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from: / Ralph Hudnall
date: / October 5, 2011
subject: / EPA ENERGY STAR®Verification Directive dated August 3, 2011

On August 3, 2011, the Environmental Protection Agency (EPA) issued Directive number 2011-06, dated August 3, 2011, covering Product Selection for Verification Testing. As a result, AHAM Staff is issuing the following interpretation.

For the purpose of this interpretation, the following terms will be defined as indicated:

Model additions are models that have been introduced into commerce after the Model Submission Form has been sent to the Program Laboratory. These models shall be added to aunique, but secondarypage of the AHAM Directory continuously throughout the Program Year.

Model deletions are models for which production has been discontinued by the Licensee after the Model Submission Form has been sent to the Program Laboratory. These models will be added to the unique, but secondary page along with model additions throughout the Program Year. At the present time,the AHAM Directory will be modified with model additions and deletions at the beginning of the next Program Year.

Model selection is when the Program Laboratory reviews the Licensee’s Model Submission Form (and the ENERGY STAR Qualified Products List when applicable) and determines the number of verification tests required for the specific Licensee and identifies the specific models to be obtained for testing.

Obtaining units for testing is the process by which the Program Laboratory chooses the specific unit, or units, that are to be provided to the Program Laboratory for verification testing. This may either consist of a laboratory selector visiting a warehouse or selecting units from retail, contingent on availability. This is sometimes referred to by the Program Labs as “tagging the units.”

Unique model is a term used by EPA in Directive 2011-06. For purposes of determining unique models, both private labeled models and basic models are considered. Private labeled models and the associated OEM model count as one unique model, and any one of the models may be selected for verification testing. Basic models count as one model for purposes of determining unique models, and any one of the models may be selected for verification testing.

Basic model group, or basic model means all units of a given type of product, manufactured by one manufacturer, having the same primary energy source and which have essentially identical electrical, physical, functional (or hydraulic) characteristics that affect energy consumption, energy efficiency or water efficiency. This is identical to the term Model Group in the Procedural Guides. EPA sometimes refers to this as a “product family” and it will often be the same as a unique model.

Unique, but secondary page is the page of the AHAM Directory that is separate from the main Directory page and contains all model additions and deletions for the current Program Year. The Program Laboratory will compare this page and the main page of the AHAM Directory with the current years’ QPL to verify that any products added by Licensees to the QPL are referenced on the unique, but secondary, page of the Directory. If any models are noted on the QPL that are not included in the Directory or on the unique, but secondary page, the Program Laboratory will notify AHAM. AHAM shall verify with the Licensee that the new models should be added to the unique but secondary page of the Directory and communicate the answer to the Program Laboratory.

Per EPA Directive 2011-06, all unique models on the EPA’s Qualified Products List (QPL) are candidates for verification testing. To accommodate this requirement, the Program Laboratory will generate the AHAM Directory upon receipt of the Model Submission Forms from the Licensees. Upon completion of the Directory, the Program Laboratory will review the QPL to ensure no other models were added by Licensees. If there are additions, these will be placed on a unique, but secondary page associated with the AHAM Directory after confirmation from AHAM.

Model selections will be made promptly upon the Program Labs’ completion of the AHAM Directory. The number of models selected for verification testing is determined based on the number of basic model groups in the AHAM Directory (and on the QPL) on the date of selection. This will allow the Program Lab to establish a specific point in time with which it can select models for verification testing (i.e., identify the number of models that will be tested) in order to begin staging the testing required to meet all of the needs within the program year and to comply with our internal guidelines of testing within 6 months of selection, where appropriate.

Model Additions:

  1. All model additions will be added to a unique, but secondary page of the AHAM Directory during the program year.
  2. All models in the AHAM Directory, including the unique, but secondary page of the Directory, (and, presumably, the QPL) are eligible for verification testing.
  3. Model additions of new basic models could increase the number of models selected for verification testing if added before model selection is made.
  4. Model additions of new basic models made after model selection is made will not add to the number of models required to meet the Licensees’ obligations for verification.
  5. Model additions to a basic model already in the Directory will not increase the number of models selected for verification testing.
  6. Model additions will become part of the pool eligible for verification testing should a model selected for verification not be available when the Program Lab attempts to obtain units for verification testing (i.e., model additions may be used as substitutions for unavailable models).
  7. Because model additions will recently have undergone certification testing, AHAM adopts a preference to select model additions made to a basic model only after all other options for obtaining a unit within that basic model have been exhausted. In the case where it is necessary to go outside the basic model to obtain a replacement, AHAM adopts a preference to select model additions only after all other options for obtaining a unit have been exhausted. These preferences apply regardless of whether the model addition was made prior to or after model selection. If a model addition is a new basic model and is submitted prior to model selection, it will be a low priority for verification testing selection because it has, presumably, recently undergone certification testing.
  8. For example, if Model A-1, part of basic model group A, is selected for verification, but is not available when the Program Lab attempts to obtain it, the Program Lab will first try to obtain another model from basic model group A from the Model Submission Form. If no other models in basic model group A that are listed on the Model Submission Form are available, and the model addition is part of basic model group A, it will then be selected for verification from the unique, but secondary page of the AHAM Directory. Similarly, if no other model on the Model Submission Form is available for verification testing from any basic model group, and there were no model additions from basic model group A, a model addition from another basic model group may be selected for verification testing, as a substitution for A-1, to meet the Licensee’s obligations.
  9. In accordance with the Certification and Verification Program Procedural Guides, Licensees are required to supply data for all models that are subject to the appropriate Program before the first day of production of the specific model[1], or by the time of sale to the end consumer.

Model Deletions:

  1. All model deletions will be tracked during the current program year on the unique, but secondary, page and removed from the AHAM Directory in the next program year. All models in the AHAM Directory (and, presumably, the QPL) are eligible for verification testing. This includes model deletions.
  1. Model deletions made after the submission of the Model Submission Form to the program laboratory will not decrease the number of models selected for verification testing.

Example 1—New Models Added to a Basic Model Group After Program Lab Makes Model Selections:

Manufacturer ABC has 50 basic model groups in the AHAM Verification Program, all ENERGY STAR. The total number of models in one of the basic model groups is 20 (basic model ABC-1). All of the basic model groups and their derivatives are submitted on the Model Submission Form (and should appear on the QPL). This would result in five models being selected for verification testing (10% of 50 basic models). One month after the date the Program Laboratory completes model selection for Manufacturer ABC, Manufacturer ABC increases basic model group ABC-1 by adding five new models. These new models will be added to the unique, but secondary page of the AHAM Directory (and should appear on the QPL). There are now 25 models in basic model group ABC-1.

Because these models are added to an existing basic model group, there is no increase in the number of models required to be tested for verification. The 5 model additions would only be selected for verification if a model selected for testing during model selection is not available for testing, and no existing model replacement can be obtained, when the Program Lab attempts to obtain units for testing. In other words, all 25 models in basic model ABC-1 and on the AHAM Directory (and QPL), including the five model additions, would comprise the group of potential substitutions for an unavailable model. In the event the model selected for testing cannot be obtained, attempts to obtain one of the models from the Model Submission Form will be made before obtaining any of the five model additions for testing. The model additions will only be chosen as a last resort to complete the requirements for verification testing. All models on the Directory are eligible to be tested.

The dates in the tables are illustrative of the timing between events

August 1 / September 15 / October 15 / December 1
Model Submission Forms sent to Program Lab with 50 basic models / Program Lab makes model selections of 5 unique models for verification testing / Licensee places 5 new ENERGY STAR models in an existing basic model group into commerce, adds those models to the QPL, and notifies the Program Lab of the new models. This has no effect on the number of models selected for verification as the new models are part of an existing basic model. The five model additions will be added to the AHAM Directory on the unique, but secondary page. / Program Lab obtains 5 units for testing

Example 2—New Basic Models Added Before Program Lab Makes Model Selections:

Manufacturer ABC has 50 basic model groups in the AHAM Verification Program, all ENERGY STAR. All of the basic models and their derivatives are submitted on the Model Submission Form (and should appear on the QPL). Prior to the date the Program Laboratory makes model selections, Manufacturer ABC introduces 10 new basic model groups (basic models ABC-51 through ABC-60). These new basic models will be added to the unique, but secondary page of the AHAM Directory (and should appear on the QPL). This would result in six models being selected for verification testing. The six models are determined based on a rate of 10% of the number of models in the Directory (and on the QPL) on the date of model selection (50 original basic model groups + 10 new basic model groups = 60 basic model groups for selection). All models on the Directory are eligible to be tested.

The dates in the tables are illustrative of the timing between events.

August 1 / August 15 / October 15 / December 1
Model Submission Form sent to Program Lab—includes 50 basic models (all ENERGY STAR) / Licensee places 10 new basic models (ENERGY STAR) into commerce, adds those models to the QPL, and notifies the Program Lab of the new models. AHAM adds the model additions to the unique, but secondary page of the AHAM Directory. / Program Lab makes Model Selections—selects 6 models for verification from the Directory/QPL.
The model additions are included in the list from which the Program Lab selects, but are a low priority. / Program Lab obtains units for testing.

In the above scenario, the Licensee will have to provide six models for verification testing, as the model additions were new basic models and were made prior to the Program Lab making model selections. However, the Program Lab should make its selections from the original list of models, as the new model groups would have recently been certified, and AHAM has expressed a preference to test model additions only after other options have been exhausted.

Example 3—New Basic Models Added and Other Basic Models Deleted Before Program Lab Makes Model Selections:

Manufacturer ABC has 50 basic model groups in the AHAM Verification Program, all ENERGY STAR. All of the basic models and their derivatives are submitted on the Model Submission Form (and should appear on the QPL). Prior to the date the Program Laboratory makes model selections, Manufacturer ABC introduces 10 new basic models (basic models ABC-51 through ABC-60) and has model deletions of five basic models (basic models ABC-45-49). The model additions will be added to the unique, but secondary page of the AHAM Directory (and should appear on the QPL). The model deletions will appear on the unique, but secondary page of the AHAM Directory. Manufacturer ABC now has 60 (50 original basic model groups + 10 new basic model groups = 60 basic model groups for selection) basic models eligible for verification testing. The 5 basic model groups deleted are not removed from the directory until the beginning of the following program year.) Accordingly, six models will be selected for verification testing, including the model additions and deletions. The deletions are not ineligible for testing because they remain in the Directory and may still be available to consumers. All models in the Directory are eligible for verification testing. The model additions will be a low priority for testing—i.e., the preference will be for the Program Lab to select models from the Model Submission Form before selecting model additions. At the beginning of the following Program Year, these model additions and deletions will be reflected on the new AHAM Directory.

The dates in the tables are illustrative of the timing between events.

August 1 / August 15 / October 15 / December 1 / Next Program Year
Model Submission Form sent to Program Lab.
AHAM Directory completed shortly after this date. / Licensee places 10 new basic models into commerce, adds those models to the QPL, and notifies the Program Lab of the model additions. AHAM adds the model additions to the unique, but secondary page of the AHAM Directory.
Licensee discontinues five basic models from production and notifies the Program Lab.
The model deletions will appear on the unique, but secondary page of the AHAM directory. / Program Lab makes Model Selections—selects 6 models from a list that includes the model additions and deletions. The model additions are a low priority for selection. / Program Lab obtains models for testing. / Model additions are added and deletions are removed from the Directory.

There are several reasons for of this interpretation: As noted, the EPA has issued guidance requiring all models on the QPL be eligible for verification testing, and this interpretation will bring the AHAM Verification Programs into compliance. Continuously modifying the AHAM Directory, by use of the unique, but secondary page will keep the Directory more aligned with the EPA’s QPL. If a model group is not available through normal selection channels when the Program Lab attempts to obtain units for testing, keeping the AHAM Directory current will provide a wider selection base from which the Program Lab may make alternate selections. This will help to minimize the instances of a basic model being removed from the AHAM Directory and EPA QPL for a lack of available models. Lastly, our desire to become the “go-to” source for consumers attempting to verify the ratings of products is compromised if the AHAM Directory is not updated continuously through the use of the unique, but secondary page. Part of the effort to prove that our programs are robust (and thus having the DOE and EPA focus their verification efforts in other product categories) is that we build a reliable, user-friendly, accurate database of product ratings. Continuously updating the Directory in this manner is key in this effort.