Third-Party Certification
Training for EPA-Recognized
Certification Bodies
Kathleen Vokes and Eamon Monahan
ENERGY STAR Program Integrity
December 2, 2010
Farragut Center, Washington, DC

Agenda• Part I – ENERGY STAR® Certification Review and Data
Transfer (9:00 a.m. – 12:00 p.m.)• Break for Lunch (12:00 p.m.-1:00 p.m.)• Part II – Verification and Challenge Testing (1:00 p.m.2:30 p.m.)• 15 minute Break (2:30 p.m.- 2:45 p.m.)• Part III – Audits, Accountability and the Relationship withEPA (2:45 p.m.- 3:45 p.m.)• Q&A (3:45 p.m.- 4:30 p.m.)• Note that a lighting-specific training will be offered from9:00 a.m. to 1:00 p.m. tomorrow.

Part I: ENERGY STAR® Certification
Review and Data Transfer

A Brief History of ENERGY STAR
• Early 1990s– Started as a manufacturer-focused, self-certification
program focused largely upon computers andmonitors• Nearly 20 Years Later– ENERGY STAR has evolved as an internationallyrecognized program that covers more than 60 productcategories from nearly 3,000 manufacturing partners– More than 75% of Americans recognize the ENERGYSTAR mark1Background and Premise of ThirdParty Certification• Strengthening the Mark: From SelfCertification to Third-Party Certification– DOE-EPA Memorandum of Understanding(MOU)– Increased scrutiny of voluntary programs• Inspector General Reports at EPA and DOE• Government Accountability Office ENERGY STAR Investigation– Increased financial value of ENERGY STAR
• Rebates• Utility Incentives

2Comparing Self-Certification toThird-Party Certification•Self-Certification (1992-2010)– Partners test products, confirm
conformance to specification,and label with the ENERGYSTAR– Partners submit test data toEPA to qualify their products– EPA reviews test data andadds products to lists ofqualified products– EPA verifies energy
performance of select models
only•

Third-Party Certification (startingin 2011)– Partners will have products tested
in EPA-recognized labs prior toqualification and labeling– CBs will certify that products meet
program requirements based on areview of test data
– CBs will upload certified data toEPA for creation of qualified
product lists– CBs will conduct verification andchallenge testing afterqualification– CBs will evaluate retested
products that have undergone
significant post-qualification
changes3

Laboratory Requirements under New
Third Party Certification Scheme• CBs may accept data for certification only fromlabs that are recognized by EPA• Based on accreditation to ISO 17025; or• If lab participates in CB’s Supervised or Witnessed
Manufacturers Testing Lab Program• First party labs are not required to participate inan SMTL or WMTL if they are recognized byEPA• CB is responsible for ensuring that test data isacceptable if testing conducted prior toaccreditation4

Product Certification Overview• The Guide for Certification Review: An ENERGYSTAR Standard Operating Procedure (SOP) for
Product Evaluation• Designed by EPA to reflect the steps followed whenreviewing products against ENERGY STAR productspecifications• Key Sections of the SOP––––General Requirements
Eligibility Criteria
EPA-Recognized Laboratory Report Checklist
Product-Specific Appendices5

General SOP-Related Guidance• The SOP is complementary to theENERGY STAR product specifications• CBs must ensure that products meet all
aspects of the ENERGY STAR productspecifications– Product specifications can be found atwww.energystar.gov/specifications

6Collecting Required Data
• Collect all information needed to determine thatthe product can be certified– The information on the Certified Product Data
Submission form usually only represents a subset of
this data• Collect other information as needed for purposesof verification and challenge testing• The ES partner must submit information to certifya product– If a recognized lab or other party submits a subset ofdata and includes the partner in the correspondence,
the CB should consider this information submitted by
the partner7

Verifying Applicant/Partner Status• To submit a product for certification,
manufacturer must have indicated intent topartner with ENERGY STAR by signingand submitting a Partnership Agreement.
– This results in EPA generation of anOrganization ID (OID)• Log in to My ENERGY STAR Account(MESA) at www.energystar.gov/MESA andlook up the manufacturer’s OID
8Verifying Laboratory Status• Check to ensure that lab conducting testing is
recognized by EPA– By January 1, EPA will begin maintaining anonline database of all EPA-recognized labs inaddition to the labs listed on the website– Log in to MESA to look up the laboratory’s OID– Labs will be recognized if participating in the CBs
SMTL/WMTL program; however information onthese labs must be shared with EPA
9Using MESA to Verify Manufacturer
and Laboratory Status and OIDs

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Using MESA to Verify Manufacturer
and Laboratory Status and OIDs

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Verifying Product Family Membership• If Applicant/Partner wishes to certify aproduct in a member of a specificationappropriate product family, it must provide:– Test report(s) for representative model(s)– An explanation of any variations within the family– An up-to-date list of models included in the family• CBs must maintain a list of all products in afamily
12Certifying Product-Specific Aspects
and Performance• If the product does not meet the Program
Requirements, it cannot be certified
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Checking Laboratory Test Reports• At a minimum, locate lab report fields
specified on the SOP (serial number,environmental conditions, etc.) to ensurethat the product was appropriately tested• If the information cannot be verified, theproduct cannot be certified until that
information is furnished14Adhering to Supplemental EPAGuidance• SOP Appendix A– Product-specific supplemental guidance• Routing Further Inquiries– If other product-specific aspects ofcertification review are unclear, route any andall questions back to EPA via product-specific
ENERGY STAR inboxes

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Certifying Privately-Labeled Products• CB can certify a different brand of thesame model without data review if themodel is already certified by the CB– EPA encourages CBs to work together toavoid duplicative testing and review– CBs will need to flag models that are certified
under different brand names– CBs will need to maintain a data field with themodel tested to help track this information
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Transferring Data to EPA• If product can be certified– Enter the relevant product and productsubtype being certified into the relevant
Certified Product Data Submission form

• After data entry– Submit data to EPA using the MESA interface• Frequency of data submission– Initially will start on a bimonthly basis, but will
move to monthly for most products
17Certified Product Data Submission onMESA

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Transferring Data to EPA, Continued• Timeline for Evolution of Data Exchange
Process– Near-Term (January to Mid-2011)• Use Excel-based data submission forms to submit Qualified
Product and Product Development data– Mid-2011• Approximate completion date of the XML-based systemallowing for simultaneous data transfer and validation)• New system will involve the addition of new fields to what
CBs will collect in the near-term (e.g. tested versus certified
values, codes that will link privately-labeled models, UPC
codes, version numbers)
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Keeping Certified Product Lists
Current• CBs are responsible for keeping lists of certified
products up to date– Need to establish a policy for ensuring thatcertified products are available for verificationtesting– CBs will need to delist products that are nolonger available or are disqualified

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Enhancing the Impact of ENERGY STAR:Collaboration with California EE Programs• Complying With CEC Appliance Standards– EPA encourages CBs to offer Title 20 reporting
services in conjunction with their ENERGY STAR
certification programs in order to allow more ENERGYSTAR qualified products to receive rebates.
– More information (and a list of covered appliances)can be found at http://www.energy.ca.gov/appliances/

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Questions?

22Part II: Verification and Challenge
Testing
Eamon Monahan
ENERGY STAR Labeling BranchGoals of Verification and Challenge
Testing• Ensure the process of third-party
certification has effectively represented theenergy savings claims of ENERGY STARpartners• Allow for a fair process for partners tochallenge the performance claims ofcompetitors1Model Selection for Verification
Testing• Annually test a minimum of 10% of certified
products in each category and included subtype– Category: Imaging.
– Subtypes: copiers, digital duplicators, fax machines,
mailing machines, multi-function devices, printers,scanners.

• Product Families– All members of family are subject to testing, but not morethan one per round• Private labelers– Brand A, B, and C are all one product for verification
testing purposes
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EPA Role in Verification Testing ModelSelection• “Approximately 50% of models shall be randomlyselected…”• Best interpreted as “at least 50%” In practice it could
vary– Partners with routine failures can be subject to additional testing– Referrals from third parties such as consumer groups areaccepted only at CB discretion– Referrals from EPA may be limited• In the event of significant failures, EPA may request anincrease in the number of models selected insubsequent years
3Verification Testing Model Selection• “The more recently a model has
undergone verification or challenge
testing, the less likely it should berandomly selected.”– EPA has not defined “less likely.”– Products can be removed entirely from thepool for a given amount of time, or simply
rejected if it is randomly chosen, in favor ofanother random selection.
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Verification Testing Model Selection• Information not included in QPL that caninform model selection:– All relationships between products, including:• Base model and manufacturer for each privately labeledproduct• All privately labeled model numbers associated with eachOEM product• Clear indication of which qualified products are OEMproducts and which are privately labeled products– All relationships between manufacturers not covered
by OEM-PL relationship• e.g.: “ Acme submitted this product on behalf of Roadrunner”
4Procurement of Units for Verification
Testing• Off-the-shelf procurement is favored• EPA does not define “prohibitively expensive topurchase or transport…”– If a CB allows for warehouse or off-the-line
procurement, it should be prepared to justify thatchoice.

• Partners are required to provide at least threelocations where a product is available, EPA
suggests this be included in productsubmissions for certification.
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Preferred Locations for Verification
Testing• Verification must generally occur only atEPA-recognized third party labs.
• EPA-Recognized first party facilities arepermissible ONLY when off-the-line testingis the only practical option, provided that:– CBs witness the test
– CBs must be able to defend their decision toallow use of first party lab (as withprocurement)
6Re-evaluation of Products in theEvent of Significant Changes• CBs require partners to notify them of productchanges• CB is not required to re-test all changed
products– The CB retains discretion to decide if changes warrant are-test• Notify EPA– If there is no change in status, on the normal upload
schedule– If there is a change in status (product no longer meets ES
requirements), within two business days
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Challenge Testing• CB must have a policy built into thecontracts it signs with partners.
– Challenges can be initiated by partners
outside of your certification scheme• CB must judge the legitimacy of achallenge claim• CBs have discretion to establish the rules
for challenge testing program– A “loser pays” scheme may be easiest
8Challenge Testing• “A challenge may be initiated only when
the CB has conveyed details of thechallenge to the challengee…”• To ensure partners cannot influence theprocurement process, EPA has defined“initiated” to mean after the unit has beenprocured.

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Enforcement Threshold forVerification and Challenge Testing• EPA will allow for a 5% enforcement threshold
during verification testing• If a product exceeds the ENERGY STAR spec
by 5% or more it will be considered a failure– Aligns with DOE procedures for appliances– Allows EPA to target resources on products that donot• Only one “tier” or “stage” of testing is allowed– A failed test should not trigger a second round oftesting10

Reporting Failures to EPA• Delisted products can simply be omitted upona full refresh of the qualified products list
• However, all failures must also be reported
via a product-specific report to EPA.
– At present, EPA is developing a procedure fortransmitting information related to products thatcan no longer qualify– CB will need to notify EPA within 2 business daysof initial product failure1Questions?

Eamon Monahan
ENERGY STAR Program
U.S. Environmental Protection Agency
Phone: 202-343-9589
Fax: 202-343-2200

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Part III: The Ongoing Relationshipbetween Certification Bodies and EPA

Ensuring Procedural Accountability• Auditing CB Operations– EPA is developing a comprehensive audit plan
– EPA will work with IAF MLA signatory accreditors (A2LA,ANSI, and SCC) for each CB to ensure sufficient oversight– Audits will likely include site visits and interviews with CB
reviewers and personnel• Following up on deficiencies– EPA will work with recognized CBs to resolve issues asneeded– Failure to adhere to the “Conditions and Criteria for
Recognition of Certification Bodies for the ENERGY STARprogram” may result in EPA revoking recognition

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Usage of the ENERGY STAR Mark• The ENERGY STAR marks are reservedfor partner use only– CBs are not permitted to use (or have accessto) ENERGY STAR logos or marks in any oftheir marketing materials or upon anythingthat they distribute– Use of the mark by non-partners (including
recognized CBs, ABs, and labs) will betreated as a logo violation by the Agency
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ENERGY STAR Marketing Materials
Review• Ensuring Message Consistency– EPA will review all marketing materials (ENERGY
STAR-related web pages, press releases and othercommunications to clients) to ensure that partners
have a clear, consistent understanding of therequirements– Please submit all marketing materials as describedabove (either existing or planned) toENERGYSTARVerificationProgram@energystar.gov
for EPA review.
3Common Third-Party Certification
Communication Issues– Refer to the procedures as “Third-Party Certification,” not“Enhanced Testing and Verification”– Capitalize ENERGY STAR in all communications and use thesuperscripted registered mark (®) only with the first usage ofENERGY STAR in a given context– Refer to Third-Party Certification as a set of procedures, not as anew program– Do not refer to the procedures as “a new program” or a “newENERGY STAR”– Do not advertise certification services that you are not yet
recognized by the Agency to offer

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Ongoing Communications with CBs• EPA Short-Term Objectives– Share final data templates and standard operatingprocedure– Share detailed schedule for when data templates should
be uploaded during interim data exchange process• EPA Longer-Term Objective– Webinar/Meeting in Spring 2011 to discuss long-term dataexchange, verification testing issues and audits for CBs
and Laboratories

5Questions?

Kathleen Vokes
ENERGY STAR Program
U.S. Environmental Protection Agency
Phone: 202-343-9019
Fax: 202-343-2200

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