WaterSense Web Meeting
Product Certification and Labeling
September 15, 2008, 2:30 - 5:00 p.m. EDT
Stephanie Tanner (EPA) welcomed the participants and provided an overview of the
WaterSense Program.
Joanna Kind (ERG) discussed the status of the irrigation control technology protocol and
potential WaterSense draft specification.
Ms. Tanner clarified that product certification and labeling (the topic of the web meeting) occurs
after a WaterSense specification has been finalized for a product. This meeting served to inform
irrigation stakeholders about the third party certification and labeling process, so they are
familiar with it when a WaterSense specification becomes final for their product category. Ms.
Tanner continued the meeting by reviewing the proposed draft WaterSense certification and
labeling scheme.
Following Ms. Tanner's presentation, five guest speakers presented information to the
participants. The first four were WaterSense licensed certifying bodies (CBs) and the fifth was a
small plumbing manufacturer.
John Glowacki (CSA International) discussed the benefits of third party certification. Third party
certification is a powerful tool that allows clients to know that certified systems and products
have undergone rigorous testing. It builds confidence and differentiates the market, as all
products are subject to the same requirements. Accreditation provides the manufacturer with
confidence that the CB is capable of performing third party certification. Since many accredited
CBs exist, manufacturers have the option to search the market for the CB that best meets their
Shahin Moinian (IAPMO R&T) discussed the testing options for manufacturers. Accredited CBs
can use their own laboratories or subcontract testing to other accredited laboratories.
Subcontracted, accredited laboratories must comply with standards set by the CB to perform
testing. The CBs regularly assess the lab's test equipment, calibration and traceability,
documentation, record keeping, and personnel competence. During the assessment, the
laboratory must demonstrate performance of test protocols.
Tom Bowman (Underwriters Laboratory) discussed the experience CBs have working with small
businesses. CBs offer services to all manufacturers and treat them all as equals. They do not
offer expedited services to large companies. Since there are a variety of CBs, small businesses
can choose which CB suits them best among the market competition.
Tom Palkon (Water Quality Association) discussed how CBs seek to bring new industries into
their certification programs. Many CBs work to develop the test protocols that they use to certify
products. They encourage manufacturers to become involved in this process so they feel that
test protocols are fair and optimal. Since CBs are seeking to develop test protocols for new

products and are seeking help from those manufacturers, they are expanding their base to
include new industries and businesses. In the long run, certification assures that products are
well-performing and meet the needs of consumers and is positive for industry.
Lloyd Hathcock (Niagara Conservation, Corp.) represents a plumbing manufacturer, similar in
size to many of the irrigation manufacturers. His company specializes in water efficiency
products. With labeled toilets and faucet aerators already on the shelves, Mr. Hathcock
discussed Niagara's experience from the certification process. In the past two years that they've
been participating in the voluntary WaterSense program and have seen many benefits. Niagara
is venturing into water efficiency program planning and management as a result of their
experience with WaterSense. They have moved from manufacturing only plumbing products to
including irrigation products in their product line. The WaterSense label has proved to be a
significant marketing tool for products and services and has leveled the playing field for product
performance levels. The certification process allowed Niagara to be proactive rather than
reactive as they were a part of the specification development process for toilets, faucets, and
showerheads. They identified new products and concepts that wouldn't have come to fruition if
WaterSense were not in place. WaterSense products and services are in the front line for
incentive program selection by water and energy agencies. The certification process can be
short depending on how well prepared the industry is. Mr. Hathcock recommended that
irrigation manufacturers learn the certification process now, allowing them to be prepared for
product labeling when a specification is final.
Roy Sieber (ERG) opened the floor for questions to the five guest speakers.
A participant asked if their product had already passed in the SWAT test, would it need to be
certified again for WaterSense.
Ms. Tanner responded that SWAT testing alone is not equivalent to the anticipated WaterSense
certification. Because certification involves more than product testing and CIT is not an
accredited laboratory of a WaterSense CB, past SWAT testing is not appropriate for use in the
WaterSense program. In addition, the SWAT protocol that WaterSense will likely adopt is a new
version; therefore, WaterSense will not be grandfathering any previously tested products. All
products will have to be tested to the new Draft 8 protocol.
A participant noted that the certification process can take over a year sometimes and asked
what the CBs suggest to achieve a 30-60 day certification process.
Mr. Bowman (Underwriters Laboratory) explained that Underwriters has a new way to handle
work flow and have completely redesigned their work flow process. Most products will be
certified much quicker than in the past with the new process in place.
Mr. Moinian (IAPMO R&T) added that for products which go through the iterative process (i.e.,
they do not have all of the necessary information available at the time of their application), the
certification process can be 70+ days (for toilets and faucets). If their information is complete
during the time of application, the certification process can be as quick as 5 days for these
Mr. Glowacki (CSA International) noted that CSA has had similar experiences to IAPMO. If
manufacturers go through the iterative process, the certification process is slowed down

Ms. Tanner reiterated that third party certification is successful because the market is open for
manufacturers to take their business where they feel service is best. Manufacturers can
competitively choose where to spend their money and do their testing. WaterSense sets the
criteria for CB's performance standards.
A participant asked if any CBs have reviewed the SWAT Draft 7 irrigation controller protocol for
completeness and if any CBs could run the test.
Ms. Tanner explained that EPA has sent the CBs the existing protocol for review but it is not
currently in a format that that would allow for implementation by CBs. EPA is currently
conducting additional research on the repeatability of the protocol and working with SWAT to
assure that the protocol is clear and understandable for other testing bodies. Since the protocol
documentation package is not complete, EPA has not asked the CBs to fully evaluate the
protocol at this time.
Ms. Tanner led the participants through the proposed final certification scheme. Kim Wagoner
(ERG) discussed WaterSense draft Certification Scheme.
Mr. Sieber opened the floor for questions and discussion.
A participant asked if the WaterSense label would supersede the SWAT label.
Ms. Tanner replied that WaterSense label will not supersede the SWAT label. WaterSense will
use the SWAT protocol as the performance test for products to earn WaterSense label. It is up
to utilities to decide if they require SWAT testing or the WaterSense label for their incentive
programs. WaterSense works with utilities and encourages them to promote uniformity in what
they offer and set requirements to WaterSense levels, but they are not bound to that.
A participant asked for clarification regarding the process and repeated her understanding that
WaterSense plans to use the SWAT protocol to develop product performance information. Then
WaterSense wants to place additional criteria on smart controllers that will be required for
certification, which haven't been completely determined yet (user interface features, etc.). Also
as part of the labeling program, there will be a CB that oversees laboratories to make sure they
are in compliance with certifying products. The CBs will oversee manufacturers to guarantee
that products continue to meet WaterSense requirements. The participant asked for
confirmation that the stated information was correct.
Ms. Tanner agreed that the procedures described were correct. CBs audit the manufacturing
process. They conduct visits to manufacturing plants to ensure manufacturers are meeting the
minimum quality standard. CBs assure that manufacturers are continuing to mass produce a
quality product. Ms. Tanner reiterated that WaterSense does not want to develop test protocols.
WaterSense wants the industry to develop and agree on test protocols. WaterSense will require
that products meet or exceed the performance level (currently in development based on the
SWAT protocol) to receive the label. The CB will determine if a product should receive the label
and will assess if the product continues to meet the specification criteria over the years. Ms.
Tanner explained that EPA does not receive test reports. EPA will not know if a product fails or
how many times a product has been tested. EPA will know that a CB has tested X controllers
and had X failures. Ms. Tanner reiterated that WaterSense is a pass/fail program, not a tiered or
rating system program.

A participant asked what the passing score on the SWAT test would be.
Ms. Tanner responded that EPA would decide on the passing score during the specification
development process. Once the controller study, which is currently being conducted at the
University of Florida, is complete and EPA receives the final Draft 8 protocol, WaterSense will
be able to discuss performance levels.
A participant asked when WaterSense would publish a specification for irrigation control
Ms. Tanner explained that WaterSense is hoping to complete the current University of Florida
study and issue a draft specification at the beginning of next year. Currently only one laboratory
tests products using the protocol. The lab wrote the protocol and performs it. EPA needs to be
sure that the final test protocol package can be implemented by all of the CBs.
A participant suggested that products be ranked instead of meeting pass/fail criteria. Then the
participant asked if a product would have to be retested if a manufacturer chose to change the
design of their product. He asked if the product would have to be retested even if the change
would not affect test protocol scores.
Ms. Tanner explained that the manufacturer would need to write up the details of the design
change and submit them to the CB. The CB would decide if that change impacted the test and if
the results of the previous test would still apply. This decision would be made in conjunction with
the manufacturer.
Mr. Moinian (IAPMO R&T) added that in the licensing agreement that manufacturers sign prior
to product testing, they are obligated to report changes in their product as soon as the change
occurs. The CB and the manufacturer will decide if the protocol covers the change or not. Mr.
Moinian also responded to the participants comment on WaterSense using a ranking approach
noting that a ranking system may be misconstrued as promoting a particular product. He added
that accrediters may have a problem with certification based on a ranking scale.
A participant asked if manufacturers are going to have to wait for the rainfall requirements of the
SWAT protocol to be achieved, or if labs are going to produce weather conditions.
Ms. Tanner responded that there will be no weather chamber testing. Manufacturers will have to
wait for the protocol's weather requirements to come into effect. However, since CBs are all
over the country, they may be in places where rain is more frequent than CIT in Fresno. If EPA
moves forward in using the SWAT protocol, it will be because the protocol can be implemented
nationwide in places with various weather patterns, and yet, produce consistent results.
A participant asked if EPA had a list of eligible CBs available for certification.
Ms. Tanner explained that EPA will develop this list as the draft specification is written. CBs will
become accredited to use the specification when it becomes final. Then, a public list of
accredited CBs and labs that work under each will be available. Ms. Tanner explained that first,
WaterSense has to write a draft specification, publish if for public comment, incorporate
comments, assure that CBs are accredited, and then issue the final specification.
Mr. Sieber introduced the certification costs for further discussion. He noted that third party
certification balances a rigorous testing scheme with affordability. Mr. Sieber asked if anyone
had any misconceptions about the costs and if the participants understood the benefits of the
third party certification process.

A participant asked if the costs presented were for toilet certification or for other products. He
noted that the highest cost he had experienced for independent testing of his controller was
Mr. Sieber explained that the presented costs were based on testing for high efficiency toilets
and covered more than product testing. The costs shown represent the cost of full certification,
including the manufacturer quality review and other elements.
A participant noted that the total cost of $5,000-$15,000 seemed too high.
Ms. Tanner noted that EPA tried to provide cost figures to display how much product testing can
be. However, there are many things that go into these costs and these specific examples are for
the plumbing industry. Since the SWAT protocol is not finished and the CBs haven't been able
to look at the protocol in detail, WaterSense is not sure how much testing for irrigation
controllers will be. The testing for irrigation products may be simpler than plumbing products
because plumbing products have to account for many health and safety issues that irrigation
products do not have. For recertification, small manufacturers may have their products tested
every year or every other year (since the certification scheme requires that one model per
manufacturer be checked every year). This may not be realistic and may change if it is
inappropriate. Utilities want the CB to buy the product retail so they can see the representative
sample in the marketplace; this also increases the cost of the test. WaterSense is looking at
how often the certification scheme requires the CB to examine the manufacturer process, how
often products are recertified, etc. The goal is not to make it so rigorous that no one can afford
to participate, but rigorous enough so utilities will agree that there is integrity behind the label
and they can trust the performance of these products over the long run.
A participant expressed concern that if manufacturers make a new product, they do not want to
stock it on retail shelves just so CBs can pull one off of the retail shelf for testing. They want to
get their product tested first, before it goes out retail.
Ms. Tanner explained that the initial products are not pulled off the retail shelf. Products are
pulled off the shelves for recertification (i.e., when a product is tested a year or two after initial
certification). This allows for post market surveillance of the marketplace. It allows the CBs to
see if all products carrying the label have been adequately tested. This is to the benefit of all
A participant asked what "listing" meant in terms of being a portion of the certification cost.
Mr. Glowacki (CSA International) explained that certification is an ongoing process, and CBs are
continuously maintaining a listing of certifications manufacturers hold. There is also a cost for
maintaining the licensing agreement. The listing category includes these things. The prices
listed in the presentation range high because toilets (the basis for the data in the presentation)
sometimes come from the international marketplace, which makes product testing more
A participant asked when EPA would develop a specification for soil moisture sensors.
Ms. Tanner noted that EPA will include soil moisture sensors in the irrigation control technology
specification after there is an industry-accepted test protocol for these products.

A participant asked if anyone could comment on the status of the SWAT irrigation control
technology protocols.
Brian Vinchesi, SWAT Committee Member, stated that the Draft 8 weather-based irrigation
controller protocol is complete. It is under a definition review within the Irrigation Association.
The protocol should be delivered to EPA by next week. Comments on Phase 2 of the Draft 5
soil moisture sensor protocol are being addressed. A new draft will be issues for a 90 day
review soon. Phase 1 of the soil moisture sensor protocol is complete.
A participant asked if there is going to be a WaterSense update the Irrigation Association show
this year.
Ms. Tanner explained that WaterSense will be in the middle of our controller testing at UF and
will not have an update at the meeting. She added that WaterSense will hold a general program
Jenna Smith (SWAT Chair) added that SWAT will discuss WaterSense at the annual SWAT
If any participant has a question for the CBs, their contact information can be found at
http://www.epa.gov/watersense/basic/cert bodies.htm#het.