Commercial Refrigeration: Manufacturer`s Guide

Transcription

Commercial Refrigeration:
Manufacturer’s Guide to the Changing
U.S. Regulatory Landscape
www.intertek.com/appliances
Commercial Refrigeration: Manufacturer’s Guide
to the Changing U.S. Regulatory Landscape
Contents
Introduction ........................................................................................................................3
Scope of the Commercial Refrigeration Industry ................................................................3
New U.S. Efficiency, Refrigerant, and Testing Requirements Impacting the Commercial
Refrigeration Industry ........................................................................................................4
New DOE Efficiency Standards for Commericial Refrigeration Equipment:
Direct Final Rule 79 FR 17725 .....................................................................................4
New DOE Efficiency Standards for Walk-in Refrigeration: AWEF ................................5
New DOE Efficiency Standards for Commercial Ice Machines .....................................5
New EPA Standards for Refrigerants: SNAP ...............................................................6
Rule 20 .................................................................................................................6
Rule 19 .................................................................................................................6
New Approach to Testing: AEDM .................................................................................8
Changes to Testing and Certification Procedures ..............................................................8
Global Considerations .....................................................................................................10
Challenges for Manufacturers ..........................................................................................10
The Critical Role of Third-party Quality Assurance...........................................................13
About Intertek ..................................................................................................................13
Contact Us .......................................................................................................................13
APPENDIX ......................................................................................................................14
2
Introduction
The U.S. commercial refrigeration industry is a mature marketplace comprised of many longstanding competitors who have traditionally focused on drivers such as quality and reliability,
availability and delivery time, total cost of ownership, and meeting the more recent green and
sustainability objectives of their customer base. Based on a host of national, international,
and cultural forces, however, the industry is currently undergoing a regulatory transformation
that will have significant implications on the way commercial refrigeration manufacturers
design, test, and market their products.
Manufacturers of commercial refrigeration systems are facing a changing landscape, from
new energy standards imposed by the U.S. Department of Energy (DOE) and more
environmentally friendly refrigerant alternatives required by the Environmental Protection
Agency (EPA), to the introduction of alternate methods of calculating system efficiency and
simulating the performance of refrigeration units for testing purposes.
Manufacturing compliant products will require a detailed understanding of the new
regulations, the potential incorporation of new materials and/or product designs, and their
adherence to new testing procedures—or facing the risk of being restricted from selling
products that are determined to be non-compliant as of the effective dates of the new
standards.
This white paper provides an overview of the numerous regulatory changes affecting the
commercial refrigeration industry today, discusses the new rules and measures
manufacturers will need to comply with by specific dates in order to continue marketing and
selling their products in the U.S. It also offers insights into the benefits of partnering with an
accredited third-party testing organization to support the all-important testing, submission,
and compliance process.
Scope of the Commercial Refrigeration Industry
The roughly $10 billion U.S. commercial refrigeration industry is comprised of a diverse array
of products,including:
 Self-contained refrigeration products
 Remote products
 Reach-in and walk-in refrigerators and freezers
 Commercial ice machines
 Vending and custom products
3
o
Note: Any product meant to distribute a beverage through a nozzle (not
bottled), including frozen beverage machines or those that make slushy-type
products, are not specifically included in new regulations, but are expected to
be incorporated moving forward.
According to the DOE, commercial refrigeration equipment is a product used for food storage
and merchandising purposes in the food retail industry (e.g., grocery stores, supermarkets,
convenience stores, specialty food stores, etc.) and the food service industry (e.g.,
restaurants and cafeterias). Any or all of the above products may be impacted by the
following new regulations and rulings.
New U.S. Energy, Refrigerant, and Testing Requirements Impacting
the Commercial Refrigeration Industry
New DOE Energy Standards for Commercial Refrigeration Equipment:
Direct Final Rule 79 FR 17725
Since 2014, the DOE has been extremely active in setting new energy conservation
standards (ECS) in the commercial refrigeration arena, publishing over 100 notices on its
Energy Efficiency & Renewable Energy (EERE) website, issuing more than 25 testing
updates, and enforcing more than 15 final rules that dramatically reduce the energy
consumption of a variety of refrigeration products.
With the implementation of
new DOE Direct Final Rule 79
FR 17725, requirements for
Maximum Daily Energy
Consumption (MDEC) in some
refrigeration products must be
reduced by at least 30% and
up to 60%, depending on the
type of product involved.
Of greatest importance within the commercial refrigeration
segment is the DOE’s issuance of Direct Final Rule 79 FR 17725
on March 28, 2014, within the Federal Code of Regulations
which will require the Maximum Daily Energy Consumption
(MDEC) requirements in some refrigeration products to be
reduced by as much as 30–60% depending on the product
involved, effective March 27, 2017.
According to the DOE, this Rule “will save approximately 2.9
quads of energy and result in approximately $11.7 billion in
energy bill savings for products shipped from 2017–2046. The
standards will avoid about 142 million metric tons of carbon
dioxide emissions, equivalent to the annual greenhouse gas
emissions of 27 million automobiles.”
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Because the new MDEC requirements are more stringent than current ENERGY STAR®
thresholds, ENERGY STAR will also have to produce new conservation standards prior to
March 2017 or risk this program not being available for these products in 2017. This may
cause many currently listed products to be removed from its approved list, requiring impacted
manufacturers to potentially undertake research and development and product redesign
activities in order to be compliant with the new regulations.
New DOE Efficiency Standards for Walk-in Refrigeration: AWEF
Within the category of walk-in refrigerators and freezers, which are largely used in the
commercial sector, the DOE has responded to manufacturer concerns regarding the difficulty
of running test procedures for not only refrigeration systems but components (such as the
door and panels) as well by issuing new efficiency standards for walk-ins on June 3, 2014
(79 FR 32049), with an amendement on March 6, 2015. Walk-in
systems are now measured according to the formula, known as
the Average Walk-in Energy Factor (AWEF).
AWEF
Applicable to walk-in and evaporator products as well as a
variety of condensing solutions (dedicated, multiplexed, etc.), the
resultant efficiency number takes into account the system’s
cooling capacity delivery, power consumption, and insulation and
focuses on the installation and refrigeration elements of the
products.
This new standard is officially moving forward, with the DOE
conducting public meetings with the industry to finalize the
energy conservation standards and applicable dates through the
negotiated rulemaking process. Currently, most of the walk-in
standards appear as though they will not take effect until 2020.
Average Walk-in Energy
Factor (AWEF) is calculated
by dividing yearly average
refrigeration output (e.g., how
much cold the unit produces
over a 24-hour period) by the
energy input (e.g., the
amount of energy required to
produce it).
AWEF =
yearly average refrigeration output
energy input
New DOE Efficiency Standards for Commercial Ice Machines
The DOE’s January 2015 Rule (80 FR 4645) also proposes new maximum energy
requirements for commercial ice machines, condensers, and related water usage, with
implementation targeted for January 28, 2018. This efficiency regulation will establish a new
cap on energy consumption and implement energy consumption regulations on “continuoustype” ice makers (previous regulation only pertained to “batch-type”) that may be challenging
for some manufacturers and will require significant testing and evaluation over the next few
years to understand and verify compliance.
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New EPA Standards for Refrigerants: SNAP
As a follow-up to its Clean Air Act of 1990, which requires the EPA to “evaluate substitutes
for ozone-depleting substances to reduce overall risk to human health and the environment,”
the EPA created its Significant New Alternatives Policy (SNAP), through which it can
generate lists of acceptable and unacceptable substitutes for each of the major industrial use
sectors and promote a smooth transition to safer alternatives for the affected industries.
In the case of commercial refrigeration, the following two Final Rules, issued in April 2015
and July 2015 (implementation dates per application detailed in appendix), are designed to
minimize contributions to global warming and promote an
environmentally-responsible future:
EPA’s SNAP Program
According to epa.gov, the
Significant New Alternatives
Policy (SNAP) Program is the
EPA’s program to evaluate and
regulate substances for the
ozone-depleting chemicals that
are being phased out under the
stratospheric ozone protection
provisions of the Clean Air Act.
In Section 612(c) of the Clean
Air Act, the EPA is authorized
to identify and publish lists of
acceptable and unacceptable
substitutes for class I or class II
ozone-depleting substances.
The purpose of SNAP is to
allow a safe, smooth transition
away from such compounds by
identifying substitutes that offer
lower overall risks to human
health and the environment.
 Rule 20 – “Prohibition on the use of certain high-GWP
HFCs as alternatives”
According to SNAP regulations, “various hydrofluorocarbons
(HFCs) and HFC-containing blends that were previously listed as
acceptable alternatives under the SNAP program are now listed
as unacceptable for specific uses. This rule is part of the SNAP
program’s continuous review of alternatives to find those that
pose less overall risk to human health and the environment.
Specifically, this action changes the listing status for certain
HFCs in various end-uses in the aerosols, refrigeration and air
conditioning, and foam blowing sectors. This action also changes
the status from acceptable to unacceptable for certain
hydrochlorofluorocarbons (HCFCs) being phased out of
production under the Montreal Protocol on Substances that
Deplete the Ozone Layer and section 605(a) of the Clean Air
Act, where substitutes are available that pose overall lower risk
to human health and/or the environment.”

Rule 19 – “Climate-Friendly Refrigerant Alternatives”
According to SNAP regulations, the EPA is “providing additional
options for refrigerants in the United States that offer better
climate protection without harming the ozone layer. EPA is listing
certain climate-friendly hydrocarbons (ethane, isobutane, and
propane) and a hydrocarbon blend (R-441A) as acceptable in
6
stand-alone commercial and household refrigerators and freezers, very low
temperature refrigeration, non-mechanical heat transfer, vending machines, and room
air conditioning units.
EPA is also listing HFC-32 as acceptable in room air conditioning units. HFC-32 has
one-third the GWP of the conventional refrigerants currently being used in room air
conditioning units. Through this rulemaking, EPA is also
exempting ethane, isobutane, propane, and R-441A from the
§608 venting prohibition for the specific applications listed
above."
Refrigerant Testing
Alternative refrigerants can be
incompatible with existing
system components, and it is
vital to determine the purity of
refrigerants.
Refrigerant testing and
chemical analysis provide
valuable information to help
improve product performance.
Manufacturers should ensure
in-house or third-party testing
meets all analytical provisions
mandated in Clean Air Act
Section 608, tests to the
current ARI-700 standard, the
Industry Recycling Guideline
(IRG-2), and meets the
requirements of ISO/IEC Guide
25 - General Requirements for
the Competence of Calibration
and Testing, which exceeds
requirements in ISO 9002.
Overall, while most commercial refrigerant manufacturers in the
industry have historically relied on two popular refrigerant
materials—R-134a and R-404A—manufacturers will no longer
be able to produce units operating on those refrigerants
(implementation dates per application detailed in appendix)
based on their high global warming potential, and are
encouraged/required to pursue more natural refrigerants such as
CO2, ammonia, or flammable materials such as ethane, propane,
and isobutane.
R-134a will still be allowed in some systems, but disallowed for
“self-contained” systems.
This ruling will not only impact refrigeration manufacturers but
their suppliers as well, from whom they will need to source new
refrigerant materials as well as new components such as
compressors.
New refrigerants are expected to emerge including R-448A, R449A, and R-450A as replacements for R-134a and R-404A.
However, the actual acceptable use list will be somewhat fluid as
the regulations continue to evolve.
Examples of replacement refrigerants currently being discussed
throughout the industry are outlined below.
7
Refrigerant
Stand-Alone
Remote Condensing
Unit
Supermarket Rack
Current
404A
134a
404A
407A/F
404A
407A/F
<1,500 GWP
A1 Non-Flammable
450A, 513A
134a, 448A, 449A
450A, 513A
134a, 448A, 449A
450A, 513A
134a, 448A, 449A
<150 GWP
Mildly Flammable
HDR110
HDR110
<10 GWP
290
744
290
744
744
Note: above table merely provides examples of refrigerant replacements currently being discussed in the industry.
Intertek does not endorse any specific replacement as more or less acceptable or effective.
New Approach to Testing: AEDM
While product testing is a critical means of demonstrating a
product’s compliance with performance standards, the testing
process within the commercial refrigeration industry can be
costly and time consuming, and manufacturers have long
complained of the difficulty in building the necessary models on
which to conduct tests. In response to these voiced concerns,
the DOE will allow the use of an Alternative Energy
Determination Method (AEDM), a mathematical model that
simulates the energy comsumption performance of a product line
in a test setting, that will serve to more cost-effectively predict
the product’s performance in the marketplace and enable the
product to be deemed compliant or non-compliant. While this
new approach is expected to increase the speed and efficiency
of the cataloguing process for manufacturers, it may also place
new pressures on manufacturers to create value added AEDMs
and test an appropriate number of products so as to ensure the
validity of the model.
AEDM Tolerances
Test results from each model
must be compared to
simulated results from the
applicable AEDM. Tolerance
requirements:
 For energy consumption
metrics, the AEDM Result for
Model A must be greater than
or equal to the test result for
Model A * 0.95
 For energy-efficiency metrics,
the AEDM Result for Model A
must be less than or equal to
the test result for Model A*1.05
Changes to Testing and Certification Procedures
The following chart provides insights into the way product testing and certification procedures
will likely be impacted by the new efficiency rulings, refrigerant requirements, and
measurement standards in the commercial refrigeration industry:
8
How Testing Procedures Will Be Affected by New Efficiency and Refrigerant Standards
Key Changes in Testing or Required
Procedures
System
Type
New Standard or
Approach
Commercial
Refrigeration
Equipment
(CRE)
New DOE Energy
Conservation
Standards (ECS) for
commercial
refrigeration equipment:
Direct Final Rule
79 FR 17725
March 27, 2017
30–60% reduction in allowed energy
consumption.
Walk-In
Coolers and
Freezers
(WICF)
Average Walk-in
Energy Factor (AWEF)
(79 FR 32049)
June 5, 2017
New regulation will likely not take effect until
2020.
Automatic
Commercial
Ice Makers
(ACIM)
New DOE Efficiency
Standards for
Commercial Ice
Machines
(80 FR 4645)
January 28, 2018
ACIMs previously unregulated will now have
maximum prescribed energy limits.
Category not directly impacted by SNAP,
however, component manufacturers may shift
focus to SNAP-friendly models.
No limits set by DOE on potable water use,
but limits are prescribed by ENERGY STAR
should manufacturers seek certification.
MULTIPLE
Prohibition on the use
of certain high-GWP
HFCs as alternatives
(SNAP: Rule 20)
April 10, 2015
MULTIPLE
Climate-friendly
refrigerant alternatives
(SNAP: Rule 19)
July 20, 2015
MULTIPLE
Alternative Energy
Determination Method
(AEDM)
(78 FR 79579)
(79 FR 27387)
Current as of January
2015.
Effective for commercial HVAC, Water
Heaters, and Refrigeration Equipment January
30, 2014.
Effective for commercial WICF February 4,
2054.
MULTIPLE
ENERGY STAR
No ENERGY STAR
published notices about
these updates.
New 2017 DOE standards are more stringent
than current ENERGY STAR standards. Since
ENERGY STAR typically aims to capture the
part of the market operating at 15% or better
than federal requirements, we expect updates
around the time the DOE standards take
effect. Having the ENERGY STAR Mark will
help drive consumer decisions.
Effective Date
(including any new evaluation, sampling, and
testing equipment or processes)
9
Global Considerations
This white paper focuses primarily on regulatory changes for products being sold within the
U.S. However, there are a variety of additional global regulations impacting commercial
refrigeration products that manufactuers should consider if they plan to export to multiple
markets. Manufacturers should consider engaging with a third-party agency with expertise in
the similarities and differences between various global regulations, then create a plan for
quality assurance and compliance across all target markets. Having a comprehensive
compliance plan prior to product design and launch can create efficiencies in the testing and
certification processes required for market entry.
Challenges for Manufacturers
Manufacturers within the commercial refrigeration industry are currently experiencing a
convergence of paradigm shifts—from requirements to lower their products’ energy
consumption maximums to regulations enforcing the use of more environmentally-friendly
refrigerants, in tandem with numerous new testing procedures to certify compliance. All of
these changes will consume R&D and engineering talent, involve the dedication of additional
time and resources as well as potential investments in product redesign, and require
attention to new testing procedures in order to ensure product compliance by the specific
dates. Manufacturers may need to source new materials, pursue new safety certifications, reevaluate pressure limits, reassess their entire manufacturing process, and re-test units to
ensure they have capacity and can manufacture compliant product by the new deadlines.
Beyond all this, as manufacturers grow internationally, indepth knowledge of the regulatory requirements of those new
markets is critical. For manufacturers with their own test
facilities, this also requires the capability to test to new
requirements.
As part of a proactive response to these industry dynamics,
manufacturers are encouraged to plan for the changes by
understanding the new standards and procedures required by
each regulatory body, how they apply to their product lines,
and whether their products comply. As the direction and pace
of these federal energy efficiency and environmental changes
is expected to continue, manufacturers are encouraged to get
engaged and participate in industry working groups to help
ensure a smooth, accurate, and executable transition to the
new standards, as well as to proactively plan out the necessary
Manufacturers now need to
consider changing DOE and EPA
requirements, any international
requirements, and unique
requirements for different products.
10
redesign and certification activities they will need to undertake to ensure that testing labs will
have the capacity to test and certify their new products by the published deadlines.
What is the impact to manufacturer products and processes?
When products and processes are redesigned to accommodate these changes, there are a
variety of considerations and decisions to be made. Crucially, new product components may
require product safety listings to be revised or reissued to allow for the continuation of the
safety certification mark. The introduction of new refrigerants will necessitate changing
components, which will then require both performance and safety evaluation. Incorporating
flammable refrigerants into a manufacturing process requires review of facilities and
processes to consider hazardous location evaluation, detection methods and methodology,
upper and lower explosive limits, emergency stops, electrical power, area and exit lighting,
visual markings, air change, operational procedures, employee training plans, personal
protective equipment (PPE), shipping and handling, and hazardous materials certification.
The below graphic highlights some key considerations manufacturers may need to address.
Redesigned Products
Need to
Validate
Performance
Compared to
Regulations
Need to
Publish Data
to DOE
Website &
Manage
Program
Testing or
AEDM or both
Process to
Handle
Verification
Issues
Redesigned Processes
Redesigned
Products
Need Safety
Certification
Facility and
Processes
Need to be
Evaluated as
Hazardous
Locations
Operational
& Staff
Training
Changes
New
components
mean product
listings need to
be revised or
reissued
Flammable
refrigerant
products
require HazLoc
evaluation due
to the potential
of an explosive
atmosphere
(including S&H)
Detection
methods,
explosive limits,
emergency
stops, electrical
power, lighting,
exit lighting, air
change, PPE &
training plans
Use a Third Party
or Do It Yourself?
11
The Critical Role of Third-Party Quality Assurance
The dynamic U.S. market for commercial refrigeration is undergoing a multitude of changes
designed to enhance the energy efficiency and environmental friendliness of products as well
as streamline testing procedures. The ability for a manufacturer to certify that products
comply with all relevant energy, performance, and environmental standards will help to meet
sales targets, assure end users that products are qualified for specific applications, and
deliver manufacturers marketing and competitive advantages. Because specific standards
and submission procedures can be very tedious and precise to administer, but are critical to
a company’s growth and sales objectives, manufacturers may choose to partner with a
skilled third-party quality assurance organization with expertise in standards development,
testing, and compliance processes to ensure maximum success.
Accredited third-party quality assurance and testing organizations like Intertek can help take
the guesswork out of the successful achievement of compliance. A test lab’s possession of
and investment in the most precise and capital-intensive testing equipment ensures
consistent testing procedures and accurate results, while demonstrated expertise in the
unique details and requirements of all industry certification programs and initiatives assures
manufacturers of the utmost in quality coverage and representation. Along with established
relationships with all of the industry’s key regulatory organizations, a third-party testing lab’s
understanding of and experience with the broad range of products, standards, and testing
procedures in the rapidly-evolving commercial refrigeration industry can proactively support a
manufacturer’s compliance while delivering security and peace of mind to both
manufacturers and customers alike.
Intertek’s Unique Value to Manufacturers
Intertek can help you navigate these changes in many ways, including:
 Product Design for Safety, Performance, and Manufacturability
 Test Facility Building or Improvement Assistance
o Incorporating current and future planned changes to regulatory requirements
and for new environmentally friendly refrigerants
 Employee Training
 Testing Expertise and Capacity
 AEDM Development Assistance
 Contract Manufacturer Integration
 Program Management
Get on-demand expertise to accelerate product design and market launch, access global
markets, reduce costs, and mitigate risks. By combining worldwide testing facilities and
experts with an industry-leading breadth of consulting services, Intertek offers a unique
12
partnership approach to managing quality assurance. Our clients leverage our expertise in
quality assurance and regulatory compliance to allow their teams to focus on core
competencies and business growth.
About Intertek
Intertek is a leading quality solutions provider to industries worldwide. From auditing and
inspection, to testing, training, advisory, quality assurance and certification, Intertek adds
value for its customers by helping improve the quality and safety of their products, assets
and processes. With a network of more than 1,000 laboratories and offices and over 42,000
people in more than 100 countries, Intertek supports companies’ success in the global
marketplace, by helping customers to meet end users’ expectations for safety, sustainability,
performance, integrity and desirability in virtually any market worldwide. Visit
www.intertek.com.
Contact Us
If you would like to connect with an expert to answer your technical questions or obtain a
quote for a new testing project, contact Intertek at 1-800-967-5352 (1-800-WORLDLAB),
email [email protected], or visit our website at www.intertek.com/appliances.
This publication is copyrighted by Intertek and may not be reproduced or transmitted in any form in whole or in
part without the prior written permission of Intertek. While due care has been taken during the preparation of this
document, Intertek cannot be held responsible for the accuracy of the information herein or for any consequence
arising from it. Clients are encouraged to seek Intertek’s current advice before acting upon any of the content.
13
APPENDIX
Tables sourced from EPA’s Significant New Alternatives Policy (SNAP) Program Fact Sheet,
published July 2, 2015.
Table 1: SUMMARY OF SECTORS MODIFIED BY THE FINAL RULE
14
Table 2: FOAMS
15
Table 3: RETAIL FOOD REFRIGERATION
16
Table 4: VENDING MACHINES
17

Commercial Refrigeration: Manufacturer`s Guide

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