time. Press 1 to begin and then press 300 to speak with a
representative. However, to file a report with the Underwriters
Laboratory Inc. (UL), you can contact the UL toll-free at
1-800-285-4476 or via web site www.ul.com. Please be advised that you
may obtain CPSC publications, recalls and general safety related
information via our web site at www.cpsc.gov. Click on the "Search"
icon and type in your topic. You may also file an incident report via
the web site mentioned above. man/myg
-----Original Message-----
From: James Arjuna <A
HREF="mailto:[mailto:ja@spaspecialist.com]">[mailto:ja@spaspecialist.com]</A>
Sent: Saturday, June 14, 2003 8:02 PM
To: <A
HREF="mailto:James.Abplanalp@us.ul.com">James.Abplanalp@us.ul.com</A>
Cc: Information Center; <A
HREF="mailto:UCE@FTC.GOV">UCE@FTC.GOV</A>; <A
HREF="mailto:info@nspi.org">info@nspi.org</A>
Subject: Report a product to UL
Dear UL;
I am a pool and spa professional and I work in the design of hot tubs
and spas.
I am trying to understand how Watkins Products, Hot Spring Spas has a
UL listing, since they are not a safe product according to the ANSI
standards for building hot tubs and spas in the United States and your
own UL standards.
They have several areas where the do not conform to the ANSI standard
for safety and UL.
First of all I want to address the issue with the heater recall on the
"No-Fault" heater used with a 6000 Watt heater.
There was a recall issued by the US Consumer Products Safety Commission
back in Dec 2001.
<A HREF="http://www.cpsc.gov/cpscpub/prerel/prhtml02/02068.html">http://www.cpsc.gov/cpscpub/prerel/prhtml02/02068.html</A>
When I first heard about the use of the 6000 watt heater with the tiny
Lainge Circulation pump, I did some testing to see what the exit heat
from the heater under various conditions would be, it averaged 130
degrees or more on the water at the heater exit according using that
pump and the mazzie injection ozone system. Considering that the
filters are blocking the suction on Watkins circulation pump, when the
filter media is dirty the flow is even less, causing even higher
temperatures inside the heater housing. The average consumer does not
clean the filters as much as needed, so this engineering does not
account for actual use by Hot Spring owners.
Basically a 6,000 watt heater CANNOT be used on a water pump that moves
less than 18 to 20 Gallons per minute in order to keep the heater high
limits below the ANSI standard of 122 degrees F. It is because of
improper matching of originally a 120 V 1500 watt heater then upping
the power to 6,000 watts that this failure and the fires occurred. If
the heater had been tested by you, UL then you would see the exit heat
as being way to high for normal safety limits. That is why the recall
was only on the 6,000 watt versions. This is basically a dangerous
combination according to the ANSI standards for safety.
From The "American National Standards Institute, "American National
Standard for Portable Spas ANSI/NSPI-6 1999
Quote:
12.0 HEATER AND TEMPERATURE REQUIREMENTS
12.3.1 Water Temperature Regulating Controls: Water temperature
regulating controls shall comply with ANSI/UL 1563 "Standard for
Electric Hot Tubs, Spas and Associated Equipment". and UL 372 "Primary
Safety Controls for Gas and Oil-Fired Appliances."
Owner/operator shall routinely check the in-spa water temperature to
ensure that the temperature does not exceed 104° F. [40° C].
Any adjustment, if required, shall be performed in accordance with
manufacturer's specifications.
12.3.2 Water Temperature Limiting Controls: Water temperature limiting
controls shall comply with ANSI/UL 1563 "Standard for Electric Hot
Tubs, Spas and Associated Equipment". The water temperature at the
heater return outlet shall not exceed 122°F [50°C].
Unquote:
My commentary;
This seems pretty straight forward, except that the largest hot tub
manufacture on earth has a thermal high limit switch calibrated much
higher than this. The purpose of the high limit is to protect, the
bathers from super hot water entering the spa vessel from the heater.
If you have a 240 Volt, 6,000 Watt, heaters it is impossible for the
water to exit the heater at less than 122 degrees with a tiny
circulation pump. So, you cannot have a 240 volt 6,000 watt heater on
many spas according to this safety standard. If the filter clogs up,
the little child standing on the outlet of the heater in the floor of
the spa will have scalded feet (the reason for the safety limit in the
first place).
When that tiny circulation pump was first used it was on a 115 volt
1500 Watt heater, which is inadequate for cold climates. At 3 GPM they
still had problems with the high limit at 121 degrees tripping. The 121
Degree "Hi-Limit Switch" was the standard because it keeps the limit
below the specified 122 degrees in the ANSI Standard. As the other spas
progressed and started using larger heater, this company (Watkins) was
left in the dark ages with cold tubs. In order to compete, they started
using the same tiny amount of water flow on a 6,000 Watt heater. Some
of the early versions had a 151 degree F high limit on the heater. If
you ever get a chance, and want to see how hot that is, stick your
finger in 151 degree F water, and tell me if you could stand it?
<A HREF="http://www.cpsc.gov/cpscpub/pubs/5112.html">http://www.cpsc.gov/cpscpub/pubs/5112.html</A>
According the the ANSI standard above, the rate of water turn over for
a portable spa shall be the entire contents circulated in one hour to
have adequate, minimal filtering.
The Hot Spring, Watkins products do not follow that standard either.
Under Article V of the ANSI/NSPI American National Standard for
Portable spas also states:
Quoted:
5.0 CIRCULATION SYSTEMS
5.1.1 The system shall be designed to turn over the entire spa water
capacity at a minimum of once every hour.
Unquote.
If you do the math that means the a spa with 500 gallons must filter
12,000 gallons per day. In my testing a spa with 500 gallons use by
four people daily needs about 30,000 gallons of filtering in order to
clean up the water,, or you have to use lots of extra chemicals to help
the filtering.
Do the math: A 7 GPM ( maximum) tiny circ pump in a 525 ( The Watkins,
Hot Spring Grandee Model) gallon spa does not turn over the water once
every hour. At 5 GPM it is worse. According to the manufacture the spa
turns over the water from 5,200 gallons per day, not 12,600 gallons
required by the bare minimums of the ANSI standard.
On page 14 of their advertising brochure it states that they turn over
the water 10 to 15 times per day, instead of the ANSI required 24 times
per day. That means the owners are having to deal with poor quality
water, by using a lot more chemicals and water clarifiers, scum
digesters, more powerful and dangerous "corona discharge" ozone
gtenerators and the like. It is not good to breath the ozone from a
poor ozone system that allows the ozone to gas off above the water
where the bathers can breath it. *(See quote from the ANSI standard
below)
Considering that a spa with 500 gallons and four daily bathers has the
same amount of debris per gallon as a 20,000 gallon swimming pool with
200 swimmers, due to the heat, sweat, and the amount of human skin per
gallon of water, you can understand why I believe this is a health
hazard.
In my own testing a 500 gallon spa needs to have about 19,000 to 24,000
gallons of water turn over per day to have clean water, because of the
amount of body waste per gallon.
There have been several newspaper articles lately about people getting
sick from indoor hot tubs. The doctors believe that the build up of
bio-film in the spa spits out bacteria into the air and give the "hot
tub lung" disease. I believe that part of the problem is inadequate
filtering, that allows the scum to build up in the spa plumbing. Then
when the spa jets are turned on they spew out bacteria into the air
around and above the hot tub. In an indoor spa the bacteria is carried
to the sleeping area by the house ventilation system. This is a serious
problem that can be partially solved if the spa manufactures were to
follow the ANSI minimums.
I don't think the ANSI minimums are safe according to my testing on
spas regularly used by four or five people. Watkins doesn't even come
close to those inadequate minimums.
Under Article VIII of the ANSI/NSPI American National Standard for
Portable spas also states:
Quoted:
8.0 RETURN INLETS AND SUCTION OUTLETS
8.2.2 A minimum of two (2) suction outlets shall be provided for each
pump and the suction outlet system, separated by a minimum of three
feet (3) [91.44 cm] or located on two (2) planes; i.e., one (1) on the
bottom and one (1) on the vertical wall, or two (2) separate vertical
walls. These suction outlets shall be plumbed such that the water is
drawn through them simultaneously through a common line to the pump.
Unquote.
If you examine the Hot Spring, Watkins products there is no second
suction inlet on any of the spas. All of the water is passed through
two filters and they are on the same plane, in the same filter housing.
Also the size of the filters are not large enough each to fulfill the
UL on having each suction inlet be able to take the full flow of the
pump volume. The pumps on Hot Spring, Watkins are capable of 60 to 70
Gallons per minute GPM (according to their representatives) and the
filters are capable of a maximum of 30 GPM each, according to the
manufacture of the filter fiber and the largest filter housing
manufacture in the US, Waterway plastics. Each of the suction
"fittings" must be able to draw a minimum of 60 Gallons Per Minute,
equivalent to the total draw of the pump attached.
My commentary:
This is about a simple as "apple pie". You can change the spices in the
pie, but you can't leave out the "apples and the crust". You must, by
these rules of safety, separate the suction inlets and have two on each
jet pump. The fittings have to be ANSI/NSPI and UL safety suction
fittings as well and each suction inlet must be rated for the full flow
of the water pump.
Take a close look at a Hot Spring spa and tell my why you have put your
UL sticker on it. It is not only against the UL standards, it is
against the ANSI standards.
More.
Most all of the problems relating to this company is due to the 100% no
bypass filtering and the tiny circ pump, the two major selling points
they use. These spas should be outlawed, until they conform to the ANSI
and UL standards. Any spa that touts a 24 hour circulation pump, and a
6000 Watt heater, you better check to see what the circulation rate is
and the heater exit temperature. The bare minimum for safety is 18
gallons per minute according to my testing. When you start with a
flawed engineering, then try to build on it, it just gets worse. This
is why I tell consumers to avoid all spas that use a tiny pump, less
than 18 gallons per minute on a high Watt heater. That takes care of
about 20 brands that I know of, including all the major ones from
Southern California.
Because Hot Spring spas sells so many spas, other companies are
following these dangerous concepts of inadequate filtering and super
hot heater "high limits", including Sundance spas, Jacuzzi, Dimension
One and many others.
They seem to think that placing similar devices on their spas will
increase sales. In this way the sales people do not have to sell
against the concepts of the tiny worthless filtering from a Lainge pump
that moves 5 GPM past the mazzie injector.
This is a health and fire hazard (as already shown) and needs to be
rectified, NOW!
I have written directly to Hot Springs about these issues, and they do
not respond. They deny there is anything wrong with their spas.
You should take the UL listing of Hot Spring spas completely away,
until they conform to the safety standards of the United States.
Thank you for taking the time to consider this very important issue.
* Quote from the ANSI standard on Ozone.
Page 31 Appendix D.
Quote:
"Although the decomposition precludes the possibility of large amounts
of ozone being present, ozone, like all chemicals capable of oxidation,
is a hazardous substance, and ozone-generating equipment can produce
dangerous levels of the gas. The United States Occupational Safety and
Health Administration (OSHA) has standards for the exposure to ozone.
Research indicates that there are no irreversible effects caused by
accidental exposure to low non-lethal concentrations of ozone. As a
general principle, however, breathing even low levels of ozone should
be avoided at all times. Further information can be obtained from OSHA
or the International Ozone Association, Pan American Group, 31
Strawberry Hill Avenue, Stamford, CT 06902".
The way that Watkins uses ozone does not conform to this either. When
these reports were generated the CD(corona discharge) ozone generator
was not in common use. The CD ozonator produces nearly 5 to 7 times the
ozone output of the prior ozone generators. The only way to inject
ozone safely is to have shut off on the unit while the bathers are
present, or to use a 100% ozone saturation contact chamber, that
Watkins does not use. Raw ozone is escaping the top of the vessel in
fairly high concentrations.
I believe that an immediate recall be issued to Watkins to notify all
of their existing customers about the safety issues in the Watkins,
Hot Spring Products.
They Watkins proceed to repair and fix all of the existing spas that do
not conform to the UL or the ANSI standards for clean water; for
suction safety and heater high limit violations from the standard
maximum of 122 degrees F. The spas should be tested and the heater out
let temperatures tested to see if the outlet sends water higher than
the safety maximum. The water flow for filtering needs to be raised to
meet the minimums of the ANSI for 24 times a day of changeover and
second suctions need to be placed on each pump on all the existing spas
James Arjuna
Havenmade Inc.
Broomfield, CO 80023
CC: US Department Consumer Products Safety Commission
CC: The US,. Federal Trade Commission
CC: National Pool and Spa Institute