Texas Specification No. 425-40-04C
Effective Date: June 22, 1990
FILING CABINETS, STEEL, LATERAL, LETTER SIZE
1. SCOPE: This specification establishes the minimum requirements for free standing steel lateral filing cabinets which are adaptable for filing letter and other size materials either laterally or in a front-to-back arrangement under conditions of medium to heavy use.
2. APPLICABLE SPECIFICATIONS AND STANDARDS: Reference to specifications, standards, test methods, and other documents shall be to the issues in effect on the date of the Invitation for Bids. The following documents form a part of this specification to the extent specified herein:
2.1. AMERICAN NATIONAL STANDARDS INSTITUTE (ANSI), 1430 Broadway, New York, NY 10018:
2.1.1. ANSI/BIFMA X5.2-89 -- Office Furnishings, Lateral Files, Tests.
2.1.2. ANSI Z34.2-87 -- Self Certification by Producer or Supplier.
2.2. AMERICAN SOCIETY FOR TESTING AND MATERIALS (ASTM), 1916 Race Street, Philadelphia, PA 19103:
2.2.1. ASTM B-117 -- Method of Salt Spray (Fog) Testing.
2.2.2. ASTM D-522 -- Test Method for Elongation of Attached Organic Coatings With Conical Mandrel Apparatus.
2.2.3. ASTM D-523 -- Test Method for Specular Gloss.
2.2.4. ASTM D-2247 -- Practice for Testing Water Resistance of Coating in 100% Relative Humidity.
2.2.5. ASTM D-2794 -- Test Method for Resistance of Organic Coatings on the Effects of Rapid Deformation (Impact).
2.2.6. ASTM D-3359 -- Method for Measuring Adhesion by Tape Test.
2.2.7. ASTM D-3363 -- Test Method for Film Hardness by Pencil Test.
2.2.8. ASTM D-4060 -- Test Method for Abrasion Resistance of Organic Coatings by the Tabor Abrasive.
2.2.9. ASTM G-23 -- Practice for Operating Light-and-Water-Exposure Apparatus (Carbon-Arc Type).
2.3. IRON AND STEEL SOCIETY (ISS), 410 Commonwealth Drive, Warren Cole, PA 19103:
2.3.1. Sheet Steel Manual.
2.4. FEDERAL SPECIFICATIONS, Superintendent of Documents, U.S. Government Printing Office, Washington, DC 20402:
2.4.1. A-A-1709C -- Cabinet, Steel, Lateral and Front to Back Filing, Legal and Letter.
2.4.2. TT-C-490C -- Cleaning Methods for Ferrous Surfaces and Pretreatment for Organic Coatings.
3. CLASSIFICATION: Lateral filing cabinets shall be classified by type, size and style as follows:
3.1.1. Sliding door (nominal 12" height opening) overfile height.
3.1.2. Two drawer (nominal 12" height opening) height.
3.1.3. Three drawer (nominal 12" height opening) height.
3.1.4. Four drawer (nominal 12" height opening) height.
3.1.5. Four drawer (nominal 15" height opening) EDP height.
3.1.6. Five drawer (nominal 12" height opening) height.
3.1.7. Ten drawer (nominal 6" height opening).
3.2. Sizes: (See Table No. One.)
3.2.1. 36" wide.
3.2.2. 42" wide.
3.3.1. All drawers.
3.3.2. All shelves.
3.3.3. All drawers and one shelf (top).
3.3.4. All shelves and one drawer (bottom).
4. DEFINITIONS: Terminology used in this specification is intended to be generic in nature and consistent with meanings that have been defined through general use, industry standards, and accepted trade practices. Where variant meanings may exist, the applicable interpretation shall be determined by the Texas Procurement and Support Services (TPASS).
4.1. Lateral File: A file whose width is greater than its depth.
4.2. Normal Use: Use which can be expected in a general office setting operating on a standard forty (40) hour work week.
5. REQUIREMENTS: Products furnished under this specification shall meet or exceed the following requirements:
5.1. General Requirements:
5.1.1. Cabinets furnished under this specification shall meet or exceed the requirements of ANSI/BIFMA X5.2.
5.1.2. Cabinets shall be new, unused, currently standard products of an established manufacturer except for such deviations as may be required by this specification.
5.1.3. Cabinets shall be free of all imperfections, defects, and hazards which might affect appearance, normal life, serviceability, or user safety.
5.1.4. Details not specifically defined herein shall be in accordance with the best commercial practice for products of this type.
5.1.5. Cabinets shall be constructed to withstand the strains, vibrations and other conditions incidental to shipping, storage, and service.
5.1.6. There shall be no exposed raw metal edges.
5.1.7. All hardware shall be corrosion resistant.
5.1.8. All components not specifically mentioned, that are necessary for the units to be complete and ready for use shall be furnished.
5.2.1. All welding, riveting, and bracing shall assure rigid joints in proper alignment, and adequate strength.
5.2.2. Welds shall be sound and without porosity. Exterior welds shall be smooth. Interior welds shall be finished to eliminate sharp edges or rough surfaces. Corners shall be smooth,, rounded, and polished.
5.2.3. Files shall have one piece, wrap around construction (unitized). If stack-on or modular construction is employed, each module shall be unitized.
5.2.4. The file cabinet shall not deviate from a true vertical state (titling). Flanging or reinforcing shall assure strength and rigidity.
5.3. Materials: The materials used in the construction of lateral filing cabinets shall conform to the requirements stated herein. When not specified, they shall be of the quality used in good commercial practice.
5.3.1. Steel: The steel sheet used in fabrication of cabinets, drawers, and shelves shall be "commercial quality", cold rolled steel. Steel sheet used for all exposed parts shall have a "stretcher leveled standard of flatness" as defined in the applicable section of the Steel Products Manual.
The thickness of steel to be used for individual parts shall be as specified herein and are the minimum thicknesses permitted subject to the tolerances given in the Steel Products Manual. The steel sheet used shall be smooth, free of rust, scale, pits, scratches, laps, crimps, and buckles.
5.3.2. Hardware: The material for cabinet, drawer, and shelf face hardware shall be Type 302 corrosion resistant steel, anodized aluminum, chromium plated aluminum, chromium plated die-cast zinc alloy, brass, or bronze.
Hardware, bolts, nuts, screws and accessories located elsewhere in the cabinet shall be corrosion resistant.
Face hardware shall be polished or satin finish, whichever is manufacturer's standard. It shall be free of sharp edges and burrs.
5.4. Finish: All metal surfaces to be painted shall be thoroughly cleaned and free from dirt, oil, grease, and moisture.
The cleaning and priming of the surfaces shall conform to one of the methods of Federal Specification TT-C-490, at the manufacturer's option.
5.4.1. Enamel: The finish coat shall be enamel, applied and baked in accordance with the enamel manufacturer's recommendations. the enamel shall be a true baking enamel. air drying enamels, whose drying time is shortened by the application of heat or infrared rays will not be acceptable. The finish shall produce a smooth, uniform exposed surface without runs, wrinkles, grits, areas of thin film or no film, and separation of color. (See Paragraph 9.1.).
5.4.2. Color: When so specified in the Invitation for Bids, the color of finish shall be one of the following:
|Color Name||Color Code Number|
The above colors shall match those shown in the Texas Color Charts for Steel Furniture.
Note: When so specified in the Invitation for Bids, the manufacturer's full range or standard colors shall be acceptable. The bidders shall provide a cross reference chart identifying the color name and number with the Texas Color Chart. Colors equivalent to other major manufacturer's shall also be noted on a cross reference sheet.
5.4.3. Gloss: all finished colors for steel vertical filing cabinets shall have a minimum specular gloss rating of forty (40) at a sixty degree (60 °) angle when tested in accordance with ASTM D-523.
5.5. Cabinet: The cabinet case shall be manufactured of not less than twenty-two (22) gauge steel, be rigidly formed, braced, reinforced and welded to withstand heavy use without warping, twisting or distortion which impairs operation.
5.5.1. Interiors shall be completely modular and interchangeable so that cabinets can be retrofitted with new accessories and interiors as required.
5.5.2. When so specified in the Invitation for Bids, plastic laminate tops for free standing files shall be provided.
5.6. Drawers: Drawers shall fit squarely in their openings. The steel used shall be of sufficient thickness and quality to withstand heavy use. Drawers shall be of the fixed, solid front type and shall have the following features and components:
5.6.1. Drawer Configuration: All drawers shall have provisions for filing letter size material in a lateral manner and in a front-to-back manner. The drawers shall be easily converted (with the use of simple hand tools) from the lateral (side-to-side) filing configuration to a multiple compartment (front-to-back) filing configuration. (Exception: Six inch (6") Drawer.).
5.6.2. Sign Conversion: Each drawer shall be equipped with a component part which will enable conversion from letter to other size media. (Exception: Six inch (6") Drawer.).
5.6.3. Hanging Folder Frames: When so specified in the Invitation for Bids, each drawer shall be equipped with hanging folder frames to support legal and/or letter size material filed in a lateral manner or hanging frames to support documents filed in a front-to-back manner. (Exception: Six inch (6") Drawer.).
5.6.4. Follower Blocks: When so specified in the Invitation for Bids, each drawer shall have an adjustable follower block (compressor) to hold documents filed laterally. (Exception: Six inch (6") Drawer.).
5.6.5. Dividers: When so specified in the Invitation for Bids, each drawer shall have a minimum of three (3) vertical snap-in dividers per drawer (priced per set of three (3)) adjustable on approximately one to two inch (1"--2") centers, to hold documents filed laterally.
5.6.6. Safety Interlock Mechanism: Drawers shall have a safety interlocking mechanism which allows only one drawer to be opened at a time.
5.6.7. Optional Filing: When so specified in the Invitation for Bids, each drawer shall have provision for the following type filing (agency will specify drawer locations by numbering drawer and/or shelves from top to bottom):
220.127.116.11. Card Trays:
18.104.22.168.1. 5" x 3"
22.214.171.124.2. 6" x 4"
126.96.36.199.3. 8" x 5"
188.8.131.52.4. Floppy Discs.
184.108.40.206. 6" Drawer shall also have:
220.127.116.11.2. Flat Filing.
18.104.22.168.3. Card Trays.
22.214.171.124. 15" EDP Drawer shall also have provisions for:
126.96.36.199.1. EDP Printouts.
188.8.131.52.3. Center Point Hanger Bars.
184.108.40.206.4. Two Point Over the Hinging Frames.
5.6.8. Pulls: When so specified in the Invitation for Bids, drawer pulls shall be full width recess style.
5.7. Shelves: Filing shelves shall be the roll out type with receding or drop doors. The steel used in construction of filing shelves shall be of sufficient thickness and quality to withstand heavy use. filing shelves shall have the following features and components:
5.7.1. All filing shelves shall have provisions for conventional filing of letter size material in a lateral manner. (Exception: Six inch (6") Depth Shelf).
5.7.2. Configuration: All shelves shall be equipped with a component part which will enable conversion from letter to other side media. (Exception: Six inch (6") Depth Shelf).
5.7.3. Hanging Folder Frames: When so specified in the Invitation for Bids, each filing shelf shall be equipped with hanging folder frames to support letter size material filed in a lateral manner or hanging frames to support documents filed in a front-to-back manner. (Exception: Six inch (6") Depth Shelf).
5.7.4. Follower Block: When so specified in the Invitation for Bids, each shelf shall have an adjustable follower block (compressor) to hold documents filled laterally. (Exception: Six inch (6") Depth Shelf).
5.7.5. Dividers: When so specified in the Invitation for Bids, each shelf shall be furnished with at least three (3) snap-in dividers (priced per set of three (3)) to support letter size materials filed in a lateral manner. The dividers shall be adjustable on approximately one to two inch (1"-- 2") centers.
5.7.6. Optional Filing: When so specified in the Invitation for Bids, each shelf shall have provisions for the following tray type filing. (Agency will specify into which shelf (s) these types of filing are to be providing by number shelves from top to bottom.)
220.127.116.11. Card Trays:
18.104.22.168.1. 5" x 3"
22.214.171.124.2. 6" x 4"
126.96.36.199.3. 8" x 5"
188.8.131.52.4. Floppy Discs.
184.108.40.206. 6" Shelf shall also have:
220.127.116.11.2. Flat Filing.
18.104.22.168.3. Card Tray. (Not necessary to provide for letter or legal filing due to height of shelf.)
5.7.6..3. 15" EDP Drawer shall also have provisions for:
22.214.171.124.1. EDP Printouts.
126.96.36.199.3. Center Point Hanger Bars.
188.8.131.52.4. Two Point Over the Hinging Frames.
5.8. Drawer and Shelf Suspensions: All drawer and shelf suspensions shall travel easily and smoothly. All moving parts shall be permanently lubricated. Suspension shall accommodate uneven drawer loads or indirect push and/or pull forces.
5.8.1. The case tracks shall be secured to prevent horizontal and vertical movement. Tracks shall be in proper relation to each other and shall hold the compartments squarely in compartment openings.
5.8.2. The suspensions (drawer supports) shall be of the ball bearing and/or solid type and designed to permit drawers or shelves to be closed by pressure applied at any point on the drawer or shelf front without binding. Each receding door, drawer, and shelf shall contact rubber or polyplastic bumpers when fully closed. Outstops shall prevent the drawer or shelf from falling from the cabinet when it is fully extended.
5.8.3. Detents: Detents shall provide a positive anti-rebound feature which retains compartments in their closed position without creeping or running forward.
5.8.4. Corrosion: All suspension systems parts shall be corrosion resistant.
5.8.5. Operation: Drawers and shelves shall have full travel suspensions which extend far enough to allow unobstructed insertion and removal of hanging files. Drawer operation shall be silent.
5.9. Posting or Reference Shelf: A posting shelf on five (5) tier cabinets shall be provided if so specified in the Invitation for Bids. The shelf shall be located between the third and fourth tiers of the cabinet.
5.10. Adjustable Glides (Levelers): The glides shall be positioned one (1) at each of the four (4) corners on the cabinet bottom. The glides shall have an adjustment form zero (flush with the cabinet bottom) to not less than three-fourths inch (3/4") when fully extended. the base of the glide shall be not less than one inch (1") in diameter. Glides shall be finished smooth so as not to abrade floor surfaces.
5.11. Safety Interlock: All cabinets shall be provided with a positive mechanical interlock mechanism. When one (1) drawer or shelf is extended up to two inches (2") beyond the fully closed position, the safety interlock shall have been activated, and on other drawer or shelf in the cabinet shall extend more than two inches (2") beyond the face of the cabinet.
5.12. Lock: When so specified in the Invitation for Bids, the cabinet shall be equipped with an automatic unit lock. The locking mechanism may be integral with the interlock mechanism or may be a separate built-in mechanism which will lock all doors or shelves when activated. Two (2) keys shall be provided. The locking mechanism shall hold the drawers and/or doors positively locked against forward tilting of the cabinet or raising or lowering of the drawer or door front. The lock shall be permanently lubricated.
5.13. Knockouts: All cabinets shall be provided with knockouts to facilitate ganging of cabinets or anchoring to wall.
5.14. Dimensional Requirements: The dimensions of lateral filing cabinets shall be as specified in Table Nos. One and Two.
TABLE No. ONE (1)
CASE OUTSIDE DIMENSIONS
|Case Height||No. of Drawers||Case Width 1||Case Depth 1||Interior Height 1|
TABLE No. TWO (2)
INSIDE DIMENSION OF DRAWERS AND SHELVES
|6" Drawer||36" case: 33" wide x 15-1/8" deep.|
|6" Drawer1||42" case: 39" wide x 15-1/8" deep.|
|12" Drawer1||36" case: 33" wide x 15-1/8" deep.|
|12" Drawer1||42" case: 39" wide x 15-1/8" deep.|
|15" Drawer (EDP)1||36" case: 33" wide x 15-1/8" deep.|
|15" Drawer (EDP)1||42" case: 39" wide x 15-1/8" deep.|
|6" Rollout Shelf||36" case: 33" wide x 15-1/8" deep.|
|6" Rollout Shelf2||42" case: 39" wide x 15-1/8" deep.|
|12" Rollout Shelf2||36" case: 33" wide x 15-1/8" deep.|
|12" Rollout Shelf2||42" case: 39" wide x 15-1/8" deep.|
|15" Rollout Shelf2||36" case: 33" wide x 15-1/8" deep.|
|15" Rollout Shelf2||42" case: 39" wide x 15-1/8" deep.|
|12" Sliding Door Overfile||36" case: 33" wide x 15-1/8" deep.|
|12" Sliding Door Overfile||42" case: 39" wide x 15-1/8" deep.|
5.15. Options: Options shall be as specified in Paragraphs 5.4.2., 5.5.2., 5.6., 5.7., 5.9., and 5.12. (color, laminate top, drawers, shelves, and locks).
5.16. Vendor Requirements: Bidders shall be responsible for completion of bid response (See Paragraph 14.1), test certification (See Paragraphs 6 and 14.2.) and color reference sheets, if applicable (See Paragraph 5.4.2.).
6. TESTING: Testing shall be done by, or at the direction of, the Texas Procurement and Support Services and/or the receiving State agency. Tests shall be performed on products from shipments to ordering agencies. In the event products tested fail to meet or exceed all conditions and requirements of this specification, the cost of the samples used and the cost of the testing shall be borne by the supplier.
6.1. Tests: The products furnished under this specification shall be tested by the following methods or approved equally applicable procedures: (Certification is required.)
6.1.1. ANSI/BIFMA X5.3.
6.1.2. Table Three (3).
6.2. Certification: The vendor shall submit certified laboratory test results to the Commission with the bid. (See Attachment No. One.)
TABLE No. THREE (3)
|Specular Gloss||ASTM D-523, glossmeter geometry of 60 °||40-60 (high gloss)|
|Colorfastness to Light||ASTM G-23, Method 3, carbon-arc lamp 120 hours exposure||Maximum 20 AATCC units fading. No chalking, significant yellowing, etc.|
|Hardness||ASTM D-3363, Use Eagle Turquoise T2375 or Eberherd Faber Microtomic pencil leads.||"H" hardness, minimum.|
|Adhesion||ASTM D-3359, Method B.||4B: 5% maximum adhesion loss.|
|Abrasion||ASTM D-4060, Taber Abraser CS-10, 1000 gram load.||Maximum 40 mg/50 cycles weight loss.|
|Deformation||ASTM D-2794, Indirect||30 in-lbs., minimum at impact failure end point.|
|Elongation of Coatings||ASTM D-522, conical Mandrel Test.||No severe cracking.|
|Water Resistance||ASTM D-2247, 100% relative humidity.||200 hours exposure with no evidence of water related failure of the coating.|
|Corrosion||ASTM B-117, salt spray.||72 hours exposure. No corrosion.|
7. SAMPLES: Unless otherwise specified in the Invitation for Bids, no prepurchase samples will be required. Testing shall be performed on samples taken from regular orders (See Paragraph 14.3.).
8. INSPECTION: Products furnished under this specification shall be inspected by, or at the discretion of the Texas Procurement and Support Services and/or the ordering State agency either at destination or place of manufacture.
9. WARRANTY: All cabinets shall carry the manufacturer's standard warranty and shall be guaranteed against defects in materials, workmanship, and performance for a minimum of five (5) years. The warranty shall begin on the date of acceptance of the unit by the ordering agency. During this warranty period, the vendor shall repair or replace defective components and/or units at no cost to the State of Texas.
9.1. Finish: For cabinets having any areas of thinness and/or separation of color (allowable only on inside of drawer heads and cabinet bottoms), the manufacturer must provide a minimum five (5) year warranty.
10. AVAILABILITY OF SERVICE AND PARTS:
10.1. Service: When so specified in the Invitation for Bids, the bidder shall submit a list of companies or individuals, and their addresses, who stock repair parts and who can perform service on the equipment furnished.
10.2. Parts: A adequate supply of repair parts shall be readily available for the expected life of all products furnished under this specification.
11. INSTRUCTION MANUAL: The vendor shall furnish the ordering agency with one (1) copy of operating and maintenance instructions for each product delivered. The materials furnished shall include instructions for cleaning and protecting the exterior finish.
12. PACKING AND/OR PACKAGING: Packing shall be in accordance with recognized industry practices in a manner readily acceptable by common carriers engaged in interstate commerce. Within the shipping carton, units shall be packed in a manner designed to minimize damages during shipment due to rough or improper handling.
12.1. Delivery: When so specified in the Invitation for Bids, delivery shall be by one of the following:
12.1.1. Agency receiving dock.
12.1.2. Inside delivery, non-installed.
12.1.3. Inside delivery, installed.
13. MARKING AND/OR LABELING:
13.1. Marking: Each shipping container shall be clearly marked with:
13.1.1. Name of contents.
13.1.2. Order number or contract number.
13.1.3. Name and address of ordering agency.
13.1.4. Agency requisition number.
13.1.5. Name and address of the manufacturer.
13.1.6. Quantity contained.
13.2. Labeling: Each product shall bear a securely affixed and durable label showing the following:
13.2.1. Manufacturer's name.
13.2.2. Manufacturer's trademark.
13.3. Caution Labeling: Caution labels containing operation and safety instructions may be affixed directly to lateral files at the option of the manufacturer. The manufacturer shall provide safety instructions which include, but are not limited to:
13.3.1. Cabinet leveling procedures.
13.3.2. Loading techniques.
13.3.3. Recommendation for weight distribution.
13.3.4. General safety precautions.
14. BID LITERATURE: All bids shall be accompanied by a complete and illustrated description of the products being offered.
14.1. Bid Response: Bidders shall provide a line item by line item written answer to all technical specifications of Paragraph 5.
14.2. Certification: Bidders shall provide testing lab certification that the files meet the requirements of Paragraph 6. and ANSI/BIRMA X5.2. See Attachment No. One.
14.3. Bid Samples: The manufacturer and/or vendor shall provide samples within ten (10) days of request.
15. COMPLIANCE: In order for consideration to be given to the bid on an item under this specification, the bidder must comply with the following:
15.1. Product Identification: The make, model number, name of the manufacturer, brand or trade name, etc., as applicable, of the item which the vendor proposes to furnish must be stated as part of the bid.
15.2. Exceptions: Notwithstanding the above, any exception taken by the bidder to the requirements and conditions of this specification must be stated and described in detail as a part of the bid. If no exceptions or deviations are identified in this manner, the items must be furnished exactly as described herein.
15.3. Proof: The bidder shall bear the burden of proof of compliance with this specification.
16. REFERENCED MANUFACTURERS: The following manufacturers are listed for reference purposes only. Such references are not meant to be restrictive. Listing dose not relieve the manufacturer and/or vendor from meeting each requirement of this specification.
16.1. Manufacturers: All Steel, Burroughs, GF, Haworth, Invincible, Office Specialty, Shaw Walker, Steel Case, StorWal.
17. PRODUCT INFORMATION: All roll-out lateral filing systems because of their design can, under certain conditions, tip or fall over when in use. It is recommended that these precautions be followed to insure satisfactory performance:
The unit is equipped with a device that prevents more than one drawer or shelf from being extended at any one time. Do not try to override or disconnect this device as the file may tip.
When the files are used side by side, or back to back, it is recommended that they be fastened together (ganging) and if used against a wall, that they be anchored to the wall.
When loading the empty cabinet with filing material, do so by evenly distributing the material among all openings, staring with the bottom openings first. Fully loading the top opening first, and then extending it, may cause the file to tip.
18. ORDERING DATA: When ordering products conforming to this specification the requisitioning agency shall specify the following:
18.1. The number of this specification (425-40-04C).
18.2. The type of file cabinet (See Paragraph 3.1.)
18.3. The size (See Paragraph 3.2.).
18.4. The style (See Paragraph 3.3.).
1.8.5. The color (See Paragraph 5.4.2.).
18.6 Options (See Paragraph 5.15.).
18.7. Service (See Paragraph 10.1.).
18.8. Delivery (See Paragraph 12.1.).
18.9. Quantity required of each model.
19. AVAILABILITY OF SPECIFICATIONS: Copies of this specification may be obtained by calling or writing:
Texas Procurement and Support Services
Austin, TX 78711-3047
ATTACHMENT ONE (1)
CERTIFICATE OF COMPLIANCE
To: Purchaser "N"
Texas Procurement and Support Services
P. O. Box 13186
Austin, TX 78711-3047
By my signature below, I hereby certify:
1. that I an officer of my company and am authorized to make this certification;
2. that the information contained herein is true and correct and is provided in accordance with ANSI standard Z 34.2: Self Certification by Producer or Supplier;
3. that records verifying the information contained herein will be made available, upon request, to the Texas Procurement and Support Services of the State of Texas in accordance with the provisions of ANSI Standard Z34.2;
4. that this certification is for the following product manufactured by my company:
Model No: _______________ Description: _______________
5. that the product identified above meets or exceeds all requirements of the following Texas Specification No. 425-40-04C, Filing Cabinets, Steel, Lateral.
6. that the product identified above meets or exceeds all applicable requirements of the following documents as determined by our own testing program or the test results of an independent testing laboratory.