In a previous column last year, I identified a change in definition, by the U.S. Department of Energy (DOE), regarding showerheads, body sprays and safety shower showerheads. In December 2020, during the Trump administration, DOE basically redefined “showerhead” as a single device that discharges water. Hence, if you installed two showerheads installed on a single shower valve, DOE would consider them two showerheads.
The impact the change in definition had was that it clarified that the maximum allowable flow rate of 2.5 gpm would apply to each showerhead, not each shower. If you had a shower with two showerheads, the maximum flow could be 5 gpm, with each showerhead discharging 2.5 gpm. Of course, this seemed counter to the philosophical approach of conserving water.
The one benefit of the Trump Administration’s definition is that showerhead manufacturers only had to concern themselves with the flow rate through the showerhead. They did not have to worry about how many showerheads were installed in a single shower. On the flip side, it allowed a manufacturer to sell a two- or three-shower head arrangement for a shower enclosure. Each showerhead could be interchanged with no regard to the total water use through the multiple showerheads
In addition to the revised definition of showerhead, the definitions of “body spray” and “safety shower showerhead” were added in December 2020. The definition of safety shower showerhead was identified as necessary to distinguish a showerhead that is not regulated for flow rate. A safety shower showerhead discharges significantly more water than 2.5 gpm in order to protect the user from an emergency incident.
The definition of body spray basically eliminated the product from being regulated for flow rate. If a body spray was connected to a shower valve, the flow rate through the body spray could far exceed 2.5 gpm. At one code hearing, a testifier indicated that a body spray should continue to be allowed to discharge 8 gpm to 10 gpm. Hence, that provides an idea of the flow rate some thought should be allowed to continue for body sprays.
The definition of showerhead, body spray and safety shower showerhead all relate to the adoption of the Energy Policy Act (EPAct) of 1992. The purpose of the 1992 law was to conserve water. Included in the law was the switch to 1.6 gpf closets and 1.0 gallons per flush urinals.
The Biden Administration re-examined the December 2020 definition of showerhead and found it to be in conflict with the intent of EPAct. Rather than conserving water, the definition of showerhead would allow for an increase in water usage. This would be the opposite of Congress’s original intent in adopting EPAct.
The change in the Dec. 14, 2021 rule by DOE reverses the definition of showerhead and removes the definition of body spray. The definition of safety shower showerhead remains unchanged. The new definition of showerhead reads, “Showerhead means a component or set of components distributed in commerce for attachment to a single supply fitting, for spraying water onto a bather, typically from an overhead position, excluding safety shower showerheads.”
This reverts the definition back to the concept that has been applied for years by environmental organizations. If you want multiple showerheads, the total amount of water through all of the showerheads cannot exceed 2.5 gpm. The showerhead definition relates to the individual or single shower valve.
By removing the definition of body spray, the flow rate through a body spray is classified as a showerhead, since the definition includes “components” that are used “for spraying water onto a bather.” Thus, by removing the definition of body spray, the flow rate through a body spray is now regulated as being 2.5 gpm. While the definition of showerhead includes “overhead position,” it also states, “typically.” Body sprays are not typical, and they do not spray water from overhead. Therefore, they clearly fit within the definition of showerhead.
While there are always attempts to circumvent the Federal water conservation requirements, the DOE rule explains why the definition of body spray is being removed. It explicitly states that the purpose is to conserve water by assuring that body sprays fall within the definition of showerhead, thus limiting the flow rate to 2.5 gpm.
Following the law
It should be noted that EPAct is a mandatory federal law, as opposed to WaterSense, which is a voluntary Federal program. A product is not allowed to be entered into commerce if it does not meet the EPAct water conservation provision. For example, it is illegal to sell a 3.5 gallon per flush water closet in the United States. The same is true for multiple showerhead arrangements unless the total flow rate from all of the showerheads does not exceed 2.5 gpm. This is also true for body sprays.
Engineers are often asked to design a shower enclosure to flow more than 2.5 gpm. In the past, engineers have specified two showerheads, thus increasing the flow rate to 5.0 gpm. Such a design would now clearly violate Federal law. The only alternative that an engineer has in the design of a shower enclosure is to install two or more shower valves. While this may sound weird, it actually is done for his and her showers in many high-end homes. If showering together, each shower valve discharges 2.5 gpm and each bather gets 2.5 gpm.
The other impact this will have on the engineering community is the design of diverter valves for showers. It is common to have an overhead showerhead and a handheld shower. A diverter valve is used to switch between the handheld shower and the overhead showerhead. However, many diverter valves allow a flow between one or the other or both. The “both” setting would become illegal under the new definition.
The change in the federal definition of showerhead is a major victory for environmental and water conservation advocates. It reinstalls water conservation as it was originally intended by Congress in 1992. It is also a victory for the engineering profession since our first obligation is to protect the public.
The views expressed here are strictly those of the author and do not necessarily represent PM Engineer or BNP Media.
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