ARRA Explanation for HDPE Fittings
May 20, 2011
To Whom It May Concern:
This letter is intended to describe the country of manufacture for fabricated HDPE pipe fittings and their conformance to the “Buy American” provisions of the ARRA. Please refer to the attached matrix illustrating the material’s relationships to the requirements of the act. This form was developed to create a template by which material origin can be evaluated as per the ARRA.
Note that we use HDPE pipe extruded by others as a raw material. Because some components and materials are not domestic U.S. in origin, we are unable to comply with the provision of Item 1 on the attached form.
However, conformance with any one of the Items 1, 2 or 3 qualifies material as ARRA compliant. Our provided material conforms with both Item 2 and 3.
Item 2a and 2b concern the alteration of one good to another. We fabricate fittings using
HDPE pipe as a raw material. Our operation changes the physical properties of the pipe good into one of another use—a pipe fitting. This change results in the change of a product with one use into a product with a different use. Therefore, these products satisfy the requirements of Items 2a and 2b.
Items 3a-e concern the manufacturing process we employ. A short description of our process might help to explain my responses to these questions. As a raw material, theHDPE pipe must be precisely cut to pre-determined lengths. Fabrication of some configurations require that portions of this material be heated until pliable, while keeping other portions cold and rigid. The pliable portions of the HDPE pipe section are then formed and shaped over or inside of steel tooling on manually operated hydraulic presses. The thermo-formed plastic fitting is then cooled so as to retain its new shape. Several such fabricated components may then be joined to complete fabrication. Butt-fusion joining of HDPE pipe segments and fitting sub-components is a costly, time intensive and highly skilled process that requires several distinct steps. Because the manufacturing of these fittings requires the above, the processes satisfy the requirements of Items 3 a-e.
All fabricated HDPE fittings are manufactured at our Bellingham WA or Stevensville MT locations.
If you have any questions or need more information, please contact me.
Sincerely,
Brad Sukolsky
Technical/QC Department
Specified Fittings
ARRA Explanation for PVC Fittings
March 1, 2011
To Whom It May Concern:
This letter is intended to describe the country of manufacture for the material in question and its conformance to the “Buy American” provisions of the ARRA. Please refer to the attached matrix illustrating the material’s relationships to the requirements of the act. This form was developed to create a template by which material origin can be evaluated as per the ARRA.
Note that we use PVC pipe extruded by others as a raw material. Because some components and materials are not domestic U.S. in origin, we are unable to comply with the provision of Item 1 on the attached form.
However, conformance with any one of the Items 1, 2 or 3 qualifies material as ARRA compliant. Our provided material conforms with both Item 2 and 3.
Item 2a and 2b concern the alteration of one good to another. We fabricate fittings using PVC pipe as a raw material. Our operation changes the physical properties of the pipe good into one of another use—a pipe fitting. This change results in the change of a product with one use into a product with a different use. Therefore, these products satisfy the requirements of Items 2a and 2b.
Items 3a-e concern the manufacturing process we employ. A short description of our process might help to explain my responses to these questions. As a raw material, the PVC pipe must be precisely cut to pre-determined lengths. Portions of this material must then be heated until pliable, while keeping other portions cold and rigid. The pliable portions of the PVC pipe section are then formed and shaped over steel tooling on manually operated hydraulic presses. The thermo-formed plastic fitting is then cooled so as to retain its new shape. Several such fabricated components may then be joined to complete fabrication. Because the manufacturing of these fittings requires the above, the processes satisfy the requirements of Items 3 a-e. All fabricated PVC fittings are manufactured at our Bellingham WA location.
If you have any questions or need more information, please contact me.
Sincerely,
Brad Sukolsky
Technical/QC Department
Specified Fittings
ARRA Form for PVC Fittings
CERTIFICATION OF SUBSTANTIAL TRANSFORMATION OF MANUFACTURED GOODS IN COMPLIANCE WITH ARRA BUY AMERICAN REQUIREMENTS
This project is being funded in part by funds from the American Recovery and Reinvestment Act of 2009 (ARRA). Section 1605 of ARRA requires the use of iron, steel and manufactured goods made in the United States.
Manufactured Good: PVC FITTINGS, FABRICATED
Manufacturer: SPECIFIED FITTINGS
- Were all of the components of the manufactured good manufactured in the United States and were all of the components assembled into the final product int he United States? No.
- Was there a change int he character of use of the good or the component in the United States? (The following questions pertain tot he the good as a whole and not the individual components.)
- Was there a change int he physical and/or chemical properties or characteristics designed to alter the functionality of the good? Yes.
- Did the manufacturing or processing operation result in a change of a product(s) with one use into a product with a different use? Yes.
- Did the manufacturing or processing operation result int he narrowing of the range of possible uses of a multi-use product? No.
- Was (were) the process(es) performed in the United States (including but not limited to assembly) complex and meaningful?
- Did the process(es) take a substantial amount of time? Yes.
- Was (were) the process(es) costly? Yes.
- Did the process(es) require particular high level skills? Yes.
- Did the process(es) require a number of different operations? Yes.
- Was substantial value added in the process(es)? Yes.
Per US EPA, if the answer to question 1, 2a, 2b, 2c or any two questions in 3 is (are) YES then the Manufactured Good is Substantially Transformed in the United States.
Manufacturer certifies that the Manufactured Good is Sustainably Transformed in the United States.
Brad Sukolsky
Technical/QC Department
8/31/11