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By Jennifer Rice, Staff Writer of Fox Valley Labor News
People certainly don't want the government
in their showers, but that is
exactly what is happening with the Department
of Energy's recent announcement
that it is enforcing its 35-year-old
energy efficiency standards
this year.
Even though the
government hasn't enforced
the DOE's rules
and regulations for decades,
the Plumbing
Manufacturers Institute
(PMI) members
take them very seriously
and abide by them,
including the 2.5 gallon
per minute fl ow rate.

Executive Director
for PMI Barbara Higgens
said its members
have been very frustrated
with import
showerheads, which
exceed those fl ow rates.
She spoke last weekend
during a two-day Plumbing and
Mechanical Contractors Authority of
Northern Illinois (PAMCANI) convention
in Downers Grove
The DOE is interpreting a showerhead
as, "any plumbing fitting that is
designed to direct water onto a bather,
regardless of the shape, size, placement,
or number of sprays or openings
that it may have."
The impact of this is to curtail, if
not ban, the sale of the multi-headed
shower systems, Higgens
said, adding it
has a new and very
aggressive team to
enforce these regulations.
"Between January
and March of this year,
[DOE] has initiated 75
enforcement investigations
on plumbing
and other products.
It also failed to certify
116 product models
that didn't meet federal
water conservation
standards. So before
they even get to fl ow
rates, they are looking
at certification," Higgens
explained. Other
products include faucets, air conditioners,
heat pumps, lamps, lighting
fixtures, refrigerators, freezers, washing
machines and dryers.
To add more complication to this
problem, currently there is an attempt
to redefine a showerhead as a nozzle,
which was published in the Federal
Register. All nozzles would count as
a single showerhead and be deemed
noncompliant, if, taken together, they
exceed 2.5 gallons per minute. With
only 30 days to respond to the announcement,
PMI countered
that the actual definition
needs to be redefined
and the DOE's announcement
was illtimed
with the nations'
economy.
"This is not
a great time for
homebuilders or
manufacturing
and it's not a good
time to impose further
restrictions on
the sales of our products,"
Higgens said.
Redefining a showerhead
as a nozzle significantly impacts
the long-standing definition.
Also, the water savings is very nominal
and too small to be measured.
Higgens said the DOE did not conduct
any cost-benefit analysis, nor did it
consider any alternative or less costly
options.
"By changing the rule, the impact
to us is about $4 million in the first
year and then a repeated cost of $300
million annually," Higgens explained.
Cost is refl ected in lost sales, training
and packaging.
To counter the DOE, PMI formed a
coalition to address the DOE's definition
change. It also brought to
light that this definition
change is not likely to
include gang showers
and hand-held
showers typically
used by the elderly
and disabled.
Currently, DOE
is in the middle
of 90-day process
to decide if
it will revise, with
additional input,
adopt as submitted,
withdraw or start over
with formal rulemaking.
"Forming this coalition
and addressing these issues says
a lot about our trade associations and
its ability to pull people together,"
Higgens said.
This article originally appeared in the Fox Valley Labor News October 28, 2010
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