KOHLER CO. KOHLER, WISCONSIN 53044 PHONE 414457-4441

February 7, 1997

Dear Mr. McCabq

RE: Trough Type Urinals

This is a follow-up to our conversation of Febr uuy 5,1997, regarding the acceptability of

trough urinals related to their water use restrictions. As we diiscussed , in areas that

accept their use the applications are normally in buildings where a great number of people

use the facilitiessimultaneously, such as stadiums, sports bars, et cetera.

Normally these factutes we produced in a variety of sizes from 36" to 72" in length,

approximately 18" wide, bowl depth of 7 3/4", 8" high back - with a center outlet for a

1 1/2" trap. the water supply is dispersed in the urinal by a spreader bar that flushes the

back and sides of the fixture.

Because of the varied lengths of these fixtures, they resemble a factory wash fountain in

that they accommodate more than one user at a time. The best rule of thumb is one

person for every 16 to 18" of urinal length.

Standard trough urinals sizes are 36", 48", 60", and 72"_ This relates to. the approximate

water usage in the following table:

'TROUGH URINAL WATER CONSUMF'TTON

Urinal Length 36" 60- 72"

Gallons/Flush 2 3 4 4.5

I want to thank you for taking the time to discuss and resolve this ,matter with us. The

plumbing fixture under discussion is not used in too many instances today . However, a

request is made occasionally for a football stadium or other high density application where

local plumbing codes allow trough urinals.

Sincerely,

r^rL'

Sargent

ager, Codes and Standards

Mr. Mtchaet McCabe

Unuited States Department of Energy

Washington, D.C.

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Department of Energy

Washington, DC 20585

March 24, 1997

Mr. James Sargent

Manager, Codes and Standards

Kohler Co.,

444 Highland Drive

Kohler, WI 53044

Dear Mr. Sargent:

Thank you for your letter of February 7, 1997, to the Department of Energy

(Department) regarding the applicability of water conservation standard for

trough-type urinals designed for multiple users. The Energy Policy Act of 1992

amended the Energy Policy and Conservation Act (EPCA), to provide water

conservation standards for certain plumbing products, including urinals.

EPCA defines the term "urinal" to mean "a plumbing fixture which receives only

liquid body waste and, on demand, conveys the waste through a trap seal into a

gravity drainage system." EPCA also established a maximum water use of 1.0

gallon per flush (gpf) for urinals when such products are manufactured after

January 1, 1994. The Kohler Co. believes that trough-type urinals are a covered

product. Kohler states that these fixtures are produced in sizes of 36," 48," 60,"

and 72" in length, are approximately 18" wide with a bowl depth of 73/4," 8" high

back - with a center outlet for a 1'/2" trap, and the water supply is dispersed in the

urinal by a spreader bar that flushes the back and sides of the fixture. In addition,

Kohler requested that it be allowed to comply with the water conservation

standard by prorating the water consumption based on a capacity criterion of 16

inches of urinal length per person.

The Department agrees with Kohler's view that these units can be considered as a

covered product. The Department believes that any urinal, regardless of the

number of users the fixture was designed to accommodate, shall constitute a

covered "urinal" subject to the applicable water conservation standard. The

Department believes the maximum water consumption, for trough-type urinals,

may be prorated based on the number of users it can accommodate at one time.

This approach is consistent with a proposal, by the Department for multiple-user

spray heads with collectively-controlled orifices, where the maximum water

consumption is defined by prorating based on a capacity criterion of 20 inches of

rim space per lavatory or individual. (62 FR 7834, February 20, 1997). Although

the Department is unaware of any plumbing code applicable to trough-type urinals,

the Department believes that Kohler's request to prorate the maximum water

consumption based on 16 inches of urinal length per person may be reasonable.

Printed with soy ink on recycled paper

 EE-RM-TP-97-600 COMMENT 0I
The Department plans to gather information on this issue at the April 1, 1997,

public hearing for plumbing products. Prior to the publication of the Final Rule,

the Kohler Co. can distribute and install the above trough-type urinals, provided

the maximum water consumption of such products does not exceed 2.3 gpf, 3.0

gpf, 3.8 gpf, and 4.5 gpf, respectively. If you have questions or need additional

information please contact Mr. Bill Hui of my staff at (202) 586-9145.

Sincerely,

Michael J. McCabe, Director

Office of Codes and Standards

Building Technology. State and

Community Programs

Energy Efficiency and Renewable Energy

cc: Mr. Jim Neumann

Manager, Manufacturing Support

Eljer Industries, Inc.

Mr. Richard W. Church II

Managing Director

Plumbing Manufacturers Institute

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