Charles Llenza

December 5, 2013

commercial_refrigeration_equipment@ee.doe.gov

Commercial Refrigeration Equipment

Notice of Proposed Rulemaking 

Public Meeting on Test Procedures 
2

Welcome

• Introductions (around the room)

• Role of the Facilitator

• Ground Rules

– Speak one at a time.

– Say your name for the record – there will be a complete transcript of 

this meeting.

– Be concise – share the “air-time.”

– Keep the focus here – cell phones on silent; limit sidebar 

conversations.

– Webinar participants turn phone on mute; “raise your hand” to be 

recognized to speak.

• Housekeeping Items

• Agenda Review

• Opening Remarks
3

Listening Via the Webcast

• The U.S. Department of Energy (DOE) is broadcasting this 

meeting live over the Internet.

• DOE is providing the webcast to accommodate stakeholders 

who are unable to attend the public meeting in person.

• The web broadcast allows stakeholder to listen in and view 

the slides.

• All stakeholders are encouraged to submit written comments 

after the public meeting.
4

Opening Remarks
5

Public Meeting Topics

1 Introduction

2 Rulemaking History & Timeline

3 Test Procedure Scope & Definitions

4 Clarifications to the Test Procedure

5 Other Test Procedure Issues

6 Closing Remarks; Contacts & Information
6

Agenda

9:00 – 9:30 am Welcome, Introductions, Opening Remarks

9:30 – 9:45 am Rulemaking History & Timeline

9:45 – 10:30 am Test Procedure Scope & Definitions

10:30 – 10:45 am Break

10:45 – 12:00 pm Clarifications to the Test Procedure

12:00 – 12:15 pm Break

12:15 – 12:30 pm Other Test Procedure Issues

12:30 – 12:45 pm Burden of Testing & Regulatory Review

12:45 – 1:00 pm Closing Remarks

1:00 pm Adjourn
7

Purpose of this Public Meeting

• Purpose

– To present DOE’s proposed test procedure (TP) amendments for 

commercial refrigeration equipment (CRE).

– To answer questions about DOE’s proposed approach.

• Comments from Participants

– Participants are invited to provide summary comments or statements 

and raise additional issues for discussion.

– Notice of proposed rulemaking (NOPR) comment period closes on 

January 13, 2014.
8

Issue “Boxes” for Discussion

• Issue “boxes” correspond to the list of issues for which the 

Department seeks comments.

• A list of issues are in the NOPR document, available at: 

http://www.regulations.gov/#!documentDetail;D=EERE-2013-BT-TP-0025

Issue Box: In the test procedure NOPR for commercial 

refrigeration equipment, DOE welcomes comment. Throughout 

this presentation, specific issues will be raised for discussion on 

slides such as this, with identifying numbers corresponding to 

those in the test procedure NOPR document. In addition, DOE 

has added questions that are not in the NOPR document. These 

questions are identified by a letter.
9

How to Submit Written Comments

• In all correspondence, please refer to the CRE Test Procedure rulemaking 

by:

– Commercial Refrigeration Equipment Test Procedure Rulemaking,

– Docket Number EERE-2013-BT-TP-0025, and

– Regulatory Identification Number (RIN) 1904-AC99.

• Email: CRE2013TP0025@ee.doe.gov

• Comment period closes: January 13, 2014, 11:59 PM EST
10

Public Meeting Topics

1 Introduction

2 Rulemaking History & Timeline

3 Test Procedure Scope & Definitions

4 Clarifications to the Test Procedure

5 Other Test Procedure Issues

6 Closing Remarks; Contacts & Information
11

CRE Test Procedure Regulatory History

• EPCA, as amended, directs that:

– Test procedures for commercial refrigerators, freezers, and 

refrigerator-freezers must be:

1) the test procedures determined to be generally accepted industry 

testing procedures; or 

2) rating procedures developed or recognized by ASHRAE or by 

ANSI.

(42 U.S.C. 6314(a)(6)(A)(i)) 

– The initial test procedures for self-contained refrigerators, freezers, 

and refrigerator-freezers with doors shall be the ASHRAE 117 test 

procedures that went into effect January 1, 2005. (42 U.S.C. 

6314(a)(6)(A)(ii))
12

Authority to Amend CRE Test Procedure

• EPCA states that:

– If ASHRAE 117 is amended, the Secretary must, by rule, amend the 

DOE test procedure to ensure consistency with the amended ASHRAE 

117 unless certain findings are made by clear and convincing 

evidence. (42 U.S.C. 6314(a)(6)(E)) 

– If a test procedure other than ASHRAE 117 is approved by ANSI, the 

Secretary must review the relative strengths and weaknesses of the 

new test procedure relative to the ASHRAE 117 test procedure and, 

based on that review, adopt one new test procedure for use in the 

standards program. 

(42 U.S.C. 6314(a)(6)(F)) 

– At least once every 7 years DOE must conduct an evaluation of each 

class of covered equipment to determine whether to, among other 

things, amend the test procedures for such equipment. (42 U.S.C. 

6314(a)(2))
13

Current CRE Test Procedure

• On December 8, 2006, DOE established a

test procedure for commercial refrigeration 

equipment, which references the AirConditioning and Refrigeration Institute 

(ARI) Standard 1200-2006. 

• ARI 1200-2006 references American Society 

of Heating, Refrigerating and AirConditioning Engineers (ASHRAE) Standard 

72-2005 as the method of test.

• DOE adopted Association of Home Appliance 

Manufacturers (AHAM) Standard HRF-1-

2004 for measuring refrigerated 

compartment volume. 71 FR 71370 (Dec. 8, 

2006). 
14

2012 CRE Test Procedure Amendments

• On February 21, 2012, DOE issued a test procedure final rule for commercial 

refrigeration equipment , amending the procedure previously established in 

2006. 77 FR 10292; 10318-21 (Feb. 21, 2012).

• The 2012 test procedure final rule made a number of amendments and 

updates, including:

- updating references to industry test procedures to their current versions,

- incorporating methods to evaluate the energy impacts resulting from the 

use of night curtains and lighting occupancy sensors and controls, and

- allowing commercial refrigeration equipment which cannot achieve the 

specified rating temperature to instead be tested at the lowest 

temperature at which it is able to operate.
15

Proposed Test Procedure Revisions

• Since publication of the 2012 CRE test procedure final rule, DOE has received 

several inquiries from interested parties regarding: 

– the applicability of DOE’s test procedure and current Federal energy conservation 

standards to various equipment types and features, 

– the definition of certain terms pertinent to commercial refrigeration equipment, 

– the proper configuration and use of certain components and features of 

commercial refrigeration equipment when testing according to the DOE test 

procedure, 

– the proper application of certain test procedure provisions, and 

– the compliance date of certain provisions specified in the DOE test procedure final 

rule published on February 21, 2012. 

• The NOPR proposes a number of test procedure revisions in response to these 

inquiries.
16

Proposed Test Procedure Revisions, Continued

• During the summer of 2013, DOE initiated a negotiated rulemaking process 

for certification of commercial heating, ventilation, air conditioning, 

refrigeration, and water heating equipment (Docket No. EERE-2013-BT-NOC0023). 

• During the negotiated rulemaking meetings, discussions were held on the 

treatment of certain features or product attributes specific to commercial 

refrigeration equipment under the DOE test procedure.

• Consensus was reached regarding treatment of these features and it was 

agreed that these clarifications would be codified in a future rulemaking.

• This test procedure NOPR contains proposals reflecting these positions agreed 

upon through the negotiated rulemaking. 
17

CRE Test Procedure NOPR

NOPR Final

Rule

• The NOPR document and materials from today’s public meeting will be 

available online:

http://www.regulations.gov/#!docketDetail;D=EERE-2013-BT-TP-0025
18

CRE Test Procedure Rulemaking Timeline

2014 2015

TP NOPR 

Public Meeting

Dec. 5, 2013

Proposed Final Rule 

Effective Date 

(30 days after the 

publication of any 

Final Rule)
19

Public Meeting Topics

1 Introduction

2 Rulemaking History & Timeline

3 Test Procedure Scope & Definitions

4 Clarifications to the Test Procedure

5 Other Test Procedure Issues

6 Closing Remarks; Contacts & Information
20

Scope of Commercial Refrigeration Equipment

• EPCA defines covered commercial refrigeration equipment 

broadly as refrigeration equipment that:

– is not a consumer product;

– is not designed and marketed exclusively for medical, scientific, or 

research purposes; 

– operates at a chilled, frozen, combination chilled and frozen, or 

variable temperature;

– displays or stores merchandise and other perishable materials 

horizontally, semivertically, or vertically; 

– has transparent or solid doors, sliding or hinged doors, a combination 

of hinged, sliding, transparent, or solid doors, or no doors;

– is designed for pull-down temperature applications or holding 

temperature applications; and 

– is connected to a self-contained condensing unit or to a remote 

condensing unit.

42 U.S.C. 6311(9)(A)
21

can be tested with DOE TP cannot be tested with DOE TP

Scope of CRE Test Procedure

• DOE’s CRE test procedure is applicable to all equipment for which DOE has 

established energy conservation standards, as well as to some equipment 

types for which DOE has not yet established energy conservation standards, 

such as chef bases and griddle stands.

• The current DOE test procedure is not applicable to salad bars, prep tables, 

and refrigerated buffet tables.

• For equipment to which it applies, the DOE test procedure must be used for 

making representations of energy consumption.

commercial refrigeration equipment that is not currently covered by energy conservation standards
22

Scope of CRE Energy Conservation Standards

• DOE has only established standards for certain types of commercial 

refrigeration equipment.

– These standards are specified at 10 CFR 431.66 and are applicable to all new 

equipment distributed in commerce. 76 FR 12422, 12426 and 12437 (March 7, 

2011).

– DOE’s standards are not applicable to rebuilt or refurbished equipment. Id.

• There are also several types of equipment for which DOE has not 

yet established energy conservation standards.

– These include, for example, buffet tables, salad bars, prep tables, and griddle 

stands.

– This notice includes proposed regulatory text to clarify this point. 
23

Definition of “Chef Base or Griddle Stand”

• To clearly differentiate “chef bases” and “griddle stands” from 

conventional types of commercial refrigeration equipment, 

DOE proposes to establish a new definition for chef base or 

griddle stand as follows:

Chef base or griddle stand means commercial 

refrigeration equipment that is designed and marketed 

for the express purpose of having a griddle or other 

cooking equipment placed on top of it that is capable of 

reaching temperatures hot enough to cook food.

Issue 1: DOE requests comment on the proposed definition for 

“chef base or griddle stand.”
24

Cases Shipped with Doors as After-Market Additions

• A basic model of commercial refrigeration equipment is 

tested, rated, and subject to standards based on the 

equipment class(es) to which that basic model belongs.

• For equipment that is offered for sale with doors as an 

optional accessory, regardless of how the unit is shipped, such 

unit must be tested and certified as equivalent to a basic 

model shipped with doors pre-installed. 
25

Classification of CRE Basic Models

• DOE currently categorizes commercial refrigeration 

equipment by equipment classes based on the following 

general characteristics:

– geometry of the case (i.e., vertical, horizontal, or semi-vertical); 

– presence of doors (closed equipment) or no doors (open equipment); 

– door type, if applicable (transparent or solid); 

– condensing unit configuration (self-contained or remote condensing); 

– holding temperature application or pull-down temperature 

application; and

– operating temperature (refrigerator, freezer, or ice-cream freezer).
26

Commercial Refrigeration Equipment with Drawers

• DOE interprets the term “door” to mean any movable 

component of the CRE unit that:

– when closed, separates the interior refrigerated space from the 

ambient air; and 

– when opened, provides access to the refrigerated products inside the 

CRE unit. 

• DOE considers drawers to be doors for purposes of DOE’s 

regulatory program.

• Compliance for equipment with drawers is determined based 

on the standard level for the equivalent equipment class with 

doors as tested in accordance with the DOE test procedure. 
27

Definition of “Door”

• To clarify how DOE’s regulatory scheme applies to basic 

models of CRE units with drawers, DOE proposes to add a 

definition of a door, to read as follows: 

Door means a movable panel that: 

(1) separates the interior volume of a unit of commercial 

refrigeration equipment from the ambient environment, 

(2) is designed to facilitate access to the refrigerated space for 

the purpose of loading and unloading product, and

(3) is affixed such that it is not removable without the use of tools. 

This includes hinged doors, sliding doors, and drawers. 

Issue 2: DOE requests comment on its proposed definition of 

“door,” and, in particular, its specification that the term is 

inclusive of drawers. 
28

Determination of Transparency

• DOE prefers a quantifiable method to determine light 

transmittance.

• DOE proposes that ASTM E 1084-86 (Reapproved 2009), 

“Standard Test Method for Solar Transmittance (Terrestrial) of 

Sheet Materials Using Sunlight,” is widely applicable to 

transparent materials that would be used to construct 

commercial refrigeration equipment. 

– ASTM E 1084-86 (Reapproved 2009) is the basis for other industrystandard test methods for determining visible transmittance of 

fenestration products (e.g., ASTM E 972-96 and NFRC 202-2012).
29

Definition of “Transparent”

• DOE proposes to establish a definition for “transparent” as 

follows:

Transparent means greater than or equal to 65 percent light 

transmittance, as determined in accordance with ASTM Standard E 

1084-86 (Reapproved 2009), “Standard Test Method for Solar 

Transmittance (Terrestrial) of Sheet Materials Using Sunlight,” at 

normal incidence. 

Issue 3: DOE requests comments from interested parties on the 

proposal to define “transparent” based on the optical properties 

of the material, as determined by ASTM E 1084-86 (Reapproved 

2009) as incorporated by reference.
30

Definition of “Closed Solid” and “Closed Transparent”

• At 10 CFR 431.66, DOE refers to equipment families using the terms 

“closed solid” and “closed transparent” (for example vertical closed solid 

(VCS) and vertical closed transparent (VCT)). 

• DOE proposes to establish a definition for “closed solid” and “closed 

transparent” as follows:

Closed solid means equipment with doors, and in which more than 25 

percent of the outer surface area of all doors on a unit is not transparent.

Closed transparent means equipment with doors, and in which 75 percent 

or more of the outer surface area of all doors on the unit is transparent.

Issue 4: DOE requests comment on its proposed definitions of 

the terms “closed solid” and “closed transparent.” 
31

Hybrid Equipment and Commercial Refrigerator-Freezers

• DOE’s regulations currently cover commercial hybrid 

refrigerators, freezers, and refrigerator-freezers in addition to 

non-hybrid commercial refrigerators, freezers, and 

refrigerator-freezers.

• There appears to be some confusion regarding the 

differentiation of hybrid equipment from non-hybrid 

commercial refrigerator-freezers. 

• At 10 CFR 431.62, DOE defines a “commercial hybrid 

refrigerator, freezer, or refrigerator-freezer” as having two or 

more chilled and/or frozen compartments that are in two or 

more different equipment families, contained in one cabinet, 

and sold as a single unit.
32

Definitions Concerning Commercial Hybrid Equipment

• To clarify the relationship between commercial hybrid 

equipment and non-hybrid commercial refrigerator-freezers, 

DOE proposes to remove DOE’s existing definition of 

“commercial hybrid refrigerator, freezer, or refrigeratorfreezer” and establish new definitions for “commercial 

hybrid” and “commercial refrigerator-freezer” as follows:

Commercial hybrid means a unit of commercial refrigeration equipment 

(1) Consisting of two or more refrigerated compartments that are in two 

or more different equipment families, and

(2) Which is sold as a single unit.

Commercial refrigerator-freezer means a unit of commercial refrigeration 

equipment consisting of two or more refrigerated compartments where at 

least one refrigerated compartment is capable of operating at or above 

32 °F and at least one refrigerated compartment is capable of operating 

below 32 °F.
33

Difference Between Hybrid and Non-Hybrid Equipment 

Commercial RefrigeratorFreezerCommercial Hybrid 

Refrigerator

Commercial Hybrid 

Refrigerator-Freezer

A model with one compartment

≥32 °F and one compartment <32 °F 

from the same equipment family

A model with two compartments

≥32 °F from different equipment 

families

A model with one compartment ≥32 °F 

and one compartment <32 °F from 

different equipment families

Meets definition of commercial 

refrigerator-freezer, but not 

commercial hybrid

Meets definition of commercial 

hybrid, but not commercial 

refrigerator-freezer

Meets definition of commercial 

refrigerator-freezer and commercial 

hybrid

0 F 38 F 38 F 38 F 0 F 38 F

Issue 5: DOE requests comment on the clarity and sufficiency of the 

proposed definitions for “commercial hybrid” and “commercial refrigeratorfreezer.”
34

Rating, Operating, and Integrated Average Temperatures 

Term Rating Temperature Operating 

Temperature

Integrated Average 

Temperature (IAT)

Location 10 CFR 431.66(d)(1) 10 CFR 431.66(d)(1) 10 CFR 431.64(b)(3)

Use Describing the IAT at which a 

model of commercial 

refrigeration equipment 

should be evaluated in 

accordance with the DOE test 

procedure.

Refers to the range of 

IATs at which the unit 

of commercial 

refrigeration 

equipment is capable 

of operating.

The average refrigerated 

compartment 

temperature as 

determined as a result of 

testing a given model of 

commercial refrigeration 

equipment.

Definition

at 10 CFR 

431.62

The integrated average 

temperature a unit must 

maintain during testing.

The range of 

integrated average 

temperatures at 

which a commercial 

refrigeration unit is 

capable of operating.

The average of all the 

test package 

temperature 

measurements taken 

over the course of the 

test.

New proposed definitions
35

Defining DOE’s Temperature Classifications

• DOE uses the operating temperature range of the equipment 

to establish the appropriate equipment class for CRE basic 

models based on the standards table at 10 CFR 431.66(d)(1). 

Term Commercial 

Refrigerator

Commercial Freezer Commercial 

Refrigerator

-Freezer

Ice Cream Freezer

Operating 

Temperature

≥ 32 °F < 32 °F ≥ 32 °F and 

< 32 °F

≤ -5 °F

Definition at 

10 CFR 431.62

A unit of commercial 

refrigeration 

equipment in which all 

refrigerated 

compartments in the 

unit are capable of 

operating at or above 

32 °F.

A unit of commercial 

refrigeration 

equipment in which 

all refrigerated 

compartments in 

the unit are capable 

of operating below

32 °F.

As stated on 

previous 

slide.

A commercial freezer 

that is designed to 

operate at or below -5 °F 

and that the 

manufacturer designs, 

markets, or intends for 

the storing, displaying, or 

dispensing of ice cream. 

New proposed definitions
36

Variable Temperature Equipment

• Some models feature operating temperature ranges that cause the models to 

span multiple equipment classes. For example, a CRE model with an operating 

temperature range of >15 F and <36 F meets the definition of both a 

commercial refrigerator and a commercial freezer. 

• DOE proposes that equipment capable of operating within multiple equipment 

classes would have to be tested and certified as each of these equipment 

classes to demonstrate compliance with DOE’s energy conservation standards. 

• The CRE model described above would need to be tested and certified as both 

a commercial refrigerator and a commercial freezer. 

Issue 6: DOE requests comment on its proposed definitions for “operating 

temperature” and “rating temperature,” and its proposal to clarify the 

relationship between integrated average temperature and rating 

temperature. DOE also requests comment on its proposed definitions of 

“commercial refrigerator” and “commercial freezer.”
37

Public Meeting Topics

1 Introduction

2 Rulemaking History & Timeline

3 Test Procedure Scope & Definitions

4 Clarifications to the Test Procedure

5 Other Test Procedure Issues

6 Closing Remarks; Contacts & Information
38

Treatment of Equipment Features/Accessories

• During the 2013 negotiated rulemaking for certification of 

commercial heating, ventilation, air conditioning, 

refrigeration, and water heating equipment, issues were 

raised by stakeholders regarding the treatment during the 

DOE test procedure of specific features, components, and 

accessories which may be in place on certain basic models of 

commercial refrigeration equipment (Docket No. EERE-2013-

BT-NOC-0023). 

• The ensuing slides discuss specific features, components, and 

accessories, and present proposals on how these items should 

be treated under the existing and any amended DOE test 

procedure provisions. These proposals reflect positions 

previously agreed upon during the negotiations.
39

Customer Display Signs/Lights

• Description: Some customers may wish to add additional 

exterior signage, outside of the body of the refrigerated 

cabinet, for the purposes of advertising the product inside. 

This lighting and signage is optional and is not integral to the 

cabinet. Further, this auxiliary signage does not serve to 

illuminate product inside the body of the cabinet. 

• Proposal: Supplemental lighting that exists solely for the 

purposes of advertising or drawing attention to the case and 

is not integral to the case would not be operated during 

testing under the DOE test procedure. 
40

Condensate Pan Heaters and Pumps

• Description: In many types of equipment, defrost meltwater 

is collected in a pan beneath the unit. Some models of 

commercial refrigeration equipment come equipped with 

electric resistance heaters that evaporate this water out of 

the pan and into the ambient air. Other models may come 

equipped with pumps, which pump meltwater to an external 

drain. 
41

Condensate Pan Heaters and Pumps

• Proposal: Heaters and condensate pumps must be installed 

and operational during the entire test (per section 6.1.1, 

“Accessories,” of ASHRAE 72-2005). 

– The “entire test” includes stabilization (including pull-down), steadystate, and performance testing periods. 

– Prior to the start of the stabilization period, as defined by ASHRAE 72-

2005, the condensate pan should be dry. 

– For the entire period of the test following the start of the stabilization 

period, any condensate moisture generated should be allowed to 

accumulate in the pan, as it would during normal operations. 

– Water should not be manually added to or removed from the 

condensate pan at any time during the entire test.
42

Anti-Sweat Door Heaters

• Description: Many transparent-door cases come equipped 

with anti-sweat electric resistance heaters that serve to 

evaporate any water that condenses on the transparent 

surface of the door during operation. In some instances, 

manufacturers may equip their cases with higher-powered 

anti-sweat heaters in anticipation of potential adverse 

operating conditions. 
43

Anti-Sweat Door Heaters

• Proposal: DOE proposes that anti-sweat heaters should be 

operational during testing under the DOE test procedure. 

– Models with a user-selectable setting must be turned on and set to 

the maximum usage position. 

– Models featuring an automatic, non-user-adjustable controller that 

turns on or off based on environmental conditions must be operating 

in the automatic state. 

– If a unit is not shipped with a controller from the point of 

manufacture, and is intended to be used with a controller, the 

manufacturer must make representations of the basic model based 

upon the rated performance of that basic model as tested when 

equipped with an appropriate controller. 
44

Ultraviolet Lights

• Description: Some manufacturers equip certain models of 

commercial refrigeration equipment with ultraviolet lights, 

which can be operated by end users to neutralize pathogens 

and ensure case cleanliness. 

• Proposal: Ultraviolet lights should not be turned on during 

the conduct of the test procedure.
45

Illuminated Temperature Displays and Alarms

• Description: Manufacturers may equip some commercial 

refrigeration equipment models with illuminated displays that 

provide visual information to the equipment operator 

regarding, for example, the temperature inside the 

refrigerated case. Manufacturers may also offer alarms that 

notify operators if the case temperature falls outside of a 

specified range. 

• Proposal: These items should be enabled during the test as 

they would be during normal field operation. 
46

Condenser Filters

• Description: Manufacturers may offer models equipped with 

non-permanent filters over a model's condenser coil to 

prevent particulates such as flour from blocking the 

condenser coil and reducing airflow.

• Proposal: Non-permanent filters should be removed during 

the test. 
47

Refrigeration System Security Covers

• Description: Manufacturers may offer for sale with a basic 

model an option to include straps or other devices to secure 

the condensing unit and prevent theft or tampering. 

• Proposal: Security devices should be removed during testing 

under the DOE test procedure.
48

Grill Options

• Description: Manufacturers may offer for sale with a basic 

model optional grills that are used to direct airflow in unique 

applications, such as when a unit is mounted close to a rear 

wall and the airflow needs to be directed upwards.

• Proposal: If present, non-standard grills should be removed 

during testing. 
49

Coated Coils

• Description: These coils, generally specified for use in units 

that will be subjected to environments in which acids or 

oxidizers are present, are treated with an additional coating 

(such as a layer of epoxy or polymer) as a barrier to protect 

the bare metal of the coil from deterioration through 

environmental contact. 

• The existing test procedure accurately accounts for the 

performance of all types of coils, including coated coils.
50

Misting or Humidification Systems

• Description: Manufacturers may offer for sale with a basic 

model optional misting or humidification systems, which 

dispense a water mist used to maintain the optimal quality of 

products. These are commonly used with cases containing, for 

example, fresh produce, meat, or seafood. 

• Proposal: If present, these systems should be inactive during 

testing. 
51

Air Purifiers

• Description: Manufacturers may offer for sale purifying 

systems to remove contaminants from air recirculated within 

the interior of a refrigerated case. 

• Proposal: Air purifiers should be inactive during testing under 

the DOE test procedure.
52

General Purpose Outlets

• Description: Some commercial refrigeration equipment may 

be offered for sale with integrated general purpose electrical 

outlets, which may be used to power additional equipment 

such as scales or slicers. 

• Proposal: While testing using the DOE test procedure, no 

external load should be connected to the general purpose 

outlets contained within a unit. 
53

Crankcase Heaters

• Description: Some models of self-contained commercial 

refrigeration equipment feature electric resistance heaters 

designed to keep the compressor warm in order to maintain 

the refrigerant contained within at optimal conditions when 

the unit is operating at low ambient temperatures. 

• Proposal: If present, crankcase heaters should be operational 

during the test. Under this proposal, if a control system, such 

as a thermostat or electronic controller, is used to modulate 

the operation of the crankcase heater, it should be used as 

intended according to the manufacturer's instructions.
54

Use of Energy Management Systems During Testing

• DOE TP specifies that all devices that would normally be used 

in the field must be installed and operated in the same 

manner during the test unless this is inconsistent with any 

requirement of the test procedure.

– This includes energy management systems.

• If normal field installation or operation would be inconsistent 

with any test procedure requirement, then the specific 

function that causes inconsistency must be disabled.

– Example:

• If EMS raises or lowers the cabinet temperature such that the applicable 

IAT cannot be maintained throughout the test.

• In this case the function of EMS that varies temperature must be disabled.

• Other functions may remain enabled, provided they do not violate TP.

• If functions cannot be controlled separately, all must be disabled. 
55

Use of Lighting During Testing

• The DOE test procedure specifies that all devices that would 

normally be used in the field must be installed and operated 

in the same manner during the test.

– ARI Standard 1200-2006 and AHRI Standard 1200-2010 specify that 

the total daily energy consumption (TDEC) or calculated daily energy 

consumption (CDEC) for self-contained or remote condensing cases 

shall include lighting loads.

– ASHRAE 72-2005 specifies in section 6.1.1, that “all standard 

components, such as...lights...shall be installed and used as 

recommended by the manufacturer.”

– These explicit references to case lighting indicate that the energy 

consumption associated with lights installed on a model of commercial 

refrigeration equipment is intended to be captured during testing.
56

Use of Lighting During Testing

• In the 2012 TP final rule, DOE adopted specific provisions for 

the treatment of lighting occupancy sensors and scheduled 

controls. 

– DOE established specific time periods during which these variable 

lights may be turned off or dimmed during the test.

• DOE wishes to clarify that a mechanical light switch does not 

constitute an energy management system.

– Models of commercial refrigeration equipment with lighting installed 

on the case and no energy management system should be tested with 

lights on to their maximum illumination level for the duration of the 

test. 

– Any lighting controls with a user-selectable setting must be turned on 

and set to the maximum usage position.

– Exception: models with solid doors with lighting controls that 

automatically turn off internal case lighting when the door is closed.
57

Use of Lighting During Testing

• The NOPR includes proposals to clarify lighting operation:

Appendix A • All lighting must be energized to the maximum illumination level 

throughout the whole test. 

• An exception is proposed for closed solid-door models that include 

automatic controls that disable case lighting when the door is closed.

Appendix B • All lighting shall be energized to its maximum illumination level, except 

for when a model is equipped with lighting occupancy sensors and/or 

scheduled controls, or when a model is outfitted with other permanently 

installed, automatic energy management systems that control lighting. 

•If the unit includes an automatic lighting control system, it should be 

enabled during test. If the unit is equipped with lighting occupancy 

sensors and controls, it should be tested in accordance with the 

provisions adopted in the 2012 test procedure final rule. 
58

Test Package Temperatures

• Stakeholders have inquired whether the DOE test procedure 

has specific temperature requirements for the test simulators 

and filler packages that must be met prior to loading the 

packages

• ASHRAE 72-2005 provides specific instruction as to the 

loading of test simulators and filler packages (section 6.2) and 

temperature stabilization (section 7.4).

– Unit must run until “steady state” conditions, as defined in section 3, 

are achieved.

– After steady-state operation is reached, unit must operate for another 

period of 12 hours before it is deemed to be stabilized.

• DOE does not believe the product simulators or test packages 

need to be a specified temperature prior to loading.
59

Public Meeting Topics

1 Introduction

2 Rulemaking History & Timeline

3 Test Procedure Scope & Definitions

4 Clarifications to the Test Procedure

5 Other Test Procedure Issues

6 Closing Remarks; Contacts & Information
60

Rounding of Test Results & Certified Ratings

• The current DOE test procedure, which incorporates by reference 

provisions from ARI Standard 1200-2006 and AHRI Standard 1200-2010, 

requires that the energy consumption for covered commercial refrigeration 

equipment be expressed in terms of kilowatt-hours (kWh) per day and 

must be stated in increments of 0.01 kWh per day. 

• DOE is proposing clarifications to 10 CFR 431.64 that explicitly establish 

that all calculations must be carried out using raw, measured values, and 

the results from the testing of a single unit of a given basic model should 

be expressed in 0.01 kWh per day. 

• These calculation and rounding requirements are also applicable to 

reporting certified ratings for a basic model at 10 CFR 429.42, and DOE 

proposes to update the language commensurately. 

Issue 7: DOE requests comment on its proposed rounding 

provisions for commercial refrigeration equipment. 
61

2012 Test Procedure LAPT Provisions

• In the 2012 test procedure final rule, DOE established 

provisions for testing equipment that is not capable of 

achieving the prescribed rating temperature for its respective 

equipment class at the lowest application product 

temperature (LAPT). 77 FR at 10320 (Feb. 21, 2012). 

• DOE defines LAPT as follows:

10 CFR 431.62

Lowest application product temperature means the 

integrated average temperature closest to the specified 

rating temperature for a given piece of equipment 

achievable and repeatable, such that the integrated 

average temperature of a given unit is within ± 2 °F of 

the average of all integrated average temperature 

values for that basic model.
62

Testing at the Lowest Application Product Temperature

• If a certain basic model of commercial refrigeration 

equipment cannot be operated at the prescribed rating 

temperature for its given equipment class, the manufacturer 

must test the equipment at the LAPT. 

– All other requirements of the DOE test procedure must be met, except 

that the rating temperature for this equipment will be the LAPT and 

the IAT measured during the test will be within 2 F of the LAPT 

instead of within 2 F of the prescribed rating temperature for that 

equipment class. 
63

Clarifying the Lowest Application Product Temperature

• The LAPT is the lowest temperature at which a given basic 

model is capable of operating. 

– For example, if a basic model of freezer has an operating range from 8 

to 28 F, and thus cannot operate at the prescribed rating temperature 

of 0 F, that basic model would be tested at its LAPT of 8 F. 

– In this case, if DOE were to randomly select a representative unit of 

this model to test for compliance purposes, DOE should be able to test 

the unit such that an integrated average temperature between 6 and 

10 F is maintained over the duration of the test procedure after 

setting the unit to maintain an internal refrigerated temperature of 

8 F. The selected unit must not be able to operate at 0 F. 

– For many cases this will be the lowest thermostat setting and will be 

achieved by turning the thermostat down all the way.

– For cases without thermostats, DOE established specific provisions for 

establishing the LAPT. 77 FR 10304-5 (Feb. 21, 2013).
64

Revised LAPT Definition

• To clarify the intent and application of the LAPT, DOE proposes to modify 

the definition of LAPT as follows:

• Due to the explicit reference of ASHRAE 72-2005, DOE proposes to 

incorporate by reference ASHRAE 72-2005 at 10 CFR 431.63. 

Issue 8: DOE requests comment on its proposed modification to 

the LAPT definition and its proposal to incorporate by reference 

ASHRAE 72-2005. 

Lowest application product temperature means the 

lowest integrated average temperature at which a given 

basic model is capable of consistently operating (i.e., 

maintaining so as to comply with the steady-state 

stabilization requirements specified in ASHRAE 72-2005 

(as incorporated by reference, see §431.63) for the 

purposes of testing under the DOE test procedure).
65

AHRI Standard 1200-2010 Interpretations

• Since publication of the 2012 test procedure final rule, AHRI has 

published five interpretations to AHRI Standard 1200-2010. 

– Interpretations 1 through 4 to AHRI Standard 1200-2010 were issued by 

AHRI to clarify the method for calculation of Total Display Area (TDA). 

– Interpretation 5 to AHRI Standard 1200-2010 clarifies the approach for 

testing commercial refrigeration equipment with two independent 

refrigeration sections. 
66

AHRI Standard 1200-2010 Interpretations

• Guidance developed and issued by industry regarding 

referenced industry standards can be helpful in identifying 

areas where DOE’s existing test procedures may be 

misinterpreted.

• However, it is not official guidance with respect to the DOE test 

procedure unless formally put forth by DOE. 

• DOE has reviewed the AHRI interpretations and believes 

Interpretations 1, 3, 4, and 5 to the AHRI standard also apply to 

ARI Standard 1200-2006 and the DOE test procedure.

• Interpretation 2 is inconsistent with the way DOE determines 

TDA for the purposes of compliance with energy conservation 

standards. 
67

Measuring Total Display Area

• ARI Standard 1200-2006, appendix D, as incorporated by 

reference by the DOE at 10 CFR 431.63, provides 

– a definition for TDA as follows:

– and instructions on the calculation of TDA:

Total Display Area (TDA) is the sum of the projected 

area(s) for visible product.

TDA = Dh*L + Ae , where

Ae = Projected area from visible product through end walls

Dh = Dimension of projected visible product

L = Length of Commercial Refrigerated Display Merchandiser
68

Scenario 1: Case Wall Flush with Visible Area

Boundary of 

refrigerated 

volume

Boundary of 

refrigerated 

volume

A

B

C D E

For the purposes of calculating TDA, should length “L” in AHRI 1200 be measured as:

– Length “A” – inside wall to inside wall of refrigerated volume;

– Length “B” – entire continuous length containing visible area (same as “A” here); or

– Lengths “C”+”D”+”E” – sum of lengths of visible areas? 

Vertical case, 

front view
69

Scenario 2: Case Body Overhangs Refrigerated Volume

Boundary of 

refrigerated 

volume

Boundary of 

refrigerated 

volume

A

B

C D E

For the purposes of calculating TDA, should length “L” in AHRI 1200 be measured as:

– Length “A” – inside wall to inside wall of refrigerated volume;

– Length “B” – entire continuous length containing visible area; or

– Lengths “C”+”D”+”E” – sum of lengths of visible areas? 

Vertical case, 

front view
70

Scenario 3: Case Body Overhangs Refrigerated Volume

Boundary of 

refrigerated 

volume

Boundary of 

refrigerated 

volume

A

B

C D

For the purposes of calculating TDA, should length “L” in AHRI 1200 be measured as:

– Length “A” – inside wall to inside wall of refrigerated volume;

– Length “B” – entire continuous length containing visible area; or

– Lengths “C”+”D” – sum of lengths of visible areas? 

Vertical case, 

front view
71

Scenario 4: Visible Area Overhangs Case Body

Boundary of 

refrigerated volume

Boundary of refrigerated 

volume

A

B

C D E

For the purposes of calculating TDA, should length “L” in AHRI 1200 be measured as:

– Length “A” – inside wall to inside wall of refrigerated volume;

– Length “B” – entire continuous length containing visible area;

– Lengths “C”+”D”+”E” – sum of lengths of visible areas; or

– Lengths “F”+”G”+”H” – sum of lengths of visible areas overlooking refrigerated 

volume?

F G H

Vertical case, 

front view
72

Compliance Date of Test Procedure Amendments

• DOE also proposes to:

– reorganize the test procedure requirements at 10 CFR 431.64 into new Appendices A 

and B so they are easier to understand, and 

– update the compliance date to reflect that the publication of the energy conservation 

standards final rule has been extended (Docket No. EERE-2010-BT-STD-0003).

Appendix Content Required to be Used as of

Appendix A • Test procedure for commercial refrigeration 

equipment established in the 2006 test 

procedure final rule

• Clarifications established as part of this NOPR

30 days after publication of any test 

procedure final rule.

Appendix B • Test procedure amendments adopted in the 

2012 test procedure final rule

• Clarifications established as part of this NOPR

Compliance date of any amended 

standards established in the ongoing 

energy conservation standards 

rulemaking (Docket No. EERE-2010-

BT-STD-0003). 

Issue 9: DOE requests comment on the reorganization of the test 

procedure requirements at 10 CFR 431.64 into Appendix A and Appendix B. 
73

Public Meeting Topics

1 Introduction

2 Rulemaking History & Timeline

3 Test Procedure Scope & Definitions

4 Clarifications to the Test Procedure

5 Other Test Procedure Issues

6 Closing Remarks; Contacts & Information
74

Request for Closing Remarks

At this time DOE welcomes any closing remarks from interested 

parties.
75

CRE TP Web Pages and DOE Contacts

• DOE Appliance Standards webpage:

– http://www1.eere.energy.gov/buildings/appliance_standards/

• Commercial Refrigeration Equipment Test Procedure webpage:

– http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx?ruleid=80

• Contact Charles Llenza, Commercial Refrigeration Project Manager, from the Appliance 

Standards Program for additional information: 

– commercial_refrigeration_equipment@ee.doe.gov

• Contact Ashley Armstrong, Test Procedure Team Lead, from the Appliance Standards 

Program for additional information: 

– Ashley.Armstrong@ee.doe.gov