SUBJECT: REQUEST for COMMENTS on PROPOSED POSTPONEMENT of EFFECTIVE DATE for the Shifting

March 28, 2007

Our Reference: / File / «FILENOS»

SUBJECT: REQUEST FOR COMMENTS ON PROPOSED POSTPONEMENT OF EFFECTIVE DATE for the Shifting and Bunching Clauses for the Sixth Edition of the UL Standard for Marine Buoyant Devices, UL 1123 from September 01, 2007 until March 01, 2009.

Comments Due: April 30, 2007

An industry review notice dated August 11, 2005 was distributed to the Subscriber’s of UL’s Listing Service under the following categories regarding the new and revised requirements in UL 1123, effective September 01, 2007: OPZY – Flotation Aids and Special Use Devices and OQFZ – Near Shore Buoyant Vests.

Due to the concerns expressed by a significant representation of the manufacturing community regarding the severity of this requirement, a Working Group was formed at the STP meeting held on March 13th and 14th, 2007. This working group has been tasked to specifically develop appropriate methodology and data that will result in a refined requirement to evaluate the “shifting and bunching” of internal buoyant material. This Working Group consists of the following members:

1)Chris James (UL) - Chair

2)Sam Wehr (USCG)

3)Ralph Stegar (Stearns)

4)Robin Scott (Sport Dimension Inc., dba Body Glove Wetsuit Co., dba Jet Pilot, dba Hydrodynamic)

5)Dennis Campbell (Kent Sporting Goods Co. Inc.)

6)Steve Brugee (Safegard Corp.)

7)Maury Turner (UL)

8)Mike Cunningham (UL)

UL proposes to postpone the Effective Date from September 01, 2007 to March 01, 2009 for UL 1123 Section 5.4. Once the above STP Working Group develops a new method for determining appropriate shifting and bunching of internal buoyant material, the proposal will then be processed through the STP for ballot. Once a consensus has been validated, a new effective date will be established accordingly.

REQUEST FOR COMMENTS

Please provide your comments on the proposed postponement of effective date. Written comments should be sent by regular mail, fax, or e-mail to the attention of Chris P. James at UL’s Research Triangle Park, NC Office.Please reference all correspondence to Subject 1123. If you respond by fax or e-mail, please include your full name, title, company address, email address and phone number to ensure a reply. Please note that comments may be made public.

All comments should be sent to arrive by April 30, 2007.

Unless specifically requested to do so, UL will not acknowledge comments indicating concurrence with this proposal.

Thank you in advance for your communication on this topic.

Sincerely:

Chris P. James

Principal Engineer - Personal Flotation Devices

Ph: 919-549-1499

Fx: 919-547-6395

Underwriters Laboratories Inc.

12 Laboratory Drive

Research Triangle Park, NC 27709