EPA
WaterSense
Response to Public
Comments Received
on
February 2007 Draft WaterSense(
High-Efficiency Bathroom
Sink Faucet Specification
October 1, 2007
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Response to Comments on Draft
High-Efficiency Bathroom Sink Faucet Specification
This document provides WaterSense's responses to public comments received on the February
8, 2007, Draft High-Efficiency Bathroom Sink Faucet Specification. The actual comments can be
viewed at www.epa.gov/watersense/docs/faucet_comments508.pdf.
October 1, 2007
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Response to Comments on Draft
Sff1S High-Efficiency Bathroom Sink Faucet Specification
Issue Page
I. General Specification Comments 4
II. Comments on Section 1.0-Scope and Objective 6
III. Comments on Section 2.0-Water Efficiency and Performance 7
IV. Comments on Section 5.0- Definitions 11
V. Comments on Supporting Documentation 12
October 1, 2007
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Response to Comments on Draft
High-Efficiency Bathroom Sink Faucet Specification
1,
Specification Name
a. Several commenters recommended changing the name of the specification from "High-
Efficiency Bathroom Sink Faucet Specification" to "High-Efficiency Lavatory Faucet
Specification" for clarity, as this is the terminology used within the industry and in
referenced standards to describe this category of product.
Response: WaterSense agrees with this recommendation and has made the appropriate
changes throughout the specification.
Reference to Standards
b. Several commenters recommended updating all references made to ASME A112.18.1 to
the full title of the standard, ASME A112.18.1/CSA B125.1.
Response: WaterSense agrees with this comment and has updated all references to this
standard throughout the specification and in the supporting documentation.
c. One commenter recommended including a reference to NSF/ANSI Standard 61, Section
9. This standard addresses the requirements under Section 1417 of the Safe Drinking
Water Act requiring all pipes and plumbing fittings or fixtures intended to dispense water
for human consumption to be lead-free.
Response: WaterSense recognizes the need to clarify that any WaterSense labeled
faucet or faucet accessory certified under this specification is also required to comply
with NSF/ANSI 61, Section 9. While NSF/ANSI 61, Section 9 is already incorporated by
reference into ASME A112.18.1/CSA 125.1, and is therefore part of this specification,
WaterSense decided to make it clear that all WaterSense labeled faucets meet all
applicable health and safety standards. Section 2.0 of this specification has been
updated to include the appropriate reference to the NSF/ANSI standard. WaterSense
has also incorporated by reference, in Section 7.0 - Definitions, the appropriate
definitions found in NSF/ANSI Standard 61, Section 9.
Product Marking
d. Several commenters suggested adding a new section to the specification to address
flow rate marking on products and product packaging. Commenters recommended using
the product and packaging marking requirements delineated in the U.S. Code of Federal
Regulations (16 CFR Part 305Rule Concerning Disclosures Regarding Energy
Consumption and Water Use of Certain Home Appliances and Other Products Required
Under the Energy Policy and Conservation Act [Appliance Labeling Rule], §305.11 -
Labeling for Covered Products).
October 1, 2007
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Response to Comments on Draft
High-Efficiency Bathroom Sink Faucet Specification
Response: WaterSense agrees that a requirement for proper marking of the flow rate on
products and/or product packaging should be included in the specification. To address
this comment, the following new section and language has been added to the
specification:
"4.0 FLOW RATE MARKING
The product and/or the product packaging shall be marked in accordance with 16
CFR 305.11(f) with the maximum flow rate in gpm and L/min as determined
through testing and compliance with this specification. Marking shall be in gpm
and L/min in two-digit resolutions (e.g., 1.5 gpm [5.7 L/min])."
e. Another commenter requested that WaterSense require a WaterSense impression
(either words or label) on the qualifying product itself to make post-installation
identification easier.
Response: WaterSense decided not to require the actual certified products to carry a
WaterSense impression. While WaterSense acknowledges that identifying labeled
products after installation can be difficult, requiring manufacturers to imprint faucets,
aerators, or other flow control devices would be burdensome and in cases of small
components (e.g., aerators), impractical. The primary purpose of the WaterSense label
is to help consumers identify and choose water-efficient products at the time of
purchase. The appropriate labeling of product packaging will serve this purpose.
Long-Term Durability
f. One commenter expressed concern that the long-term durability of water savings is not
addressed by the specification. Specifically, the commenter cited a lack of criteria that
addresses clogging of faucet aerators or other flow control devices and questioned how
likely these devices are to be retained by consumers if they clog frequently and cannot
be easily cleaned.
Response: WaterSense acknowledges that frequency of clogging and the ability of
users to easily clean faucet accessories may have an impact on the long-term
sustainability of water savings from these products. One way in which this issue is
addressed by the specification is in allowing faucet accessories to be removable. When
WaterSense posed the idea of requiring faucet accessories to be non-removable (to
decrease the likelihood of vandalism or replacement with a higher flowing accessory),
interested parties felt that including this type of provision would be needlessly design-
restrictive and could result in high levels of user frustration and dissatisfaction.
Interested parties overwhelmingly indicated that faucet accessories should be
removable to facilitate cleaning and maintenance. To address long-term durability in
terms of continued performance over the product's life, the ASME A112.18.1/CSA
B125.1 Plumbing Supply Fittings standard, which is incorporated by reference in the
specification, requires devices, accessories, or components without moving parts to be
life-cycle tested. After 500,000 testing cycles, the faucet or faucet accessory shall
continue to function as it did in the beginning of the test and shall not develop any
defects that could adversely affect their functionality, serviceability, or appearance.
October 1, 2007
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Response to Comments on Draft
SdlSe High-Efficiency Bathroom Sink Faucet Specification
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a. One commenter felt that the scope of the specification should be narrowed to just cover
faucet aerators, and should not include entire faucets. This commenter stated that
manufacturers are very unlikely at this time to develop a faucet that meets the
requirements of this specification; rather they will simply use qualifying aerators. The
commenter believes that maintaining the specification's current scope is misleading and
will result in reduced water savings for the nation. The commenter feels that a national
aerator replacement program targeting the large number of inefficient lavatory aerators
currently in use has the potential to yield larger water savings. The commenter also
believes that homeowners are more likely to replace their inefficient aerators than to
replace their entire faucet with a WaterSense labeled faucet. In proposing to narrow the
scope of the specification to aerators only, the commenter does suggest crafting the
specification so as to allow any faucets developed in the future that meet the
requirements to qualify for use of the label.
Response: WaterSense recognizes that many manufacturers will choose to use
WaterSense labeled aerators or other accessories on their faucets to achieve the
specification requirements. In fact, WaterSense clarified that a lavatory faucet is
considered to meet the flow rate requirement if equipped with a lavatory faucet
accessory that meets the flow rate requirement. WaterSense, however, has decided not
to limit the specification to encompass only faucet accessories. This would preclude a
manufacturer from internally incorporating a flow rate control mechanism and would be
unnecessarily design-restrictive in the approach to increasing the water efficiency of
lavatory faucets. Since aerators and other flow control accessories are able to earn the
WaterSense label individually, local, state, regional, and even national aerator
replacement programs will still be possible. WaterSense does not believe that revising
the specification to limit its scope will increase water savings and would be needlessly
design-restrictive. WaterSense also intends to educate consumers regarding the value
of installing a WaterSense labeled faucet accessory as a cost-effective retrofit option.
b. One commenter recommended that the specification state that "needle spray" aerators
(those that have no screen and emit water in a tight stream) not be allowed to qualify for
the WaterSense label. The commenter has experienced performance issues related to
splashing and splattering by 1.0 gpm needle spray aerator attachments.
Response: While WaterSense has heard complaints concerning faucet accessories
using this type of spray pattern, WaterSense does not want to endorse or deprecate one
technology over any other, particularly because some users may find this type of spray
pattern satisfactory or indeed desirable for their application. In addition, WaterSense
does not want to establish requirements that are unnecessarily design-restrictive.
Rather, WaterSense feels it is up to manufacturers and consumers to decide which
technologies to market and purchase. WaterSense may engage in a consumer
education campaign related to product spray patterns to help consumers recognize
there are a variety of products on the market.
October 1, 2007
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Response to Comments on Draft
SeilSe High-Efficiency Bathroom Sink Faucet Specification
Another commenter suggested that WaterSense include a "quarter turn" performance
standard in regards to the opening and turning-off of faucets. The concern was that
lavatory faucets that require several rotations of the handle to turn off the water are less
likely to be turned off by users when performing tasks such as brushing teeth or shaving.
The commenter points out that lavatory faucet water consumption is a function of not
only flow rate (i.e., gallons/minute) but also total time of usage. The commenter's
contention is that users will be more likely to turn off faucets during certain activities with
a faucet that requires a quarter turn or less (or lowering the handle through an arc of
less than 90 degrees for single lever faucets) than a faucet that requires multiple turns.
Response: While WaterSense encourages the manufacture of easy-to-shut off and
ergonomically correct faucets, it is uncertain at this time whether including this type of
requirement in the specification will result in any increase in water savings. Furthermore,
the commenter suggests that a survey is necessary to determine whether a correlation
with faucet type can be made with the likelihood of end users to shut-off the faucet when
brushing teeth. Without conclusive data indicating that such functionality impacts user
behavior and increases water savings, WaterSense has concluded that including this
type of requirement in the specification at the time may be unnecessarily design-
restrictive.
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Faucet Accessory Testing
a. Several commenters remarked that the specification was too vague as to whether the
entire faucet (including any flow control accessories) must be tested according to the
ASMEA112.18.1/CSA B125.1, or whether just the flow control accessory could be
tested alone. The commenters pointed out that under the current testing protocols, just
the accessory (e.g., aerator or laminar flow device) can be tested for compliance with the
standard and any faucet to which it is subsequently attached is assumed to be in
compliance with the required flow rate as well. The commenters questioned whether
WaterSense intended to require all faucets and accessories to be tested together to
qualify for use of the label.
Response: WaterSense does not intend to change the current testing protocols with this
specification. It has always been WaterSense's intention that either the faucet or flow
control faucet accessory be able to earn the WaterSense label. It is also WaterSense's
intention to allow faucets that are manufactured and sold with WaterSense labeled
accessories to qualify for and use the WaterSense label. WaterSense clarified the
language in Section 2.0 to state that "A lavatory faucet is also considered to meet this
flow rate requirement if equipped with a lavatory faucet accessory that meets this
requirement."
October 1, 2007
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Response to Comments on Draft
High-Efficiency Bathroom Sink Faucet Specification
Establishing Maximum and Minimum Flow Rates
b. Several commenters suggested clarifying that the 1.5 gpm flow rate at 60 pounds per
square inch (psi) is the maximum allowable flow rate and that the 1.2 gpm flow rate at 20
psi is the minimum allowable flow rate.
Response: WaterSense has added the terms "maximum" and "minimum" in the revised
specification to clarify that these are just maximum and minimum flow rates, and that
flow rates in between are acceptable.
c. Several commenters expressed concern that setting the maximum allowable flow rate at
1.5 gpm at 60 psi could actually result in an increase in water consumption in areas
where 1.0 gpm aerators are already widely used (if homeowners were to replace their
1.0 gpm aerator with a WaterSense labeled aerator). One commenter also suggested
that WaterSense did not provide adequate justification for the proposed water-efficiency
levels in the specification (i.e., maximum and minimum flow rates). The commenter felt
that these decisions for establishing flow rate requirements should be made based upon
actual testing and user satisfaction data, not on opinion or a 20 percent improvement in
water-efficiency guideline. The concern is that WaterSense might be setting the
maximum and minimum flow rates too high when users might in fact be satisfied with
significantly lower flow rates. The commenter also pointed out that there are several
areas of the country where local water utilities have implemented aerator replacement
programs using aerators with maximum flow rates below those specified in the draft
specification, and that have had very high reported levels of user satisfaction. The
commenter believes WaterSense's objective should be to identify the lowest water
use/flow rate that still obtains a 95 percent or greater consumer satisfaction.
Several other commenters agreed that consumer satisfaction research should determine
the minimum flow rate requirements, but argued that this type of research takes
considerable time to conduct. While this research is being conducted, they see no harm
in adopting the currently proposed specification. If the research shows that allowing
products that flow at lower flow rates are acceptable to the end user, the specification
can always be revised accordingly.
Response: WaterSense considered data from the Seattle, Washington;1 East Bay
Municipal Utility District, California;2 and Tampa, Florida3 retrofit studies and other
factors in making the flow rate determinations, including examining product performance
specification sheets for existing products, considering manufacturer and other interested
party comments and recommendations, and our own technical expertise all within the
context of the WaterSense program goals. In addition, WaterSense recognizes that
1 Seattle Home Water Conservation Study: The Impacts of High Efficiency Plumbing Fixture Retrofits in
Single-Family Homes, December 2000.
2 Water Conservation Study: Evaluation of High Efficiency Indoor Plumbing Fixture Retrofits in Single-
Family Homes in The East Bay Municipal Utility District Service Area, July 2003.
3 Tampa Water Department Residential Water Conservation Study: The Impacts of High Efficiency
Plumbing Fixture Retrofits in Single-Family Homes, January 2004.
8 October 1, 2007
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Response to Comments on Draft
High-Efficiency Bathroom Sink Faucet Specification
several water utilities across the country have distributed faucet aerators with flow rates
less than 1.5 gpm and that have demonstrated very high levels of user satisfaction. In
response, WaterSense has maintained the maximum flow rate at 1.5 gpm, but has
lowered the minimum flow rate from 1.2 gpm to 0.8 gpm in order to allow faucet aerators
with maximum flow rates less than 1.5 gpm to meet the specification and qualify for the
WaterSense label.
d. Numerous commenters made recommendations on changes to the proposed minimum
flow rate of 1.2 gpm at 20 psi. Most commenters recommended lowering the minimum
flow rate and a few suggested having no minimum flow rate at all.
Specific suggestions for lowered minimums included 1.0 gpm at 20 psi, 1.1 gpm at 20
psi, and 0.8 gpm at 30 psi. The commenters that recommend 1.0 gpm and 1.1 gpm at
20 psi were concerned with user satisfaction issues when fixed orifice flow restrictors
are used at low water pressures. Besides the reduction in flow due to low water
pressures, they also cited the further reduction in flow rates that result from attaching
any faucet accessory (e.g., aerators) to faucets due to the upstream restriction of the
faucet. Setting the minimum at either 1.0 gpm or 1.1 gpm at 20 psi essentially requires
manufacturers to use pressure compensating faucet accessories. They felt this would
help ensure a high level of user satisfaction.
One commenter recommended that the minimum flow rate be set at 0.8 gpm at 30 psi.
This would allow for non-pressure compensating devices and provides a lower minimum
value that would allow for lower maximum flow rates.
A few commenters suggested using a flow rate differential (instead of establishing a
single minimum flow rate) from the faucet or accessory's designed flow rate to establish
allowable minimum flow rates (20 percent at 20 psi was recommended). This means
that a faucet or accessory designed to flow at 1.5 gpm at 60 psi would be allowed to flow
at 1.2 gpm at 20 psi. Similarly, this would mean the minimum allowable flow rate for a
1.0 gpm fixture fitting at 60 psi would be 0.8 gpm at 20 psi, and 0.4 gpm at 20 psi for a
fixture fitting designed to flow at 0.5 gpm at 60 psi. The commenters felt that a benefit of
this approach would be to address the concern many other commenters had expressed
regarding utility sponsored projects that give away 1.0 gpm or 0.5 gpm fixtures, which
might not otherwise qualify for the WaterSense label.
The commenters advocating no minimum flow rate at all want to also maximize water
savings by allowing faucets with flow rates lower than 1.5 gpm at 60 psi (e.g., 1.0 gpm
or 0.5 gpm) to be used when appropriate conditions exist. Examples provided by these
commenters included 0.5 gpm fixture fittings in guest room bathrooms of hotels and
hospitals with hot water recirculation systems and good water pressure. Some
commenters also wanted utilities to be able to continue distributing 1.0 gpm aerators, or
even 0.5 gpm aerators, as part of their water conservation initiatives and for these
products to earn the WaterSense label.
Response: WaterSense strongly believes that there needs to be a minimum allowable
flow rate to ensure performance and user satisfaction. Based upon the comments
October 1, 2007
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Response to Comments on Draft
High-Efficiency Bathroom Sink Faucet Specification
received; water savings and user satisfaction data generated by the Seattle,
Washington; Tampa, Florida; and East Bay Municipal Utility District retrofit studies that
used 1.0 and 1.5 gpm maximum flow aerators; and product flow curves for fixed orifice
and pressure compensating aerators and laminar flow devices, WaterSense has revised
the minimum allowable flow rate from 1.2 gpm at 20 psi to 0.8 gpm at 20 psi.
WaterSense believes that this approach allows for the greatest degree of design
freedom for manufacturers and helps ensure a high level of performance and user
satisfaction. With this minimum flow rate, 1.5 gpm at 60 psi fixed orifice faucet
accessories and pressure compensating faucet accessories with maximum flow rates as
low as 1.0 gpm at 60 psi will be able to qualify for the WaterSense label (according to
currently available product specifications and flow curves). This approach ensures that
utility programs that are providing 1.0 gpm aerators to their consumers will be able to
use WaterSense labeled products to continue to achieve substantial water savings.
WaterSense decided not to adopt the differential flow rate approach. Regardless of the
differential, WaterSense felt it would still need to establish some absolute minimum flow
rate in order to avoid extremely low flow rates, particularly in low water pressure
settings, that are likely to cause user dissatisfaction. In addition, there are no conclusive
data correlating minimum flow rates to user satisfaction and to the ability of the lavatory
faucet to perform its intended functions. WaterSense has decided to err on the side of
caution and has set the minimum allowable flow rate at a level where performance and
user satisfaction will be maintained. If in the future, conclusive data become available
that demonstrates lower flow rates are acceptable to users, then WaterSense will revisit
this specification and make any appropriate revisions.
e. Several commenters lobbied for a provision in the specification allowing lavatory faucets
with flow rates less than the minimum allowable flow rate (e.g., 0.5 gpm at 60 psi) to
qualify for the WaterSense label if the faucets or faucet accessories are employed
specifically in commercial settings with adequate water pressure and where hot water
recirculating systems are used. The commenters argued that many new "green" and
LEED certified buildings are using such systems and it would be beneficial to facility
owners if such systems were recognized by WaterSense.
Response: Adding language to this specification to allow the use of fixtures with flow
rates below the allowable minimum only in certain situations, provided hot water
recirculating systems are used or facility water pressure is above some minimum level,
goes far beyond what can be tested and certified by the licensed certifying bodies under
the current WaterSense certification scheme. Enforcement of the end use of a product
would be extremely difficult and is currently beyond the capabilities of the WaterSense
program.
As stated in the specification and the accompanying supporting statement, this
specification does not apply to faucets intended for public use, which are subject to a
maximum flow rate of 0.5 gpm at 60 psi as specified in the ASMEA112.18.1/CSA
B125.1 standard. If WaterSense decides to address water efficiency and performance
for these types of faucets, it will do so under a separate specification at a later date. To
10 October 1, 2007
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Response to Comments on Draft
High-Efficiency Bathroom Sink Faucet Specification
provide further clarification, the scope of the specification has been revised to indicate
that the specification applies only to lavatory faucets in private use, such as in
residences, and private restrooms in hotels and hospitals. Metering faucets, lavatory
faucets in public use, and residential kitchen faucets are not covered by this
specification. Furthermore, WaterSense incorporated definitions for public and private
use from the National Standards Plumbing Code. These are as follows:
"Private Use - Applies to fixtures for the private and restricted use of one or more
individuals in dwelling units, including hotel guest rooms and hospital rooms, and
other facilities that are not intended for public use."
"Public Use - Applies to fixtures for the unrestricted use of more than one
individual (including employees) in assembly occupancies, business
occupancies, public buildings, transportation facilities, schools and other
educational facilities, office buildings, restaurants, bars, other food service
facilities, mercantile facilities, manufacturing facilities, military facilities, and other
facilities that are not intended for private use."
Flow Rate Tolerance
f. Several commenters recommended deleting the +/- 0.1 gpm variance/tolerance
proposed in the draft specification and suggested replacing it with the statistical
measurement technique required under U.S. Department of Energy (DOE) regulations
relating to the Energy Policy Act of 1992 (found at 10 CFR Part 430). Commenters felt
the proposed variance was arbitrary and potentially at odds with DOE's regulations.
Response: WaterSense agrees with the commenters recommendations and has
replaced the proposed flow variance/tolerance language with a reference to the
appropriate DOE regulatory requirements.
IV, on 5.0 -
(Note: Due to the addition of new sections to the specification, this section has been
renumbered as Section 7.0.)
a. Several commenters suggested that the definition for "certified flow rate" be either 1)
modified so as not to contain performance requirements, 2) replaced with a definition of
"maximum flow rate" for clarity, or 3) deleted.
Response: With the changes made to the variance/tolerance requirement in Section 2.0
- Water Efficiency and Performance Criteria (see previous comment and response "f." in
Section III of this document), the term "certified flow rate" has been removed and no
longer requires defining.
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Response to Comments on Draft
High-Efficiency Bathroom Sink Faucet Specification
on
a. One commenter recommended improving the retail cost and savings analyses provided
in the WaterSense High-Efficiency Bathroom Sink Faucet Specification Supporting
Statement by correcting the assumed retail cost of a WaterSense labeled aerator from
$10 each to no more than $4 each. The commenter also suggested using the
incremental cost between a new WaterSense aerator and a standard replacement
aerator in determining the cost effectiveness of these products for consumers. The
commenter argues that in many cases the consumer is purchasing a new aerator
anyway, so the true cost of the WaterSense aerator is the incremental cost above the
price of the standard aerator. The commenter also recommended including the
imbedded value of energy in the water supply and wastewater treatment in the cost
calculations. The commenter felt that this represents a national savings that needs to be
considered.
Response: WaterSense agrees with the recommendation to use a lower retail cost for
WaterSense labeled faucet accessories in determining their cost effectiveness and
payback period. This change has been made in the revised supporting statement
released with the final specification.
WaterSense decided not use the incremental cost of a WaterSense labeled aerator over
a standard aerator in its cost effectiveness calculations. In these examples, WaterSense
wants to demonstrate the water, energy, and cost saving benefits of using labeled high-
efficiency products to promote their use and acceptance. WaterSense feels that by
demonstrating the potential savings and quick payback period even when paying full
retail cost to replace a functioning, less efficient aerator with a WaterSense labeled
product makes a stronger case for their universal use. This is consistent with the
approach WaterSense used for calculating the estimated water savings for the Tank-
Type High-Efficiency Toilet Specification.
WaterSense is primarily targeting residential homeowners for its education and outreach
campaign. For the purpose of the information contained in the supporting statement,
WaterSense does not feel that it is necessary to include the national energy, water
supply, and wastewater treatment cost savings from reduced water consumption.
WaterSense agrees that these national savings are significant and a desirable result of
increasing the efficiency of lavatory faucets, and may provide this information in a
different format for a different target audience.
12 October 1, 2007
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