The EISA 2007 document required that performance based standards for walk-in coolers and freezers be published no later than January 1, 2012. The first step to completing the new walk-in cooler and freezer standards is to finalize the testing procedure. This has now been completed and published. The next step is to publish the standards, which determines the required performance results of the mandatory tests.
The final test procedures for testing walk-in coolers and freezers have been finalized and released. There are test procedures for panels, doors and refrigeration systems. The tests that have been adopted are designed to produce test results that reflect energy efficiency, energy use and estimated operating costs for industrial equipment.
DOE has finally made a ruling on definitions that were unclear in previous documents. The most important ruling that affects our dealers is who is now considered the manufacturer.
Manufacturer of a walk-in cooler or walk-in freezer means any person who:
- Manufactures a component of a walk-in cooler or walk-in freezer that affects energy consumption, including, but not limited to, refrigeration, doors, lights, windows, or walls;
- Manufactures or assembles the complete walk-in cooler or walk-in freezer (76 FR 12504).
This definition extends the compliance responsibility to both the component manufacturer and the assembler. In the final rule, DOE clarified that the component manufacturer would be the entity responsible for certifying compliance of the components they manufacture for walk-in applications. The manufacturer is responsible for the products they manufacture. If a manufacturer puts the entire system together, including the walk-in and refrigeration, the manufacturer is responsible for the equipment to meet federal standards.
Assemblers of the complete walk-in system, including the walk-in envelope and refrigeration, are required to use only components that are certified to meet the applicable federal standards. In situations where the entire system is not purchased from the manufacturer, the assembler is responsible for ensuring products meet federal regulations. For example, if a Foodservice Dealer purchases the walk-in envelope from the walk-in manufacturer and the refrigeration system from a Refrigeration Wholesaler, the Foodservice Dealer becomes the assembler. Therefore, the Foodservice Dealer is the manufacturer and is responsible for ensuring all the products installed for the walk-in system are compliant.
If you do not order the entire walk-in system from the manufacturer, you can be held responsible. When purchasing the different elements that make-up the walk-in system such as the walk-in envelope and the refrigeration unit, you will need to make sure each part is compliant. Once the standards are finalized, manufacturers will be required to test their products. Each product will have an efficiency code that meets the standards. You can be held liable if the products you assemble have not been tested or do not meet the criteria.
DOE notes that the definition of Walk-in Coolers and Freezers in the EISA 2007 document needed to be clarified and was unclear. The original 2007 EISA document defined walk-in coolers and freezers as the following:
WALK-IN COOLER; WALK-IN FREEZER.— (A) IN GENERAL.—The terms ‘walk-in cooler’ and ‘walk-in freezer’ mean an enclosed storage space refrigerated to temperatures, respectively, above, and at or below 32 degrees Fahrenheit that can be walked into, and has a total chilled storage area of less than 3,000 square feet. (B) EXCLUSION.—The terms ‘walk-in cooler’ and ‘walkin freezer’ do not include products designed and marketed exclusively for medical, scientific, or research purposes.
The final test procedure document clarifies the term “refrigerated” in terms of walk-in coolers and freezers as:
In particular, DOE is defining “refrigerated” for purposes of walk-ins to mean “held at a temperature at or below 55 degrees Fahrenheit using a refrigeration system.
The remainder of the definition remains the same.
Now that the testing procedures for walk-in coolers and freezers have been defined, the final step will be the standards that the testing must meet. Over the next several months the DOE will be working to come up with the required standards for these products. In 2012, manufacturers will be required to test their products and meet the requirements. If these standards are not met and enforcement is necessary, DOE will determine who is responsible for noncompliance on a case-by-case basis. DOE’s enforcement plan should be in the standards when they are released.