# Presentation: 787536

## ENERGY STAR for Residential Light FixturesDurability ImplementationJune 23, 2003

## ENERGY STAR Durability Requirements

- ANSI-IEC Lamp Standardization:
- Proposing to Add to RLF Eligibility Criteria through Specification Amendment.
- Maximum Ballast Operating Case Temperature:
- Enforcement Through Current Specification (V. 3.1).

**Notes:**
Corresponds to the two problems ID by LRC Heat and lamp/ballast compatibility.

## Purpose of Durability Requirements

- Compliance with ANSI Standards for Lamps:
-  Compatibility.
-  Accountability.
- Compliance with Maximum Ballast Operating Case Temperature for Optimal Performance:
-  Existing requirement.
-  Key to addressing premature failures.

**Notes:**
Reasons for Amendment:
Standardization is one way fixture manufactures can make sure the lamp and ballast being used in their fixtures are compatible.
Provides fixture manufacturers the information needed to select a ballast or design a ballast that will operate the lamp –fixture manufacturers should understand the relationship between lamp and ballast in the fixture.
Note: LRC recommends this as an interim step– According to LRC, ANSI compliance does not reduce uncertainty as to premature failures or that products will meet rated life.
Electrical Information per ANSI C82 is already required for many ballast performance requirements. 
Reasons for Enforcement:
Anecdotal reports of premature failures from industry, retailers, and consumers caused concern.
LRC Research: Evidence that temperature is high inside the fixture. The manufacturers and round table participants (first roundtable) suggested the link between heat and premature failure.  LRC measured the temperatures and found that they are close to or above 90C 
In EPA’s opinion, it is in the best interest of any manufacturer to identify overheating conditions that will undermine product durability and long-tem performance. 

## ENERGY STAR Amendment

- Lamps shall meet ANSI C78.901-2001 and C78.81-2001 as appropriate.
- Supply applicable ANSI or ANSI-IEC Standard Data Sheet Number.
- When using non-ANSI standardized lamps, supply a manufacturer lamp specification sheet that describes the electrical and dimensional information typically found in ANSI lamp data sheets.

**Notes:**
Show evidence that lamp is ANSI Compliant – Note: information provided on the NEMA-ALA Matrix is considered acceptable evidence. 
Specific lamp characteristics that are required are provided in the draft amendment under (Table 1 they are highlighted in yellow).

## ENERGY STAR Amendment: Process & Timeline

- Draft amendment to be released for public comment around **July 1, 2003.**
- Partners and interested parties will be given a 30-day comment period.
- Amendment and comments will be posted on the ENERGY STAR Specifications in the Product Development Web site.
- Amendment will go into effect on **September 2, 2003.**

**Notes:**
Actual time required to adopt finalize amendment will depend on complexity of the comments, additional research required as a result of comments, possible need for additional stakeholder meetings.

## ENERGY STAR Amendment: Implementation

- All new submittals received after the Amendment effective date will require the ANSI/ANSI-IEC Standard data sheet number or a manufacturer lamp specification sheet.
- Manufacturers of qualified product will have three months from the effective date to submit required documentation .
- Products will be de-listed if information is not received within 30 days from deadline.

## ENERGY STAR Specification Enforcement

- Laboratory test report will be required for a sub-set of fixtures from high risk fixture categories including: recessed and ceiling flush mount.
- The Laboratory test report shall demonstrate that the temperature of the ballast case, when installed in the fixture, meets the ENERGY STAR Specification for Maximum Ballast Operating Case Temperature for Optimal Performance:
_**<**_** 90****o ****C or shall not exceed ballast manufacturer requirements, whichever is lower.**** **

**Notes:**
This is NOT part of the Amendment Process.  EPA is requesting the following information within the current specification.  (Beyond your immediate feed back today, there will be no discussion period)
Table 3 of the spec states “A laboratory test report must be submitted upon EPA request.”

## ENERGY STAR Specification Enforcement: Documentation

- _Option One_:
- Use existing test report completed in accordance with UL 1598 and demonstrate that the ballast case temperature, when installed in the fixture, does not exceed the lower of 90° C or ballast manufacturer requirements for performance.
- _Option Two_:
- If no existing test report is available, use the LRC’s “Proposed Durability Testing Method: Temperature” as guidance. The temperature of the ballast case should be taken at the “hot-spot” locations for performance as indicated by the ballast manufacturer.

**Notes:**
All ballast case operating temperature measurement should be taken within the fixture.
LRC’s testing method follows UL 1598, but thermocouple locations will be different than the ones required by UL.
One test should be completed for each fixture model listed in the letter.
The test report may come from any of the following: 1) “In-house” fixture manufacturer lab. 2) lamp or ballast manufacturer lab. 3) third party independent lab.  Note: EPA will accept existing test report data.

## ENERGY STAR SpecificationEnforcement: Implementation

- In Early July, manufacturers will receive written request for a laboratory test report proving the fixture meets ENERGY STAR’s maximum ballast operating case temperature requirement for performance.
- Manufacturers will be given 60 days from date of written request to provide laboratory test reports.
- Failure to provide laboratory test reports within 15 days of due date, will result in product de-listing.
- New product submittals will be tested according to the LRC’s “Proposed Durability Testing Method:  Temperature” effective 9/1/03.

**Notes:**
Note: Again, lab test documentation will be required for a sub-set of fixtures from the high risk categories: recessed and ceiling flush mount fixtures.  EPA is currently review the E*qualified products list from these two categories to determine worst-case scenarios by manufacturer.  Initially, only those fixtures will require additional test data.