The Department of Energy has proposed a rule clarification that, if implemented, would alter the way most in the industry have traditionally defined “showerhead” as it relates to water use and, as a result, potentially eliminate some multi-head shower installations. The Plumbing Manufacturers Institute (PMI) is lobbying against the proposal, and installers have expressed concern about the potential loss of business.
In the proposal, the DOE “reinterprets” the definition of a showerhead to include any size, placement, or number of sprays provided they all come from one inlet. Under this new interpretation, the DOE “will find a showerhead noncompliant with the EPCA’s maximum water use standard if the showerhead’s standard components, operating in their maximum design flow configuration, taken together use in excess of 2.5 gpm when flowing at 80 psi, even if each component individually does not exceed 2.5 gpm.”
In other words, multi-head shower systems, whether they are custom installed or part of one panel of sprays, would have to abide by flow restrictions currently applied to a single showerhead.
“Over the past months, DOE has received several complaints alleging that certain showerhead products exceed the federal water conservation standard,” says DOE spokesperson Christina Kielich. “In the course of investigating these complaints, DOE discovered some confusion as to how the Department’s definition of ‘showerhead’ for water conservation purposes applied to new showerhead designs being marketed under names such as waterfalls, shower towers, rainheads, and shower systems. ... We note that DOE’s draft interpretation is not a rule change, but a clarification of the definition in our current regulation. It makes clear DOE’s view of how the standard for showerheads should be applied to that definition.”
PMI says the proposal’s classification as an “interpretive” rule change does not provide proper weight to its potential ramifications. “PMI’s biggest concern is that the process to make this rule change is inappropriate,” says Lee Mercer, president of PMI and director of product compliance for Moen. “They really haven’t examined the potential implications and unintended consequences of changing this definition.”
PMI is pushing for the proposed change to be qualified as a “substantive” rule, which would provide more time for interested stakeholders and the public to comment on the potential impact, provide input, and collaborate on a solution.
Mercer and other manufacturers we spoke to say they recognize that saving water is important, as proven in the strides they have made through the EPA’s stringent, consensus-based WaterSense standards and the vast array of high-performance, low-flow fixtures now available. But they also feel that consumer needs and preferences also should be taken into account. “We support their goal … but [not] how they’re going about doing it,” says Gray Uhl, director of design at American Standard.
“We’re committed to water conservation,” Mercer agrees. “On the other side of that, we’re also committed to developing products to the consumer and believing in consumer choice.” Though multi-head systems conjure images of high-end homes and luxury installs, manufacturers say there are a number of other audiences, such as the disabled and the elderly, who rely on the height flexibility and/or therapy the systems provide.
Rob Zimmerman, senior staff engineer for water conservation initiatives at Kohler, also expressed concern that the rule change could amplify the already-existing problem of non-compliant products being sold illegally with few consequences.
“Once we have had a chance to review the comments, we intend to issue a final interpretive rule to clarify the definition of ‘showerhead’ as used in our rules,” Kielich says. “As we proceed, we will be mindful of manufacturers’ production decisions that may have been based on a misunderstanding of the definition of the term showerhead for purposes of DOE’s rules.”
Installers have already lashed out on the online board, lamenting the loss of business that could result from the elimination of custom shower systems.
The percentage of bathrooms equipped with multi-spray systems is hard to find, though some manufacturers estimate it to be as low as 2%. Still, a Remodeling magazine reader panel found that 50% of master bathroom remodels used only one showerhead, while 24.4% used two, and 23% used one showerhead plus at least three side sprays.
Katy Tomasulo is Deputy Editor for EcoHome.