DOE Showerhead Definition Looming
The United States Department of Energy reportedly expects to announce its ruling on the potential re-definition of the word "showerhead" by October, meaning those with more than one nozzle and/or emitting more than 2.5 gallons of water per minute at 80 pounds per square inch would be classified as shower valves.
DOE General Counsel Scott Blake Harris also told Congressional Quarterly Weekly that the change will make an exception for the elderly and disabled, and that the move is more a clarification than a rule change.
Since the current regulation took effect in 1994, the widely accepted standard has been that only the individual nozzles - not the entire shower system - must meet the 2.5 gallon/80 psi benchmark in order to be in compliance.
Industry groups say they are simply meeting the demands of homeowners who want the high-end shower systems, some of which emit up to 12 gallons per minute. They also say they should have been given more notice and more time to comment.
Barbara Higgens, the executive director of the Plumbing Manufacturers Institute, released a statement criticizing the DOE for its actions: "DOE's characterization of the proposed interpretive rule change as a ‘mere clarification' ignores the very real implications including an estimated $400 million negative impact on the plumbing industry in today's volatile economy," she wrote.
Harris disputed the industries claims in an interview with pme magazine.
"They have to provide the information to back that up," Harris said. "Based on numbers we've seen, these showerheads are in 1 to 4 percent of homes. I don't know how you do the math to get $400 million. If you don't have a 10-gallon-per-minute showerhead, you still need a showerhead. It's going to be less expensive. Maybe people don't spend $5,000 on the shower and they spend $1,000 or $200 or 49 bucks like me?"
"Civilization is about a balance of individual choice and social needs," Harris said in response to concern about consumer choice. "My kid would desperately love to drive 95 miles per hour on the Interstate. Society says he can't. There are people here in my office who would love to smoke cigarettes in the office. Society said you can't because of the impact on other people. This rule is a restraint on choice because of other people wasting water and wasting an enormous amount of energy. Because of that, Congress put this constraint on.
"Congress ruled on this issue almost 20 years ago," Harris said. "It says any showerhead can't be more than 2.5 gallons per minute. If you add two nozzles, that's two showerheads? Give me a break. That doesn't pass the giggle test. If your showerhead has four nozzles, then the showerhead should use 10 gallons per minute rather than the statute-mandated 2.5. I thought that was somewhat of a stretch.
"It's clear to me industry wrongly and mistakenly adopted this view to what the law meant. We issued an interpretation and will respond to substantive arguments people make. People are entitled to do that and those comments will have an impact on our thinking as is appropriate."
The full interview with Mr. Harris can be viewed on pme's website at http://www.pmengineer.com/Articles/Industry_News/2010/07/26/DOE-Likely-To-Modify-Showerhead-Definition
It should be noted that the 2009 Uniform Plumbing Code requires showerheads to comply with ASME A112.18.1 standard, which establishes a maximum flow rate of 2.5 gpm. The 2009 UPC does not specifically address the issue of maximum water consumption in a shower compartment. IAPMO's 2010 Green Plumbing and Mechanical Code Supplement states that a shower, regardless of the number of outlets, is only allowed to consume no more than 2.0 gpm of water. An additional 2.0 gpm of water is permitted for showers exceeding 1,800 sq. in. to accommodate shower compartments designed for use by two persons or the elderly and disabled. |
