1 | Energy Efficiency and Renewable Energy eere.energy.gov

July 28, 2015

James Raba

Department of Energy

Building Technologies Office

EERE-2014-BT-TP-0055

SprayValves2014TP0055@ee.doe.gov

Test Procedure:

Notice of Proposed Rulemaking for

Commercial Prerinse Spray Valves
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Welcome

• Introductions (around the room)

• Role of the Facilitator

• Ground Rules

– Speak one at a time

– Say your name for the record – there will be a complete transcript of 

this meeting

– Be concise – share the ‘air-time’

– Keep the focus here – cell phones on silent; limit sidebar conversations

– Webinar participants turn phone on mute; “raise your hand” to be 

recognized to speak

• Housekeeping Items

• Agenda Review

• Opening Remarks
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Agenda

1) 9:00 AM Introductions

2) 9:05 AM Opening Statements

3) 9:15 AM Regulatory History & Scope

4) 9:30 AM Definitions & Industry Standards Referenced

5) 10:00 AM Proposed Additions

6) 10:25 AM Small Business Impacts

7) 10:35 AM Closing Remarks for test procedure

8) 10:45 AM Break/Transition to ECS
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Public Meeting Slides Topics

1 Opening Statements

2 Regulatory History & Scope

3 Definitions & Industry Standards Referenced

4 Proposed Additions

5 Small Business Impacts

6 Closing Remarks

7 Break
5

Listening Via the Webcast

• DOE is broadcasting this meeting live over the Internet

• DOE is providing the webcast to accommodate stakeholders that 

are unable to attend the public meeting in person

• The web broadcast allows interested parties to listen in and view 

the slides

• All interested parties are encouraged to submit written comments 

after the public meeting
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Purpose of the Public Meeting

• Present DOE’s proposed test procedure for commercial prerinse 

spray valves (CPSVs)

• Invite comment on the notice of proposed rulemaking (NOPR) 

document

• Discuss next steps in the rulemaking

• Invite participants to provide summary comments or statements 

and raise additional issues for discussion
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Opening Remarks

Meeting participants are invited to provide opening remarks or 

statements at this time
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Issues for Discussion

Issue Box

DOE welcomes comments, data, and information concerning its proposed 

test procedure for commercial prerinse spray valves. Issues are numbered to 

correspond to issues presented in DOE’s published NOPR. Whether invited 

by an issue box or not, comments are welcome on any part of DOE’s 

analysis.

DOE welcomes comments, data, and information concerning its 

proposed test procedure for commercial prerinse spray valves. 

Whether invited by an issue box or not, comments are welcome 

on any part of DOE’s analysis. 
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How to Submit Written Comments

In all correspondence, please refer to these commercial prerinse spray valve 

rulemakings by:

Postal: Courier

Ms. Brenda Edwards Ms. Brenda Edwards

U.S. Department of Energy U.S. Department of Energy

Building Technologies Program, Building Technologies Program, Suite 600

Mailstop EE-5B 950 L’Enfant Plaza, SW

1000 Independence Avenue, SW Washington, DC 20024

Washington, DC 20585-0121 Tel: 202 586-2945

Title CPSV Test Procedure

Docket Number: EERE-2014-BT-TP-0055

Regulation Identification 

Number (RIN): 1904-AD41

Email: SprayValves2014TP0055@ee.doe.gov

Comments Due: September 8, 2015, 11:59 PM ET
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Public Meeting Slides Topics

1 Opening Statements

2 Regulatory History & Scope

3 Definitions & Industry Standards Referenced

4 Proposed Additions

5 Small Business Impacts

6 Closing Remarks

7 Break
11

Regulatory History & Authority

• Energy Policy and Conservation Act of 1975 (EPCA) Pub.L. 94-163

– The Act set forth a variety of provisions designed to improve the energy 

efficiency of various products and equipment

– Part B of Title III provides for the “Energy Conservation Program for 

Consumer Products Other than Automobiles” (42 U.S.C. 6291-6309)

• Energy Policy Act of 2005 (EPAct) Pub.L. 109-58

– Amended EPCA to include commercial prerinse spray valves

– EPAct defined CPSVs (42 U.S.C. 6291(33)), established a test procedure 

(42 U.S.C. 6293(b)(14)), and determined energy efficiency standards for 

flow rate (42 U.S.C. 6295 (dd))
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Regulatory History & Authority

• History of the Test Procedure

– DOE incorporated by reference in 2006 ASTM Standard F2324-03 under 

10 CFR 431.263. 71 FR 71340,71374 (Dec. 8, 2006)

– DOE updated the test procedure for CPSVs in 2013 by incorporating by 

reference ASTM Standard F2324-03 (2009) under 10 CFR 431.263. 78 FR 

62970, 62980 (Oct. 23, 2013)
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Steps in the Test Procedure Rulemaking

• DOE initiated a test procedure to support the CPSV energy conservation 

standard

– TP NOPR published in the Federal Register on June 23, 2015 (80 FR 

35874)

– TP NOPR Public Meeting today, July 28, 2015

• Comments on TP NOPR from interested parties 

– Transcript records oral comments from today’s public meeting

– Written comments (comment period closes September 8, 2015)

• DOE reviews and considers all comments

• Final Rule publication

– Final Rule is expected to be issued by the end of the year

NOPR Final

Rule
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Proposed Changes in this NOPR

In this NOPR, DOE proposes the followings changes:

1. Modify the current definition of the term “commercial prerinse spray 

valve,” and add a definition for the term “spray force”

2. Incorporate by reference relevant portions ASTM Standard F2324-13

3. Add a test method for measuring spray force

4. Add a requirement for measuring flow rate and spray force for each 

spray pattern in commercial prerinse spray valves with multiple spray 

patterns

5. Modify rounding requirement for flow rate and add a requirement for 

spray force

6. Modify current CPSV sampling requirements
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Public Meeting Slides Topics

1 Opening Statements

2 Regulatory History & Scope

3 Definitions & Industry Standards Referenced

4 Proposed Additions

5 Small Business Impacts

6 Closing Remarks

7 Break
16

Definition of Commercial Prerinse Spray Valve

• DOE’s current definition: Commercial prerinse spray valve means a 

handheld device designed and marketed for use with commercial 

dishwashing and ware washing equipment that sprays water on dishes, 

flatware, and other food service items for the purpose of removing food 

residue before cleaning the items. (42 U.S.C. 6291 (33)(A))

• DOE proposes the following definition of commercial prerinse spray valve:

Commercial prerinse spray valve means a handheld device suitable for use 

with commercial dishwashing and ware washing equipment for the purpose 

of removing food residue before cleaning the items.

Issue 1a. Commercial Prerinse Spray Valve Definition

DOE requests comment on the proposed revised definition of commercial 

prerinse spray valve. 
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Proposed Definition of Spray Force

• DOE proposes to define the term “spray force” to distinguish 

between product classes (see CPSV energy conservation 

standard NOPR for more details)

• Spray force is used in ASTM Standard F2324-13 and defined as 

“the amount of force exerted onto the spray disc”

• DOE proposes the following definition of spray force:

Spray force means the amount of force exerted onto the spray 

disc, measured in ounce-force (ozf). 

Issue 1c. Spray Force Definition

DOE requests comment on its proposed definition of spray force. 
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Method of Test

• The current DOE test procedure incorporates by reference ASTM 

Standard F2324-03 (2009) under 10 CFR 431.263. 78 FR 62970, 

62980 (Oct. 23, 2013)

• DOE proposes to update the method to the most recent industry 

method by incorporating by reference ASTM Standard F2324–13, 

which replaces the cleanability test with a spray force test

– Where the cleanability test evaluated cleaning time of a standard dinner 

plate, the current ASTM Standard F2324–13 prescribes spray force, 

measured in ounce-force (ozf)
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Industry Standards Incorporated by Reference Comparison

Metric Current DOE Test Procedure Proposed DOE Test Procedure

Water Pressure

Two different requirements to 

measure flow rate at water 

pressure of 60 ± 1 psi and 60 ± 2 psi

CPSV flow rate only measured 

at a water pressure of 60 ± 2 psi

Flow Rate of 

Flex Tubing 7 gpm 3.5 gpm

Water 

Temperature for 

Testing

120 ± 4 oF 60 ± 10 oF

Length of Water 

Pipe to be 

Insulated

Any insulation to have a thermal 

resistance (R) of 4 oF x ft2 x h/Btu 

for the entire length of the water 

pipe, from the mixture valve to the 

inlet of the flex tubing

No requirement

• The following table identifies other differences between ASTM 

Standard F2324–03 (2009) and ASTM Standard F2324–13
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Industry Standard Incorporated by Reference Sections

• DOE proposes to incorporate by reference only these sections 

of ASTM Standard F2324–13: 

Section(s) Description

6.1 – 6.9 Apparatus

9.1 – 9.5.3.2 Preparation of apparatus for flow rate and spray force 

tests

10.1 – 10.2.5 Flow rate test method

10.3.1 – 10.3.8 Spray force test method

11.3.1 Flow rate calculation

General Replace the plural “nozzles” with “nozzle”, and exclude 

references to the “Annex”
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Public Meeting Slides Topics

1 Opening Statements

2 Regulatory History & Scope

3 Definitions & Industry Standards Referenced

4 Proposed Additions

5 Small Business Impacts

6 Closing Remarks

7 Break
22

Proposed Additional Test Method – Spray Force

• DOE discussed in the September 2014 Framework public 

meeting for the CPSV energy conservation standard the 

addition of spray force to separate product classes

• DOE proposes to incorporate by reference sections 6.2 and 6.4 

– 6.9 (Apparatus), 9.1 – 9.5.3.2 (Preparation of apparatus for 

the spray force test), and 10.3.1 – 10.3.8 (Spray force test 

method) of the ASTM Standard F2324-13 for the measurement 

of spray force

Issue 2. Spray Force

DOE seeks comment on the proposed addition of the spray force test 

method.
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Proposed Additional Test Method – CPSVs with Multiple Spray 

Patterns

• DOE has identified several commercial prerinse spray valves on 

the market with multiple spray patterns

– The valves contain an average of three spray patterns

– Each spray pattern could have a different spray force and flow rate

• Therefore, DOE proposes that for a valve with multiple spray 

patterns, the flow rate and spray force for each spray pattern be 

tested

Issue 3. Spray Patterns

DOE requests comment on testing all spray patterns for commercial prerinse 

spray valves with multiple spray patterns.
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Proposed Rounding Requirements

• DOE proposes changing the rounding requirements for flow rate 

to two decimal places

– EPA’s WaterSense program currently requires rounding flow rate to two 

decimal places (1.28 gpm)

• DOE proposes to follow the spray force rounding requirements 

in section 11.4.2 of ASTM Standard F2324-13 – round to one 

decimal place

Issue 4. Rounding Requirements

DOE seeks comment on changing the flow rate measurement rounding

requirements from one decimal place to two decimal places.

DOE seeks comment on rounding requirements for spray force rounded to 

one decimal.
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Public Meeting Slides Topics

1 Opening Statements

2 Regulatory History & Scope

3 Definitions & Industry Standards Referenced

4 Proposed Modifications & Additions

5 Small Business Impacts

6 Closing Remarks

7 Break
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Review Under the Regulatory Flexibility Act

• DOE has used the Small Business Administration definition of 

small entities:

– Commercial prerinse spray valve manufacturers are included in NAICS 

332919, “Other metal valve and pipe fitting manufacturing”

– The SBA standard for small entities in this industry description is < 500 

employees

• DOE found that eight out of eleven manufacturers of commercial 

prerinse spray valves qualify as small businesses
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Testing Burden Comparison

• Projected compliance requirements of the proposed rule for 

CPSVs, relative to current DOE test procedure:

Current Test Procedure Proposed Test Procedure Difference

Testing at least two units 

per basic model

Testing at least two units 

per basic model None

Does not require spray 

force test Requires spray force test

Negligible change in test time 

since DOE believes 

manufacturers already test for 

spray force

No requirement to test all 

spray patterns for CPSVs 

with multiple spray 

patterns

Requires CPSVs with 

multiple spray patterns be 

tested for flow rate and 

spray force for each 

pattern

+ approximately 1 hour
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Public Meeting Slides Topics

1 Opening Statements

2 Regulatory History & Scope

3 Definitions & Industry Standards Referenced

4 Proposed Modifications & Additions

5 Small Business Impacts

6 Closing Remarks

7 Break
29

Request for Closing Remarks

At this time DOE welcomes any closing remarks from 

interested parties
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Reminder: How to Submit Comments

• Public Meeting – Oral comments will be captured in the transcript and 

become part of the public record.

• Written comments – NOPR comment period open until September 8, 2015.

Reference docket #: EERE–2014–BT–TP–0055 and/or RIN #: 1904–AD41

Email: SprayValves2014TP0055@ee.doe.gov

Mail: Mrs. Brenda Edwards

U.S. Department of Energy

Building Technologies Office

1000 Independence Avenue SW., Mailstop EE-5B

Washington, DC 20585-0121

Courier: Mrs. Brenda Edwards

U.S. Department of Energy

Building Technologies Office

950 L'Enfant Plaza, Suite 600

Washington, DC 20024

Telephone: 202 586-2945
31

Public Meeting Slides Topics

1 Opening Statements

2 Regulatory History & Scope

3 Definitions & Industry Standards Referenced

4 Proposed Modifications & Additions

5 Small Business Impacts

6 Closing Remarks

7 Break