Energy Star Program Requirements for Pre-rinse Spray Valves Final Draft Eligibility Criteria

ENERGY STAR

ENERGY STAR® Program Requirements
for Pre-Rinse Spray Valves

Final DRAFT Eligibility Criteria

Below is the FINAL DRAFT product specification for ENERGY STAR qualified pre-rinse spray valves. A
product must meet all of the identified criteria if it is to be labeled as ENERGY STAR by its manufacturer.

1) Definitions: Below is a brief description of a pre-rinse spray valve and other related terms as relevant
to ENERGY STAR.

A. Pre-Rinse Spray Valve: A handheld device that uses a spray of water to remove food waste from
dishes prior to cleaning in a commercial dishwasher. Pre-rinse spray valves consist of a spray
nozzle, a squeeze lever that controls the water flow, and a dish guard bumper. Models may
include a spray handle clip, allowing the user to lock the lever in the full spray position for
continual use.

Note: Based on stakeholder feedback, EPA has added the term "commercial" to the pre-rinse
spray valve definition above. This change clarifies that pre-rinse spray valves are designed for and
used in commercial applications.

One stakeholder suggested that EPA further modify the definition to reflect different configurations
that may be provided to allow for greater throughput. For example, in some operations, the unit's
actuator clip is removed so that it is permanently on; then, it is mounted vertically to a rigid pipe
and plumbed for on/off operation by a foot pedal. EPA has chosen not to incorporate this change
because these types of modifications are often made in the field after the unit has left the
manufacturer's factory. As such, the manufacturer cannot certify the unit's efficiency in
accordance with the test procedure.

21 B. Flow Rate: The maximum amount of water, in gallons, that can flow through the pre-rinse spray

22 valve per minute. Flow rate is expressed in gallons per minute (gpm) at pounds per square inch

23 (psi).

25 C. Cleanabilitv (Cleaning Performance'): The effectiveness of the pre-rinse spray valve to remove soil

26 from the plate before it is placed in a dishwasher. Cleanability is measured in seconds per plate.

Note: Research has shown that not all low-flow designs exhibit comparable cleaning
performance. For example, devices that are made to be "low flow" by inserting a flow restrictor in a
standard device may not exhibit adequate cleaning performance and therefore jeopardize
customer satisfaction as compared with those that are truly redesigned to be low-flow devices.
Consistent with ENERGY STAR'S Guiding Principles, this Final Draft specification includes
cleanability requirements to help ensure that product quality is not compromised for energy
efficiency. To read more about the key principles that guide EPA's ENERGY STAR specification
development efforts, visit www. eneravstar. aov/Droductdevelopment.

29 2) Energy-Efficiency Specifications for Qualifying Products: Only those products listed in Section 2

30 that meet the following criteria for both Flow Rate and Cleanability may qualify as ENERGY STAR.

32 A. Proposed ENERGY STAR requirements for Flow Rate and Cleanability are provided in Table 1,

33 below. Pre-rinse spray valve models with multiple settings, such as shower, mist, and pulse, must

34 meet the ENERGY STAR criteria at all settings in order to earn the ENERGY STAR.

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35

Table 1: Proposed ENERGY STAR Criteria for Pre-Rinse Spray Valves

Flow Rate (at 60 psi)

Cleanability

< 1.6 gpm

< 26 seconds per plate

Notes: The Final Draft performance levels for flow rate and cleanability have not changed and
remain consistent with Draft 1 (Page 2, Table 1: Proposed Tier 1 ENERGY STAR Criteria for Pre-
Rinse Spray Valves). The proposed specification recognizes the more efficient products on the
market while allowing several manufacturers to participate in ENERGY STAR.

EPA has added a clarifying statement in this Final Draft for pre-rinse spray valve models with
multiple settings. To avoid any consumer confusion, EPA is proposing that these models meet the
ENERGY STAR criteria at all settings to qualify for ENERGY STAR.

Tiers

EPA has decided not to pursue a Tier 2 specification at this time and, as such, all references to
Tier 2 have been removed. Once the final specification takes effect, EPA will monitor and evaluate
the market (including new product designs, user satisfaction, and product life) to determine when
new efficiency targets are needed. As stated in Section 5 of this draft, EPA reserves the right to
adjust or otherwise alter its specifications in the future, provided that stakeholders are given
adequate time to respond to and implement the changes.

One stakeholder suggested that ENERGY STAR implement parallel or concurrent tiers rather
than successive, more aggressive tiers over time. The suggested approach is inconsistent with
the ENERGY STAR philosophy and program design. As a single attribute label with a unique
specification for each product category, ENERGY STAR makes it easy for consumers to identify
energy-efficient models (i.e., they simply choose ENERGY STAR and don't have to educate
themselves about the various levels and savings opportunities associated with them) and
minimizes participation and labeling costs for manufacturers.

Water Pressure and Temperature

One stakeholder group voiced concern about pre-rinse spray valve performance problems caused
by either very high or low water pressure within a building. EPA understands that water pressure
not only varies by locality, but also may vary within a facility at different times throughout the day
(i.e., water pressure may be lower during peak demand times). After consultation with staff at
PG&E's Food Service Technology Center, EPA has developed the following approach:

To address high-pressure issues (e.g., 80 psi), EPA will educate users to turn down their
valve or tap as needed to reduce excessive splashing or spraying.

To better understand low-pressure issues, EPA conducted additional testing of standard
and low-flow pre-rinse spray valves at 40 psi. The results, as one might expect, were that
the flow rate moderately decreased and the cleanability time moderately increased; this
was the case for both standard and low-flow units, although the impact on cleaning time
was modestly greater for low-flow. Of note, the efficient low-flow models were rated well
below the proposed 1.6 gpm flow rate level (when tested at both 60 and 40 psi). Given
that low water pressure is an issue for any spray valve and taking into account current
flow rates in the low-flow market, relaxing the flow rate requirement (to allow for increased
flow) as suggested by this stakeholder group will not change overall performance with
regard to flow rate. Rather, EPA intends to provide user education about the performance
impact of extreme water pressures in its program communications.

This same stakeholder group also noted that hot water temperatures vary across facilities and
affect the cleaning performance of pre-rinse spray valves. EPA concurs and will address this issue
by indicating optimal operating conditions (i.e., 60 psi, 120°F) in its messaging on the ENERGY
STAR Web site and in other materials.

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Cleanabilitv Test

One stakeholder commented that the cleanability requirement should be relaxed to no more than 30
seconds per plate. Given that most of the known pre-rinse spray valve programs use 26 seconds
per plate, EPA has retained the 26-second proposal in the interest of harmonization/ consistency.
Please note, the cleanability test serves as a screening tool in that it ensures that low-flow models
provide at least a minimum level of cleaning effectiveness (see Note on page 1). It is not intended
to measure real world cleaning times.

Other Certifications

Another stakeholder recommended that certification with ANSI/NSF61-2003e "Drinking Water
Systems Components - Health Effects" be added as an ENERGY STAR requirement for pre-rinse
spray valves. After further consultation with this commenter, EPA has decided that requiring this
certification is outside the scope of ENERGY STAR, but recognizes that some customers may
request it when placing their purchase orders. Through ENERGY STAR, EPA strives to ensure that
efficient models meet, or in some cases exceed, basic product safety requirements. Since people
are not normally expected to drink from pre-rinse spray valves, compliance with ANSI/NSF61 would
be considered an added benefit for those models that meet it.

ENERGY STAR Representation in the Market

One stakeholder group questioned why EPA was deviating from typical practice of setting an
ENERGY STAR specification that could be met by approximately 25% of available models. When
developing ENERGY STAR specifications, EPA's goal is to initially recognize approximately the top
25% of the available models in the marketplace. This guiding principle or rule of thumb is
sometimes adjusted based on market conditions (e.g., number of market players, lead times for
manufacturers to design to new specifications, variations in energy use across models, etc.). In
product markets with few manufacturers and few total available models (both efficient and
"inefficient"), a greater percentage of the market is often represented by ENERGY STAR in order to
ensure that the specification does not favor one manufacturer and/or one technology or design
approach. It is important to keep in mind that the purpose for including pre-rinse spray valves in
ENERGY STAR is to transform the market to more energy and water efficient models, which is
what this Draft specification proposes to do.

40 3) Test Methodology: The specifics for testing the flow rate and cleanability of a pre-rinse spray valve

41 are outlined in ASTM Standard F 2324-03: Standard Test Method for Prerinse Spray Valves.

42 Manufacturers are required to perform tests using this ASTM Standard to determine ENERGY STAR

43 qualification.

Note: Based on concerns with the cleanability test, one stakeholder suggested that any references
to ASTM Standard F 2324-03 be eliminated from these draft Eligibility Criteria. EPA respectfully
disagrees with this position for the following reasons:

ASTM Standard F 2324-03 measures both cleanability and flow rate. Eliminating the ASTM
Standard would leave EPA without any means to measure and compare product models.
As noted earlier, the cleanability test was designed to ensure a minimum level of cleaning
performance and was not designed to be representative of a real world cleaning
environment such as a restaurant.

EPA is confident that ASTM Standard F 2324-03 serves the intended function of screening
products based on their basic ability to clean dishes.

Submittal of Qualified Product Data to EPA: Partners are required to self-certify those product models
that meet the ENERGY STAR guidelines and report information to EPA. ENERGY STAR qualifying
product lists, including information about new models as well as notification of discontinued models,
must be provided on an annual basis, or more frequently if desired by the manufacturer.

ENERGY STAR Program Requirements for Pre-Rinse Spray Valves - FINAL DRAFT

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50 4) Effective Date: The date that manufacturers may begin to qualify and promote products as ENERGY

51 STAR will be defined as the effective date of these Eligibility Criteria. The proposed ENERGY STAR

52 pre-rinse spray valve effective date is August 1, 2005.

Note: Most stakeholders who provided written comments on Draft 1 supported the proposed Tier 1
effective date of August 1, 2005. One stakeholder, however, suggested an alternative date of
October 2005. Based on some recent market research that identified several manufacturers with at
least one qualifying model, and because we are confident that the cleanability test procedure
serves its intended function, EPA does not feel any further delay is warranted and hence has not
changed the effective date in this Final Draft specification.

5) Future Specification Revisions: EPA reserves the right to change the specification should

technological and/or market changes affect its usefulness to consumers, industry, or the environment.
In keeping with current policy, revisions to the specification are arrived at through stakeholder
discussions. In the event of a specification revision, please note that ENERGY STAR qualification is
not automatically granted for the life of a product model. To qualify as ENERGY STAR, a product
model must meet the ENERGY STAR specification in effect on the model's date of manufacture. The
date of manufacture is specific to each unit and is the date on which a unit is considered to be
completely assembled.

ENERGY STAR Program Requirements for Pre-Rinse Spray Valves - FINAL DRAFT

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