## SUPPLEMENTAL NOTICE OF PROPOSED RULEMAKING TECHNICAL SUPPORT DOCUMENT (TSD):
ENERGY CONSERVATION PROGRAM FOR CONSUMER
PRODUCTS AND CERTAIN COMMERCIAL AND INDUSTRIAL EQUIPMENT: TEST PROCEDURES FOR SHOWERHEADS, FAUCETS, WA TER CLOSETS, URINALS,
AND COMMERCIAL PRERINSE SPRAY VALVES:

Showerhead Flow Control In sert Retention Testing

April 2, 2013

U.S. Department of Energy Assistant Secretary Office of Energy Efficiency and Renewable Energy Building Technologies Program Appliances and Commercial Equipment Standards Washington, DC 20585This Document was prepared for the Department of Energy by staff members of

Pacific Northwest National Laboratoryi SHOWERHEAD FLOW CONTROL INSERT RETENTION TESTING

TABLE OF CONTENTS

1.0 BACKGROUND .................................................................................................................... 1
2.0 PURPOSE OF THE DOCUMENT ........................................................................................ 1
3.0 FLOW CONTROL INSERT RETENTION EVALUATION ................................................ 1
3.1 Manual Qualitative Assessment .......................................................................................... 2
3.2 Pulling-Force Test ............................................................................................................ ... 2
3.3 Gravity Test .................................................................................................................. ...... 6
4.0 FLOW RATE TESTING ........................................................................................................ 9
5.0 PROPOSED FLOW CONTROL INSERT RETENTION TEST METHOD ....................... 10

LIST OF TABLES

Table 3.1 Flow Control Insert Retention Testing Results ................................................................8

LIST OF FIGURES

Figure 3.1 Diagram of the Force Test Set Up ..................................................................................3 Figure 3.2 Pulling-Force Test Results for Sample 2: Insert Was Removed With Less than
8 lbf ......................................................................................................................... .5 Figure 3.3 Pulling-Force Test Results for Sample 10: Insert Could Not Be Removed with
Less than 8 lbf ..........................................................................................................6 Figure 3.4 Pulling-Force Test Results for Sample 9: Insert Was Removed Close to 8 lbf .............6 Figure 3.5 Diagram of the Gravity Test Set Up ...............................................................................71 SHOWERHEAD FLOW CONTROL INSERT RETENTION TESTING

1.0 BACKGROUND

The Energy Policy and Conservation Act of 1975 includes a provisi on requiring, in part, that showerheads must meet the requirements of section 7.4.3(a) of American Society of Mechanical Engineers (ASME) / American National Standards Institute (ANSI) A112.18.1M1989. (42 U.S.C. 6295(j)(1)) The referenced industry standard generally requi res that if a flow control insert is used as a component of a s howerhead, the showerhead must be manufactured such that a pushing or pulling force of 8 pounds (l bf) or more is required to remove the flow control insert. DOE subsequen tly adopted this de sign requirement in 10 CFR 430.32(p). This requirement has been retained in the update d A112.18.1-2011 issued by ASME and the Canadian Standards Association (CSA), but has been moved to section 4.11.1. DOE proposed in a May 30, 2012 Notice of Proposed Rulemaking to incorporat e by reference this up dated version of the A112.18.1 procedure. 77 FR 31742.

This ASME standard, however, does not specif y a procedure to test the amount of force required to remove the flow control insert. Like wise, the U.S. Department of Energy (DOE) does not have a method for verifying that manufacturer s have met this design requirement. To address this issue, DOE investigated test method options and performed flow contro l insert retention tests
on a selection of showerheads in preparation of a supplementa l notice of proposed rulemaking (SNOPR) regarding the test procedures for shower heads, faucets, water closets, urinals, and commercial prerinse spray valves that was published on April 8, 2013. 78 FR 20832.

2.0 PURPOSE OF THE DOCUMENT

The objective of this techni cal support document is to summarize the systematic assessment DOE performed to arrive at the propos ed test procedure for s howerhead flow control insert retention provided in the SNOPR. DOE’s investigation provided in sight on the type of flow control mechanisms on the market and appr opriate methods for testing the retention of inserts, and ultimately suggested a test procedure th at allows repeatable results, is simpler to set up, and has a low cost burden.

DOE first investigated the general types of showerhead flow control designs on the market and qualitatively assessed the retenti on of the inserts. Based on results from the qualitative assessment, DOE developed two differ ent testing methods: a pulling-force test and a gravity test. The pulling-force test method provided insight into the amount of force necessary to remove a showerhead insert, but had a fairly complex setup and produced inconclusive results for several showerhead models. In response, DOE developed a gravity test that was less complex and produced conclusive results. This techni cal support document provides a summary of the tests performed along with a summary of results on the test ed showerheads.

3.0 FLOW CONTROL INSERT RETENTION EVALUATION

DOE obtained 23 showerheads of different models produced by 11 manufacturers to investigate a variety of showerhead flow contro l designs. In general, four basic flow control designs were identified:2  Plastic disc : Fifteen of the twenty-three showerheads contained plastic disc inserts with or without an o-ring in the middle of the insert. Some of the disc inserts that contained an o-ring provided pressure co mpensation, where the o-ring deforms at increased pressure, blocking a greater fracti on of the flow path and providing a more
uniform flow at differe nt supply pressures.

 Rubber disc : One showerhead contained a rubb er disc flow control insert.

 Permanent flow control : Six of the twenty-three showerheads obtained were manufactured with the flow control integral to the showerhead housing with no insert.
These showerheads were found to automati cally meet the desi gn requirements per ASME A112.18.1-2011, section 4.11.1, because th ese showerheads did not contain a removable flow control insert. Therefore, DOE did not test these showerheads as part of this investigation.

 Sealing gasket : One showerhead contained an insert that also serves as the seal between the showerhead and supply fitting. S howerheads that use a sealing gasket as the flow control mechanism are exempt from the design requirement because ASME A112.18.1-2011, section 4.11.1, states that the de sign requirement does not apply to showerheads that would cause significant l eakage of water from areas other than the spray face if the flow control insert is removed. Therefore, DOE did not test this showerhead as part of this investigation. As discussed in the S NOPR, DOE interprets the term “leak significantly” to mean the visi ble emergence of water from parts of the showerhead other than the spray face or nozzle that does not occur when the flow control insert is installed, such as from the connecti on between the showerhead and the plumbing fitting

3.1 Manual Qualitative Assessment

First, DOE performed a manual qualitative assessment to ascertain how easily the flow control inserts could be removed by pulling on the insert with needle-nos e pliers by hand. Of the 16 showerheads that had plastic or rubber inserts, 12 were manua lly removed with needle-nose pliers, while 4 could not be removed, as show n in Table 3.1. Based upon available references, DOE assumed that the peak manual for ce applied ranged between 20 and 37 lbf. a As a result of this manual qualitative assessment, which resulted in insert removal in most cases, DOE pursued a more rigorous pulling-force test to measure the force required for insert removal.

3.2 Pulling-Force Test

DOE constructed a pulling-force test system to determine if the showerheads previouslyevaluated during the qualitative assessment met the 8 lbf retention requirement. The pullingforce test system consisted of the following equipment (shown in Figure 3.1 ):

 Test stand with a hand-powered, screw-driven translating stage

a The 5 th percentile pulling strength for a human ranges between 20 and 37 lbf, assuming a 90 degree elbow flexion when using the right hand. This means that 95 percent of adult humans, male or female, can exer t a force greater than 20-37 lbf and ensure s the force exerted during qualitative testing was greater than th e 8 lbf limit. Information gather ed from National Aeronautics a nd Space Administration website on Human Performance Capabilities (accessed December 2012): http://msis.jsc.nasa .gov/sections/section04. htm#_4.9_STRENGTH3  S-style Omega LC101 force transducer (Omega Engineering, Inc., Stamford, Connecticut) connected to the top of the te st stand with a capacity of 25 lbf, a fullscale accuracy of 0.03 percent and a Nationa l Institute of Standards and Technology (NIST)-traceable calibration

 Omega DP25B display for visual observati on, connected to the force transducer

 Campbell Scientific CR1000 data logger (C ampbell Scientific, Inc., Logan, UT), configured to measure the force transducer output every 100 milliseconds and record the average over 500 millisecond intervals

 PC computer connected to the data l ogger for data collection and analysis

Figure 3.1 Diagram of the Force Test Set Up

New showerheads, of the identical model and from the same manufacturer, were procured to replace the samples evaluated during the manual qualitative assessment. The following steps were performed during a pulling-force test b :

1. The showerhead’s sealing gasket, which provides a seal between the showerhead and supply fitting, and the screen upstream of the flow contro l insert were removed (if present and a separate component from the flow control insert).

2. The showerhead was secured such that it would not move with a pulling-force of at least 20 lbf; the showerhead was secured by th e test stand, directly beneath the clamp,
with the inlet connection facing vertically upward.

b The pulling-force test was performed on shower head samples 2, 3, 4, 5, 9, 10, 11, 12, 14, 15, and 16. Showerhead samples 6, 7, 8, and 13 were not tested because the flow control inserts were pressed into the housi ng such that the insert could not be remo ved manually, and therefore DOE deemed that the pulling-force test was unnecessary.4 3. A clamp was attached to the flow control in sert by translating the force transducer and clamp assembly vertically upward or downward as needed; the clamp was
connected to the bottom of the force trans ducer by a flexible linkage that did not
deform under tension and could withstand a fo rce of at least 20 lbf; the clamp was used to grip the flow contro l insert and consisted of a modified set of needle-nose locking-pliers.

4. Once attached to the flow control insert, the force transducer and clamp assembly were translated vertically upward slowly by a hand-powered, screw-driven translating stage at a consistent speed that applied a pulling-force onto the flow control insert. c

5. The pulling-force value shown on the display was observed in each case; however, it was difficult to clearly identify the exact maximum force applied prior to removal of the insert. (The force was also recorded by th e data logger and the data were used to determine the maximum force applied to the flow control insert. Examples of pullingforce test results are provided in Figure 3.2, Figure 3.3, and Figure 3.4.)

6. The force transducer and clamp assembly were translated vertically downward to reduce the applied force.

7. Once the pulling-force was removed complete ly, the clamp was detached from the
flow control insert.

The pulling-force testing produced three basic groupings of results d :

 A pulling-force well below 8 lbf was able to remove the insert: This result occurred for two plastic disc inserts and one rubbe r disc insert (samples 2, 14, and 16). An example of this result is shown in Fi gure 3.2 for showerhead sample 2, where showerhead sample numbers are provided in Table 3.1. The test began at time equal to zero, and from zero to 10 seconds the clam p was being attached to the flow control insert. Application of the pulling-forc e began at around 10 seconds (indicated by point 1 in Figure 3.2) and increased as the force transducer and clamp assembly were translated vertically upward. The peak a pplied force was achieved, at which time the flow control insert began sliding out of the showerhead (indicated by point 2), resulting in a decrease in the force (indicate d by point 3). The force returned to zero once the flow control insert was comp letely removed from the showerhead.

 A pulling-force of at least 8 lbf could not remove the insert: This result occurred for five plastic disc inserts (samples 4, 5, 10, 11, and 12). An example of this type of result is shown in Figure 3.3 for showerhead sample 10. Similar to Figure 3.2, point 1 indicates the applied pulling-force is bei ng applied and point 2 is the peak force achieved. However, between points 2 and 3, additional force was applied and was held fairly constant. At approximately 30 seconds (as indicated by point 3), the force

c The hand-powered screw-driven translating stage displaced the force transducer and clamp asse mbly vertically up and down. The speed of this displacement was not meas ured. The weight of the clamp assembly was taken into account so that the recorded force represents the upward force applied on the flow control insert only and does not include the weight of the clamp.

d It should be noted that the da ta logger did not record correctly during one test , so the results were inconclusive for that showerhead. This test was not repeated w ith a new showerhead of the same model.5 was reduced by translating the clamp and force transducer assembly vertically
downward until the force returned to zero.

 A pulling-force very close to 8 lbf was able to remove the insert: This result occurred for two plastic disc inserts (samples 3 and 9). An example of this type of result is shown in Figure 3.4 for showerhead sample 9. Again, at point 1 (around 10 seconds), the pulling-force was applied and increased until the peak force was achieved at point 2. However, the flow control insert bega n sliding between 20 seconds and point 2.
The flow control insert conti nued to slide as the clamp and force transducer assembly were translated vertically upward until ar ound 40 seconds (as indicated by point 3). At this point, the flow control insert wa s removed completely from the showerhead, resulting in a quick decrease in the force back to zero.

Figure 3.2, Figure 3.3, and Figure 3.4 provide sample results for the pulling-force test. e

Figure 3.2 Pulling-Force Test Results for Sample 2: Insert Was Removed With Less than 8
lbf

e The amount of force is shown as zero in the charts from time zero until point 1 ( i.e. , the time at which the force is applied). The actual measured data varied slight ly from zero prior to point 1 because of forces applied to the transducer while attaching the clamp to the flow control insert. Similarly, the force prior to point 3 has been shown as zero. This step was performed to prov ide visual clarity and focus on the pulling-test results.6 Figure 3.3 Pulling Force Test Results for Samp le 10: Insert Could Not Be Removed with
Less than 8 lbf

Figure 3.4 Pulling-Force Test Results for Sample 9: Insert Was Removed Close to 8 lbf

A summary of the pulling-force testing results is provided in Table 3.1, where samples 3 and 9 exhibited questionable failures because of ambiguous and inconclusive results (as discussed above relative to Figure 3.4). Because of the need for more conclusive results, DOE decided to pursue a more robust, and repeatable, pulling-force testing approach that eliminated the potential for ambiguous results a nd simplified the test system.

3.3 Gravity Test

The gravity testing approach was develope d to address the ambi guous results observed during the pulling-force testing that relied on interpretation of the measured pulling force. In addition, the gravity testing approach eliminates the requirement for a force transducer and data logger, which reduces the cost burden while ensu ring the test is easily repeatable and provides
definitive results.

The gravity test system consists of a test stand, hanging mass, clamp, and laboratory jack as shown schematically in Figure 3.5. The test stand holds the shower head with the inlet7 connection facing vertically downward so that the showerhead does not move when a pullingforce is applied to the flow control insert. A ha nging mass is attached by a connecting wire to a clamp and rests on a laboratory jack ( i.e. , screw-driven scissor jack). The laboratory jack allows the mass and clamp assembly to be raised and lowered. The clamp is used to grip the flow
control insert and consists of a modified set of needle-nose locking-pliers (similar to the clamp used in the pulling-force test system).

Figure 3.5 Diagram of the Gravity Test Set Up

Prior to testing, the weight of the hanging mass was adjusted precisely such that the combined weight of the hanging mass and clam p assembly (including the connecting wire) weighed 8.05 pound-mass (lbm). The weight was measured using a Mettler-Toledo PM30-K balance (Mettler-Toledo Internat ional, Inc., Columbus, OH) with a capacity of 32 kg (70.55 lbf), resolution of 1 gram (0.07 lbf), and a NIST-traceable calibration.

Five showerheads (samples 2, 3, 4, 12, and 15) were selected from the eleven that were tested using the pulling-force test system f , representing one failure, one questionable failure, two passes, and one test where the data logger faile d to record. New shower heads of the identical model and from the same manufacturer were proc ured to replace the samples evaluated during the pulling-force testing. These five samples were then evaluated with the gravity test.

The following steps were performed during a gravity test:

f A subset of showerheads were selected to ascertain if a simplified gravity test produced more conclusive results on those showerhead that had ambiguous re sults in the pull-force test.8 1. The showerhead’s sealing gasket, which provides a seal between the showerhead and supply fitting, and the screen upstream of the flow cont rol insert was removed (if present).

2. The showerhead was placed on the test stand such that the visible face of the flow control insert was directed downward and a pul ling-force of at l east 8 lbf applied to
the insert would not cause the showerhead to move.

3. The hanging mass was raised to create slack in the connecting wire such that the clamp could be attached to the flow control insert.

4. The clamp was attached to the flow control insert such that at least 8 lbf could be applied without separating the clamp from the insert.

5. The hanging mass was slowly lowered ben eath the showerhead using the laboratory jack until all the slack was removed from the connecting wire and the hanging mass hung freely below the flow control insert.

6. Once the calibrated mass was freely suspe nded, resulting in a pu lling-force of 8.05 lbf applied to the flow control in sert, a test start time was in itiated and the time recorded for at least 60 seconds from that initiation point.

If the flow control insert re mained in the showerhead hous ing after 60 seconds, then the showerhead met the 8 lbf retention requirement . After each test was completed, the hanging mass and clamp assembly was re-weighed and this weight was recorde d, documenting the force applied during the gravity test. Fo r all five showerheads tested, the measured weight recorded ranged from 8.04 to 8.05 lbf. Using the gravity te st, there were no questionable results. Two
showerheads failed the test while three passed. It should be noted that one of the flow control inserts could not support the weight of the cl amp assembly, which weighs approximately 0.4 lbm. Therefore, this showerhead failed the test prior to adding the hanging mass. The gravity testing results are also shown in Table 3.1.

Table 3.1 Flow Control Insert Retention Testing Results

Sample
Number Flow Control Insert Type Manual Qualitative
Assessment Pulling-Force Test Gravity Test

1 Plastic Removed Not Available * Not Available *

2 Plastic Removed Fail Fail
3 Plastic Removed Inconclusive Fail
4 Plastic Removed Pass Pass

5 Plastic Removed Pass Not tested †

6 Plastic Not removed Not tested ** Not tested **

7 Plastic Not removed Not tested ** Not tested **

8 Plastic Not removed Not tested ** Not tested **

9 Plastic Removed Inconclusive Not available *

10 Plastic Removed Pass Not tested †

11 Plastic Removed Pass Not tested †

12 Plastic Removed Pass Pass
13 Plastic Not removed Not tested ** Not tested **

14 Plastic Removed Fail Not tested †

15 Plastic Removed Data logger
malfunction Pass9 16 Rubber Removed Fail Not tested †

17 Gasket N/A N/A N/A
18 Permanent N/A N/A N/A
19 Permanent N/A N/A N/A
20 Permanent N/A N/A N/A
21 Permanent N/A N/A N/A
22 Permanent N/A N/A N/A
23 Permanent N/A N/A N/A * Additional showerhead samples of these models were not available for purchase for the tests indicated. ** These samples were not tested because the insert co uld not be removed during the manual qualitative assessment.

† These samples were not included in the sub-set of showerheads selected for the gravity test.

4.0 FLOW RATE TESTING

In addition to the flow control insert reten tion testing, DOE performe d a flow rate test on five showerheads that had plastic flow control in serts to gather backgro und data on the relative impact on flow rate resulting from removal of the insert. New showerheads were procured for this testing. The objective of th e flow rate test was to dete rmine whether removing the flow
control insert would affect the flow rate through the showerhead compared to the original offthe-shelf configuration. The flow rate through the showerhead was measured with an Omega FPR311 flow meter with a flow range of 0.07 to 5 gallons per minute and a 1 percent full-scale accuracy, as provided by the manufacturer. The out put from the flow meter was recorded with a Campbell Scientific CR1000 data logger. The static pressure was also obse rved using a pressure

gauge. g

To measure these changes in the flow rate, DOE used a test set up that was in accordance with the DOE test procedure for showerhead flow rate in appendix S to s ubpart B of 10 CFR part 430. However, the flow rate test did not comply with the spec ified calibration requirements for the flow meter and pressure gauge and the test wa s not performed at the re quired test pressure or temperature. Because the objective of these test s was only to measure th e relative impact of removing the flow control insert, and not to dete rmine whether the showerhead met the flow rate standard, DOE considered these deviations ac ceptable for these purpos es. In addition, the instruments DOE used were calibrated by their manufacturer and provided sufficient accuracy to achieve the stated test objective.

The flow rate of each showerhead was tested under three conditions: (1) the original offthe-shelf configuration; (2) with the flow contro l insert o-ring removed (if applicable); and (3)
with the entire flow control insert removed. The flow rate for each condition was measured by turning on flow to the showerhead for 30 seconds , collecting 1 minute of flow rate data, and averaging 1 minute of measured flow rate.

Three of the showerheads tested had a “dis c with o-ring” design for the flow control insert. For all three showerheads, removal of the o-ring from the fl ow control insert increased the flow rate between 8 and 42 percent, relative to the original off-the-shelf configuration. h Complete
removal of the flow control insert increased th e flow rate between 12 and 55 percent. Another
showerhead was tested that had a disc flow control insert with no o-ring. The flow rate increased 12 percent with the remova l of the insert. Last, a dual-flow rate showerhead that had a rubber

g The measured pressure was not used in the analysis to compare flow rate differences am ong the showerheads tested.

h All percentages provided are relative to the original off-the-shelf configuration.10 disc-style flow control insert wa s tested. For this showerhead, th e flow rate increased 36 percent
with the rubber disc removed when the showerhe ad was tested at the highest flow setting.

5.0 PROPOSED FLOW CONTROL INSERT RETENTION TEST METHOD

DOE’s preliminary testing described above showed that for all the showerheads DOE examined that use a removable insert, flow contro l insert retention testing could be accomplished using a pulling-style test (as oppos ed to a pushing force). DOE determined that the simplified gravity test approach is sufficient to allow validation of the flow control insert design requirement that is currently included in manufacturers’ certification reports.

The proposed test method provided in the SNOPR reads as follows:

Showerhead Flow Control Insert Test.

The following test method is for verification of compliance with the requirements of 10 CFR 430.32(p) pertaining to retention of showerh ead flow control inserts. This test is not required for certification under 10 CFR 429.12 but may be used by DOE to verify compliance with these requirements duri ng testing conducted pursuant to 10 CFR
429.104 or 10 CFR 429.110.

(a) General provisions: (1) If removal of the flow control insert would cause signific ant leakage between
the showerhead and the s upply fitting, the showerhead is exempt from the flow control insert design requirement. (2) If the means of controlling flow ra te is not physically removable, the showerhead is exempt from the flow control insert design requirement.

(b) Test method: If items in section (3)(a)(1) or (2) of this appendix do not apply, perform the following steps: (1) Remove the showerhead’s sealing gasket, which prov ides a seal between the showerhead and supply fitting, and the screen upstream of the flow control insert (if present). (2) Attach a clamp (or other gr asping device) to the flow control insert such that a force of at least 8 lbf can be applie d without separating the clamp (or other grasping device) from the flow control insert. (3) Secure the showerhead such that the vi sible face of the flow control insert is directly downward and a force of at l east 8 lbf will not cause the showerhead

to move. (4) Apply a pulling force using a combined 8 pound-mass (lbm) (  0.4 lbm) (total combined weight including clamp, connecting linkage, and hanging mass) secured to the clamp and lowered beneath the showerhead at a rate of no more than 1 inch per second until the mass freely hangs such that a downward 8 lbf
is exerted on the flow control insert. (5) Continue to apply the 8 lbf to the flow control insert for a minimum of 60
seconds.11 (c) Determination:
If the flow control insert is retained in the showerhead after performing sections (3)(b)(1) through (5) of this appendix, the showerhead complies with the design requirement.