The DLC understands that in some scenarios, products that are required to be tested may be unable to test in the necessary apparatus’ as stated in the Horticultural Technical Requirements, due to size or other restrictions. In the event that a product is identified as requiring testing for a DLC application, but cannot be tested due to the constraints of the testing equipment, the DLC will need to understand and collect the following information:
- Specific reasons why the product in question cannot be tested.
- A proposal from the manufacturer on how to evaluate the performance of the product. Proposals must comply with industry testing standards and be technically sound and demonstrate a thorough understanding of the product’s construction and performance-affecting variables.
- Rationale for why the proposal is representative of the product’s performance.
Proposals, once complete with the details mentioned above, will be reviewed on a case-by-case basis by DLC program management.
Please provide this information ahead of submitting an application as proposals need to be approved prior to allowing the use of alternate data within an application. This will help ensure application reviews are completed as efficiently as possible. As always, the DLC reserves the right to require additional information, and manufacturers should be prepared to provide documentation that addresses concerns that arise.
The DLC has developed and approved alternative procedures for testing products with a length greater than or equal to five feet and can be seen in the Horticultural Testing Constraints Equipment Size Restriction procedure document.
Development of additional standard procedures for evaluating performance of products with other testing restrictions is on the DLC policy development wish list. The DLC welcomes proposals for standardizing this process. Please send all proposals to email@example.com.