As part of Prime Advantage, Endorsed Suppliers have been invited to share their insights on the present and future of manufacturing success. In this post, Mark Keller from Intertek examines how changing environmental regulations are impacting processes for refrigeration manufacturers.
A changing regulatory environment and new standards from the U.S. Department of Energy (DOE) and Environmental Protection Agency (EPA) are further transforming the way commercial refrigeration manufacturers evaluate their products and processes. These standards will bring a greater emphasis to energy efficiency and environmentally-friendly refrigerant alternatives in commercial refrigeration products.
The DOE standards are bringing significant changes to commercial refrigeration equipment, both through Direct Final Rule 79 FR 17725, which requires certain refrigeration products to reduce their Maximum Daily Energy Consumption (MDEC) by 30–60%; as well new efficiency standards specifically for walk-in refrigeration and commercial ice machines.
The EPA’s Significant New Alternatives Policy (SNAP) will establish a list of acceptable substitutes for ozone depleting substances, with the goal of reducing the health and environmental risks associated with those substances.
These changes will mean increased pressure on manufacturers to take the proper steps to ensure that their products are compliant with the new standards by the established deadlines. To prepare for these changes, manufacturers are encouraged to educate themselves on the new requirements and how they apply to their products and processes.
As we covered in our first article, the first question for manufacturers regarding these new standards is whether they need to redesign their products to achieve compliance. If they do indeed need to redesign products to comply with either the DOE or EPA standards, or both, there are three main criteria that should be assessed:
Validation: The DOE standards require performance testing of redesigned products to ensure they meet the new energy efficiency requirements.
Verification: As part of the updates, manufacturers will need to develop a process to handle verification issues, including publishing data to the DOE website.
Certification: Any products redesigned as a result of the new standards will be required to undergo recertification, meaning product listings would need to be revised or reissued to continue to receive the safety certification mark.
When conducting performance testing on redesigned products, manufacturers should determine if testing will be performed through traditional performance testing, the Alternative Energy Determination Method (AEDM), or both. AEDM works to simulate, in a test setting, the energy consumption performance of a particular product. It should be noted that with the use of AEDM comes the requirement to test an appropriate number of products to ensure that the AEDM established is valid.
Changes to processes that come about as a result of the new standards will be primarily in the form of facility evaluation for hazardous locations, and operational and staff training changes.
The introduction of flammable refrigerants brings with it a variety of considerations that must be addressed in order to ensure a safe working environment. If commercial refrigeration manufacturers use flammable refrigerants in their products, their facilities and processes will need to be evaluated as hazardous locations. A facility being classified as a hazardous location brings with it operational and staff training changes, such as the establishment of explosive limits, emergency stops, employee training plans, and personal protective equipment (PPE) requirements, among others.
A change of refrigerant may also require working with suppliers to source new materials. This could entail evaluating the properties of new materials, pursuing new safety certifications, re-evaluating pressure limits, and conducting an overall assessment of the supplier’s manufacturing process to ensure they have the capability to produce to the new standards by the compliance dates.
In our next article we will discuss how changes to refrigerants can impact the maintenance of your installed products.
With compliance dates established within the next few years for these standards, it is important for manufacturers to begin planning now for products to be designed, manufactured, tested, complaint, and still competitive under these new regulations. Processes also need to be evaluated to ensure a consistent level of quality and safety.
A third-party quality assurance and testing organization like Intertek can help address any questions you have about new and upcoming standards, and put you on the road to compliance. An agency with strong industry expertise can help put you on the cutting edge of testing and quality assurance to make certain that compliant and competitive products are brought to global markets in the fastest and most efficient manner possible.
For further information on these new standards and Intertek’s services, visit our Commercial Refrigeration web page or download our white paper on Commercial Refrigeration: Manufacturer’s Guide to the Changing U.S. Regulatory Landscape