If you ever want to see how the wheels of our federal bureaucracy works, you simply need to read the Federal Register. This daily publication of thousands of pages encompasses proposed new laws, enacted new laws and rules issued by government agencies. In August, the Department of Energy (DOE), published a proposed rulemaking that would change the definition of a showerhead.
While this sounds simple enough, you have to remember this is the federal government. If the model plumbing codes wanted to change the definition of a showerhead, it would take up one page in a code change monograph. If the ASME standard wanted to change the definition of showerhead, it might extend to two pages for the proposal. The Federal Register only took 28 pages, reduced to 8-1/2 by 11, to propose a change to the definition of a showerhead. You can read the DOE proposal at: https://bit.ly/2FpucD5.
In reality, reading the Federal Register is somewhat fascinating. It provides the history and the problem associated with the definition of showerheads. Since the enactment of EPact 1992, showerheads have been regulated by the federal government, with a threshold of 2.5 gpm, following the testing in ASME A112.18.1. EPact 1992 became a part of the DOE Energy Policy and Conservation Act (EPCA).
The only exclusion to these requirements were safety showers, however, DOE never defined a safety shower. The federal law requires manufacturers to test all of their showerheads and report the results on an annual basis to DOE. You can go to the DOE website to find all of the available showerheads in the country and their corresponding flow rates.
I have to give credit to the DOE for active enforcement of the law. Many years ago, a catalog that my wife received advertised a showerhead that flowed 8 gpm. It basically claimed you didn't have to suffer with the new 2.5 gpm showerheads. Just for the heck of it, I turned in the catalog to DOE. Within no time at all, the ad disappeared from the catalog, never to show up again. DOE did state that they took care of it.
Defining a showerhead
With great enforcement of the showerhead requirements, manufacturers and engineers started to look for ways to avoid limiting a shower (not showerhead) to 2.5 gpm. The first response was multiple showerheads. Rather than showering with a single showerhead, why not two? That was followed with adding body sprays.
This created a dilemma for DOE as to what constitutes a showerhead. Is it one showerhead per fixture? Is a body spray a showerhead? Do multiple showerheads have to discharge a total of 2.5 gpm?
These questions were answered in a variety of ways. Everyone involved in water conservation considered the spirit and intent of the federal law was to mandate only using 2.5 gpm when taking a shower. If there were multiple showerheads, the total volume of all showerheads must meet the 2.5 gpm limitation.
While this was a nice, if not great, interpretation, this is not how the plumbing codes nor standards are written. There is no limitation on the number of showerheads for a single shower valve. There is no flow rate specified for body sprays, either in the plumbing codes or the plumbing fixture standards.
As a result, green codes started to identify the maximum water use for a given shower area. The intent was to limit each bather to one showerhead using 2.5 or 2.0 gpm. While the green codes accepted this concept, the model plumbing codes did not.
Taking a side
DOE’s proposed rule basically will be siding with the plumbing codes and standards. It will identify a showerhead as a single item. Hence, if you have two showerheads, both showerheads must discharge a maximum of 2.5 gpm. That translates to allowing a maximum of 5 gpm out of both showerheads when both are operating.
The additional change is to define body sprays as not being a showerhead. As a result, there would be no regulated flow rate for any body sprays. The two new definitions would read, as follows: Body spray means a shower device for spraying water onto a bather from other than the overhead position. A body spray is not a showerhead. Showerhead means any showerhead (including a handheld showerhead) other than a safety shower showerhead. DOE interprets the term “showerhead” to mean an accessory to a supply fitting for spraying water onto a bather, typically from an overhead position.
The final added definition is of safety shower showerhead, which is proposed to read: Safety shower showerhead means a device specifically designed and intended to deliver a flushing fluid in sufficient volume to cause that fluid to cascade over the entire body.
While not the greatest definition, at least a safety shower showerhead is understood to be an emergency shower fixture as we know it in the plumbing profession. The flow rate is regulated by the ISEA Z358.1 standard, which stipulates a minimum flow rate of 20 gpm for a minimum of 15 minutes.
The other change proposed by DOE is to update the reference of ASME A112.18.1 to the 2018 edition of the standard. There is also a reference to the 2012 edition since that standard may still be applicable to certain showerheads. The listing agencies always allow a grace period for complying with the updated standard. Although, the requirements between the 2012 and 2018 standard for showerhead flow rates are the same.
While these are proposed rules, I can only assume there will be a number of comments submitted by the Sept. 14 deadline. (Editor’s note: This column was submitted before the deadline date). DOE will have to review the public comments in preparation of a final rule. There is no time frame associated with the issuance of final rules. Furthermore, there is always the possibility that the proposed rule gets withdrawn.
One has to assume that the plumbing fixture manufacturers support the proposed rule. If finalized, the ambiguity we have been living with for 28 years will finally be clarified.
Note: The views expressed here are strictly those of the author and do not necessarily represent PM Engineer or BNP Media.