National Electrical Manufacturers Association

2101 L Street. N.W.. Suite 300

Washington, DC 20037 (202) 457-8400

Telex 904077 NEMA WSH

February 22, 1993

Mr. Michael J. McCabe

Director

Office of Codes and Standards

U.S. Department of Energy

Room 5E 066

1000 Independence Avenue, SW

Washington, DC 20585

Dear Michael:

Post-it' Fax Note 7671 Date S' z_ I S

To j ^O CG From COGt^^5OO^1

Co./Dept. Co.

Phones Phone s

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The National Electrical Manufacturers Association is pleased to submit recommended

regulations to implement Section 123 (d)(1) of the Energy Policy Act of 1992,

regarding the prescription of test procedures for covered fluorescent and Incandescent

lamps. We hope that these recommended regulations will assist the Department in

implementing the Energy Policy Act of 1992.

We would be pleased to provide a fuller explanation or answer any questions with

respect to any of our recommendations. Please do not hesitate to call me and I will

ensure that our staff, member companies, and legal counsel address any inquiries or

questions that may be raised.

We look forward to working closely with you and your staff in implementing the many

energy efficiency regulations required under the Energy Policy Act of 1992.

Very truly yours

Kyld'Pitsor

Manager, Government Affairs

Enclosure

Cc: Terry Logee, Department of Energy

L.

EE-RM-94-220-IF COMMENT 23
Recommended Part 430 Proposed Regulations

Implementing Section 323(b)(6) of the Energy Policy

and Conservation Act, as Added by

Section 123 (d)(1) of the Energy Policy Act-of 1992

Test Procedures for General Service Fluorescent

and Incandescent Reflector Lamps

1. Section 430.1 should be amended to read as follows:

This part establishes the regulations for the

implementation of Part B of Title III (42 U.S.C. 6291-

6309 ) of the Energy Policy and Conservation Act (Pub. L.

94-163), as amended by Pub. L. 94-385, Pub. L. 100-12,

Pub. L. 100-357, and Pub.-L. 102-486, which establishes an

energy conservation program for consumer products other

than automobiles.

2. The following defined terms in Section 430.2 should be

amended to read as follows:

Act means the Energy Policy and Conservation Act

(Pub. L. 94-163 ), as amended by the National Energy Policy

Conservation Act (Pub . L. 95-619 ), the National Appliance

Energy Conservation Act of ` 1987 ( Pub. L. 100-12), the

National Appliance Energy Conservation Amendments of 1988

(Pub. L. 100-357), and the Energy Policy Act of 1992 (Pub.

L. 102-486).

Basic mgl means all units of a given type of

covered product (or class thereof) manufactured by one

manufacturer and --

(15) With respect to general service fluorescent

lamps, which are designated as having electrical

characteristics which are essentially identical and which

do not have any differing physical or functional

characteristics that affect energy consumption or

efficiency.

(16) With respect to incandescent reflector lamps,

which are designated as having electrical and lighting

characteristics which are essentially identical and which

do not have any differing physical or functional

characteristics that affect energy consumption or

efficiency.

EE-RM-94-220-IF COMMENT 23
(17) With respect to medium screw base fluorescent

self-ballasted lamps, which are designated as having

electrical and lighting characteristics which are

essentially identical and which do not have any differing

physical or functional characteristics that affect energy

consumption or efficiency.

(18) With respect to general service incandescent

lamps, which are designated as having electrical and

lighting characteristics which are essentially identical

and which do not have any differing physical or functional

characteristics that affect energy consumption or

efficiency.

General service fluorescent lamp means any general

service fluorescent lamp, as defined in Section

321(a)(30)(B) of the Act, that is described in and subject

to lamp efficacy and CR1 standards set forth in Section

325(i) (1) (A) of the Act.

General service incandescent lamp means any

incandescent lamp defined in Section 321(a)(30),(D) of the

Act, or that would be so defined if the manufacturer or

importer rated the voltage of a lamp within a voltage

range of 115 and 130 volts.

Incandescent reflector lamp means any incandescent

reflector lamp, as defined in Section 321(a)(30)(C)(ii) of

the Act, or that would be so defined if the manufacturer

or importer rated the voltage of a lamp within a voltage

range of 115 and 130 volts, and that is subject to lamp

efficacy standards set forth in Section 325(i)(1)(A) of

the Act.

Medium screw base fluorescent self-ballasted lamp

means any fluorescent lamp defined in Section

321(a )(30)(S) of the Act, that is an integrally ballasted

fluorescent lamp with a medium screw base and a rated

input voltage of 115 to 130 volts and which is designed as

a direct replacement for a general service incandescent

lamp.

Lamp efficacy means the lumen output of a lamp

divided by its wattage, expressed in lumens per watt

( LPW).

CRT or col or rendering index means the measure of the

degree of color shift objects undergo when illuminated by

a light source as compared with the color of those same

objects when illuminated by a reference source of

comparable color temperature.

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EE-RM-94-220-IF COMMENT 23
Energy conservation standard means:

(a) . . .

(b) A design requirement for the products specified

in paragraphs ( 6), (7),(8), (10 ), ( 13), and (14) of

section 322(a ) of the Act; . . .

Iag wattage means the total electrical power

consumed by a lamp in watts, after the initial seasoning

period provided for in an industry standard test procedure

referenced in'Appendix R to this Part 430 and, in the case

of rapid start fluorescent lamps, are watts plus cathode

watts.

L=en output means total luminous flux ( radiant

power) of a lamp in lumens , as measured in accordance with

an industry standard test procedure referenced in Appendix

R to this Part 430.

Average ID efficacy means the average lumen output

of a basic model of lamp, as measured in accordance with

this Part 430, divided by the average wattage of samples

of the same basic model of lamp, as measured in accordance

with this Part 430.

ANSI means the American National Standards Institute.

= means the Commission Internationale de

1°Eclairage.

TES means the Illuminating Engineering Society of

North America.

NVLAP means the National Voluntary Laboratory

Accreditation Program.

3. There shall be added to Section 430.22, entitled Test

Procedures for Measures of Energy Consumption, the following new

subsection (r):

(r) LAMs . (1) The average lamp efficacy of a basic

model of a general service fluorescent lamp shall be the

quotient of (i) the average lumen output of a sample of

the basic model , as tested and determined in accordance

with Appendix R to this Subpart B, divided by (ii) the

average lamp wattage consumed by the same sample of the

basic model , as tested and determined in accordance with

Appendix R to this Part 430, the resulting quotient then

being rounded off to the nearest unit of lumens per watt.

EE-RM-94-220-IF COMMENT 23
(2) The CRI of a basic model of a general service

fluorescent lamp shall be tested and determined in

accordance with Appendix R to this Part 430 and rounded

off to the nearest unit.

(3) The average lamp efficacy of a basic model-of an

incandescent reflector lamp, expressed in lumens per watt,

shall be the quotient of (i) the average lumen output of a

sample of the basic model, as tested and determined in

accordance with Appendix R to this subpart, divided by

(ii) the average lamp wattage consumed by the same sample

of the basic model , as tested and determined in accordance

with Appendix R to this Part 430, the resulting quotient

then being rounded off to the nearest 0.5 of a lumen per

watt.

(4) The average lamp efficacy of a basic model of a

medium screw base fluorescent self-ballasted lamp,

expressed in lumens per watt, shall be the quotient of

(i) the average lumen output of a sample of the basic

model, as tested and determined in accordance with

Appendix R to this subpart, divided by (ii) the average

lamp wattage consumed by the same sample of the basic

model, as tested and determined in accordance with

Appendix R to this Part 430, the resulting quotient then

being rounded off to the nearest unit of a lumen per watt.

(5) The average lamp efficacy of a basic model of a

general service incandescent lamp , expressed in lumens per

watt , shall be the quotient of (i) the average lumen

output of a sample of the basic model , as tested and

determined in accordance with Appendix R to this'subpart,

divided by (ii) the average wattage consumed by the same

sample of the basic model, as tested and determined in

accordance with Appendix R to this Part 430, the resulting

quotient then being rounded off to the nearest unit of a

lumen per watt.

4. Section 430..23, entitled Units To Be Tested, shall have a

new subsection (r) added at the end thereto:

(r)(1) For each basic model of general service

fluorescent lamp or incandescent reflector lamp that has

been manufactured during at least four months of the

preceding 12 months, the sample for testing lumen output

and wattage shall be 20 lamps, consisting of at least

three randomly selected lamps of the same month's

production code being tested for at least four separate

months of production. For each basic model of general

service fluorescent lamp or incandescent reflector lamp

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EE-RM-94-220-IF COMMENT 23
that has been manufactured during fewer than four months

of the preceding 12 months, the sample of 20 lamps shall

consist of at least 3 randomly selected lamps from each

month's production code. Any represented value of lumen

output or wattage, or other measure of estimated annual

energy operating costs or energy consumption of a basic

model shall be equal to the mean of the sample.

(2) For each basic model of general service

fluorescent lamp the sample for testing CRI shall be 10

lamps, including at least three randomly selected lamps

from at least two month's production codes during the

preceding 12 months, provided that fora basic model that

has been manufactured only in one month of the preceding

12 months, the sample of 10 lamps shall be randomly

selected from that one month's production code. Any

represented value of CRI shall be equal to the mean of the

sample.

(3) For each basic model of medium screw base

fluorescent self-ballasted lamp or of general service

incandescent lamp a sample for testing lumen output and

wattage shall consist of four randomly selected lamps.

Any represented value of lumen output or. wattage, or other

measure of estimated annual energy operating costs or

energy consumption of a basic model shall be equal to the

mean of the sample. .

5. Section 430.28, entitled, Accredited Laboratory Report,

should be added to read as follows:

430.28 Accredited Laboratory Report.

(a) Accredited Test Laboratories. The test

procedures for general service fluorescent lamps,

incandescent reflector lamps, medium screw base

fluorescent self-ballasted lamps, and general service

incandescent lamps, as specified in Appendix R to this

Part 430, regardless of country of manufacture, must be

conducted by test laboratories accredited by NVLAP. A

manufacturer 's or importer's own laboratory, if so

accredited, may conduct the applicable test procedures.

(b) Certified Laboratory Reports. (1) Each

manufacturer or importer of a general service fluorescent

lamp or an incandescent reflector lamp must submit a

report to the Department of Energy's Office of Codes and

Standards from an accredited test laboratory described in

subsection (a) certifying compliance of each basic model

of lamp which is subject to standards established pursuant

to Section 325(i) of the Act. The report required by this

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EE-RM-94-220-IF COMMENT 23
Section 5 shall be deemed to satisfy the requirements of

Section 325 (i)(7) of the Act if it certifies that, with

respect to any basic model of lamp , categorized at its

nominal lamp wattage, the average lamp efficacy of the

sample exceeds the minimum standard required under Section

325(i ), and with respect to any basic model of a covered

general service fluorescent lamp, that such lamp exceeds

the minimum CRI standard required under Section 325(i).

Such certification of compliance must be based on the use

of test procedures in accordance with this Part 430 and

Appendix R hereto. in addition to the requisite

certification of compliance , a certification report under

this Section 430.28 need disclose only the following

information , which shall be sufficient to permit

verification or retesting of a sample of the basic model

of lamp:

(i) the basic model tested:

(ii) lamp designations and brand names;

(iii) production date codes of the sample;

(iv) reference to back-up lamp report; and

.(v) laboratory's NVLAP identification.

(2) Each manufacturer or importer of a medium screw

base fluorescent self-ballasted lamp or a general service

incandescent lamp must submit a statement to the

Department of Energy's office of codes and Standards from

an accredited test laboratory described insubsection (a)

certifying that the labelling information required for

each basic model of lamp under Section 324(a)(2)(C)(1) of

the Act is substantiated by testing pursuant to

subsection (a).

(C) Certifild Reports to Cover 12 Months of Manufacture.

(1) Each manufacturer or importer must submit the

certification report required under subsection (b)(1) no

later than the date on which the standards established

pursuant to Section 325(i) of the Act become effective for

a basic model of lamp, provided that such basic model has

been manufactured for at least 12 months prior to

certification.

(2) With respect to basic models of lamps which have

not been manufactured for at least 12 months preceding the

date that such standards become effective pursuant to

Section 325(i ) of the Act , each manufacturer or importer

must submit a certification of compliance , as required

under subsection ( b)(1), based on testing data as is

available prior to such effective date and a certification

of compliance based on the first 12 months of manufacture,

no later than 90 days after such 12-month period ends.

- 6 -

EE-RM-94-220-IF COMMENT 23
(3) With respect to basic models of lamps which have

not been manufactured prior to the effective date of

standards applicable pursuant to Section 325(i) of the

Act, no lamp may be manufactured or imported unless the

manufacturer or importer files a certification report, as

prescribed under subsection ( b)(1), based on premanufacture or pre-import testing.

6. Appendix R to Subpart B of Part 430 shall be added as

follows:

Appendix R to Subpart B of Part 430 -- Uniform Test Method

for Measuring the Average Lamp Efficacy and CRI of General

Service Fluorescent and Incandescent Reflector Lamps

1. Definitions

Definitions contained in Section 430.2 are applicable

to this Appendix.

2. Test procedures

2.1. General service fluorescent lamps. The test

conditions , test equipment and apparatus , calibration and

testing procedures for testing lumens of general service

fluorescent lamps shall be done in accordance with IES

test method code LM-9, which is also designated as NVLAP

test method code 22/POla , entitled "Fluorescent Lamps -

Photometric - Total Flux Measurements , approved

December 7, 1988. The test conditions for testing wattage

of general service fluorescent lamps shall be done in

accordance with ANSI test method code ANSI-C78 . 375 (1991),

which is also designated as NVLAP test method 22/EO5,

entitled " Fluorescent Lamps - Electrical Measurements,

approved July 15, 1991 . The test conditions, test

equipment and apparatus , calibration and testing

procedures for testing CRI for general service fluorescent

lamps shall be done in accordance with IES test method

code LM-58, entitled " Spectroradiometric Measurements,"

approved 1983 for test data and calculation of CRI in

accordance with CIE publication No. 13.2 , 1974 (reprint

1988 ). Copies of IES LM-9 and LM-58 may be obtained

through IES , 345 East 47th Street , New York, N.Y. 10017.

Copies of ANSI-C78 . 375 may be obtained from through ANSI,

11 West 42nd Street , New York , N.Y. 10036 . Copies of CIE

publication No. 13 . 2 may be obtained through IES at the

above address . Copies of these test procedures may be

inspected at the Department of Energy , Freedom of

Information Reading Room.

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EE-RM-94-220-IF COMMENT 23