EPA
WaterSense* Notification of Intent
Notification of Intent (NOI) to Develop Draft Performance
Specifications for High-Efficiency Urinals
I. Introduction
There are currently an estimated 12 million urinals in the United States. Up to 80 percent (9.6
million) of these urinals are inefficient units with flush volumes exceeding the current 1.0 gallon
per flush (gpf) maximum flush volume allowed by federal standards by 0.5 gallon to as much as
4.5 gallons per flush. Since the federal standards were enacted, manufacturers have developed
even more efficient urinals that use significantly less water than the standard 1.0 gpf fixtures or
no water at all. These new fixtures can save an additional 0.5 gallon to 1 gallon of water per
flush compared to standard fixtures, resulting in a savings of between 2,300 and 4,6001 gallons
per urinal per year. Replacing older, inefficient urinals with these new fixtures can save even
more water.
To capitalize on this tremendous opportunity for potential water savings, and to raise consumer
awareness, further improve water efficiency, and promote the use of more efficient urinals,
WaterSense® is announcing its intent to develop specifications for labeling water-efficient, high-
performing urinals. These specifications, once final, will establish performance criteria to identify
and differentiate those products that meet criteria for both water efficiency and performance.
Industry and utilities have already laid much of the groundwork for recognizing more efficient
urinals. In the past, any urinal with a flush volume less than the national 1.0 gpf standard was
referred to as a "high-efficiency urinal (HEU)." In 2004, the California Urban Water Conservation
Council, in conjunction with a select group of its water provider members, developed a definition
for HEUs that has become widely recognized and accepted as the plumbing industry standard.
An HEU is now defined as a urinal fixture with a flush volume of 0.5 gpf (1.9 liters per flush [Ipf])
or less, including non-water urinals.
Wth growing interest in the promotion of water conservation practices and technologies by
water utilities to head off projected water shortfalls and infrastructure cost increases, and the
growing popularity of "green" building practices and certifications, a number of manufacturers
are marketing an increasing number of flushing and non-water HEUs. According to market
research, there are at least six manufacturers offering close to two dozen models of flushing
HEUs and at least nine manufacturers offering nearly 30 models of non-water HEUs.
Wth this NOI, WaterSense has preliminarily identified the water-efficiency and performance
criteria it intends to include in draft specifications for HEUs. While the major criteria have been
identified, some technical points require further consideration and assessment before draft
specifications can be published. To better define these criteria and establish appropriate levels
that ensure increased water efficiency and a high level of performance, WaterSense 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
1 According to data from the U.S. Department of Labor Statistics and Amy Vickers, Handbook of Water Use and
Conservation, Water Plow Press, 2001, it is estimated that the average urinal is flushed 18 times per day. Savings
assumes urinals are typically used 260 days per year.
May 22, 2008
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EPA
WaterSense* Notification of Intent
NOI. Interested parties are encouraged to submit data and comments to WaterSense regarding
any of the issues presented in this notice by submitting written comments to watersense-
urinals@erg.com.
II. Scope
The American Society of Mechanical Engineers (ASME) defines a urinal as "a plumbing fixture
that receives liquid waste and conveys the waste through a trap seal into a gravity drainage
system."2 WaterSense is considering developing specifications for two categories of HEUs—
flushing urinals (the standard configuration found in most public restrooms) and non-water
urinals. As defined by the American National Standards Institute (ANSI), a non-water urinal is "a
plumbing fixture that is designed to receive and convey only liquid waste through a trap seal into
the gravity drainage system without the use of water for such function."3 Because of the
differences in design, components, how they function (i.e., remove waste), and the standards to
which they are subject, WaterSense intends to develop separate specifications for the two
categories of HEUs.
WaterSense is considering excluding composting urinals and retrofit devices or other
aftermarket retrofit systems from the scope of an HEU specification. Composting urinals are part
of a self-contained engineered system with different design and performance requirements, and
as such would require unique specification criteria. Retrofit devices will not be addressed
because the intent of the specification is to recognize and label complete, fully functioning
fixtures or fittings, and not individual components.
III. Water 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. To
achieve the water-efficiency component of this goal, WaterSense seeks to establish a new
maximum flush volume for urinals.
At this time, WaterSense is considering establishing in a draft specification for flushing urinals, a
maximum allowable flush volume of 0.5 gpf (1.9 Ipf). There are several advantages for using
this flush volume. First, it represents at least a 50 percent increase in efficiency compared to the
current federal standards, significantly exceeding the stated program goal of at least a 20
percent increase in efficiency. Second, this flush volume matches the currently accepted
industry definition for HEUs and therefore should be acceptable to water-efficiency stakeholders
and manufacturers. Third, several manufacturers are already selling urinals that meet and
exceed this flush volume. As stated previously, recent market research shows that at least six
manufacturers are selling nearly two dozen models of flushing urinals that would meet this water
efficiency requirement, with more anticipated to enter the market in the near future. Many of
these products have been on the market for years and have well-documented performance and
customer satisfaction records.
2 American Society of Mechanical Engineers. ASME A112.19.2.-2003, Vitreous China Plumbing Fixtures and
Hydraulic Requirements for Water Closets and Urinals. June 14, 2004.
3 American National Standards Institute. ANSI Z124.9-2004, American National Standard for Plastic Urinal Fixtures.
February 19, 2004.
May 22, 2008
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EPA
WaterSense* Notification of Intent
Since non-water urinals use no water by definition and are inherently water-efficient,
establishing a maximum flush volume is not necessary. As previously discussed there currently
are at least nine manufacturers of non-water urinals offering nearly 30 models of non-water
urinals that could qualify for the WaterSense label.
IV. Performance
With all of its specifications, WaterSense develops criteria to ensure that labeled products
perform as well as or better than their conventional counterparts. All urinals, including flushing
and non-water HEUs, are already subject to rigorous national performance standards. Vitreous
china flushing urinals are subject to the performance requirements of ASME A112.19.2, while all
plastic urinals (flushing and non-water) must comply with ANSI Z124.9. The flushometer valves
used on these urinals are subject to American Society of Sanitary Engineering (ASSE) #1037.
Vitreous china non-water urinals have a separate standard, ASME A112.19.19, with which they
must comply, and plastic non-water urinals are subject to ANSI Z124.9, as previously
mentioned. The performance requirements of these national standards have a proven record of
ensuring a high level of performance and durability in urinals. For non-water urinals,
WaterSense plans to use existing performance standards and is not considering including any
additional performance requirements in a draft specification.
For flushing urinals, WaterSense does intend to address in a specification concerns regarding
the adjustability and interchangeability of components of flushometer valves. WaterSense is
considering a requirement that flushometer valves, in addition to complying with the rigorous
ASSE #1037 requirements, be non-adjustable as to flush volume (within some tolerance to be
determined); tamper-proof; not contain interchangeable parts that would allow the flush volume
to be increased once installed (e.g., interchangeable diaphragms or pistons); and include a non-
hold down/automatic shutoff feature. These requirements will help ensure that flush volumes in
the field do not exceed the maximum volume allowed by the specification. Many flushometer
valves on the market today already incorporate these features. Therefore, these additional
requirements should not create technical difficulties in complying with specification criteria and
will be valuable additions for preserving the long-term efficiency and performance of labeled
products.
V. Certification and Labeling
WaterSense has established a product certification process, described in the WaterSense
Program Guidelines located at: .
Under this process, products are certified to conform to applicable WaterSense specifications by
accredited third-party certification bodies. Manufacturers are then authorized to use the
WaterSense label in conjunction with certified products.
One certification and labeling issue to be resolved concerns how the separate components of
flushing HEUs (the flushometer valve and the urinal fixture) will be tested and certified, and how
the WaterSense label will be displayed in situations when these parts are manufactured by
different companies. With flushing urinals, it is not uncommon for a company to manufacture
only the vitreous china or plastic urinal fixture and to require the use of another company's
flushometer valve. The urinal fixtures' specification sheets for these products often indicate
which make and model valves are best suited for use with the urinal.
May 22, 2008
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EPA
WaterSense* Notification of Intent
To address this issue, WaterSense is considering the following options:
Require flushometer valves and urinal fixtures to be tested together.
Test and label valves and fixtures separately and recommend only labeled components
be matched by consumers.
Test and label flushometer valves only.
Of these options, WaterSense is considering allowing each urinal fixture and flushometer valve
to be tested and labeled independently. This approach is the common industry practice and
ensures that WaterSense is not significantly increasing the burden associated with the
certification of HEUs. It also enables consumers to easily identify labeled HEUs by identifying
and matching labeled components, rather than verifying the individual component model
numbers for compatibility. One possible drawback of this approach, however, is the potential for
variability in performance with certain valve and fixture combinations, as not all possible
combinations may be tested.
WaterSense intends to further explore these options and is seeking input and recommendations
as to the most viable approach, giving consideration to costs, and providing adequate
assurance to purchasers and specifiers that the product they purchase will save water and meet
their performance expectations.
VI. Other Issues
One currently unresolved issue of concern is the impact that significantly reduced water flows
from HEUs might have on buildup of urine solids in the drain line, leading to restricted flow or
clogging. This issue primarily has been raised in the context of non-water urinals. The long drain
line carries common in commercial, industrial, and institutional settings where urinals are
typically installed and the absence of supplementary water flows through drain lines (e.g., from
sinks, showers, toilets, other water using appliances) could further compound this problem. One
study performed in 2005 at the Gelsenkirchen University of Applied Sciences in Germany
examined the performance of six non-water urinals over a two year period and found that drain
line buildup was significant enough to reduce waste removal. Manufacturers of non-water
urinals in the United States and Canada have challenged the findings and methodology of this
study and questioned its relevance to non-water urinals sold in North America.4
Regardless of whether this study's findings are transferable to U.S. fixtures, it adds to concern
in the field that drain line buildup is a potentially real issue that requires further examination.
Currently, there are two ongoing studies5 that are assessing the performance of several makes
and models of flushing and non-water HEUs, including their impact on drain line buildup.
WaterSense will evaluate the results of these studies to determine the significance of this issue
4 One manufacturer provided written comments that challenged the researchers' use of non-water urinals with
mechanical traps (which do not conform to code in the United States); the design of the study's drain line system,
which also would not meet U.S. plumbing codes on several accounts; and the researchers intentionally not
maintaining the fixtures according to manufacturers' recommendations. The manufacturer's conclusions are that the
drain line system's inadequate design caused the drain line buildup and not the reduced water flows of the non-water
urinals.
5 Veritec Consulting and Koeller and Company are conducting a study in the Region of Peel, Ontario, Canada and
Roger Van Gelder is performing a study sponsored by the Seattle Public Utilities at the University of Washington.
May 22, 2008
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EPA
WaterSense* Notification of Intent
and decide if further research is necessary and if drain line buildup needs to be addressed in its
HEU draft specification scope or technical requirements in some manner. In addition,
WaterSense is seeking relevant data from interested parties that might help assess and address
the drain line buildup issue.
In light of the concerns raised by these studies and other anecdotal evidence submitted to EPA,
WaterSense has decided to develop and issue the two separate specifications according to
different schedules. Development of the flushing urinal specification will continue on its current
schedule. Development of the non-water HEU specification will be delayed until more data can
be collected and the drain line issue can be satisfactorily resolved. The specific questions
WaterSense needs to resolve before moving forward with a non-water HEU specification
include:
1. Is drain line buildup a significant issue that will negatively affect a non-water urinal's
long-term performance?
2. Can maintenance according to the manufacturer's instructions prevent drain line buildup
and how rigorous does need it need to be?
In addition to drain line buildup, other concerns regarding non-water urinals have been raised,
including their long-term cost-effectiveness as a result of increased maintenance requirements
and life expectancy of the liquid seal or cartridge. As with all plumbing products, there are an
unlimited number of design and technical approaches to achieving increased water efficiency.
While some designs and approaches are more expensive to procure and maintain than others,
they can still meet the WaterSense program's goals of increasing water efficiency and
maintaining a high level of performance. With these specifications, WaterSense does not intend
to limit manufacturers' options or be design restrictive in any way. Ultimately, it is up to
consumers to weigh all the associated costs and benefits of each technology and decide for
themselves whether it is the optimal system for their operations. WaterSense will engage in a
proactive education and outreach campaign to provide consumers with the knowledge to help
make informed purchasing decisions. At this time, WaterSense is seeking relevant data from
interested parties that might help further assess the issue of long-term cost-effectiveness.
References
American National Standards Institute. ANSI Z124.9-2004, American National Standard for
Plastic Urinal Fixtures. February 19, 2004.
American Society of Mechanical Engineers. ASME A112.19.2-2003, Vitreous China Plumbing
Fixtures and Hydraulic Requirements for Water Closets and Urinals. June 14, 2004.
American Society of Mechanical Engineers. ASME A112.19.19-2006, Vitreous China Nonwater
Urinals. November 2006.
American Society of Sanitary Engineering. ASSE #1037, Performance Requirements for
Pressurized Flushing Devices (Flushometers) for Plumbing Fixtures. March 1990.
May 22, 2008
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EPA
WaterSense* Notification of Intent
Demiriz, Mete. "Applications of Dry Urinals." Gelsenkirchen University of Applied Sciences,
2005.
Falcon Waterfree Technologies, LLC. Response to Demiriz's "Applications of Dry Urinals."
May 22, 2008
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