Building Technologies Program 1 

Building Technologies Program

NOPR Public Meeting

For Plumbing Products Test

Procedures

pictures

Lucas AdinTuesday, July 24Lucas.Adin@ee
Building Technologies Program 2 

• Meeting Agenda

• Introductions• Role of the Facilitator• Ground Rules

– Listen as an ally

– Focus on issues

– Use short, succinct statements/keep to the point

– One person speaks at a time (raise hand to be recognized

name for the record)

– Hold sidebar conversations outside the room

– Set cell phones to silent/vibrate

• Housekeeping Items

Welcome and Introductions
Building Technologies Program 3 

Attending Parties Opening Statements

At this time DOE welcomes opening remarks/statements o

notice of proposed rulemaking (NOPR) on test procedure

showerheads, faucets, water closets, urinals, and comme

prerinse spray valves.
Building Technologies Program 4 

Test Procedure

Notice of Proposed Rulemaking (NOPR) AnalysesClosing Remarks, Contacts & Information

Public Meeting Slides Topics

5672 Regulatory History4 Rulemaking Overview

1 Introduction

3 Scope
Building Technologies Program 5 

• Present proposed amendments to the DOE test pro

for showerheads, faucets, water closets, urinals, ancommercial prerinse spray valves.

• Provide a forum for public discussion of rulemaking 

• Encourage interested parties to submit data, inform

and written comments.

• Inform interested parties and facilitate the rulemak

process.

Introduction

Meeting Purpose
Building Technologies Program 6 

Introduction

Issue Box In the NOPR for test procedures for showerheads,

faucets, water closets, urinals, and commercial prerinse spra

valves, DOE welcomes comments on particular issues raised 

text box like this. Throughout this presentation, specific issue

be raised for discussion on slides such as this, with identifyin

numbers corresponding to those in the NOPR document.

Nonetheless, comments concerning any part of the documen

presentation are welcome.

Request for Comment Format
Building Technologies Program 7 

Test Procedures

Notice of Proposed Rulemaking (NOPR) AnalysesClosing Remarks, Contacts & Information

Public Meeting Slides Topics

5672 Regulatory History4 Rulemaking Overview

1 Introduction

3 Scope
Building Technologies Program 8 

• The Energy Policy and Conservation Act (EPCA) of 1975 (Pub

163) established the energy conservation program.

• The amendments to EPCA in the Energy Policy Act of 1992 (

102‐486) established water conservation standards for show

faucets, water closets, and urinals and established the test p

as:

• ASME/ANSI A112.18.1M‐1989 for faucets and showerh

• ASME/ANSI A112.19.6‐1990 for water closets and urina

Regulatory History

Water Conservation Standards and

Test Procedures for Plumbing Products
Building Technologies Program 9 

• These procedures were subsequently revised by ASME, w

DOE to commence a rulemaking to update its procedures

required by EPCA, as amended.

• In a March 18, 1998 final rule (63 FR 13308), DOE incorpo

currently referenced versions into the Code of Federal Re

• ASME/ANSI A112.18.1M‐1996 for faucets and showe

• ASME/ANSI A112.19.6‐1995 for water closets and uri

• This rule did not change the relevant water conservation 

Regulatory History

Water Conservation Standards and

Test Procedures for Plumbing Products
Building Technologies Program 10 

Regulatory History

• The Energy Policy Act of 2005 amended EPCA to establish a 

national water conservation standard for commercial prerin

valves, and established the test procedure as ASTM Standar

U.S.C. 6293(b)(14)).

• DOE incorporated the 2003 version of this standard into the 

Federal Regulations in a final rule published December 8, 20

71340).

• Since the 2006 final rule, ASTM has reissued the F2324 stan

any substantive changes.

Standards and Test Procedures for

Commercial Prerinse Spray Valves
Building Technologies Program 11 

Regulatory History

• If ASME revises the test procedures for showerheads, f

water closets, or urinals, EPCA requires DOE to conduct 

rulemaking to evaluate adoption of the revised version

U.S.C. 6293(b)(7)(B) and 42 U.S.C. 6293(b)(8)(B))

• Because ASME has made such revisions, DOE is propos

incorporate by reference ASME/ANSI A112.18.1‐2011 a

procedure for showerheads and faucets, and ASME/ANA112.19.2‐2008 for water closets and urinals.

• As there has been no substantive update to the test pro

commercial prerinse spray valves (ASTM F2324‐03), DOproposing to retain the existing procedure with no cha

incorporate by reference the reapproved version.

Updates to Plumbing Standards Since DOE’s Last Rule
Building Technologies Program 12 

Test Procedures

Notice of Proposed Rulemaking (NOPR) AnalysesClosing Remarks, Contacts & Information

Public Meeting Slides Topics

5672 Regulatory History4 Rulemaking Overview

1 Introduction

3 Scope
Building Technologies Program 13 

• Review of existing DOE test procedures

• Comparison to current ASME test procedures• Product definitions

• Design requirement – retention of showerhead flow 

insert

• Basic model definition

• Regulatory review

Scope

NOPR Scope
Building Technologies Program 14 

Test Procedures

Notice of Proposed Rulemaking (NOPR) AnalysesClosing Remarks, Contacts & Information

Public Meeting Slides Topics

5672 Regulatory History4 Rulemaking Overview

1 Introduction

3 Scope
Building Technologies Program 15 

Rulemaking Overview & Framework

NOPR

Final

Rule

• DOE published the NOPR in a Federal Register notice on May 30, 2

31742).

• Today’s public meeting covers the proposals set forth in the NOPR 

the adoption of revised ASME test procedures for showerheads, fa

closets, and urinals and ASTM test procedure for prerinse spray va

• The NOPR provides avenues for interested parties to submit comm

Comments must be submitted to DOE by August 13, 2012.

• The NOPR information and materials are available online at:http://www1.eere.energy.gov/buildings/appliance_standards/residential/plumbing

Rulemaking Process Steps
Building Technologies Program 16 

Test Procedures

Notice of Proposed Rulemaking (NOPR) AnalysesClosing Remarks, Contacts & Information

Public Meeting Slides Topics

5672 Regulatory History4 Rulemaking Overview

1 Introduction

3 Scope
Building Technologies Program 17 

A112.18.1‐1996• No specification for

pressure differential

measurement

• Test procedure temperature

range 4 to 66  ̊C

• No specification for type of

container used to collectwater in the test procedure

A112‐18.1‐2011• Test pressure tole

be within ± 1 psi

• Test procedure te

range 5 to 71  ̊C

• Use of container l

enough to hold wcollected over a mof 1 minute when 

time/volume test 

ASME/ANSI Standard A112.18.1Faucets

Proposed Changes to Faucet Test Procedure
Building Technologies Program 18 

ASME/ANSI Standard A112.18.1Showerheads

A112.18.1‐1996• No specification for

pressure differential

measurement

• Test procedure temperature

range 4 to 66  ̊C

• No specification for

duration of flow

• No specification for type of

container used to collect

water in the test procedure

A112.18.1‐2011• Test pressure toleranc

within ± 2 psi

• Test procedure tempe

range 32 to 44  ̊C

• Flow to be maintained 

least 1 minute

• Use of container large 

to hold water collecte

minimum of 1 minute 

using the time/volumprocedure

Proposed Changes to Showerhead Test Proced
Building Technologies Program 19 

Request for Comments

Item 1 – DOE requests comment on its proposal to incorpora

reference ASME/ANSI Standard A112.18.1‐2011 for faucets a

showerheads, and specifically, the impact of the changes out

in the previous slides.
Building Technologies Program 20 

A112.19.6‐1995• No filter required in

apparatus setup

• Receiving vessel calibration

of 0.10 gallons (0.4 liters)

• No specification of timing

device; no requirement forlength of time that actuatoris activated

A112‐19.2‐2008• Filter required in t

apparatus setup

• Receiving vessel c

of 0.07 gallons (0.

• Requires use of an 

timer with incremmore than 0.1 sec

verify the actuatofor a maximum of 

ASME/ANSI Standard A112.19.6/.2

Water Closets & Urinals

Proposed Changes to Water Closet Test Proced
Building Technologies Program 21 

A112.19.6‐1995• Static pressure

requirements for aflushometer valve withsiphonic bowl are 80, 50,

and 15 psi and with blowout

bowl are 80, 50, and 35 psi

• No specification for

rounding total flush volume

A112.19.2‐2008

• Static pressure

requirements for aflushometer valve 

siphonic bowl are 8

and 35 psi and wit

bowl are 80, 45, an

• Rounding of the to

volume down to th

0.07 gallons (0.25 l

ASME/ANSI Standard A112.19.6/.2

Water Closets and Urinals ‐ Continued

Item 2 – DOE requests comment on its proposal to incorpo

reference ASME/ANSI Standard A112.19.2‐2008 for water c

urinals, and specifically ,the impact of the changes outlined
Building Technologies Program 22 

• Propose to require that dual‐flush water closets be te

according to ASME/ANSI Standard A112.19.2‐2008 to

determine maximum flush volume in full flush mode

• Propose to measure the water consumption of dual‐

water closets over a representative average period o

reflect other testing and reporting metrics.*

• Propose to measure flush volume of full and reduced 

per Section 7.4 of A112.19.2‐2008 and calculate the 

representative water use (2 reduced, 1 full).

• Water consumption reported to DOE would still be th

maximum measured value.

ASME/ANSI Standard A112.19.2Dual‐Flush Water Closets

*EPA WaterSense allows water consumption of dual-flush w

closets to be represented as a weighted average of flush vo

(assumes 2/3 of all flushes are reduced flow).
Building Technologies Program 23 

ASME/ANSI Standard A112.19.2Dual‐Flush Water Closets ‐ Continued

Item 3 – DOE requests comment on its proposal to develop 

procedure to measure the average representative water use flush water closets, and specifically, whether the use of a co

average is representative of water use and whether the 2:1 r

reduced flushes to full flushes is appropriate.
Building Technologies Program 24 

• Propose to retain existing test procedure and incorpo

reference ASTM F2324‐03 (2009), which is the most rversion of the ASTM Standard F2324 and includes no

substantive changes.

ASTM Standard F2324‐03

Prerinse Spray Valves

Item 4 – DOE requests comment on its proposal to incorp

reference ASTM Standard F2324 for prerinse spray valves,

particularly with respect to representativeness of measure

and test burden.
Building Technologies Program 25 

• Retain design requirement that showerhead flow con

insert be mechanically retained at point of manufact

subjected to 8 lb force (36 newtons) as described in s4.11.1 of the 2011 ASME Standard.

• Propose to maintain 8 lb force metric as the primary 

metric, with the 36 newton metric as a secondary m

• Incorporate the text of the requirement directly into 

rather than a reference to the ASME Standard.

ASME/ANSI Standard A112.18.1Showerhead Design Requirement

Item 5 – DOE requests comment on the prospective meth

verifying that the 8 lb force requirement has been met an

information on showerhead designs that complicate verifi

make it unnecessary.

Proposed amendments to requirements for flow restric
Building Technologies Program 26 

• Accessory means, with respect to plumbing fittings, a com

that can, at the discretion of the user, be readily added, r

or replaced and that, when removed will not prevent the 

from fulfilling its primary function.

• Body spray means a shower device for spraying water ont

from other than the overhead position.

• Dual‐flush water closet means a water closet incorporatin

feature that allows the user to flush the water closet with 

reduced or a full volume of water.

• Fitting means a device that controls and guides the flow o

• Hand‐held showerhead means a showerhead that can be 

place or used as a moveable accessory for directing wate

bather.

Proposed Definitions

Proposed definitions to be added to 10 CFR 430.2
Building Technologies Program 27 

Showerhead means an accessory, or set of accessories, to a fitting distributed in commerce for attachment to a single su

fitting, for spraying water onto a bather, typically from an ov

position, including body sprays and hand‐held showerheads, 

excluding safety shower showerheads.

Amended Definition of Showerhead

Proposed Modification in 10 CFR 430.2

Item 6 – DOE requests comment on its proposed definitions 

terms “accessory,” “body spray,” “fitting,” “hand‐held showe

and “dual‐flush water closet” and its proposed amendment 

existing definition of the term “showerhead.”
Building Technologies Program 28 

• No proposed changes to definition of a basic model

• For water closets and urinals, basic models should be 

by maximum flush volume of bowl and valve/tank

combinations for the purpose of reporting rated flus

volumes

Basic Model Definition

Item 7 – DOE requests comment on the current definition of a b

model of water closet and urinal, and any changes that might be 

to clarify the appropriate means by which to group various comb

of water closet and urinal bowls and flushing devices.
Building Technologies Program 29 

• DOE is not proposing to change the statistical sampli

and reporting requirements applicable to certificatio

for all five products.

• DOE is proposing to add rounding requirements for t

value of water consumption that is calculated for the 

sample and reported in certifications.

Certification

Item 8 ‐ DOE requests comment on all elements of the provisions 

calculation of test results, including the confidence limits; revision

sampling plans that might better reflect the level of precision tha

achievable for each respective test; and variability in measured w

consumption that is expected for each respective product.
Building Technologies Program 30 

Test Procedures

Notice of Proposed Rulemaking (NOPR) AnalysesClosing Remarks, Contacts & Information

Public Meeting Slides Topics

5672 Regulatory History4 Rulemaking Overview

1 Introduction

3 Scope
Building Technologies Program 31 

NOPR Analyses

Review Under the Regulatory Flexibility Act

DOE must determine whether the rule would result in a sign

impact on a substantial number of small entities.

• DOE used the Small Business Administration (SBA) definition 

entities:

– Plumbing equipment manufacturers are included in NAI

332913, “Plumbing Fixture Fitting and Trim Manufacturi

NAICS 327111, “Vitreous China Plumbing Fixture and Ch

Earthenware Bathroom Accessories Manufacturing.”

– The SBA standard for small entities in these industry

descriptions are 500 employees or less for NAICS 33291

750 employees or less for NAICS 327111.

• DOE identified 48 manufacturers of showerheads, faucets, w

closets, urinals, and commercial prerinse spray valves that q

small businesses.
Building Technologies Program 32 

Burden of Testing andRegulatory Review

Significance of Impact on Small Businesses

• DOE has determined the changes proposed in the NOPR will not a

test procedures, calculation methodologies or enforcement for th

products.

• DOE has determined that the proposed test procedure amendme

have a “significant economic impact on a substantial number of s

and the preparation of a regulatory flexibility analysis is not warra

Item 9 ‐ DOE seeks comment on its reasoning that the proposed 

procedure changes would not have a significant impact on a subs

number of small entities.
Building Technologies Program 33 

Test Procedures

Notice of Proposed Rulemaking (NOPR) Analyses

Closing Remarks, Contacts & Information

Public Meeting Slides Topics

5672 Regulatory History4 Rulemaking Overview

1 Introduction

3 Scope
Building Technologies Program 34 

Please reference all correspondence for this action with the following infor

– Plumbing Products Test Procedures Rulemaking

– Docket Number EERE‐2011‐BT‐TP‐0061

– Regulatory Identification Number (RIN) 1904‐AC65

Email: PlumbingPrds‐2011‐TP‐0061@ee.doe.gov

Comment period ends: August 13, 2012

Closing Remarks, Contacts & Information

Postal: Courier:Ms. Brenda EdwardsU.S. Department of Energy

Building Technologies Program

Mailstop: EE‐2J, Room 1J‐018

1000 Independence Avenue, SWWashington, DC 20585‐0121

Ms. Brenda EdwardsU.S. Department of Energ

Building Technologies Pro

950 L’Enfant Plaza, SWWashington, DC 20024

Tel: 202‐586‐2945

Plumbing Products Test Procedures Comment Submittal 
Building Technologies Program 35 

• DOE Appliance Standards

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

• Plumbing Products Test Procedures Rulemaking

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

ducts.html

• Contact Lucas Adin, Project Manager, from the Appliance Standards Program 

information:

– Lucas.Adin@ee.doe.gov

– 202. 287.1317

Closing Remarks, Contacts & Information

Plumbing Products Test Procedures

WebPages and DOE Contacts