Test Procedure Development and Revision
Most energy conservation standards rulemakings are accompanied by a concurrent test procedure rulemaking. Test procedures detail the protocols that manufacturers must follow when testing their products for compliance with Department of Energy (DOE) standards. DOE also uses the test procedures to determine compliance with the applicable standards in any verification or enforcement testing. The procedures specify how to measure and calculate the energy efficiency and/or energy use of each appliance. Test procedures also specify how to calculate an estimate of an appliance's annual operating cost, which is used on the EnergyGuide label as required by the Federal Trade Commission.
Stakeholder input is critical for developing test procedures, which are required by law to measure energy efficiency, energy use, water use (as appropriate), or estimated annual operating cost during a representative average use cycle or period of use. Test procedures must also not be unduly burdensome to conduct. To facilitate public participation, test procedures rulemakings are typically integrated into the energy conservation standard rulemaking timeline as shown below.
Test procedures often include procedures developed by industry trade associations such as the American Society of Heating, Refrigerating and Air Conditioning Engineers (ASHRAE), the Air Conditioning, Heating and Refrigeration Institute (AHRI), and the Association of Home Appliance Manufacturers (AHAM), and by international standards development organizations such as the Canadian Standards Association (CSA) and the International Electrotechnical Commission (IEC). Referring to these pre-established test procedures may help minimize test procedure development time and reduce testing burden on manufacturers.
DOE is required by statute to review all test procedures at least once every seven years. A number of factors could cause the DOE to amend an existing test procedure, including changes in product technologies; requests for waivers from the test procedures; changes in how consumers use the product; stakeholder requests for clarification or guidance on the test procedure; and revisions to procedures developed by standards organizations.