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Fluorescent Lamp Ballasts 

Test Procedure Notice of 

Proposed Rulemaking Public 

Meeting 

The Department of Energy (DOE) is holding a 

public meeting that will first cover the test 

procedure notice of proposed rulemaking 

(NOPR) for fluorescent lamp ballasts and then 

the energy conservation standards rulemaking 

for the same products. This public meeting 

gives DOE an opportunity to present the 

proposals in the test procedure NOPR and to 

respond to stakeholder questions. DOE will 

also seek input from interested parties on the 

planned methodologies, assumptions, data 

sources, and the NEMA Alternative Test 

Procedure Handout. 

The following documents are available as 

Adobe Acrobat PDFs. Download Adobe 

Reader. 

Meeting Materials 

z Test Procedures for Fluorescent Lamp 

Ballasts; NOPR, as issued by the 

Secretary of Energy (PDF 2.0 MB) 

NOTE: The official version of the NOPR 

will be published in the Federal Register

shortly. 

z NEMA Alternative Test Procedure 

EERE Information Center

Programs and Offices 

DATE: April 26, 2010 

TIME: 9:00 a.m. ET 

LOCATION:

U.S. Department of Energy 

Forrestal Building 

Room 8E-089 

1000 Independence Avenue, SW 

Washington, DC 20585 

Appliances and Commercial Equipment Standards: Fluorescent Lamp Ballasts Test Proce... Page 1 of 3

http://www1.eere.energy.gov/buildings/appliance_standards/residential/fluorescent_lamp_... 3/23/2010

EERE-2009-BT-TP-0016 DOC ID 1.2.001
Handout (PDF 90 KB) 

This document outlines a draft NEMA 

test procedure for the measurement 

of fluorescent lamp ballast efficiency. 

DOE summarizes this test procedure 

as an alternative method under 

consideration in the fluorescent lamp 

ballast active mode test procedure 

NOPR in section III.E.2. DOE requests 

comment on this alternative test 

method as noted in section V.E.5 of 

the test procedure NOPR. 

z Test Data, Appendix 5c of the 

fluorescent lamp ballast energy 

conservation standard preliminary 

technical support document (PDF 234 

KB) 

z Presentation (available after meeting) 

z Agenda (available after meeting) 

z Transcript (available after meeting) 

A transcript will also be available for 

public inspection in the Building 

Technologies Program Reading Room, 

between 9:00 a.m. and 4:00 p.m., 

Monday through Friday, except 

Federal holidays. To schedule an 

appointment or to purchase this 

transcript, contact: 

Brenda Edwards 

U.S. Department of Energy 

Building Technologies Program 

950 L'Enfant Plaza, 6th Floor 

Washington, DC 20024 

202-586-2945 

How to Submit Comments 

Submit comments electronically, by mail, or 

by courier. Wherever possible, comments in 

the electronic format should carry the 

electronic signature of the author. Absent an 

electronic signature, comments submitted 

electronically must be authenticated by 

submitting the signed original paper 

document. 

All comments submitted must identify the 

docket number, and regulatory identifier 

number (RIN). 

z Docket Number EERE-2009-BT-TP0016 and RIN 1904-AB99. 

Comments may be submitted using any of 

the following methods: 

Appliances and Commercial Equipment Standards: Fluorescent Lamp Ballasts Test Proce... Page 2 of 3

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EERE-2009-BT-TP-0016 DOC ID 1.2.001
Building Technologies Program Home | EERE Home | U.S. Department of Energy

Webmaster | Web Site Policies | Security & Privacy | USA.gov 

Content Last Updated: 03/19/2010 

z Federal eRulemaking Portal:

http://www.regulations.gov/

Follow the instructions for submitting 

comments. 

z E-mail:

FLB-2009-TP-0016@ee.doe

Include docket number EERE-2009-

BT-TP-0016 and/or RIN 1904-AB99 in 

the subject line of the message. 

z Postal Mail:

Brenda Edwards 

U.S. Department of Energy 

Building Technologies Program 

Mailstop EE-2J 

1000 Independence Avenue, SW 

Washington, DC 20585-0121 

Please include one signed original 

paper copy. 

z Hand Delivery or Courier:

Brenda Edwards 

U.S. Department of Energy 

Building Technologies Program 

950 L'Enfant Plaza, 6th Floor 

Washington, DC 20024 

Telephone: 202-586-2945 

Please include one signed original 

paper copy. 

Comments should clearly identify 

docket number EERE-2009-BT-TP0016. 

Contact Information 

Linda Graves

Project Manager 

202-586-1851 

Printable Version 

Appliances and Commercial Equipment Standards: Fluorescent Lamp Ballasts Test Proce... Page 3 of 3

http://www1.eere.energy.gov/buildings/appliance_standards/residential/fluorescent_lamp_... 3/23/2010

EERE-2009-BT-TP-0016 DOC ID 1.2.001
NEMA Test Procedure DRAFT Page 1 

U.S. DEPARTMENT OF ENERGY

Energy Conservation Program for Consumer Products and Certain 

Commercial and Industrial Equipment 

Summary: 

The following document details a draft NEMA test procedure for the measurement of 

fluorescent lamp ballast efficiency. DOE summarizes this test procedure as an 

alternative method in the fluorescent lamp ballast active mode test procedure notice of 

proposed rulemaking (NOPR) in section III.E.2. DOE requests comment on this 

alternative test procedure as noted in section V.E.5 of the test procedure NOPR. 

Problem Statement 

As electronic ballasts gain performance and features, it becomes difficult to utilize aging 

industry standard test methods like the photometric based system measurement of BEF 

to fully and completely characterize the ballast electrical performance. Variations in 

lamp performance and errors inherent in the photometric measurement cloud the true 

performance of the ballast. As BEF is a system measurement, it is difficult to separate 

the performance contributed by the lamps and errors of the photometric measurement 

system from the ballast performance. A new metric is sought to accurately characterize 

performance levels of today’s high performance instant start and full cathode cutoff 

programmed start electronic ballasts. 

Background, Task Force on Ballast Efficiency 

 The NEMA Task Force on Ballast Efficiency has worked to identify testing methods 

and test equipment characteristics necessary to accurately measure ballast 

performance. In NEMA Round Robin testing, sets of representative ballasts were 

operated on precision resistive loads and were measured by all the manufacturers and 

also by some independent laboratories. The goal was to arrive at an accurate and 

repeatable test methodology that could be used to evaluate ballast performance and 

provide a bridge to the generation of system operating parameters or a lamp equivalent 

transfer function without the use of lamps or photometric measurements. 

Testing Issues-Resistive Loads 

While good testing methodology was developed, it became clear that many sets of 

precision resistors would be needed to ensure the different ballast types were correctly 

operated with respect to the load characteristics. In the NEMA Round Robin testing, the 

resistors used approximated the “normal light level” lamp load, about 760 ohms. In 

reality, the load characteristic varies from about 500 ohms for a “high light level” ballast 

EERE-2009-BT-TP-0016 DOC ID 1.2.001
NEMA Test Procedure DRAFT Page 2 

to over 1200 ohms for a “low light level” ballast. In order to correctly test these 3 basic 

types, at least three sets of precision resistors would be needed. Trying to test the 

three different light level ballasts (L, N and H hereafter) on existing N level resistors 

would cause some ballasts to move off their designed operating point, and may not 

provide a true picture of the possible system performance. Some ballasts may react 

more or less favorably to the shift in load impedance, and may not present an accurate 

evaluation of the ballast’s true electrical performance. Also, some ballasts operate at a 

different point or output level when driving resistors compared to when driving an actual 

lamp load. 

Simplified Test Plan Using Lamp Loads 

To alleviate the issues associated with resistive loads, and to provide a simple path to 

determining ballast electrical efficiency, an alternative testing plan is presented here 

that will utilize lamp loads. The use of lamp loads will allow the ballast to operate at the 

correct output level for which the ballast was designed, as the lamp load is dynamic. 

Presently, the lamp load contributes 90 or more percent of the ballast input wattage. If 

the lamps are high in operating volts or power, this additional load will be reflected back 

as additional input wattage for the ballast and system, adversely affecting the BEF 

measurement that traditionally was the metric of ballast performance. Variations in lamp 

performance and error associated with the photometric measurement process affect the 

BEF numbers, as ballast factor divided by input wattage comprise the BEF metric. 

The proposed ballast electrical efficiency test will utilize standard full wattage F32T8 

lamps as the test load. Other lamp types may be used for comparative purposes, but 

only lamp types specified in CEE table shall be used to validate performance to CEE or 

NEMA Premium specification. The lamps used for this test should be nominal lamps 

per ANSI C78.81-2005 electrical requirements. The lamps should be seasoned for 12 

hours and tested to be electrically stable. The lamps shall be mounted in a conventional 

strip fixture with lamps facing up for the measurements. The input wattage will only be a 

reference point for an output/input measurement, and will not be significant in itself. 

This allows effects of lamp operating point variation to be minimized, as the lamps will 

only act as an electrical load for the ballast. 

The test is conducted using the highest input voltage the ballast is rated for, typically 

277V for 120-277V rated ballasts. 

Rated Input Voltage Test Voltage Comments

120V 120V +/- 2%

277V 277V +/- 2%

120-277V UNV 277V +/- 2%

347V 347V +/- 2%

347-480V UNV 480V +/- 2%

480V 480V +/- 2%

Note: Ballasts rated at other voltages are tested at the same tolerance level. 

EERE-2009-BT-TP-0016 DOC ID 1.2.001
NEMA Test Procedure DRAFT Page 3 

The ballast input power and the sum of ballast output power would be simultaneously 

measured by a multi channel power analyzer. The wide bandwidth multi channel power 

analyzer should be capable of simultaneous measurements on multiple channels. The 

sum of the total output power would be divided by the input power and multiplied by 

100, resulting in the percentage of electrical efficiency of the ballast under test. 

This testing technique would allow relatively easy verification and validation of ballast 

electrical efficiency performance levels without the confounding factors of lamp and 

photometric measurement issues. This type of test could be utilized for all instant start 

ballasts and most programmed rapid start ballasts that do a full cathode cutoff once the 

lamp is operating. Ballasts designs that have continuously heated cathodes would not 

be tested by this method, as the cathode heating losses are not assignable. 

This test method, when used in conjunction with the NEMA Premium MOU table of 

performance as shown on Appendix D, would determine if a ballast is qualified to be 

listed as NEMA Premium. 

Ballast Sampling Plan 

Ballasts to be tested shall be selected from distribution stock. Four units shall be 

selected and used for the test. In case any of the test units fails to stabilize, an 

additional four piece sample can be drawn from stock and retested. Efficiency data is to 

be obtained from four tested units and the average of this data will be the reported 

value of Ballast Efficiency for purpose of NEMA Premium electrical performance 

validation. 

Test Plan Specifics 

Lamps should be selected according to ANSI C78.81-2005 and be seasoned at least 

12 hours prior to testing to ensure stable electrical characteristics. The lamps shall be 

full wattage F32T8. Amalgam lamps will not be considered here due to the long 

stabilization time required. The test process can be used with energy saving lamps; 

however, ballasts shall only be compared while operating similar lamp types. As an 

example, no ballast operated with an energy saving lamp will be directly compared to a 

ballast operated with a standard full wattage lamp. 

For purpose of determination of compliance to NEMA Premium specification, only lamp 

types listed in CEE tables shall be used. In accordance with the NEMA Premium MOU 

Appendix D, Tables 1 and 2, the minimum electrical efficiency shall be as stated in the 

Table. 

Testing is to be conducted at room temperature, 25 C +/- 2 C, with minimal air 

movement. The lamps shall be protected from airflow that can disturb electrical 

operating characteristics, per ANSI C78.375. 

EERE-2009-BT-TP-0016 DOC ID 1.2.001
NEMA Test Procedure DRAFT Page 4 

Lamp Fixture Setup

Lamps should be mounted in a standard strip fixture with lamps facing upward to 

minimize self-heating per standard ANSI bench conditions defined in ANSI C82.1-2004 

and C78.81-2005. The ballast may be positioned on the bench, and the fixture shall be 

electrically connected to the ballast case and to earth ground. 

The ballast wire lengths shall be per manufacturer’s catalog specification. Lead wires 

shall not be shortened nor bundled or coiled to minimize stray capacitance and 

inductive effects. 

The test fixture shall be wired with standard 18 AWG solid conductor wire. All wires 

shall be loose in the fixture, not bundled or taped to the fixture metal. The wires shall 

represent wiring commonly used within a strip fixture. Connections to the ballast under 

test may be made by a terminal strip mounted on the side of the fixture or other 

convenient means of connection. 

Measurement Setup 

The input and output power shall be measured by a wide bandwidth multi channel 

analyzer that is capable of simultaneous measurements of all channels. The analyzer 

shall have a traceable calibration, and be calibrated with the current transducers in 

place. 

The ballast input current may be measured by the analyzer internal shunt or by an 

external current transducer that has been calibrated for use specifically with the power 

analyzer. The input voltage burden is negligible. 

The ballast output current must be measured using non-invasive current transducer. 

The current transducer ratio must be set in the analyzer to match the transducer to the 

analyzer, and shall be calibrated at high frequency with the analyzer. 

Note: The output from non-invasive current transducers is usually a low voltage signal; 

the actual current to voltage ratio to the power analyzer must consider the losses in 

addition to the transducer ratio. The full current to voltage ratio includes the voltage 

divider effect between the transducer and the power analyzer input. Assuming the use 

of a calibrated power analyzer and non-invasive transducer, the actual current to 

voltage ratio to use to fully correct the measurement is: 

Vout

Iin Transducer _CT _ Ratio : 

Iin: Current through transducer 

Vout: Voltage out of transducer 

EERE-2009-BT-TP-0016 DOC ID 1.2.001
NEMA Test Procedure DRAFT Page 5 

Rin: Power Analyzer input impedance. 

Rs: Transducer output Impedance. 

The lamp voltage is to be measured by use of flying individual leads to minimize stray 

capacitance of the setup. The use of coaxial cables or “zip cord” for the lamp voltage 

measurement is not recommended due to the excessive capacitance of such wiring. 

The voltage connection of the analyzer to the lamps must be made after the current 

transducers, as this allows the voltage input burden to be as part of the total ballast 

output load. 

For voltage connections to Programmed Rapid Start ballasts with full cathode cutoff, 

some residual heating voltage may be present even after the cathode heat cut off circuit 

has activated. The lamp voltage leads shall be tested in all combinations and the 

combination that produces the lowest lamp voltage per lamp shall be used for the test. 

The lead combination shall be marked for future reference. 

Methodology 

The ballast shall be operated at its highest possible input voltage, typically 277V from 

an AC power source. The output of the power source shall route through the power 

analyzer to measure the ballast input conditions. 

The lamps shall be run until a stable condition exists. Stability can be determined per 

methodology defined in ANSI C78.375-1997. A maximum of 1 hour of ballast and lamp 

system operation is permitted. If stability is not attained within the allowed one hour of 

system operation time, the lamps and /or ballast shall be replaced with additional 

samples of the same type and the test re-initiated. 

EERE-2009-BT-TP-0016 DOC ID 1.2.001
NEMA Test Procedure DRAFT Page 6 

Test Procedure 

1. Connect ballast and seasoned full wattage lamps to power analyzer and power 

source per the wiring diagram. Refer to Figure 1 for Instant Start ballasts and to 

Figure 2 for Programmed Rapid Start ballasts with full cathode cutoff. The lamps 

shall be in strip fixtures, positioned horizontally, with lamps on the topside. 

2. Energize the ballast at the highest rated input voltage; check the analyzer for 

proper polarities and positive wattages. 

3. Allow the ballast and lamps to warm up for at least 15 minutes to stabilize. The 

warm-up period can extend to an hour if needed for stability, but the final 

measurement must be taken within the hour. 

4. Record the input wattage and the sum of the output wattages measured. Other 

characteristics such as lamp currents and voltages may be recorded to ensure 

lamp performance is within the normal operating range. 

5. Divide the sum of the output wattage by the input wattage and multiply the result 

by 100 to get the percentage efficiency of the ballast under test. 

((Pout1+Pout2)/Pinput)*100 = Ballast Efficiency 

Exceptions 

Non-Dimming ballasts that have continuous cathode heating shall not be tested by this 

method 

EERE-2009-BT-TP-0016 DOC ID 1.2.001
NEMA Test Procedure DRAFT Page 7 

Schematic of Test Setup for 2 Lamp Ballasts 

IS 

Ballast

R

ed

Bl

ue

Bl

ue

Bl

Wh

ite

Current 

transducer

“Common” voltage 

measurement point

Lamp 1

Lamp 2

Voltage measurement points: after 

Current Transducer

AC Input 

Power 

from 

Analyzer

PRS 

Ballast

Bl

Wh

ite

AC Input 

Power from 

Analyzer

Lamp 1

Lamp 2

Current 

Transducer

“Common” 

voltage 

measurement 

points: select 

for Lowest 

Lamp Voltage

Lamp voltage measurement points: 

test all combinations and select for 

Lowest Lamp Voltage. 

Fig. 1

Fig. 2

EERE-2009-BT-TP-0016 DOC ID 1.2.001