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Case Study: An Update on DOE, EPA and Energy Star for Foodservice Equipment

The Department of Energy’s new energy-efficiency standards for refrigeration will take effect next spring, while the Environmental Protection Agency continues to phase out certain refrigerants with higher global warming potential.

In response, Energy Star made updates to certain specs to keep up with these new standards. As a result of some of the overlapping changes, the EPA and DOE’s timing has sparked some challenges and even lawsuits. Let’s break it all down.

DOE’s New Energy-Efficiency Requirements for Refrigeration

“There is a lot happening in foodservice right now,” says David Zabrowski, general manager at Fisher-Nickel Inc. and the Food Service Technology Center in San Ramon, Calif. “The biggest changes are happening with refrigeration and ice machines, with new, more stringent standards from the DOE for reach-in refrigerators and freezers becoming active on March 27, 2017, and the same for ice makers in 2018.”

New regulations for walk-ins will take effect January 2020.

The DOE requirements entail a 30 percent to 50 percent energy-level reduction for reach-in refrigerators, a 5 percent reduction for ice makers, and a 20 to 40 percent reduction for walk-ins.

In light of these changes, Energy Star is trying to wrap up its Version 4.0 for reach-in refrigerators and freezers to remain in accordance with the DOE standards set to take effect, but they must work fast. At press time, the final spec — which will have the same March 17 effective date as the DOE requirements — had not been released but were expected to be out by the end of August.

Typically, Energy Star prefers at least a nine-month grace period to move out existing stock and to allow manufacturers to replace existing models with new ones and update marketing materials. With March just around the corner, though, that window keeps closing gradually. Even though the 2017 DOE regulations are being contested in court, Energy Star has had to operate as if the new regulations will take effect.

“We can’t have an Energy Star spec that is more relaxed than the federal standard, or it loses its credibility — that’s why this is an exception to that nine-month grace period,” says Adam Spitz, technical specialist at ICF International who supports EPA product development as it relates to Energy Star.

The other challenge Energy Star faces with these new requirements is the even higher level of stringency they must strive toward with the new refrigeration spec, according to Zabrowski. “With the DOE’s spec so stringent, there is not a lot of room for Energy Star, which needs to achieve a 5 percent to 25 percent efficiency gain over the DOE standards, depending on the size of the unit,” he says. “A lot of brands won’t be able to meet this new spec right away. Normally, Energy Star wants to see 25 percent of available models meet their new spec, but in this case, that likely won’t be the case. All of these factors make this a uniquely dynamic situation.”

EPA Refrigerant Phaseout

At the same time the DOE’s new standards for reach-ins take effect, the U.S. Environmental Protection Agency has been phasing out CFC-based refrigerants. The EPA’s Significant New Alternatives Policy (SNAP) program aims to phase out certain refrigerants with high global warming potential in exchange for more natural alternatives or blends with lower global warming potential. Some refrigerants are on a 2019 deadline for phaseout, while others have until 2020.

New Regulations for Ice Makers

Four years after the comment period began, the DOE’s new standards for ice makers will take effect in 2018, and Energy Star is working to update the ice maker spec in response. The new standards will affect batch ice machines (cubers) as well as continuous ice machines (flakers or nuggets).

Energy Star Specification Updates

Energy Star released a new spec for commercial coffee brewers and is considering changes to the hot food holding cabinet and griddle specs.

Coffee brewers: A brand-new category, the Energy Star specs for coffee brewers — specifically type 2 commercial batch brewers and not single-cup or espresso machines — took effect in July. There is no federal standard for coffee brewers, so Spitz’s team had to use baseline data from older technologies and compare it to newer models.

No coffee brewers are Energy Star certified, but that could change soon, according to Spitz. “This is one of those categories that’s kind of like TVs,” Spitz says. Individually an Energy Star brewer might not save a ton of energy, but with hundreds of thousands of these appliances nationwide, collectively they can lead to a significant improvement in energy savings.

Fryers: The most recent revision to the fryer specification was finalized in December 2015, which means the effective date will be this September, according to Spitz. Version 3 for fryers is a more stringent electric specification, from 80 percent to 83 percent efficiency and an idle rate drop from 1,000 watts per hour to 800 watts per hour.

Dishmachines: Energy Star will revise the dishmachine spec to take into consideration a new ASTM test method. Currently, an assumed level of energy use was loosely determined based only on idle rates and hot-water consumption, but the new method will be able to more accurately pinpoint total energy and water use. Energy Star will start with door-type machines in a phased approach that will tackle flight-type machines at an unspecified later date.

Griddles: According to Zabrowski, Energy Star has begun to look at griddles because that spec hasn’t changed since it launched in 2009, even if market penetration for Energy Star units is still low.

Holding cabinets: Changes in this category are being driven by the issue of humid versus dry cabinets, according to Zabrowski. “Humid cabinets can use more energy if used in wet mode,” he says. Energy Star has added a caveat that dry cabinets could use more energy when operated in wet mode, and in the meantime, Zabrowski’s team has been working on a protocol for humidity testing to determine more accurate energy-use levels.

Energy Star’s Standards for Steam Cookers and Verification Testing

The changes in the steam cooker category have less to do with the specification itself and more to do with verification testing. In response to much industry pressure, Energy Star has rolled out a pilot program that will allow voluntarily participating certification bodies to conduct verification testing as part of their component inspection. This would apply only if any components change on a given unit. As a result, manufacturers could bypass the need to send their units for full testing each year regardless of any changes to the models.

The steam cooker verification testing pilot program was modeled after the safety-certification process that does not require manufacturers to retest models year after year. Instead, they must keep a file and log any changes to components; a safety auditor will check the list and determine if full retesting is needed.

In addition to the standard requirements for certifying Energy Star products, certification bodies are required to generate an energy file report for every unique certification in order for the models to be included in the pilot program.

This report must document the full list of critical components outlined in the Energy File Report Requirements for Energy Star steam cookers and be kept on file in association with the product certification. Partners are required to report any component changes to the certifying body (CB) immediately. If any critical components change, the certifying body is required to identify the extent of the change and determine if the product needs to be retested to maintain certification.

As it is, certifying bodies are required to conduct random inspections of manufacturing facilities throughout the year similar to the process for verifying product safety. At a minimum, each relevant manufacturing facility would be inspected twice over the course of the pilot. Each visit would include an inspection of at least one currently certified model to determine compliance with components listed in the energy file. Should an inspection uncover changes not previously approved, CBs are required to document any actions, including additional product testing, if required. In the event that a model is retested due to component changes and fails to meet Energy Star requirements, CBs are required to report the failure to the EPA consistent with standard reporting procedures.

The pilot will run for a limited time, but if successful, will likely be rolled out to other categories. According to both Spitz and Zabrowski, initial response has been positive.