Mr. lucas Adin 

CSA 

Group 

Assistant Secretary for Energy Efficiency and Renewable Energy 

U.S. Department of Energy 

Forrestal Building 

1000 Independence Ave SW 

Washington, DC 20585-0121. 

November 1, 2013 

Sublect: Petition for Recognition as a Notionally Recognized Certification Program for small electric 

motors. 

Dear Mr. Adio, 

Please accept this letter and accompanying supporting material as CSA Group's petition for 

recognition of our small motor energy efficiency verification program to be classified as a nationally 

recognized certification program in the United States, in accordance with 10 CFR Part 431. 

Enclosed please find three (3) binders, each containing the required information for the Department 

of Energy (DOE) recognition of nationally recognized certification programs described in Sections 

431.447 and 431.448 of 10 CFR Part 431, dated May 4,2012. 

Among the topics, this documentation package includes: 

1. A guide describing our small motor energy efficiency verification service program; 

2. A general description of our quality management system covering the essential elements of our 

standards and procedures for operating a certification system; 

3. CSA Group By-laws and assurance of our independence and influence from manufacturers, 

suppliers and vendors; and 

4. Samples of CSA Group accreditations. 

CSA Group has been offering a motor Energy Efficiency Verification service program since 1992 in 

support of Ca nadian Federal and Provincial Regulations and since 2002 for evaluation of electric 

motor efficiencies to US DOE requirements. Key elements of our program for confirming continued 

compliance of a motor with a standard are (II a detailed construction report for a motor on its initial 

submission; (2) follow-up inspections to confirm consistency of construction and markings; (3) annual 

re-testing; and (4) cha llenge testing service. CSA Group is confident that our organization and staff 

have proven experience in operation a certification program in this area, and our certification system 

procedures fully meet the evaluation criteria for us to be classified by DOE as a nationally recognized 

certification program. We, therefore, believe that this petition is in order and that it can be 

processed without delay. Please let me know if you require any further information. 

Thank you very much for your consideration, 

Rick Morrison P.Eng., 

Technical Manager, Energy Efficiency Verification, (SA Group. 

CSA Group, 178 Rexdale Boulevard 

Toronto, ON, M9W 1R3, Canada 

T: 416 747 4090 

Page 1 of9 
Petition for Recognition 

Energy Efficiency Evaluation of Electric Motors to United States Department of Energy 

Requirements Documented in 10 CFR 431 - Subpart B and Subpart X 

Table of Contents 

Section 1. Scope and Application 

Section 2. Overview of CSA Group 

-letters of Patent 

-Statement of Independence 

-CSA By-laws 

-Annual Report 

-Corporate Organization Chart 

Section 3. Certification and Testing - Quality Management System 

Section 4. CSA Group's Motor Energy Efficiency Verification Program 

-Product Directory 

Section 5- Examples of Other CSA Group Accreditations 

Section 1-Scope and Application 

Since 2002, CSA Group's electric motor (1 hp - 500 hpj energy effiCiency verification program has 

been DOE listed as a nationally recognized certification program. CSA Group is seeking scope 

expansion to be classified as a nationally recognized certification program in the United States under 

EPCA with respect to verifying Small Electric Motor (1/4 hp - 3 hpj efficiencies when applying the 

following test procedures and standards: 

(a) Test method B of ANSI/IEEE 112-2004, Test Procedure for Polyphase Induction Motors and 

Generators; 

(b) Test method of CSA C390-10, Test method, marking requirements and energy efficiency 

levels for three-phase induction motors; 

(c) Test method of CSA C747-09. Energy effiCiency test methods for small motors. 

(d) Test method of IEEE 114-2001, Test procedure for single-phase induction motors. 

(e) NEMA MG1- 2009, Motors and Generators 

Page 2 of9 
Facilities 

CSA Group Certification Facilities 

CSA Group has facilities in Canada, in the United States, in Europe and in the Far East. For your 

reference they are as follows: 

Area Address 

Montreal 865 EIIingham Street, Pointe Claire, PQ H9R 5E8 

Toronto 178 Rexdale Boulevard, Toronto, Ontario M9W lR3 

Edmonton 1707~94 Street NW, Edmonton, AS T6N lE6 

Vancouver 13799 Commerce Parkway, Richmond, BC V6V 2N9 

Cleveland 8501 East Pleasant Valley Road, Cleveland, OH 44131-5575 

Irvine 2805 Barranca Parkway, Irvine, CA 2606~5114 

Frankfurt Weismullerstrasse 45, 60314 Frankfurt am Main, Germany 

Shanghai 1st Floor, Building 4, Q1Iai Industrial City, 889 Yishan Road, Shanghai, 200233 Ch ina 

Designated Testing Facil ities 

As part of CSA Group's motor energy efficiency verification program we are using our Toronto test 

facility and the Loboratoire des Technologies de I'fnergie of Hydro~Quebec, (L TE) for such purposes as 

product qualification testing, re-testing, and challenge testing. The facilities of Toronto are used for 

testing the fu ll range of motors from 0.25 up to SO horsepower and the LTE facilities are used for 

motors ranging 50 to 500 horsepower. 

Summary of Section 1 Supporting Documentation 

Section 1 of the CSA petition contained no supporting documents. 

Section 2 - Overview of CSA Group 

Name and Address 

CSA Group 

178 Rexdale Blvd, 

Toronto, Ontario, M9W lR3 

(Headquarters) 

Background 

CSA Group is an independent organization providing services in the fields of Standards Development 

and Conformity Assessment. The Standards Division of CSA Group is responsible for the 

administration of the development of voluntary consensus based standards, while the Certification 

and Testing Division provides conformity assessment programs including laboratory testing 

certification and inspection. The Consumer Product Evaluation Division provides services for 

consumer product evaluation. 

Page 3 of9 
Canadian Standards Association, operating as CSA Group, was established in 1919 as an independent, 

not-far-profit corporation under Part II of the Canada Corporations Act. CSA Group is a membership 

association whose purpose is to make standards work for people and business. CSA Group is the 

largest standards developer in Canada, certifies and tests various products to standards which may 

be destined for retail markets in Canada, the US and internationally, and tests consumer products to 

retailer protocols. CSA Group has staff which includes approximately 1100 employees in 14 offices 

across North America, as well as over 7,000 members who volunteer their time and knowledge to 

develop standards and programs that benefit business, industry and society. CSA Group has sales of 

approximately S250M, is involved in 52 technologies, and has over 2,000 standards and over 88,000 

customers. 

Ownership 

CSA Group is an independent, not-far-profit organization governed by a Board of Directors selected 

by the membership. The Association has no affiliation with manufacturers or suppliers of the 

products submitted for certification. Attachment 1 provides information regarding: (a) CSA's letters 

of Patent; (b) Statement of Independence; and (e) By-laws. 

Board of Directors and Principal Officers 

See CSA Group's Annual Report for the individuals serving on our Board of Directors and Executive 

Management Team. 

See Attachment 2. 

Major components ofthe Association are shown on the "Corporate Organization Chart." See 

Attachment 3. 

Summary of Section 2 Supporting Documentation 

Section 2, Attachment 1, contains copies of: the Canadian Engineering Standards Association Charter, 

dated January 21, 1919; the Canadian Standards Association Supplementary Letters Patent, dated 

April 26, 1944; 

Section 2, Attachment 2, a sworn Statement of Independence, dated October 16, 2013; 

Section 2, Attachment 3, is a copy of the CSA Group 2012 Annual Report. 

Section 2, Attachment 4, is a copy ofthe CSA Group senior management organization chart. 

Page 4 of9 
Section 3 - CSA Group Certification Services Quality Management System 

CSA Group's Certification Division maintains the quality assurance system for the Association's 

worldwide operations. The objective of this system is to ensure, 

(a) technical excellence; 

(b) consistency of interpretation, application of standards, programs and procedures; 

(c) integrity of our Mark; and 

(d) continuous improvement. 

The Quality Assurance system for the Division is based on national and international accreditation 

requirements and specific contractual customer requirements. The accreditation req uirements are 

found in the applicable editions of the following standards. 

ISO/IE( Guide 65/ General Requirements for Bodies Operating Product Certification Systems 

SCC/CAN-P3 

SCC/CAN-P-1500 Additional Requirements for Accreditation of Certification Bodies 

ISO/lEe 17025/ General Requirements for the Competence of Calibration and Testing laboratories 

SCC/CAN P-4 

ANSI Z34.1 American National Standard for Certification-third party certification program 

CSA Group has implemented the requirement s specified in ISO/IEC Guide 65, General requirements 

for bodies operating product certification systems. CSA Group facilities are accredited by 

accreditation bodies such as Standard Council of Canada and ANSI to these req uirements. 

Divisional Quality Documents (DQDs) are operating procedures and gUidelines used by staff in 

support of the quality assurance system. 

Summary of CSA Group Section 3 Supporting Documentation 

Section 3 of the CSA petition contained no supporting documents. 

Section 4 ~ CSA Group's M otor Energy Efficiency Verification Program 

Overview of the CSA Verification Program: 

Application 

Evaluation and Testing 

Certification 

Service Agreement 

Accompanying Services 

Follow-up Inspections 

Product Re-testing 

Challenge Testing 

Corrective Action 

Sampling Process 

Expertise in Motor Test Procedures 

Page 5 of9 
As Canada's premier Standards Development Organization, (SA Group publishes consensus 

standards to improve products and enhance trade ~ all the time ensuring the needs of our various 

Stakeholders are met. By establishing consensus among the different interest groups, with a 

balanced committee process, (SA Group creates effective standards that are frequently referen ced 

in Canadian Energy Efficiency Regulations. In ad<lition, US DOE electric motor and small electric 

motor Regulations reference (SA Standards such as C39G-10 and C747-09. 

CSA Standard (390-10, Test method, marking req uirements and, energy efficiency levels for threephase induction methods, is widely used in Canada as an integral part of Federal and Provincial 

Regulations. Electrical utility programs also make use ofthis standard to promote the use of higher 

levels of energy performance on a voluntary basis. 

Our intimate knowledge of the standard coupled with CSA Group's recognition as an accredited 

Certification Organization in Canada for motor efficiency and electrical safety supports the needs of 

manufacturers, consumers and regulators. We provide the necessary independent assurance that 

motors covered by government regulations meet and continue to comply with the established 

energy efficiency requirements. 

Verification Program 

The acceptance of motors under the CSA Group's energy efficiency verification program depends 

upon the satisfactory evaluation and testing to determine that the requirements of the applicable 

standard (CSA Standard C390-10, C747-09) are met on a continuing basis. The following is a 

description of the major elements of our program used for qualifying manufacturers' motors or 

group of motors. 

Application 

The customer makes an application requesting energy efficiency verification for his motor and 

submits all required documentation such as a list of all motors being submitted by model 

designation, type, and applicable performance ratings. The application is given a specific file to track 

and record all activities to the project. A qualified person (e.g., professional engineer) is then 

assigned responsibility for handling the project. 

Evaluation and Testing 

(SA Group with the manufacturer's assistance prepares a motor control list, identifying the critical 

features and the controls for these features for maintaining consistent performance with respect to 

energy efficiency. Representative motor samples are tested by an acceptable facility such as CSA 

Group or LTE to verify manufacturers rated efficiency values. 

Attachment 1 provides a description of the procedures used for the initial motor qualification testing 

and the follow-up re-testing service to ensure continued compliance. A find ings letter is then issued 

giving the results of our evaluation and actions needed, if applicable, to meet the standard. Modified 

samples may be required for further examination and testing. 

Page 6 of9 
Certification 

After the resolution of all the action items and all the conditions ofthe standard are met, the 

applicant is formally authorized to apply the CSA Group Energy Efficiency Verification Mark. A report 

is prepared describing the product and giving the related test results. A directory listing all products 

verified for energy efficiency is published and available to the general public. See Attachment 2. 

Service Agreement 

The applicant authorized to represent its motor as verified with our Energy Efficiency Marking must 

enter a signed agreement with CSA Group. This agreement addresses the conditions for maintaining 

certification such as access to facilities and records, follow-up inspection, product re-testing and 

challenge testing. Manufacturers are also required to notify CSA Group when changes are made to 

the motor, which may affect their performance rating. These terms and conditions are designed to 

protect the integrity of our Energy Efficiency Marking. 

Accompanying Services 

After the motor has been initially evaluated and found to comply with the standard, our program 

includes additional services to ensure that motors bearing the CSA Group verification marking 

continue to meet the applicable requirements. These services are: 

(a) Follow-up inspections; 

(b) Product re-testing; and 

(c) Challenge testing. 

Follow-up Inspections 

Follow-up inspections are conducted at the point of manufacturing each year to ensure that, 

(a) our mark is only applied to motors that have been verified for energy efficiency; 

(b) the manufacturers' product control measures are continuing to produce marked products t hat 

are in compliance with our report and the standard; 

(c) samples required for re-testi ng are selected and sealed by CSA Group staff during these visits. 

Product Re-testing 

Although a report is generated for motors detailing the critical construction featu res needed for 

maintaining consistent performance with respect to energy efficiency, our program is supplemented 

with unannounced motor re-testing to the specified requirement. This facilitates continued 

compliance with the standard and maintains the integrity of our mark. 

Challenge Testing 

Another service-challenge testing- is offered to any manufacturer or other party wishing to 

confirm the motor efficiency rating of a verified motor. This feature assists in ensuring the integrity 

of our verification program and can lead to the motor efficiency de-rating or a delisting of a series of 

motors re presented by the sample motor. 

Page 7 of9 
Corrective Action 

When a motor fails to comply with the standards, we take the following steps: 

(a) remove the verification mark from the affected motor or motors; 

(b) delist the motor{s); 

(c) notify the applicable regulatory authorities and government departments of noncompliant motors 

(i.e., serial number, date code, or equivalent); 

(d) re-test and verify the motor efficiency rating after the manufacturer modifies the product. 

Sampling Process 

The objective of our sampling process is to minimize manufacturers' tests, costs and time to market, 

while providing sufficient confidence that the series of motors verified meet the applicable energy 

efficiency standard. The added features of our program such as unannounced fotlow-up inspections, 

random motor re-testing and challenge testing are critical components for demonstrating continued 

compliance to the standard. As a consequence of our CSA Group's continual surveillance, the 

following sampling process guideline has emerged. 

Samples Required for Motor Model Qualification Testing 

Test 5 units of each 5 basic motor model type (total of 25 motors). The effiCiency of the sample lot 

must equal or exceed the required nominal full load effiCiency rating. The individual sample 

efficiencies must comply with the nominal efficiency tolerance required by the Standard. 

Manufacturer's information indicating efficiency ratings must be in agreement with CSA Group's 

record s. 

Selection of Basic Model Types to represent a Series of Motors 

A minimum of five (5) basic model types are requ ired to be tested to verify the efficiency ratings of a 

series of motors. The basic model types are to be selected such that they represent the complete 

range of motors within the series. This may require that more than 5 basic model types are selected. 

High volume production motors are to be represented in the basic model types selected. 

Samples Required for Scheduled Motor Re-testing 

A goal for verifying continued compliance with the standard is to re-test high volume motors at least 

once every 2 years. Other motors of different frame series are to be retested as needed to ensure 

continued compliance. 

The initial sample lot shall consist of one motor. If the result equals or exceeds the minimum result 

from the qualification tests, then no further samples are required. If the result is less than the 

minimum result from the qualifying tests, then select motor samples per the qualifying test 

procedure. 

Page 8 of9 
Expertise in Motor Test Procedures 

CSA Group has been active in the certification for safety of electric motors since before 1940 and has 

more than 450 certification listings active at this time. 

(SA Group has been offering the Energy Efficiency Verification Service for Electric Motors since 1992 

with motor size from 1 to 500 hp. The motor efficiency is tested to Standards CSA C390-10, IEEE 112-

2004, [EEE 114 and CSA 747-09. (SA has obtained accreditation from DOE in 2002 for motor 

efficiency US Department of Energy as a nationally recognized certification program in 2002 (Federal 

Register /Vol 67, No 249/ Friday December 27, 2002/ Notices). 

Summary of CSA Group Section 4 Supporting Documentation 

Section 4, Attachment 1, contains a copy of an information letter to "All Manufacturers of AC Three 

Phase Induction Motors Rated 1 hp to 500 hp," which is entitled "Announcing CSA Standard C390-10 

Test methods, marking requirements and energy efficiency levels for three-phase induction motors, 

4th edition. " 

Section 5 - Examples of Other CSA Group Accreditations 

The certification system and technical capabilities of the Association have enabled CSA Group to be 

accredited nationally and internationally for a wide product spectrum such as electrical safety, 

energy efficiency, plumbing and gas. See Attachment 1 for examples of accreditations CSA Group has 

received. 

Qualification of (SA Group to operate as a Certification System 

The US Department of Energy recognized the Energy Efficiency Verification Service of CSA Group as a 

Nationally Recognized certification Program in a Federal Register Notice dated 27 December 2002 

(67 FR 79480). 

Summary of CSA Group Section 5 Supporting Documentation 

Section S, Attachment 1, contains copies of the following documents CSA Group has received in 

recognition of its certification system and technical capabilities: 

1. Certificate of Accreditation under the Certification Body Accreditation Program, from the 

Standard Council of Canada, June 27, 2013; 

2. Certificate of Accreditation in recognition of being an Accredited Testing organization, from 

the International Accreditation Service, November 1, 2012. 

3. Certificate of Recognition as a Nationallv Recognized Testing laboratory, from the 

Occupational Safety and Health Administration, effective through Oecember 31, 2014. 

Page 9 of9