EPA, DOE Draft Guidance on New ENERGY STAR Verification Testing Programs
On April 25, 2011, the Environmental Protection Agency and the Department of Energy released a draft guidance outlining the sample size approach to new verification testing programs for DOE and third-party certification bodies in support of the ENERGY STAR program, and how the approach relates to determining testing failures.
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EPA intends to finalize this guidance on May 9, 2011.
(In 2010, DOE launched a pilot program to verify the energy efficiency and water-use characteristics of selected ENERGY STAR products through laboratory testing. In 2011, EPA launched new requirements for qualifying products as ENERGY STAR, requiring program partners to have models certified by a third-party EPA recognized Certification Body (CB) to the ENERGY STAR specifications. The CBs also verify that a certain percentage of basic models they have certified continue to meet the ENERGY STAR requirements through verification testing on an annual basis.)
EPA Focusing Testing Thru 3rd Party CBs, DOE to Operate Gov't-Run Testing
Both CBs and DOE will be conducting new verification testing on ENERGY STAR products, which will be complementary and based on lessons learned from the 2010 DOE pilot verification testing program. EPA's verification program is focusing on testing of at least 10% of ENERGY STAR certified basic models through third-party CBs. In conjunction with the CBs' verification program, DOE intends to continue to operate a parallel, government-run targeted verification testing program for a subset of ENERGY STAR products that also evaluates how models comply with DOE's Federal energy conservation standards.
Agencies Propose Two Verification Testing Approaches
EPA states that the ENERGY STAR specification has allowed certain product categories currently subject to Federal energy conservation standards to use testing approaches consistent with DOE standards, which require testing of a sample comprising of no less than two units, and using statistical methods to determine the certified rating of each basic model.
Due to the variation in the sample size approach to qualification between those products subject to DOE standards and those that are not, EPA and DOE are proposing that products will be tested for verification consistent with how they were tested for qualification using one of the following approaches:
1. If a product was qualified based on a single test, which ENERGY STAR specifications require for products not subject to Federal energy conservation standards, then verification testing will involve a single test.
2. If a product was qualified using DOE’s certification sampling plans, which are associated with Federal energy conservation standards, then four units will be procured at once for verification testing. A spot check will be performed on the first unit. If the test result of the spot check fails by 5% or more, the additional three units will be tested and statistical methods applied to the results for purposes of determining a failure.
CBs Required to Report Testing Failures to EPA for Determination of Compliance
CBs are required to report testing failures to EPA for further consideration and a final determination regarding ENERGY STAR compliance within two days of determining a testing failure. EPA will notify the manufacturer and provide 20 days for a written response, which may include the submission of additional relevant information to EPA. EPA will review information submitted from the manufacturer and determine if any additional evaluation is necessary.
EPA will provide additional time to resolve questions of potential noncompliance as appropriate. If a decision is made to disqualify the product, the manufacturer will be required to discontinue labeling of the product and institute other corrective actions as directed by EPA.
Testing Failures Involving Federal Energy Standards Will be Referred to DOE
Testing failures that indicate potential noncompliance with respect to Federal energy conservation standards or that do not support the DOE certified rating, will be referred to DOE for further testing consistent with DOE’s sampling plans for enforcement testing of products as outlined in 10 CFR 429.
(See ITT's Online Archives or 11/10/10 news, 10111006, for BP summary of the EPA's third party certification for ENERGY STAR partners.)
Draft guidance is available by emailing documents@brokerpower.com.
More information on DOE's verification testing program is available here.