By Chuck White, Vice President of Regulatory Affairs
In 2011, the Obama Administration, through the Department of Energy (DOE), established a showerhead rule interpretation, which changed the definition of a showerhead. The Federal limit for a showerhead is 2.5 gallons per minute (gpm) at 80 pounds per square inch (psi) supply pressure. The 2011 interpretation, effective since 2013, limited the aggregate flow from all showerheads in a shower compartment (essentially per faucet) to that Federal limit of 2.5 gpm. This effectively stopped shower towers, body sprays and multiple head devices from being marketed unless, in aggregate, those devices complied with the limitation. By setting the effective date in 2013, the DOE allowed a two-year sell-through period that allowed for manufactured products to be sold.
The DOE now proposes to amend the existing test procedure for showerheads and to revise the definition of a showerhead consistent with the most recent standard developed by the American Society of Mechanical Engineers (ASME) in 2018. The Department proposes to define showerhead as that term is defined in the 2018 ASME standard, such that each showerhead or nozzle in a product containing multiple showerheads would be considered separately for purposes of determining standards compliance, and only one of them would need to be turned on or measured for testing. The DOE has determined that the proposed definition is consistent with the Energy Policy and Conservation Act (EPCA and, unlike the current definition, compliant with Office of Management and Budget (OMB) Circular A-119. The DOE also proposes to create and define new categories for the terms “body spray” and “safety shower showerhead” to clarify which products are not subject to the current energy conservation standard. Those new categories would enter the market as unregulated products and not be subject to the current Federal flow restrictions. Some examples of multiple head showerheads provided by the DOE include:
PHCC is working with industry partners and allied groups such as the Alliance for Water Efficiency (AWE) on the impacts of this Proposed Rule. The Associations Energy Efficiency & Water Conservation Committee and the Regulatory Affairs Sub-committee already have begun the process of evaluating the DOE proposal and recognize the challenges this presents to the advances made in water and energy conservation. If you would like to share any thoughts on showerheads, please contact Chuck White by email at [email protected].
Vice President of Regulatory Affairs , PHCC-National Association