Q&A with Energy Star

In researching its article "The Truth and Consequences about Energy Star," FE&S requested an interview with a representative from Energy Star and the Environmental Protection Agency. Unfortunately, the EPA could not arrange an interview but its media relations department did provide answers via email to the six questions submitted by FE&S. Below please find the EPA's responses to FE&S' questions about the Energy Star program.

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FE&S: What are Energy Star's goals for having a program for commercial kitchen equipment?

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EPA: The goals for the Energy Star commercial kitchen products are the same as the overall Energy Star program goals. EPA started Energy Star in 1992 to reduce greenhouse gas emissions through greater energy efficiency. The objectives of the program remain the same:

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Prevent air pollution, including emissions of greenhouse gases, caused by the inefficient use of energy.

Make it easy for businesses and consumers to identify and purchase products, homes and buildings with enhanced efficiency that offer savings on utility bills while maintaining, if not enhancing, performance, features and comfort.

FE&S: On January 1, 2011, some pretty big changes take effect with regard to certification and verification testing of Energy Star-rated products. How will these changes benefit the foodservice operators who purchase these products?

EPA: EPA is transitioning to third-party certification to strengthen the Energy Star program. Enhancing our testing and verification requirements in this way is an effort to preserve the operator confidence in the Energy Star label and to protect the significant value it offers program partners. EPA believes that the new requirements will mean that leadership companies' participation and the Energy Star label will become even more meaningful in the market. Maintaining the value of this brand requires ensuring products labeled with the Energy Star logo deliver on their promise to the foodservice operator.

FE&S: How will these changes enhance the value of the Energy Star program?

EPA: Having a third party certify the performance of Energy Star-qualified products will boost confidence in the Energy Star label and protect the significant value it offers program partners.

FE&S: The new verification testing seems to be pretty significant. Is there enough capacity among accredited testing parties to handle the anticipated volume?

EPA: EPA has recognized multiple certification bodies and laboratories for each commercial foodservice product category. In addition to independent labs, first-party manufacturer labs can participate in the qualification testing by either participating in an EPA-recognized Certification Body's (CB) witnessed or supervised manufacturers' testing laboratory (WMTL/SMTL) program or becoming an EPA-recognized laboratory by meeting the conditions and criteria set forth in the "Conditions and Criteria for Recognition of Laboratories for the Energy Star program" document. These requirements apply to new products starting January 1, 2011 and will be phased in as specifications change for currently qualified products.

In addition to qualification testing, CBs are responsible for annually selecting at least 10 percent of the products that they have certified for verification testing. At least half of these products will be selected randomly. As such, the number of an individual partner's products that are subject to verification testing in a given year will vary. CBs also have discretion to determine when products will be selected, so the testing may take place on a quarterly, biannual, or annual schedule depending on the CB and product category. Where off-the-line testing is the only feasible option, verification testing will be allowed in a first-party laboratory. EPA anticipates that off-the-line testing will only be an option for extremely large, expensive or custom-built products.

Links to the lists of EPA-recognized organizations supporting the enhanced testing and verification process can be found at www.energystar.gov/testingandverification.

FE&S: What's the philosophy behind the testing? Does it try to emulate real-world kitchen environments?

EPA: The test procedures used to qualify for the Energy Star program have not changed with the implementation of the enhanced testing and verification procedures. Product testing has two roles: to yield accurate energy consumption values for products whose manufacturers are hoping to earn the label, and to verify that labeled products are performing at the appropriate levels and delivering on Energy Star's promise to consumers.

When assessing the viability of a product category to be covered by Energy Star, and when developing specific performance-based specifications, EPA and Department of Energy (DOE) make every effort to choose energy performance metrics for which an industry accepted test procedure exists and is in use by manufacturers. At other times, existing industry test procedures may not be entirely appropriate for use by Energy Star, or may not exist at all. In this case, the agencies must take the lead, while working closely with manufacturers and other stakeholders, to develop an appropriate test procedure that yields accurate and precise (repeatable) energy consumption values for the units under test.

FE&S: What steps has Energy Star taken to gather feedback and incorporate suggestions from the foodservice equipment and supplies community?

EPA: Energy Star used an open stakeholder process to gather feedback on the enhanced testing and verification process. From March 26 – April 6, 2010, EPA held introductory conference calls with all stakeholders. In addition, with the release of the conditions and criteria for accreditation bodies, laboratories and certification bodies, EPA issued a draft document, solicited feedback, evaluated and incorporated feedback as appropriate and issued final conditions and criteria. For conditions and criteria for certification bodies, EPA issued two drafts before finalizing the conditions.

EPA met with commercial food service manufacturers as a group during the industry specific introductory calls, in a meeting with the North American Association of Food Equipment Manufacturers (NAFEM) members on May 14, 2010, and at the National Restaurant Show on May 24, 2010, to discuss the industry's feedback. In addition, EPA has had a number of calls and has corresponded with individual manufacturers to listen to and address their feedback.

EPA has included industry suggestions in the revised requirements. In particular, allowing first-party manufacturer test labs to participate in the program through a certified body supervised or witnessed manufacturers lab program was a suggestion made by the commercial food service industry that was incorporated into the final requirements.
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