WASHINGTON, D.C. 20460
               Notification of Intent (NOI) to Develop Draft Performance Specifications for

                               High-Efficiency Pre-Rinse Spray Valves

I. Introduction

Currently there are an estimated 1.35 million commercial pre-rinse spray valves in use in the United States. Up
to 50 percent (675,000) of these pre-rinse spray valves may be inefficient units, with flow rates exceeding the
current 1.6 gallon per minute (gpm) maximum flow rate allowed by federal standards (the Energy Policy Act of
2005 [EPAct 2005]) by between 1.0 and 3.0 gpm. Since Congress enacted the federal standard,
manufacturers have developed even more efficient pre-rinse spray valves that use significantly less water than
the standard 1.6 gpm models.  Based on current advertised product flow rates, these new valves can use
between 0.35 and 1.1 gpm less than standard models, resulting in savings of 6,400 to 20,000 gallons per pre-
rinse spray valve per year. Since pre-rinse spray valves use hot water, reducing the flow rate and total gallons
of hot water used also leads to significant energy savings of about 1,100 to 3,500 kilowatt hours (kWh) of
electricity per year or 5,600 to  17,500 cubic feet (5.6 to 17.5 Mcf) of natural gas per year1. Replacing older,
inefficient pre-rinse spray valves with these new models can save even more water and  energy.

To capitalize on this opportunity for potential water and energy savings, and to raise consumer awareness,
further improve water and energy efficiency, and promote the use of more efficient pre-rinse spray valves, the
U.S. Environmental Protection Agency (EPA) is announcing its intent to develop a specification for water-
efficient, energy-efficient, and high-performing pre-rinse spray valves for both the  WaterSense® and ENERGY
STAR® programs. The specification, once final, will establish performance criteria to identify and differentiate
those products that meet criteria for water efficiency, energy efficiency, and performance. Manufacturers
whose products meet the specification may then use both the WaterSense and ENERGY STAR labels to
highlight the efficiencies of these models.

Though EPAct 2005 specifies the maximum flow rate for pre-rinse spray valves, it does not address the
performance of these products. In order for utilities to compare pre-rinse spray valves on the market and
choose appropriate water- and energy-efficient models that do not sacrifice product performance for their
conservation programs, the American Society of Testing and Materials (ASTM) F2324-03, Standard Test
Method for Pre-Rinse Spray Valves, was developed. The test method provides a methodology for measuring
flow rate (in gallons per minute) and performance, which is measured in terms of "cleanability," or the time it
takes for the product to clean preset media from a plate in units of seconds per plate. Several states and
utilities,  including the California Urban Water Conservation Council (CUWCC) and the California Energy
Commission (CEC), are specifying the test method to measure product performance against a particular target
flow rate and performance (cleanability)  requirement. Clearly, there is a need to ensure that as pre-rinse spray
valves achieve lower flow rates, they continue to perform as expected, particularly with respect to usage time
1 Energy savings are based on the total estimated gallons of water saved per year, 6,400 to 20,000 gallons, and an estimated 175.6
kWh of energy use per 1,000 gallons of water or 0.8768 Mcf of natural gas use per 1,000 gallons of water.

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for dish cleaning.

With growing interest in the promotion of water conservation practices and technologies by water utilities to
head off projected water shortfalls and infrastructure cost increases, the increasing interest from electric and
gas utilities to reduce energy use, and the growing popularity of "green" building practices and certifications,
manufacturers are marketing an increasing number of pre-rinse spray valves with more efficient flow rates.
According to market research, there are at least 13 manufacturers offering more than two dozen models of
pre-rinse spray valves with flow rates lower than the 1.6 gpm federal standard.

With this NOI,  EPA has preliminarily identified the water- and energy-efficiency criteria and performance test
method it intends to include in a draft specification for pre-rinse spray valves. While the major criteria have
been identified, some technical points require further consideration and assessment before a draft specification
can be published. To establish and better define these criteria, EPA is requesting supporting information  and
data from all interested parties (e.g., researchers, manufacturers, water utilities, water-efficiency organizations)
on the topics discussed in this NOI. Interested parties are encouraged to submit data and comments to EPA
regarding any of the issues presented in this notice by submitting written comments to watersense-
products@erg.com. Comments and information on the issues presented in this NOI are welcome and will be
taken into consideration as EPA develops a draft specification for WaterSense and ENERGY STAR.

II.     About WaterSense and ENERGY STAR

WaterSense and ENERGY STAR are voluntary partnership programs between government,  businesses, and
purchasers designed to encourage the manufacture, purchase, and use of efficient products. The primary
objective of both programs is to make it easy for buyers to identify efficient products in the  marketplace by
differentiating them with the WaterSense or ENERGY STAR label.  Because these are voluntary, market-based
programs, it is not EPA's intention to design a specification that will allow every model to qualify. When EPA
sets a specification, it strives to recognize the top performers in the market, which offer attractive savings to
the buyer at that time. For products that do not initially meet the specification, it is EPA's hope that
manufacturers will redesign for efficiency over time, thus leading to more efficient product choices.

For more information, please visit the program Web sites: www.epa.gov/watersense or www.energystar.gov.

III. Scope

EPAct 2005 defines a commercial pre-rinse spray valve as "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." EPA is considering
developing a specification for any product that would fall under this definition.

EPA is considering excluding from the scope of a pre-rinse spray valve specification those spray valves used
for pot  and kettle filling as well as kits used to retrofit the water efficiency of existing non-EPAct-2005-compliant
pre-rinse spray valves. EPA intends to exclude pot and kettle fillers as their use is primarily volume dependent,
and as such, lowering the flow rate could unnecessarily impact user satisfaction by significantly increasing wait
times. EPA intends to exclude retrofit kits because the intent of a specification for pre-rinse spray valves is to
recognize and label complete, fully functioning devices, and not individual components or parts.

IV. Efficiency
The goal of the WaterSense program is to label products that are at least 20 percent more efficient than their
standard counterparts, while  ensuring the same or better performance. The goal of the ENERGY STAR
program is to label  products that represent the top quartile of products currently available in the market that are
cost effective to the purchaser and deliver the same or better functionality. To achieve the water-efficiency

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component of these goals, EPA seeks to establish a new maximum flow rate for pre-rinse spray valves.

With this NOI, EPA is announcing the intent to develop a draft WaterSense and ENERGY STAR specification
for "high-efficiency" pre-rinse spray valves. The flow rate selected must meet both the stated WaterSense and
ENERGY STAR program goals for efficiency and performance. The draft specification will establish a
maximum allowable flow rate that is at least 20 percent lower than the current standard for pre-rinse spray
valves. Thus, the flow rate may match the voluntary flow rate of 1.25 gpm for "low-flow commercial pre-rinse
spray valves" proposed by the American Society of Mechanical Engineers (ASME) in the draft revision of
standard A112.18.1. It may also match the Federal  Energy Management Program's (FEMP's)  December 2008
purchasing specification, requiring a 1.25 gpm maximum flow rate for pre-rinse spray valves purchased by the
federal government. Several manufacturers are already selling pre-rinse spray valves that are at or below this
flow rate requirement. Some of these products have been on the market for years and have well-documented
performance and customer satisfaction records.

V. Performance

With all of its specifications, EPA develops criteria to ensure that labeled  products perform as well as or better
than their standard counterparts on the market. Though there is a federal standard specifying the maximum
flow rate for pre-rinse spray valves, the standard does not address the performance of these products.
Currently, the only performance test established for pre-rinse spray valves is ASTM F2324-03. The test
method provides a mechanism to evaluate product performance via the output of a cleanability time in seconds
per plate cleaned. This test method was originally designed as a means to compare  product performance side-
by-side and not as a means to compare a product to a specific performance requirement or even to its
performance in the field. As such the test method does not include or specify a specific performance value
(i.e., cleanability time) that a product must meet in order to ensure user satisfaction.

EPA is considering incorporating the ASTM F2324-03 test method in its draft specification for high-efficiency
pre-rinse spray valves for WaterSense and ENERGY STAR, but has identified several unresolved issues of
concern that need to be addressed.  First and foremost  is the repeatability and reproducibility of the ASTM test
method and the correlation between cleanability times from the ASTM test method and actual  product usage
time in the field, coupled with user satisfaction.  If these issues are resolved to the  satisfaction of EPA, then
EPA will need to evaluate and  determine the impact of water pressure (both high and low) on the spray
characteristics and performance of high-efficiency pre-rinse spray valves and where  to set the performance
level for cleanability (i.e., seconds per plate).

A. Test Method Repeatability and Reproducibility

As a requirement for labeling, all products must be tested and certified for conformance with the relevant
specification by an independent third-party certifying body. Thus it is essential that any performance test
referenced  in a specification be both repeatable and reproducible among testing laboratories. As part of its
initial technical and market research, EPA had preliminary conversations with several stakeholders who have
expressed some concern regarding the repeatability of the ASTM test method and reproducibility of the results.
Some stakeholders indicated that the test method is subjective to the individual performing the test, based on
how the tester chooses to spray each plate with the pre-rinse spray valve and how they visually verify when a
plate is considered clean.  In addition, some stakeholders are concerned about the lack of specificity regarding
the  makeup of the test media;  the shade, finish, and manufacturer of the test plates;  the room  conditioning
requirements; and other test conditions. Proponents of  the test method point out that it requires 60 iterations  of
the  cleanability test in order to  achieve a statistically significant population of data to  calculate  the cleanability
average, and the high number of iterations allays any subjective variations.

In addition to issues with subjectivity, only one independent third-party laboratory,  the Food Service

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Technology Center (FSTC), currently performs the ASTM cleanability test, and as such the inter-laboratory
repeatability of the test method and reproducibility of the results have not been evaluated.

EPA is seeking input regarding the repeatability and reproducibility of the ASTM test method. In particular,
EPA is seeking to compare and evaluate performance data for the same make and model pre-rinse spray
valves tested at multiple laboratories in accordance with the ASTM test method.

B. Correlation Between Performance Test Results and Actual Usage  Time and User Satisfaction

In recent years, manufacturers have begun to meet demands for more efficient products and have introduced
high-efficiency and even ultra-high-efficiency pre-rinse spray valve models (with rated flow rates of 1.0 gpm or
less) to the market. These spray valves have demonstrated ASTM-tested cleanability times equal to or better
than standard models. Based on test reports available on the FSTC's Web site
(www.fishnick.com/equipment/sprayvalves), pre-rinse spray valves with flow rates between 1.0 and 1.6 gpm
score an average cleanability time of 21.63 seconds per plate on the ASTM test, while pre-rinse spray valves
with flow rates less than 1.0 gpm score an average cleanability time of 21.41 seconds per plate.

Minimal research has been done, particularly with these ultra-high-efficiency spray valves, to evaluate actual
field usage times, water and energy savings, and user satisfaction. The limited data that do exist from a small-
scale pilot study conducted in the Pacific Northwest suggest that usage time may increase with ultra-high-
efficiency pre-rinse spray valves and user satisfaction may vary. Since ultra-high-efficiency pre-rinse spray
valves statistically appear to have the same ASTM cleanability time as higher flow valves, yet some limited
research indicates that users have demonstrated increased usage times with use of the ultra-high-efficiency
valves in the field, it suggests that actual field usage time may not correlate to the results of the ASTM
cleanability test. To determine the correlation between the ASTM cleanability test, field  usage time, and user
satisfaction,  EPA seeks data that answers the following questions:

    1.  How do water usage and time usage vary among pre-rinse spray valves currently on the market?
    2.  Do usage times in the field correlate to cleanability times achieved using the ASTM F2324-03 test
    3.  How do flow rate, actual field usage time,  and ASTM-tested cleanability time correlate to user

EPA has concluded it is premature to draft a specification without sufficient data to answer these outstanding
questions and has outlined a detailed research study scope to assist with this data collection and evaluation.
Please e-mail watersense-products@erq.com any data which might address these questions. Please let us
know as soon as possible if you are interested in  participating in the research program to obtain these data.
EPA is planning to hold a meeting to discuss the above research in early August 2009.  More information will
be available  on the WaterSense Web site, www.epa.gov/watersense.

C. Water Pressure Issues

EPA's initial technical and market research indicates that flow rates and subsequent performance of high-
efficiency pre-rinse spray valves can be impacted by water  pressure.  Some high-efficiency pre-rinse spray
valves installed in commercial  food establishments with low water pressure might not clean kitchenware
quickly enough, which may impact user satisfaction and may negate water and energy savings if significantly
more time is necessary to clean dishes. Conversely, high-efficiency pre-rinse spray valves installed in
commercial food establishments with high water pressure might cause overspray and splashing when used on
kitchenware. As a result, purchasers may turn down their valve or tap to compensate for the excessive flows.
The plumbing industry does not recommend throttling back a shutoff valve to a partially open position because
it may result in excessive turbulence in the valve and cause unnecessary wear on the valve seat. When the

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purchaser goes to completely close the valve, it may leak due to this wear, contributing to excessive
unintentional water use and potentially greater repair and maintenance costs for the purchaser in the future.

EPA has obtained information with diverging views on the significance of this issue with respect to high-
efficiency spray valves. Some available data suggest that high-efficiency pre-rinse spray valves may be less
sensitive to the impact of pressure than standard models. Other data suggest the opposite, that high-efficiency
pre-rinse spray valves are more sensitive to water pressure variations than their less efficient counterparts.
More data are needed to determine the extent of the impact of pressure variation on flow rate and performance
of high-efficiency valves. In particular, EPA is soliciting data to show the relationship between flow rate and
flowing water pressure for a variety of spray valves. Please submit any data to further clarify the nature  and
extent of this issue to EPA via watersense-products@erg.com.

D. Selecting Performance Levels

The ASTM test method has been adopted by several organizations looking to specify the minimum
performance of pre-rinse spray valves, including CEC, CUWCC, FEMP, and the New York State Energy and
Research Development Authority. These organizations have had to select a performance level (cleanability
time) that they believe is representative of adequate product performance. These performance levels, coupled
with the maximum flow rates specified by each organization, are summarized in Table 1.

            Table 1. Flow Rate and Performance Criteria Specified by Other Organizations
New York State Energy
and Research
Development Authority
California Appliance Efficiency
Regulations, CEC-400-2005-12,
April 2005, required state standard
Rinse & Save direct-installation
program, 2002, required for
Purchasing Specification for Pre-
Rinse Spray Valves, December
2008, standard
Focus on Hospitality high-efficiency
commercial kitchen rebate
program, required for rebate
Flow Rate
based on
ASTM F2324-
If EPA is able to satisfactorily resolve the outstanding technical issues identified in this NOI and determine that
it will incorporate the ASTM test method into a draft specification for high-efficiency pre-rinse spray valves for
WaterSense and ENERGY STAR, it must then decide upon a performance level (i.e., cleanability time) that
represents adequate product performance. This level may be established based on:
   •   Data received regarding product performance and correlation of the ASTM test method to actual field
       usage times and water savings,
   •   The range of product performance on the market, and/or
   •   Other data received in response to this NOI.
                                                                                         July 10, 2009

EPA is seeking any data to determine which cleanability time will best serve as the performance level in a
high-efficiency pre-rinse spray valve specification for WaterSense and ENERGY STAR. If you have experience
with the ASTM cleanability test or suggestions for where to set the performance level, please e-mail


109th Congress. Energy Policy Act of 2005. Public Law 109-58. Augusts, 2005.

American Society for Mechanical Engineers and Canadian Standards Association Joint Harmonization Task
Group. ASMEA112.18.1/CSA B125.1 JHTG, FT06-14, Water Conservation Flow Rates for Fixture Fittings,
Proposed Amendments. October 2007.

American Society for Testing and  Materials. Standard Test Method for Pre-Rinse Spray Valves, F2324-03.

California Energy Commission. Appliance Efficiency Regulations, CEC-400-2005-12. April 2005

California Urban Water Conservation Council. Rinse & Save Program Final Report Summary.  February 2005.

Federal Energy Management Program.  FEMP Designated Product: Pre-Rinse Spray Valves, Purchasing
Specifications for Energy-Efficient Products. December 2008.

New York Energy and Research Development Authority. Focus on Hospitality. 2004.
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