EPA
WaterSense
Comments on the May 2007
Draft WaterSense Certification Scheme
November 2007
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Comments on the Draft
WaterSense Certification Scheme
Commenter Page
David Zoldoske, Center for Irrigation Technology 1
Shahin Moinian, IAPMO R&T 12
Elizabeth Gardener, Denver Water 13
Craig Selover, Masco Corporation Operational & Technological Services 14
Mary Ann Dickinson, Alliance for Water Efficiency 15
Phil Smith, A2LA 18
Dave Johnson, Rain Bird Corporation 19
Shawn Martin, PMI 21
Sally Remedies, Delta Faucet Company 24
Marsha Slaughter, P.E., City of Oklahoma 28
Ed Osann, Steering Committee for Water Efficient Products 29
Ed Osann, Steering Committee for Water Efficient Products 30
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Comments on the Draft
WaterSense Certification Scheme
Commenter: David Zoldoske
Affiliation: Center for Irrigation Technology
Comment Date: June 8, 2007
Comments on EPA "WaterSense Certification Scheme"
By Center for Irrigation Technology, California State University, Fresno
Dated June 8th, 2007
Abstract
The certification scheme places undue emphasis on a good faith commitment by the
manufacturers. This commitment assumes that the manufacturers will buy into and act on the
fundamental objectives of the EPA program because it is "the right thing to do." This
encourages the manufacturers to deal in perceptions crafted to enhance their public image.
Unfortunately perceptions don't save water, only well designed and manufactured products can
save water. In contrast, the I A SWAT product testing program has developed testing protocols
that characterize the ability of products to provide effective and efficient irrigation water use.
This effort parallels the procedures used by the ISO Committee on Irrigation and Drainage (ISO
TC23/SC18). We believe that the major emphasis of the certification scheme should be on the
development of performance testing protocols that characterize the product's ability to apply and
manage water.
1.0 INTRODUCTION
WaterSense is a public-private partnership program sponsored by the U.S. Environmental
Protection Agency (EPA) created to protect the future of our nation's water supply by promoting
and enhancing the market for water-efficient products and programs. To achieve the mission of
the WaterSense program, EPA establishes partnerships with interested stakeholders, such as
product manufacturers, retailers, and water utilities. EPA provides and maintains the
WaterSense brand and develops national specifications for water-efficient products and
programs.
Suggest that programs for appropriate product grouping be administered by product certification
bodies. The makeup of the body must be carefully balanced to reflect all segments of the
general public. The balance is required because ultimately decisions on specific issues will be
decided by voting.
EPA requires all products bearing the WaterSense label to be assessed for conformance to the
relevant WaterSense product specification by an accredited third-party product certification
body. Accredited product certification bodies will certify that products conform to applicable
specifications and authorize the use of the WaterSense label in conjunction with the certified
product.
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We believe it is a mistake to use the word certification, which implies a go/no go judgment when
describing the responsibility of the third party testing agency. These agencies test to
established protocols and certify the results. The product certification body committee would
frame the results to be effective in public programs.
The international criteria for the accreditation of product certification bodies operating product
certification programs (tangible products, processes, and services) are detailed in ISO/I EC
Guide 65, General requirements for bodies operating product certification systems.
Not sure that the ISO/IEC guidelines have much to say about the specifics of standards for turf
and landscape equipment.
This WaterSense certification scheme specifies the minimum requirements that product
certification bodies shall observe when operating third-party certifications of product
conformance to WaterSense product specifications and authorizing the use of the WaterSense
label. It provides guidance on ISO/IEC Guide 65 in order to satisfy the requirements implicit in
the certification of products for WaterSense and provides the basis for consistent application of
WaterSense certification by product certification bodies.
This document, in respect to the certification and labeling of products for WaterSense, shall be
read in conjunction with ISO/IEC Guide 65.
The requirements of this WaterSense certification scheme are applicable to the product
certification bodies and do not apply to the manufacturers that are obtaining product
certification. The WaterSense requirements applicable to the manufacturers are outlined in the
WaterSense manufacturer partnership agreement and the WaterSense program guidelines.
Figure A-1 portrays the key elements of this product certification process and the relationships
between EPA, the manufacturer, the product certification body, and the accreditation
organization.
Certification by a product certification body is not a statement that the product certification body
guarantees the efficiency and performance of a WaterSense labeled product. It is also not a
guarantee that all of the aspects of a relevant WaterSense product specification are being met
or will continue to be met, at all times. The certification and labeling of a product for
WaterSense is a statement that the manufacturer's products have been produced in accordance
with the relevant WaterSense product specification, and that the validation and verification of
conformance to the WaterSense product specification has been evaluated and determined to
meet the necessary requirements. It is also a statement of the manufacturer's commitment to:
Manufacture water efficient products in accordance with relevant WaterSense product
specifications; and
Comply with requirements of the manufacturer partnership agreement and WaterSense
program guidelines.
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"Certification" should guarantee that the product does perform to the advertised results. Not
sure what "produced in accordance with the relevant WaterSense product specifications"
means. We suggest it may be better for the WaterSense program to deal exclusively with
product performance and not engage in the manufacturing or design process.
2.0 TECHNICAL REQUIREMENTS
2.1 Scope
The WaterSense certification scheme applies to the certification of product conformance to the
technical requirements of relevant WaterSense product specifications and includes all
processes and services used to make a final product.
WaterSense product specifications, this WaterSense certification scheme, and the WaterSense
program guidelines outline the purpose and the minimum requirements for certification by a
product certification body. WaterSense product specifications are developed by EPA for various
products or product categories and detail the required attributes of products that are allowed to
bear the WaterSense label. Current WaterSense product specifications are available in Annex
A to this WaterSense certification scheme. As additional WaterSense product specifications are
developed, or modifications are made to existing WaterSense product specifications, Annex A
will be modified to incorporate the new or updated WaterSense product specifications.
Paragraph #1. Why does WaterSense include "All processes and services used to make a final
product"? Need to be concerned with performance and certain design features only including
for example end connections, pressure rating, and possibly head loss as it relates to energy
implications.
Paragraph #2. Not sure of the practicality of including the wording "the minimum requirements
for certification." This minimum definition could be a matrix of values established for a range of
parameters that also affect the product decision.
Suggest that the "product certification body" be for example the Irrigation Association's SWAT
committee in the case of the SMART irrigation system controllers.
2.2 References
Review existing materials available from other organizations such as: ANSI, AWWA, and the
"Uniform Plumbing Code."
3.0 THE PRODUCT CERTIFICATION BODY
Product certification bodies must be accredited in accordance with ISO/I EC Guide 65 to operate
the WaterSense certification scheme and certify products to the relevant WaterSense product
specifications contained in Annex A. The accreditation shall be issued by an accreditation body
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that:
Operates in accordance with the requirements of ISO/I EC 17011, General requirements
for accreditation bodies accrediting conformity assessment bodies;
Offers accreditation services to ISO/I EC Guide 65; and
Is an International Laboratory Accreditation Cooperation (ILAC) Mutual Recognition
Agreement (MRA) Signatory or International Accreditation Forum (IAF) Multi-lateral
Recognition Agreement (MLA) Signatory. Product certification bodies can seek accreditation for
any or all of the WaterSense product specifications in Annex A. The specific WaterSense
product specifications relevant to the products the product certification body certifies must be
listed in its Scope of Accreditation.
Not sure how you visualize establishing and funding the "Product Certification Body." This type
of formal operating organization will surely require a significant permanent staff. Ad hoc
committees like the I A SWAT committee can be mobilized for relatively short term assignments
on a volunteer basis. There must be some coordinating entity providing long term continuity.
Organizations like the Irrigation Association may be prepared to take on this role, if sanctioned
by the EPA.
4.0 PRODUCT CERTIFICATION SCHEME
4.1 Application
Manufacturers seeking WaterSense certification and the WaterSense label for their products
must apply directly to a product certification body that is accredited for the relevant WaterSense
product specification. The application shall be made on a form supplied by the product
certification body and shall contain at a minimum:
Manufacturer contact information;
Product brand name, model name, and model number(s); and
Manufacturer partner's URL.
The application shall relate to the specific product or group of products for which certification is
requested by the applicant. Once the application is accepted, the product certification body
shall provide the applicant with an estimate of the time required to conduct the initial evaluation,
and any further information necessary for the application process.
For manufacturers with products already listed by a product certification body, subsequent
requests for listing of new models for listed products shall be made on separate forms.
This is essentially how the current program works with one exception. We discuss with the
manufacturer the identification and mechanics of how the testing protocol is handled. We (the
third party testing agency) explain our role in administering the test and the SWAT committee's
role in formatting the test results report and adding other related sales information. The
procedure for making the results public is also discussed.
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4.2 Initial Production Inspection and Product Testing
4.2.1 General
The product certification body shall comply with the requirements of ISO/I EC Guide 65.
Upon confirmation of the acceptance of the application, the product certification body shall
make the necessary arrangements with the manufacturer for the initial evaluation in
accordance with this WaterSense certification scheme.
The product certification body shall accept responsibility for all actions included in the
WaterSense certification scheme, including product sampling and testing, assessment of the
production process or quality system (if applicable), and the surveillance of certified products.
The SWAT committee has the responsibility for defending and modifying the testing protocol.
The committee has the option of delegating some of these responsibilities to an approved third
party laboratory. Product sampling and testing details are included in the testing protocol.
There is still some confusion by the last sentence related to assessment of the production
process or quality. What is the purpose and how is the assessment conducted? We suggest
that the assessment be focused on the product.
4.2.2 Initial Production Inspection
The WaterSense program does not require an initial production inspection (audit of production
process and quality management) for products currently certified for sale in the United States.
If the product certification body has no prior certification relationship with the manufacturer in
the specific product area, the product certification body may conduct an initial production
inspection at its own discretion to audit the manufacturer's capability for production and quality
management.
Still not sure what a production inspection has to do with manufacturing useable products. If a
manufacturer "fails" the production inspection but the manufacturers product(s) perform
satisfactorily, can they still get EPA certification?
4.2.3 Initial Product Testing
4.2.3.1 Selection of Samples
Samples for testing and examination shall be selected in accordance with the requirements
specified in the relevant WaterSense product specification and this WaterSense certification
scheme.
The product certification body shall select samples of products for testing that are
representative of the model to be certified and made using components and subassemblies
identical to those used in production. The samples selected shall be made from production
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tools and assembled using methods established for the production run.
The current I A Protocol requires the vendor to bring 10 production units to the testing lab. One
unit is selected at random for testing. The tested unit is retained for historic reference purposes.
The test unit is identified by model and serial number. Testing documents contain reference to
these numbers.
4.2.3.2 Conduct of Initial Testing
The initial testing shall be carried out in accordance with the relevant WaterSense product
specification and with this WaterSense certification scheme. All test facilities used by the
product certification body shall demonstrate compliance to ISO/I EC 17025, General
requirements for the competence of calibration and testing laboratories.
The product certification body shall determine the means it will use to conduct the initial
testing. Allowable options include:
In-House Testing: The product certification body performs all product testing in its own
facilities.
Subcontract Testing: The product certification body subcontracts another party to
conduct product testing and/or evaluation.
On-Site Testing (Wtness Testing): Qualified staff from the product certification body
oversee testing conducted by the manufacturer at its own facility.
As yet we have not instituted compliance requirements with ISO/IEC 17025 standards. We
thought a special requirement of this regulation was to have the testing done by an independent
third party testing laboratory. We thought this laboratory was to be independent from the
"product certification body." Does this mean that both the product certification body and the
independent third party testing laboratory must be in compliance with ISO/IEC 17025?
4.2.4 Product Evaluation
4.2.4.1 Preparation for Evaluation
Prior to initiating product testing or a production inspection (if applicable), the product
certification body shall complete a comprehensive review of quality management
documentation and product literature and schematics to ensure that there is substantiated
evidence to show that the product is manufactured in accordance with the relevant
WaterSense product specification, and that a proper production system and quality
management system are established. The product certification body shall also verify that the
manufacturer has in place a signed manufacturer partnership agreement with EPA.
Do you really mean that the WaterSense program intends to audit the manufacturer's
production facilities to presumably ensure that they are capable of manufacturing products to
EPA standards? We question the workability of this concept. We suggest that it should be
adequate to evaluate the product quality as evidence of the production facility quality. It seems
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to us that quality standards for all aspects of the production process goes beyond the intent of
ensuring quality products. What is the intent of the manufacturing partnership agreement with
EPA? How does it deal with offshore manufacturing or the integration of multiple parts
manufactured from various parts of the world?
4.2.4.2 Evaluation
The product certification body shall carry out the product evaluation by determining if the
evaluation criteria are satisfactorily met and that the results of the initial product testing meet
the requirements of this WaterSense certification scheme and the relevant WaterSense
product specification. If an initial production inspection is conducted, the product certification
body may also evaluate the product based on the results of that inspection.
Not sure what the "production inspection" standards are and who carries on the inspection. It
would take a team of specialists to field the knowledge required to carry on the inspection.
4.2.4.3 Evaluation Report
The product certification body shall inform the applicant via a full report on the outcome of the
initial evaluation (product testing and, if applicable, assessment of production process). If the
product certification body is not satisfied that all of the requirements have been fulfilled, it shall
inform the manufacturer of the aspects for which they do not comply. If the manufacturer
shows that corrective action has been taken to meet the requirements within a time limit
specified by the product certification body in the evaluation report, the product certification
body shall repeat only the necessary aspects of the initial evaluation. It is up to the discretion
of the product certification body to determine whether a repeat of the assessment is necessary
for subsequent submittals of the same product.
Not sure how "absolute" standards of performance will be established. All products represent a
compromise of cost and quality related to the value of water saved. Since the value of water
saved varies by location, the optimum cost vs. quality judgment varies by location.
4.3 Licensing
4.3.1 Licensing Agreement Between Product Certification Body and EPA
The product certification body shall sign a Licensing Agreement with EPA prior to receiving
accreditation to certify and label products for WaterSense. This licensing agreement provides
the conditions for authorizing the use of the WaterSense label to manufacturers of certified
products.
As part of the responsibilities for certifying products and authorizing the use of the WaterSense
label, the product certification body shall also provide EPA with ongoing support including:
Provide EPA data on certified products: Product certification bodies shall
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maintain a listing of all WaterSense labeled products on their respective Web
sites. In addition, EPA will require the product certification bodies to submit an
updated list monthly so that EPA's WaterSense Web registry remains current.
The data shall be provided to EPA in a format compatible with the WaterSense
Web registry database. The data provided to EPA shall include:
o Manufacturer name and contact information;
o Brand/model/model number;
o Certification file number; and
o Certification date.
Provide EPA with an annual report: The report shall be made on a form provided by
EPA and shall contain information regarding numbers of products tested, certified, failed,
or reinstated. In addition, the annual report shall contain a summary of common label
misuse or dispute actions. EPA may utilize this information to generally track the
certifications of specific products and evaluate the effectiveness and continued
applicability of its WaterSense specifications.
Notify EPA of any WaterSense label suspensions or withdrawals: EPA will rely on the
product certification bodies to address product nonconformance, label misuse, and
dispute resolution. Accordingly, product certification bodies shall provide EPA with
notification of any WaterSense label suspensions or withdrawals, within 30 days of
occurrence.
Allow EPA to accompany accreditation organization on routine assessments: EPA
reserves the right, for EPA staff or agents acting on behalf of EPA, to accompany the
accreditation organization on any routine or follow-up assessments of the product
certification body's accreditation as it relates to the WaterSense Program.
The certified product listing must contain precise descriptions of the products tested and the test
results. It should contain a statement to the effect that nothing can be assumed relative to the
manufacturer's other products.
Need to develop a precise way of determining the basic manner in which a product can be
deemed to have failed. How are standards for failure defined? How in the world did EPA
decide that the "effective flush volume shall not exceed 1.28 gallons" (or 20% less than 1.6
gallons)? Was it a practical judgment on the state of the art after testing a range of available
products?
4.3.2 Licensing Agreement Between Product Certification Body and Manufacturer
When the certification decision has been made, the product certification body shall provide a
certification decision to the manufacturer and authorize the use of the WaterSense label in
conjunction with that certified product, in accordance with the licensing agreement (between
the product certification body and EPA) and this WaterSense certification scheme.
The product certification body shall adhere to the following conditions for issuing the
certification and authorizing the use of the WaterSense label:
Ensure that the manufacturer of a WaterSense labeled product abides by the policies
outlined in the WaterSense label guidelines.
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Verify that the manufacturer has in place a signed manufacturer partnership
agreement with EPA.
How does the "product certification body" verify that the manufacturer continues to market a
product meeting the standard's requirements? Several options are possible. Periodic re-
submittal of products forretesting or random selection of samples forretesting.
4.4 Appeals to the Product Certification Body (No comment)
4.5 Confidentiality (No comment)
4.6 Use of the WaterSense Label (No comment)
4.7 Publicity About a WaterSense Labeled Product (No comment)
4.8 Misuse of the Certification or WaterSense Label (No comment)
4.9 Extending a Certification (No comment)
4.10 Surveillance
4.10.1 Periodic Production Inspection and Product Testing
The product certification body shall, at a minimum, on an annual basis, audit the production
process and quality management of each manufacturer of a certified product(s). The purpose of
this audit shall be to:
Verify that the manufacturer continues to operate production and quality management in
a manner that will maintain a product's conformance with relevant WaterSense
specifications; and
Consider and take appropriate action where changes to the manufacturer's operations
are made that may impact a product's conformance with relevant WaterSense
specifications.
The product certification body shall also, at a minimum, every fifth year, retest each model of
each product it has certified, if the manufacturer wishes to maintain certification. Retesting for
conformance with the relevant WaterSense specification shall be conducted following the same
procedures outlined in Section 4.2.3, Initial Product Testing.
If on the fifth year retest, the product continues to perform to the specifications, the results will
be posted on the product certification body web site. If the product fails to meet the
specifications, these results will also be posted on the web site and the manufacturer will be
required to pay for the retest. The third party testing agency will contact the manufacturer, alert
them to the negative results, and offer to demonstrate the lack of compliance.
The retest protocol may be expanded to cover any product enhancements made since the
original test evaluation.
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4.10.2 Surveillance of Products on the Market
The product certification body shall conduct an annual post-market product surveillance. The
surveillance shall be conducted by an inspector appointed by the product certification body, and
shall include randomly selecting and testing one unit of one model of each certified product per
manufacturer (e.g., for a manufacturer of A, B, C faucets and X, Y, Z toilets, the product
certification body would select one model A faucet and one model Z toilet for testing), either
from the manufacturer's warehouse or at the project site or retail outlet where the product is
being used/sold. Where purchase of the product is required, the manufacturer shall pay for the
product.
Sampled products shall be tested for conformance with the relevant WaterSense specification
following the same procedures outlined in Section 4.2.3, Initial Product Testing.
The results of the product testing will be posted on the product certification body web site. The
manufacturer of a product that fails to meet the certification requirements will be notified before
the results are posted on the web site.
4.11 Suspension of the Use of the WaterSense Label on Products
The product certification body shall determine when the use of the WaterSense label shall be
suspended due to product nonconformance, improper use of the WaterSense label, or
infringement of the WaterSense certification scheme. Label suspension can occur for a limited
period of time as specified by the product certification body. During the period of suspension,
the manufacturer is prohibited from using the WaterSense label in conjunction with any product
associated with the suspended WaterSense label.
The product certification body shall provide the manufacturer of a suspended WaterSense label
the conditions under which the suspension can be removed (e.g., corrective actions that shall
be taken). At the end of the suspension period, the product certification body shall investigate
whether the indicated conditions for reinstating the WaterSense label have been fulfilled. Upon
receiving proof of fulfillment of these conditions, the product certification body shall notify the
manufacturer that the suspension has been removed. The product certification body shall notify
EPA within 30 days of both WaterSense label suspension and reinstatement.
These actions related to suspension of WaterSense labeling privileges shall be posted on the
product certification body's web site.
4.12 Withdrawal of the WaterSense Label from Products
In more severe or repeated instances of product non-conformity, misuse of the WaterSense
label, or failure to meet the requirements for reinstatement of a suspended WaterSense label,
the product certification body shall withdraw products' certification and the use of the
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WaterSense label. The product certification body shall inform the manufacturer that the
certification and WaterSense label are being withdrawn via a withdrawal notification. If the
WaterSense label is withdrawn from a product for any reason, the product certification body
shall ensure that the manufacturer and its wholesalers, distributors, and retailers immediately
cease to use the mark in conjunction with that product, and the label is to be eliminated from
product packaging/promotional materials within six months from the date of withdrawal
notification. The product certification body shall immediately notify EPA of any product
withdrawals and EPA shall decide whether termination of the partnership agreement or other
corrective action is warranted. The WaterSense label may not be used for any reason by, or in
conjunction with a product of, a manufacturer with a terminated partnership agreement.
When issues related to product non-conformity or improper use of the WaterSense label come
to the attention of EPA, EPA shall notify the product certification body that authorized the use of
WaterSense label for the product in question. The product certification body shall then engage
in investigation and resolution of the complaint in accordance with ISO Guide 65 and the
product certification body's policies and procedures.
In the event that the misuse of a WaterSense label on a single product continues for more than
six months after official notice, the certification and use of the WaterSense label on other of the
manufacturer's products will be withdrawn.
4.13 Amendments to these Rules of Procedure (No comment)
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Commenter: Shahin Moinian, P.E.
Affiliation: IAPMO R&T
Comment Date: July 13, 2007
Thank you for the opportunity to comment. We are in general agreement with the scheme
except for the fact that in section 4.2.3.1, the scheme requires the product certification body to
select the initial samples for testing. Although this was a requirement in the preceding document
to I SO/I EC Guide 65 (ANSI Z34.1), ISO/I EC Guide 65 does not require it. The normal practice
in our organization is that such samples are sent to us by applicants parallel to the initial audit
activities. This has been the normal practice for years and we recommend that it remains.
During the surveillance audits, the samples are selected by our auditors for testing. I therefore
recommend a verbiage change in that section to document the acceptability of this practice.
I thank you.
Sincerely,
Shahin Moinian, P.E.
Sr. Director of R&T
909-472-4121
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Commenter: Elizabeth Gardener
Affiliation: Denver Water
Comment Date: July 19, 2007
Denver Water's Conservation Section offers the following comments about the draft which we
received as an attachment to a May 26, 2007 e-mail from WaterSense. There is no need for
multiple testing if the first test such as MaP is authentic and done by a third party. Other tests
would be a waste of resources. We assume the details of the testing protocol in the May 24
version of Appendix A would remain at least as detailed as the current draft and not be diluted.
The May 24 draft does not mention lists of product-certifying bodies. Either these entities
should be listed or there should be a website referenced where the list could be found easily
and also updated in a timely manner by WaterSense staff. The monthly changes recommended
are too frequent for a water provider to effectively manage rebate programs. Many of us do not
communicate with our customers monthly, and having the WaterSense website announcing
items ahead of the utility's announcement is far too confusing for our customers. Other than
these few comments, we are fine with the draft and look forward to seeing the revised
document. Thanks for all your hard work on this. For your future efforts of labeling irrigation
products, it would be WONDERFUL if the really good professional irrigation products were also
available at big box retail stores. Perhaps you could work with the irrigation manufacturers on
this. We have difficulty getting quality irrigation products installed by DIY customers because
they cannot find quality products on the shelves at their local stores.
Liz Gardener
Elizabeth V. Gardener
Manager of Water Conservation
Denver Water
1600W. 12thAve.
Denver, CO 80204-3412
Phone 303-628-6325
FAX 303-628-6238
Liz.gardener@denverwater.org
web site www.denverwater.org
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Commenter: Craig Selover
Affiliation: Masco Corporation Operational & Technological Services
Comment Date: July 20, 2007
I have reviewed the Draft Certification Scheme and have the following comments:
1. If we meet the Water Sense Specifications for toilets, showerheads and faucets, we will be
providing products which easily fall within the requirements of EPACT '92, since the
WaterSense specs are set at lower water usage levels. Yet we still have to process the
paperwork and filings with both the Department of Energy and Federal Trade Commission to
meet the legal requirements. Now, to participate in WaterSense, we have to duplicate much of
that certification testing and administrative work, including the expense involved. We have
noted that only a small number of responsible companies have ever filed the EPACT required
paperwork, and most of those companies are US based. From an administrative expense
standpoint, complying with EPACT puts many of the larger US plumbing companies at a
competitive disadvantage. Deciding to participate in WaterSense, with these certification
expense requirements adds additional cost, exacerbating the competitiveness issue. We
believe that on the issue of WaterSense certification, that the EPA should work out an
agreement with DOE and FTC that WaterSense Certification meets all of the requirements of
EPACT 92, and more, and therefore the duplicative EPACT filings are waived, so long at the
WaterSense Certification is maintained.
2. Wth respect to Section 4.2.3.2, the section doesn't permit the use of the certifier and
manufacturer's Laboratory Category certification. Currently, these category certifications allow
testing without witness. The addition of the witness will add considerable expense to the testing
process, travel and per diem plus fees. Based upon the current Certifier and Manufacturers
who qualify by agreement with Category Certification requirements should be allowed to use
that procedure.
Craig Selover
Craig Selover
Director- Plumbing & Heating Platform Technology
Masco Corporation Operational & Technological Services
Alex Manoogian Research & Development Center
7500 Holland Drive
Taylor, Ml 48180
p 313 792-4457
f 313 792-4325
e cselover@masco-rd.com
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Commenter: Mary Ann Dickinson
Affiliation: Alliance for Water Efficiency
Comment Date: July 22, 2007
To Whom It May Concern:
The Alliance for Water Efficiency (Alliance) is a clearinghouse and advocate for water efficiency
research, evaluation and education. The Alliance was created in a partnership with numerous
nationwide, regional and state organizations, and locates its permanent headquarters in
Chicago. The purpose of the Alliance is to represent the needs of the water efficiency
community, develop initiatives for improved products, research new technologies for saving
water, and assemble programs for water utility involvement across the United States.
The Alliance has been and continues to strongly support the WaterSense Program as key to
bringing a new and vital focus on water efficiency in the U.S. As part of that support, the Alliance
continues to be a proponent of independent third-party testing of water-efficient products as a
requisite to WaterSense labeling. We are extremely pleased to see the depth of consideration
given to the certification process and to the rigorous approach to assuring that products meet
WaterSense specifications and perform as intended. Therefore, with one exception, the
Certification Scheme as proposed, as well as the accompanying Program Guidelines, give all of
us the assurance we need that the integrity of the WaterSense Program will be protected.
We have several comments on the Certification Scheme and Guidelines, all of which are
confined to the single area of post-certification surveillance of products. (We are not addressing
the post-certification surveillance of the application or use of the labels themselves, which we
believe is adequately covered within the documents).
1) Section 4.10.2 of the Certification Scheme states that "The product certification body shall
conduct an annual post-market product surveillance." (underlining added) It further gives the
choice to the certification body as to where the products shall be secured, i.e., "...from the
manufacturer's warehouse or at the project site or retail outlet where the product is being
used/sold." We see no definition of "post-market". It is our view that the manufacturer's
warehouse is not "post-market". We contend that, based upon past experience with current
certification bodies, that selection will never be made at the retail level if this wording is retained.
Rather, instead of post-market (retail), it will be made at the manufacturer's warehouse (which
we would offer is actually "pre-market"). Wthout random sampling of post-market product to
which the consumer has direct and immediate access, there is no assurance that the sample
selected actually represents what is available to the consumer in the marketplace as a whole.
Therefore, we believe very strongly that at least 50 percent of all such samples must be taken at
retail and/or supply outlets in the geographic market areas served by the manufacturer and that
ALL samples shall be taken "post-market".
2) Section 4.12, Second paragraph. This paragraph is significant in and of itself and should not
be buried in a section on "Wthdrawal of the WaterSense Label from Products" Actually, the
actions described in the paragraph would PRECEDE any withdrawal action and should be
separate and more clearly laid out. How will inquiries or allegations from Program Partners be
handled? How will inquiries or allegations from outside water efficiency organizations and water
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WaterSense Certification Scheme
utilities be handled? How will inquiries and allegations from consumers be handled? What
process will be followed? What evidence of "non-conformity" is required? In the event that the
Certification Process fails to implement product surveillance as we recommend above, then the
Alliance (and others) may implement its own "post-market" audit of products, purchasing them
at retail or through other paths in the chain of commerce, having them tested to all or a portion
of the applicable WaterSense specification, and submitting reports on non-conforming product
to the EPA and the certifying body. We recommend that upon receipt of an inquiry or allegation
of non-conformity by the Alliance or others, there be a clear process of resolution in place. This
process and timetable to be followed by the certifying body and the EPA should be very clearly
specified in the Certification Scheme documents.
3) Appendix A to the WaterSense Program Guidelines, Section II. B. iv. describes "ongoing
surveillance" by the product certification body and clearly describes "proper label use in the
marketplace" and "continued assessment of product conformance to the relevant WaterSense
specification" in the same sentence. We legitimately assume that the two go together. That is,
that product conformance relates to the marketplace, NOT to a manufacturer's warehouse.
Proper label use implies that the certified product conforms to the specification. Therefore, the
marketplace is to be the source for the products undergoing "assessment of product
conformance." This issue is identical to that identified as item 1) above.
4) The concerns expressed in item 3) above are further dealt with in the "Public Meeting
Summary" from June 20, 2007. On page 7 under "The WaterSense Label" the following
statements are made: "The product certification bodies are also responsible for following up
and responding to any label misuse claims that come to their attention." "The product
certification body is responsible for policing, identifying and responding to any misleading,
incorrect, or unauthorized use of the WaterSense label." Both of these sentences are
somewhat vague in their application and both appear to only address the label itself, NOT the
non-conforming product that is the subject of the label. This needs to be clarified to clearly state
that the responsibility also encompasses the product's conformance to the actual specification
as well. It may be implied, but an explicit statement would be much better, similar to the later
statement under "Surveillance" on page 8: "The product certification body is responsible for the
ongoing surveillance of products to ensure that they continue to meet the WaterSense
specification."
5) As a follow on to item 4) above, while we understand that the EPA is neither desirous of nor
equipped to police the performance of all the products that will eventually become certified, it is
not clear that the EPA will be insisting that the certifying bodies adhere to strict reporting
guidelines that would be designed to monitor the performance of any follow-up resulting from an
allegation of non-conformity. We are concerned that the document infers a somewhat lax and
undefined relationship between the EPA and the certifying body when non-conformance is
being investigated. Again, more specificity is necessary.
6) In the same Summary, pages 9 and 10 again offer at least two statements that classify a visit
to a manufacturer's warehouse to select a product sample as a "post-market" event. We very
strongly disagree and contend that a visit to the manufacturer's warehouse for a product is "pre-
market" and clearly introduces the potential for bias into the results of the test. Furthermore,
when such testing is performed and a product is found to be non-conforming, what actions are
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WaterSense Certification Scheme
to be taken by the certifying body to disqualify that product from receiving a WaterSense label.
Again, past experience indicates that, in such a situation, the sample is fixed to meet the
specification and the manufacturer is instructed "not to do that again." This would be an
unacceptable response by a certifying body to what we believe is a major non-conformance
issue. The labeled non-conforming product already on the retail shelf is not withdrawn and
remains in the chain of commerce, thus violating the intent of the entire certification process. In
this case, will the manufacturer be instructed immediately to remove the WaterSense label from
product on the retail shelf and at the supply houses that sell the product?
We consider the above issues relating to non-conformance to be so significant as to seriously
threaten the very long-term integrity of the entire WaterSense Program if they are not
addressed, something, of course, that none of us wants.
Thank you for this opportunity to comment and provide input to this important undertaking. If
you have any questions, please feel free to contact me.
Regards,
Mary Ann Dickinson
Executive Director
Alliance for Water Efficiency (AWE)
PO Box 804127
Chicago, IL 60680-4127
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WaterSense Certification Scheme
Commenter: Phil Smith
Affiliation: A2LA
Comment Date: July 23, 2007
After attending the WaterSense Certification Scheme meeting A2LA is very pleased with how
the scheme was prepared. We have no comments at this time.
Regards,
Phil Smith
Public Affairs Manager
A2LA
5301 Buckeystown Pike, Suite 350
Frederick, MD21704
Tel: 301-644-3204
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Commenter: Dave Johnson
Affiliation: Rain Bird Corporation
Comment Date: July 24, 2007
Rain Bird Corporation's Input to the EPA's Proposed WaterSense Certification Scheme
Rain Bird Corporation is very interested in the success of the WaterSense program. From the
beginning, we have been supportive of the EPA's efforts and have provided input during the
process in a variety of ways. While we recognize the importance of a certification process in the
WaterSense program, Rain Bird has significant objections to the certification scheme as it is
currently proposed.
In general, the third party certification process that is being proposed has three major
disadvantages:
1.) Lack of precedence within the irrigation industry of third party certification will
necessitate the building of a certifying body infrastructure that will ultimately lead to
higher costs, slower product development and less innovation. Few or no certifying
bodies exist in the irrigation industry that will be willing to become police of the industry
they serve. This may result in a certifying body outside the industry taking on this role.
However, the cost of developing this testing and certifying expertise could be high. The
costs will be passed on to irrigation equipment manufacturers and ultimately the
consumer. The proposed scheme allows for a certifying body to subcontract the testing
work, but this multi-step approach could lead to even higher costs. UL was mentioned
as a possible certifying body, but our experience with UL is less than satisfactory in cost
and responsiveness. Slow response by the certifying bodies or their subcontractors will
lead to delays in getting new products to the market. High cost will discourage
manufacturers, especially small ones, from participating in the program at all. Even if
new and innovative technology becomes available it may not be accepted as readily by
consumers if the product does not bear the WaterSense label.
2.) The irrigation industry may be slow in adopting the WaterSense labeling program if the
hurdles are too high. Given all of the concerns voiced to date from Rain Bird and other
manufacturers, it is our fear that an industry that is not used to third party certifications
will be slow in adopting the WaterSense labeling program
3.) The above issues, combined with other complications, will slow the acceptance of
WaterSense amongst consumers. Of course, if products are slow to market and costs
for WaterSense-labeled products are significantly higher than non-labeled products,
consumers will be less accepting of the new program. Additionally, by complicating the
label with the inclusion of the WaterSense logo AND the third party certifying body's
name consumers may be confused and the WaterSense logo will have less equity in the
marketplace. For example, will a WaterSense logo approved by UL carry more weight
with the consumer than a WaterSense logo approved by Joe's Lab? Or, will consumers
believe they mean two different things?
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In the end, Rain Bird believes that the WaterSense program, the irrigation industry and the
consumer will be better served with a less stringent certifying scheme. We propose a
certification scheme of manufacturer's declaration followed up with surveillance from a certifying
body and escalating penalties for manufacturers found to not be in compliance with their
declarations. This reduces cost and does not slow new product introduction while ensuring the
integrity of the WaterSense label.
Rain Bird appreciates the opportunity to weigh in on these important issues. Our views differ
from the majority opinion held by other members of the WaterSense steering committee of
which we are a part. As such, we felt it is important for us to make our views and objections
known. If the EPA desires more information or clarification on any of the above points, feel free
to contact either Dave Johnson or Ron Wolfarth at Rain Bird. Thank you.
Sincerely,
Dave Johnson
Director of Corporate Marketing
Rain Bird Corporation
djohnson(S) rainbird.com
520-806-5683
Ron Wolfarth
Director, Landscape Irrigation Division
Rain Bird Corporation
rwolfarth@rainbird.com
520-741-6539
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Comments on the Draft
WaterSense Certification Scheme
Commenter: Shawn Martin
Affiliation: PMI
Comment Date: July 24, 2007
July 24, 2007
Re: Draft WaterSense Certification Scheme Comments
The Plumbing Manufacturers Institute (PMI) has reviewed the Draft WaterSense Certification
Scheme dated May 24, 2007, and has developed the following four comments.
Please feel free to contact me if you require clarification or additional information.
Sincerely,
Shawn Martin
Technical Director
Plumbing Manufacturers Institute
847-481-5500
smartin(S)pmihome.org
Comment #1
Proposed Change
4.2.3.2 Conduct of Initial Testing
The initial testing shall be carried out in accordance with the relevant WaterSense product
specification and with this WaterSense certification scheme. All test facilities used by the
product certification body shall demonstrate compliance to ISO/I EC 17025, General
requirements for the competence of calibration and testing laboratories.
The product certification body shall determine the means it will use to conduct the initial testing.
Allowable options include:
• In-House Testing: The product certification body performs all product testing in its own
facilities.
• Subcontract Testing: The product certification body subcontracts another party to
conduct product testing and/or evaluation.
• On-Site Testing (Wtness Testing): Qualified staff from the product certification body
oversee Testing is conducted by the manufacturer at its own facility and witnessed by
qualified staff from the product certification body or in accordance the process
established by the product certification body.
Reason
Section 4.2.3.2 as currently drafted does not explicitly permit the use of the certifier and
manufacturer's Laboratory Category certification. This long-established and successful practice
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allows manufacturers with ISO/IEC 17025 compliant laboratory facilities to conduct in-house
testing which is overseen by an approved accreditation organization. Audits are conducted a
minimum of four times year to ensure that testing is conducted by qualified laboratory
personnel, that all testing has been conducted in accordance with the approved testing protocol,
and to conduct random actual restesting on certified models. Any certification scheme that does
not allow manufacturers to employ category certification measures that they have earned with
the certifying body will increase certification costs and introduce delays into the product
development process. Certification agencies should continue to be provided the flexibility to
develop product certification programs that provide robust compliance verification, while limiting
expense and delay.
Comment #2
Proposed Change
4.10.1 Periodic Production Inspection and Product Testing
The product certification body shall, at a minimum, on an annual basis, audit the production
process and quality management of each manufacturer of a certified product(s). The purpose of
this audit shall be to:
• Verify that the manufacturer continues to operate production and quality management in
a manner that will maintain a product's conformance with relevant WaterSense
specifications; and
• Consider and take appropriate action where changes to the manufacturer's operations
are made that may impact a product's conformance with relevant WaterSense
specifications.
The product certification body shall also, at a minimum, every fifth year, retest each model of
each product it has certified, if the manufacturer wishes to maintain certification. Retesting for
conformance with the relevant WaterSense specification shall be conducted following the same
procedures outlined in Section 4.2.3, Initial Product Testing.
Reason
We support periodic production inspection and surveillance testing, however periodic retesting
of product previously certified using procedures outlined in Section 4.2.3 is an unnecessary
measure, and will not increase product conformance. The periodic production inspection and
surveillance of products on the market described in section 4.1 provide sufficient controls to
ensure that product performance is maintained. Repetition of initial product testing will
introduce additional costs with no benefit accrued to the program or the consumer.
Comment #3
Proposed Change
4.10.2 Surveillance of Products on the Market
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WaterSense Certification Scheme
The product certification body shall conduct an annual post-market product surveillance. The
surveillance shall be conducted by an inspector appointed by the product certification body, and
shall include randomly selecting and testing one unit of one model of each certified product per
manufacturer (e.g., for a manufacturer of A, B, C faucets and X, Y, Z toilets, the product
certification body would select one model A faucet and one model Z toilet for testing), either
from the manufacturer's warehouse or at the project site or retail outlet where the product is
being used/sold (only if product is not otherwise available). Where purchase of the product is
required, the manufacturer shall pay for the product.
Sampled products shall be tested for conformance with the relevant WaterSense specification
following the same procedures outlined in Section 4.2.3, Initial Product Testing.
Reason
While it is recognized that purchase of the product from retail outlets may be necessary on
some occasions, PMI requests that this option be exercised only if the product is not available
from the other sources listed. This will minimize program compliance costs, whenever possible.
Comment #4
General Comment
Fixture manufacturers are required to report data regarding product performance to the
Department of Energy and the Federal Trade Commission to demonstrate compliance with the
provisions of the Energy Policy Act of 1992, limiting the water consumption of various plumbing
fixtures. The WaterSense program uses EPAct requirements as a baseline, and therefore any
product complying with WaterSense requirements will also comply with EPAct. In order to avoid
redundant reporting, PMI requests that EPA seek an agreement with the Department of Energy
and the Federal Trade Commission to coordinate the reporting requirements. PMI requests that
demonstration of compliance with WaterSense product certification provisions be sufficient to
demonstrate compliance with the requirements of the Energy Policy Act of 1992.
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Comments on the Draft
WaterSense Certification Scheme
Commenter: Sally Remedies
Affiliation: Delta Faucet Company
Comment Date: July 25, 2007
Kim,
We have reviewed and have the following comments on the EPA WaterSense Certification
Scheme. Please let us know if you have any questions.
For small products such as aerators how will these be labeled? Does this program use a
physical label or is it a marking on the product only, or can it be applied to packaging or other
literature?
As you may know our industry suffers from marking issues which our customers do not like to
have in visible locations, since it spoils the aesthetics.
In the introduction of the document it mentions that the certification scheme provides guidance
on ISO/I EC Guide 65. Could you explain what this guidance is and where it can be found in the
document?
Under 2.0 it mentions the scheme applies to the "technical requirements" of relevant product
specifications, do these not also include performance requirements?
In Section 3.0 the third bullet point includes requirements for the AB to be an ILAC or IAF
signatory. Is this appropriate for a Certification scheme? This is more related to a laboratory
testing scheme. ISO 65 already requires CB's to use data from an ISO 17025 recognized
laboratory.
In Section 4.0 should the term URL be expanded for those not familiar with this acronym?
Section 4.2
How does this initial evaluation work when a manufacturer buys an already WaterSense labeled
product that then ensures his products compliance to WaterSense?
4.2.3.2
Presently there are other options allowed by CB's which include auditing of manufacturers
testing facilities and ensuring compliance to ISO 17025 for these facilities. Can this be included
in the WaterSense scheme? It is a successful program. Manufacturers are audited four times a
year to ensure continuing compliance of their testing facility to ISO17025 together with
proficiency testing to ensure results of tests on similar products are the same as those tested by
the CB.
When the term "Qualified" is used in bullet point three, qualified to what and by whom does this
mean?
4.3.1
Last bullet point:
Is this not the AB that allows this, rather than the CB?
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WaterSense Certification Scheme
4.3.2
Should the CB be required to issue a report to the manufacturer on the models which can use
the WaterSense label?
4.6
Again, how big is the WaterSense label?
Can a manufacturer still maintain a WaterSense listing even if they do not use the WaterSense
label?
4.7
Is it the intent to exclude a manufacturer who does have every product listed to WaterSense?
This is the way it reads right now.
4.10.1
This type of retest program - all products every fifth year - is only usually required for products
that present a health or safety issue, not a conservation issue. NSF 61 is such a program. Other
plumbing products are usually retested using a statistical sampling program developed by the
CB, which would seem to be more appropriate for the WaterSense certifications. Could this be
revised accordingly?
4.10.2
Who will pay for this post-market program?
Does this mean 100% of the product is retested or should it say "each certified product group"?
Why would purchase of the product be required? Who would require it? This is a cost burden.
4.13
Suggest that EPA be required to notify all current holders of WaterSense certifications of the
changes made to Specifications, Policies, or Procedures, and provide partners with an effective
date for compliance.
Figure A-1
Recommend the words "Controlling Documents be replaced by "Required Documentation".
In row of Product Certification Labeling:
Suggest add "and" between Product Certification - Labeling.
Under Manuf. Partner include "test" between manufacture and "product".
Add Certifies under "Certification Body"
Annex A
3.1
Is the term 'average flush volume' the same as that defined in the ASME standard? If so, could
it say 'as defined and tested in accordance with ASME A112.19.2?
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WaterSense Certification Scheme
5.1
Is this statement intended to imply that the toilets must meet all the requirements of the two
ASME standards or just the flush volume adjustability? If it is the latter, suggest the words "the
flush volume adjustability requirements" be added before the words "ASME A112.19.2
5.2.1 Suggest add the words "Toilet tank trim" in front of Must conform.
5.2.2
Not sure of the intent of the first sentence. If it is a pilot valve type does it not have to meet the
protocol in Appendix B? If not, then should "pilot valve type" be defined?
Why would this requirement not be performance related as opposed to design based?
5.2.3.2
Why is the requirement for the full flush mode of a dual flush toilet not 1.68 gpf as it is for single
flush fixtures? Would this not better reflect water conservation goals?
For after market closure seals how many are to be tested and which types?
7.0
Suggest add "Any changes to the specification shall be sent to all partners with an effective date
for compliance."
8.0
Must all electrohydraulic toilets use a motor, pump, and controller? Is this not design restrictive?
Is the Rated flush volume different to the previously used term "effective flush volume"?
Suggest the terminology be kept as consistent as possible throughout this specification and the
ASME standards.
Appendix A
2.2.6 Why is this re-adjusted? If this is the level it normally returns to, that is how the fixture
should be tested. If the water level returns to a level above that to which it was set, this should
be a failure.
2.4.4
What is the definition of "bowl sump"? Does everyone have the same interpretation?
3.1
This soy bean paste nominal specification does not define the type of soy bean. Is it raw or
cooked? Is the bean with or without its skin?
Similarly, what type of rice is used - white, brown, wild? Is it raw or cooked?
Is the salt course or fine? Sea or regular?
Without such definitions the test could be very unrepeatable from test lab to test lab depending
on their interpretation.
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WaterSense Certification Scheme
3.3
Is the toilet paper of the plain or ripple design?
In general, suggest that where referenced the Section numbers in the ASME standards should
not be used since these can change with minor revisions to the standard, or updates.
Appendix B
Sections 2.1 and 3.1 have the exact same purpose. Should these two tests be under the same
heading?
2.3
If the water does not enter the overflow tube from the refill tube, then will this not affect the trap
reseal? Suggest delete this statement.
Appendix D
2.0
" —, or otherwise approved for that purpose by EPA". Suggest that as partners, manufacturers
need to know who these bodies are and their credentials. It must be a level playing field for all
participants.
As a general comment we would like to ask EPA if these certification schemes can eventually
supersede the present EPACt (FTC and DOE) reporting requirements of water usage rates that
manufacturers are required to submit every year, since we believe these reports should be
discontinued under the Paper Reduction Act as presently defined.
Kim, thank you for the opportunity to comment on these documents and we appreciate your
participation in the ASME/CSA harmonization efforts on water efficiency.
Sincerely,
Sally Remedios,
Ph: 3175871270
Fax: 3178480750
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WaterSense Certification Scheme
Commenter: Marsha Slaughter, P.E.
Affiliation: City of Oklahoma
Comment Date: July 27, 2007
No comments on the certification scheme. It looks thorough and appropriate.
Marsha Slaughter, PE
Director, Utilities Department
City of Oklahoma City
405.297.2822
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Comments on the Draft
WaterSense Certification Scheme
Commenter: Ed Osann
Affiliation: Steering Committee for Water Efficient Products
Comment Date: August 1, 2007
Re: Request for Re-Opening of Comment Period on WaterSense Certification for 60 Additional
Days
August 1,2007
Following the recent close of the comment period on WaterSense certification, members of the
Steering Committee for Water Efficient Products became aware of significantly divergent views
among stakeholders regarding the proposed certification framework. We believe these issues
are important enough to warrant a re-opening of the comment period for a period of sufficient
length - 60 days - to allow for additional stakeholder discussion aimed at resolution of key
issues and the submission of revised comments for EPA consideration.
Thank you for your attention to this request.
Edward R. Osann
Coordinator
Steering Committee for Water Efficient Products
301-535-4013
eosann@starpower.net
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WaterSense Certification Scheme
Commenter: Ed Osann
Affiliation: Steering Committee for Water Efficient Products
Comment Date: October 16, 2007
Steering Committee for Water Efficient Products
1001 Connecticut Ave., NW Suite 801
Washington, DC 20036
October 16, 2007
via electronic mail
These comments are submitted for the record in response to the Environmental Protection
Agency's extended comment period on the proposed WaterSense Certification Scheme.
The Steering Committee for Water Efficient Products is a working group drawn from over one
hundred organizations, companies, water utilities, and public agencies that support a national
voluntary water-efficient product labeling program. We support third-party testing for all
products and services carrying the WaterSense label, and look forward to the eventual adoption
of a wider certification framework. Certification, coupled with careful development of
performance specifications and test procedures for individual products, will be a key element in
the effort to build and maintain consumer confidence in the WaterSense label.
For the reasons indicated below, we recommend that EPA not adopt the proposed certification
scheme at this time.
The draft certification scheme envisioned in EPA's request for comments (the "final process," as
contrasted with the currently operating "interim process") envisions one or more certification
bodies stepping forward to become accredited to test and certify one or more WaterSense
product categories, including irrigation products.
Currently, the irrigation industry has little commercial experience with certification bodies -
organizations in the business of testing and certifying products and processes. No ornamental
irrigation products are currently subject to certification regarding their intended function,
durability, or materials. (Some products with electrical components receive safety certification
from UL, and backflow prevention products receive certification from IAPMO and/or USC
FCCC.)
Since no organization currently certifies irrigation product functionality, and since the
specification and test procedure against which WaterSense irrigation products must be certified
has not yet been proposed, let alone finalized, it appears virtually certain that there will be no
certification body prepared to seek accreditation to certify WaterSense irrigation products when
the specification for the first such product - weather- and sensor-based irrigation controllers - is
finalized in early to mid-2008.
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In order to avoid delay in bringing WaterSense-labeled irrigation products to market in 2008,
EPA should defer adoption of the final certification process and begin work immediately on an
interim certification scheme specifically for irrigation products. An interim process for irrigation
products should be designed to be functional before the end of 2008.
Key elements that should be considered for the interim process for irrigation products should
include-
a) provision for third-party testing;
b) manufacturers' declaration of conformity, based on publicly available test results;
c) market surveillance by EPA or its agent, testing random samples of labeled products on
the market;
d) sanctions for shipping non-conforming products and other misuse of the WaterSense
label.
We recommend that EPA be proactive in building a product testing and certification
infrastructure for WaterSense irrigation products. This should include consideration of -
a) issuing an RFP or RFQ for irrigation testing services;
b) contracting directly with organizations willing to conduct testing to the WaterSense
specification, as in the interim process for plumbing products;
c) providing monetary incentives or awards (alone or on a matching basis with utility
WaterSense partners) for an initial group of competent organizations willing to enter the
new field of irrigation product testing and certification.
There are simply too many unknowns regarding the possible configuration of the certification
environment for irrigation products for us to recommend that EPA now adopt the very specific
final certification process proposed in May. One result would be the application to the plumbing
industry of a certification scheme that the irrigation industry may ultimately find unworkable.
Full accreditation of certification bodies for all WaterSense products, together with third-
party certification, remain important objectives for the WaterSense Program, to build and
maintain consumer confidence over the long run. However, the implementation of the
final certification process should be deferred for the time being - perhaps two to three
years - at which time both plumbing and irrigation industries can transition to the same
final process together.
Thank you for your attention to these views as you prepare to act on this important proposal.
Edward R. Osann
Coordinator
Steering Committee for Water Efficient Products
301-535-4013
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