1 | Building Technologies Program 

Test Procedures for LightEmitting Diode Lamps Notice of Proposed Rulemaking

Lucy deButt

BUILDING TECHNOLOGIES PROGRAM

Department of EnEnergy Efficiency Docket Number: LEDLamps-2011-

May 3, 2012
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• Introductions (around the room)• Role of the Facilitator• Ground Rules

- Listen as an ally- Focus on issues- Use short, succinct statements/keep to the point- Hold sidebar conversations outside the room- One person speaks at a time (raise hand to be recognized; s

name for the record)

- Set cell phones to silent/vibrate

• Housekeeping Items• Agenda Review• Opening Remarks

Welcome
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9:00 – 9:15 am Welcome, Introductions, Opening St9:15 – 9:30 am Rulemaking Process and Scope9:30 – 10:15 am Test Procedure for Input Power, Lum

and Correlated Color Temperature (C

10:15 – 10:30 am Break10:30 – 12:15 pm Test Procedure for Rated Lifetime12:15 – 12:30 pm Questions and Closing Remarks

Agenda
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• The Department is broadcasting this meeting live over the • DOE is providing the webcast to accommodate stakehold

are unable to attend the public meeting in person.

• The web broadcast allows stakeholders to listen in and vie

slides.

• All stakeholders are encouraged to submit written comme

the public meeting.

Listening Via the Webcast
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• Present DOE’s proposed test procedures for light-emitting 

(LED) lamps.

• Invite comment on the test procedure notice of proposed r

(NOPR) document. 

• Discuss next steps in the rulemaking.• Invite participants to provide summary comments or statem

raise additional issues for discussion. 

Purpose of the Public Meeting
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Issue box numbering corresponds to the list of issues publisheof the NOPR document, available at: http://www1.eere.energy.gov/buildings/appliance_standards/pdopr_frnotice.pdfThe deadline for submitting comments is June 25, 2012.

Issue Box: DOE welcomes comments, data, and informconcerning its proposed test procedures for LED lamps. that correspond to those raised in DOE’s published matewill be numbered in accordance with that material. Whetinvited by an issue box or not, comments are welcome opart of DOE’s analysis.

Issues for Discussion
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Opening Remarks

Meeting participants are invited to provide openiremarks or statements at this time.
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3 Test Procedure for Rated Lifetime

Public Meeting Slides Topics

1 Rulemaking Process and Scope2 Test Procedure for Input Power, Lumen Output, and 
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Test Procedure Rulemaking Process

Milestone D

Notice of Proposed Rulemaking (NOPR) Publication ANOPR Public Meeting MComment Period Ends JunFinal Rule Publication (projected) Nove

NOPR

Today

Final

Rule
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• This rulemaking is applicable to 

integrated LED lamps as defined by ANSI/IESNA RP-16-2010.

• An integrated LED lamp is composed of 

an LED source, such as LED packages or LED arrays, LED driver, ANSI standard base, and other optical, thermal, mechanical, and electrical components.

• An LED source is the light producing 

component within an LED lamp. It is the assembly of components or dies, including electrical connections, printed on a circuit board or substrate.

Scope of Applicability

Integrated LED LampSource: Philips

LED Source

Source: Journée

LS
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Issue 1: DOE requests comment on both proposed scope definition of LED lamps.

Issues for Discussion
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3 Test Procedure for Rated Lifetime

Public Meeting Slides Topics

1 Rulemaking Process and Scope2 Test Procedure for Input Power, Lumen Output, and 
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• DOE proposes to adopt IES LM-79-2008, “Approved Meth

Electrical and Photometric Measurements of Solid-State LProducts” with some modifications.

– Industry accepted standard for determining input power, lum

and CCT.

– Referenced by ENERGY STAR’s Integral LED Lamps specif– Recommended by FTC for testing LED lamps.– Required for voluntary participation in DOE’s Lighting Facts® 

Proposed Test Procedure Overview
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• The following test conditions, test setup, and test measure

requirements are adopted without modification from IES L2008:

– Air temperature and air movement– Power supply and voltage regulation– Lamp mounting– Electrical instrumentation and electrical settings– Lumen output measurement using an integrating sphere sys

goniophotometer system

– Method of measuring CCT

IES LM-79-2008 Summary

Issue 2: DOE requests comment on the proposed incorpoIES LM-79-2008 for determining lumen output, input poweCCT.
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• IES LM-79-2008 specifies that air flow around the LED lam

be such that lumen output measurement is not affected.

• IES LM-9-2009 provides additional specification for air mo

specifies a single-ply tissue paper should be held in place lamp and visual observations be made of air-draft.

Air Movement

Issue 3: DOE requests comment on whether air movemenbe specified in more detail than that provided by IES LM-7
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• Lamp orientation is known to affect thermal conditions wit

lamp, which may affect lumen output.

• IES LM-79-2008 specifies that the lamp should be tested 

operating orientation recommended by the manufacturer fintended use of the LED lamp.

• However, manufacturers typically do not specify the opera

orientation in product literature.

• DOE proposes that an equal number of lamps be operate

base up, base down, and horizontal orientations for testin

Lamp Orientation

Issue 4: DOE requests comment on operating an equal nulamps in the base up, base down, and horizontal orientatiothroughout testing.
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• DOE proposes that LED lamps should be tested at the rat

as specified in IES LM-79-2008.

• DOE proposes that LED lamps with multiple operating vol

should be tested at 120 volts, if the lamp is rated at 120 vobecause this is the most common operating voltage of avalamps.

• If the lamp is not rated at 120 volts, DOE proposes that it 

tested at the highest rated voltage.

• For dimmable lamps, DOE proposes that the lamp should 

at the maximum input power as specified in IES LM-79-20

Electrical Settings: Input Characteristics
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• IES LM-79-2008 specifies that lamps with multiple modes 

operation, such as variable CCT, should be tested in each operation.

• DOE has not identified any lamps that function at multiple 

operation and requests information on these products.

Electrical Settings: Multiple Modes of Operation

Issue 5:• DOE requests comment on testing LED lamps at the rat

for single voltage lamps and testing lamps with dimming at the maximum input power.

• Further, DOE requests comment about testing LED lamp

rated to operate at multiple voltages at 120 volts or the hrated voltage.

• Finally, DOE requests comment on whether LED lamps 

multiple modes of operation are available and the CCT vwhich these lamps should be tested.
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• IES LM-79-2008 specifies no 

seasoning requirement.

• DOE proposes that LED lamps be 

seasoned for 1,000 hours prior to lamp stabilization and lumen output measurement.

• Industry has observed an increase in 

lumen output during the first 1,000 hours of operation of an LED source.

Lamp Seasoning

Source: Richman, Eric. “Understand

LM-80, and TM-21.” DOE SSL Works

Issue 6: DOE requests comment on seasoning the LED la1,000 hours before collecting lumen output data.
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• DOE proposes that an LED lamp reaches stability when th

variation of at least 3 readings of input power and lumen o

taken 15 minutes apart is less than 0.5% as specified in IE

2008.

• The variation should be calculated as follows:• The equation clarifies the method specified in IES LM-79-

Lamp Stabilization

minim

maximum 

Variation of at least three readings  
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Issue 7: DOE requests comment on stabilizing the lamp uvariation of at least 3 readings of the lumen output and elepower, taken 15 minutes apart, is less than 0.5 percent. Drequests comment on its clarification of the variation calcube the difference of the maximum and minimum values divthe minimum value.

Issues for Discussion
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• DOE proposes that either a sphere-spectroradiometer, sp

photometer, or a goniophotometer be used to measure lumas specified in IES LM-79-2008.

Lumen Output Measurement: All Lamps

Issue 8: DOE requests comment on measuring the lumen the LED lamp using a sphere-spectroradiometer system, sphotometer system, and goniophotometer system. In partiDOE requests comment on whether the measurements fromethod are similar and consistent.
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• DOE proposes that the total lumen output be measured fo

directional LED lamps rather than the beam lumens (or zolumens).

– Other directional lamp technologies measure total lumen ou

reporting ‘brightness’ on FTC’s Lighting Facts label.

– Different directional lamp technologies cannot be compared 

LED lamps measure beam lumens while other technologies total lumens.

Lumen Output Measurement: Directional Lamps

Issue 9: DOE requests comment on measuring total lumedirectional LED lamps instead of beam lumens.
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• DOE proposes that a minimum of 21 LED lamps should b• A minimum of 3 lamps should be selected per month for 7 

production out of a 12 month period.

• If production occurs in fewer than 7 months of the year, 3 

lamps should be selected evenly for each month of produ

• Sample sizes greater than 21 should be multiples of 3 to t

equal number of lamps in each orientation.

Sampling Plan

Issue 21: DOE requests comment on the proposed samplrequirements for testing LED lamps.
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• DOE proposes that the input power of all test units be ave

the average value be rounded to the nearest tenths digit.

• DOE proposes that the lumen output and CCT of all units 

averaged and the average values be rounded to the nearedigit.

• DOE proposes that the estimated annual energy cost ($/y

calculated as the product of the average input power (kWcost rate ($/kWh), and estimated average use (hrs/day). Tresulting value should be rounded to the nearest cent.

Rounding Requirements

Issue 10: DOE requests comment on the proposed calculrounding requirement for lumen output, input power, CCT, estimated annual energy cost.
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3 Test Procedure for Rated Lifetime

Public Meeting Slides Topics

1 Rulemaking Process and Scope2 Test Procedure for Input Power, Lumen Output, and 
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Approaches Considered to Determine Rated Lifetime

Approach 1:

L70 of LED 

Lamp

Lumen output of the LED lamp is measured using IES LM79-2008 until half the sample size is below 70% of initial lumen output.

Approach 2:

ENERGY 

STAR Lifetime 

Projection

Lumen maintenance of LED lamp is measured for 6,000 hours using IES LM79-2008. Maximum rated lifetime claim is dependent on minimum lumen maintenance at 6,000 hours.

Approach 3:

Projection of 

IES LM-79-2008 

Data

Lumen output of the LED lamp is measured for 6,000 hours minimum using IES LM79-2008 and projected to L70 life of the 

lamp.

Ap

Pro

LE

Dat

TM

LummaiLED meausin80-2projL70 u

TM-Maxlifetexcehou
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• Advantages:

– LED lamp, rather than LED source is tested to determine rat– The reported value of rated lifetime is the observed value wh

output reaches 70% of initial lumen output (L70). That is, this 

does not require projecting the rated lifetime.

• Disadvantages:

– Testing the LED lamp until the lumen output reaches 70% of 

lumen output can take a very long time (almost 3 years for 2hours).

– Because LED lamps are an emerging technology and evolvi

the product may be obsolete by the time testing is complete

Approach 1: Measuring L70 of LED 

Lamp
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• Advantages:

– LED lamp, rather than LED source, is tested for 6,000 hours 

rated lifetime.

– Lumen maintenance is projected using minimum 6,000 hour

therefore, testing is not as time consuming as Approach 1 (approximately 9 months compared to 3 years).

• Disadvantages:

– LED lamp failure mechanisms, other than lumen depreciatio

accounted for.

– Cycling is not a proven source of failure for LED lamps.

Approach 2: ENERGY STAR Lifetime Projection
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• Advantages:

– Projects rated lifetime using LED lamp performance data rat

LED source performance data.

– Projection of rated lifetime is based on minimum 6,000 hour

which is not as time consuming as Approach 1.

• Disadvantages:

– Standard method to make a projection using IES LM-79-200

not yet been developed.

– It may not be feasible to develop a method for projecting IES 

2008 data in a timely manner for the FTC Lighting Facts lab

Approach 3: Projecting IES LM-79-2008 Data 
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Approach 4: Projecting LED Source Data using IES TM-21-2011

• Advantages:

– Uses accepted industry standard IES TM-21-2011 to project 

output of LED sources as determined by IES LM-80-2008.

– Maximum allowable projection cannot exceed 25,000 hours

• Ensures exceedingly large projections are not made solely on L

data.

• Currently unknown how long the LED driver may last or how th

effects may impact LED lamp lifetime.

– Less burdensome than testing the lamp for 6,000 hours acc

LM-79 because lumen maintenance data of LED sources is available from LED source manufacturers.
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• Disadvantages:

– Projects LED source data rather than LED lamp data.– Proposed approach does not account for LED driver degrad

failure, or effect of interactions among LED sources and betwsources and other components within the lamp.

• Standardized test methods to determine the impact of these co

rated lifetime have not yet been established

• Therefore, DOE proposes approach 4 because it uses a 

standardized test and projection method and has minimal burden.

Approach 4: Projecting LED Source Data using IES TM-21-2011

Issue 11: DOE requests comment on the relative costs anof the 4 approaches considered in the NOPR to determine lifetime of an LED lamp.
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• DOE proposes to define the rated lifetime of an LED lamp 

time at which the lumen output of the LED source within thfalls below 70% of initial light output (L70).

Definition of LED Lamp Rated Lifetime

Issue 12: DOE requests comment on the proposed definitrated lifetime of an LED lamp.
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Steps to Determine Rated Lifetime

Determine insitu 

temperature

Obtain lumen 

maintenance 

data

Project lumen 

maintenance 

data

• Perform an in-situ temperature measurement te

determine the case temperature of the LED soulumen maintenance data should be used.

• Directly from LED source manufacturers.• By interpolating the data available at 2 other cas

temperatures that bound the in-situ temperature

• By measuring the lumen maintenance at the in-s

temperature.

• Use the method described in IES TM-21-2011 to 

source lumen maintenance data.

• Maximum allowable rated lifetime projection is 2
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• DOE proposes that the test setup, conditio

equipment, instrumentation, and test box and construction specified in UL 1993-200for performing the ISTMT.

• DOE proposes a thermocouple should be 

to the temperature measurement point (Tdescribed by the LED source manufacturespecified in Appendix D of the ENERGY Sspecification.

– The temporary hole for inserting the therm

should be tightly sealed during testing.

– The ENERGY STAR specification provides 

to attach the thermocouple in the LED lam

In-situ Temperature Measurement Test

Determine insitu 

temperature

Obtain lumen 

maintenance 

data

Project lumen 

maintenance 

data
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Issue 17: DOE requests comment on adopting section 8.58.14, 8.15, and 9 of UL 1993-2009 and the practicality of tthermocouple attachment requirements for performing the 

Issues for Discussion
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• DOE proposes the test conditions to be a

in IES LM-80-2008.

• DOE proposes to test the LED source onl

situ case temperature, instead of the 3 temspecified in IES LM-80-2008.

• DOE proposes the drive current passing t

LED source should be equal to or greater drive current passing through the LED soLED lamp.

Test Conditions: Case Temperature and Drive Current

Determine insitu 

temperature

Obtain lumen 

maintenance 

data

Project lumen 

maintenance 

data
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• DOE proposes the temperature of the sur

air during testing should be maintained becast temperature and 5 °C below the case 

temperature as specified in IES LM-80-20

• DOE proposes the air movement to be su

thermal stratification is avoided as specifieLM-80-2008.

Test Conditions: Air Temperature and Air Movement

Issue 13: DOE requests comment on operLED sources at the in-situ case temperaturcurrent as well as the ambient conditions foDOE also requests comment on whether thmeasurement location for air temperature nLED source and airflow around the LED soshould be further specified.

Determine insitu 

temperature

Obtain lumen 

maintenance 

data

Project lumen 

maintenance 

data
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• DOE proposes that LED sources should b

operated in the orientation specified by thmanufacturer and spaced to allow airflow each unit as stated in IES LM-80-2008.

• DOE is not proposing a specific operating 

orientation for LED sources because the ctemperature is controlled during testing, thminimizing the effect of orientation on lum

Operating Orientation

Issue 14: DOE requests comment on whetoperating orientation of LED sources affectlumen depreciation over time.

Determine insitu 

temperature

Obtain lumen 

maintenance 

data

Project lumen 

maintenance 

data
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• DOE proposes that an external driver com

manufacturer’s guidance be used to drive source as specified in IES LM-80-2008.

External Driver

Issue 15: DOE requests comment on whetrequirement that the external driver used foLED sources be as specified by the manufaneeds further clarification.

Determine insitu 

temperature

Obtain lumen 

maintenance 

data

Project lumen 

maintenance 

data
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• IES LM-80-2008 specifies that the lumen 

the LED source be measured using a spectroradiometer.

• Instead, DOE proposes that a spherespectroradiometer system, sphere-photom

system, or a goniophotometer should be umeasuring the lumen output of the LED so

Instrumentation to Measure Lumen Output

Issue 16: DOE requests comment on using photometer system or a goniophotometer fmeasuring the lumen output of LED sourceaddition to the sphere-spectroradiometer syspecified in section 6.2 of IES LM-80-2008

Determine insitu 

temperature

Obtain lumen 

maintenance 

data

Project lumen 

maintenance 

data
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• DOE proposes that lumen maintenance b

measured as specified in IES LM-80-2008 TM-21-2011.

• DOE proposes that the following guideline

ENERGY STAR guidance document shouadopted:

– All LED source units should be of the sam– Guidance on testing LED sources of a lam

the following types of sources:

• Both phosphor-converted white and single-

packages.

• LED arrays with either a common phospho

phosphor layers over individual dies.

• LED array that is an assembly of LED pack

with its own phosphor layer. 

Lumen Maintenance Measurement

Determine insitu 

temperature

Obtain lumen 

maintenance 

data

Project lumen 

maintenance 

data
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Issue 18: DOE requests comment on adopting relevant gufrom the ENERGY STAR® guidance document for measumaintenance.

Issues for Discussion
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• DOE proposes that the rated lifetime shou

projected as specified in IES TM-21-2011

• If the projected rated lifetime is greater tha

hours, the maximum rated lifetime should hours.

• If the projected rated lifetime is less than 2

hours, the rated lifetime should be the provalue.

• The rated lifetime should be calculated in 

years based on 3 hours per day of operatresulting value should be rounded to the ntenth of a year.

Projected Rated Lifetime and Rounding Requirements

Determine insitu 

temperature

Obtain lumen 

maintenance 

data

Project lumen 

maintenance 

data
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Issue 19: DOE requests comment on adopting section 5.0 TM-21-2011 for projecting the lifetime of the LED sources maximum projection of 25,000 hours.Issue 20: DOE requests comment on the proposed roundrequirement for rated lifetime.

Issues for Discussion

Issue 11: DOE requests comment on the proposed approdetermining rated lifetime of LED lamps including the propincorporation of specifications outlined in IES standards LMand TM-21-2011 and UL standard 1993-2009.
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• DOE proposes that the sample size be as specified in IES 

2011.

• At a given case temperature and drive current, at least 10 

should be tested.

– The method of projection specified in IES TM-21-2011 canno

for less than 10 units.

Sample Size Requirements

Issue 21: DOE requests comment on the proposed samplrequirements for testing LED sources for determining the rlifetime of an LED lamp.
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• DOE estimated that this rulemaking will impact 17 potenti

business manufacturers of LED lamps from a total of aboumanufacturers.

• DOE estimated that each small business manufacturer typ

manufactures 17 basic models.

• The cost for testing 17 basic models for each manufacture

– Initial setup: $12,000– Labor cost for testing: $68,000

• The cost for changing package and product labeling as w

catalogs should not impose a significant burden.

Estimate Burden to Small Businesses
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Issue 22: DOE requests comment on its estimated numbebusinesses impacted by this rulemaking as well as its esticost and associated burden to small businesses.

Issues for Discussion
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• In all correspondence, include all of the following:

– Test Procedures for Light-Emitting Diode Lamps– Docket Number: EERE-2011-BT-TP-0071– Regulatory Identification Number (RIN): 1904-AC67

• Contact information:

– Email: LEDLamps-2011-TP-0071@ee.doe.gov– URL: 

http://www1.eere.energy.gov/buildings/appliance_standards_nopr_frnotice.pdf

• Comment period closes: June 25, 2012, 11:59 PM EDT

DOE Seeks Comment on its Proposed Test Procedure

Postal Mail:

Ms. Brenda EdwardsU.S. Department of EnergyBuilding Technologies ProgramMailstop EE-2J1000 Independence Avenue, SWWashington, DC 20585-0121

Courier:

Ms. Brenda EdwardsU.S. Department of EneBuilding Technologies P950 L’Enfant Plaza, SW, Washington, DC 20024

Telephone: (202) 586-29
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Questions?