Selling (and manufacturing) lighting has never been more complicated when it comes to staying on top of new, existing, and proposed government regulations. Here are some of the most recent updates.
Ceiling Fan Action
According to the American Lighting Association (ALA), the Department of Energy (DOE) is working on the next steps in the statutorily required Ceiling Fan and Ceiling Fan Light Kit Energy Efficiency regulatory action.
The ALA’s industry task force traveled to Washington, D.C. to respond to the DOE and participate in a public meeting regarding the proposed rule for ceiling fan light kits. Among the issues discussed were the proposed efficiency formula for the lumens per watt ratio and the DOE’s requirement of a power-limiting device for integrated LEDs.
Prior to the D.C. visit, the ALA task force responded to a supplemental proposed rule on ceiling fan test procedures. The ALA has requested clarification from the DOE on changes to the definition of a ceiling fan – which could cause problems for testing products within a certain time period – and other issues.
The dialogue with the DOE is ongoing, with the next round of documents to be exchanged providing insight as to the metrics used to measure ceiling fan efficiency as well as finalizing the test procedures for ceiling fans and their respective light kits. The ALA has joined forces with the ceiling fan, ceiling fan light kits, and the controls industries on monitoring proposed changes to these issues.
Safety Engineering Issues
Members of the American Lighting Association’s (ALA) Engineering Committee traveled to San Jose, Calif., to meet with Alex Baker, Director/Standards & Regulations at Lumileds; Michael Shulman, Principal Engineer of UL’s Lighting Division; Mike O’Boyle of Philips/Lightolier, who is Co-Chair of the Engineering Committee; and Don Berlin of Intermatic.
Shulman’s presentation outlined how Hazard-Based Safety Engineering (HBSE) standards are being used to move lighting safety standards away from a rigid prescriptive approach to more flexible and more technology-neutral requirements that allow fewer constraints on design options. No lighting standards have been completed yet, according to the ALA.
Other discussions centered on the temperature and performance characteristics of LED fixtures using integral LED bulbs vs. custom-designed light engines. The topic is timely due to newly approved standards to ENERGY STAR and California’s Title 24 – effective in 2017 –
that will permit high-efficacy LED integral screw-base bulbs to be qualified. There were also discussions about the use of low-voltage residential lighting fixtures and home systems using power-over-ethernet (POE) or USB connections for fixture wiring.
O’Boyle provided updates on the National Electric Code (NEC) proceedings, which will result in a 2017 revision. According to the ALA Engineering Committee, he also included updates about the current work of the UL and CSA standards committee working on photocontrols, wiring devices, and clock-operated switches. Canadian Standards Association (CSA) activity was reviewed regarding CSA TC-419 (Performance of Lighting Equipment) and C-234 (Integrated Committee on Lighting Products). It was noted that anyone selling products in Canada should be aware that a new portable luminaire safety standard (CSA C22.2, No 250.4) is now in effect. Furthermore, the Ontario Electrical Safety Authority (ESA) is requiring safety testing of certain incandescent “visible filament” bulbs.
New Title 20 Rules Impact Lighting in California
The California Energy Commission (CEC) now requires that certain lighting products be certified and registered via the online CEC Appliance Efficiency Database before those products are sold or offered for sale in California.
According to the American Lighting Association (ALA), new enforcement rules went into effect on July 1, 2015, giving the State the power to investigate and assess civil penalties of up to $2,500 per unit sold if a product is discovered to be non-compliant.
CEC places the onus of product certification and registration on manufacturers, but also recognizes the responsibilities of retailers, suppliers, and distributors as monetary fines can be levied on all levels of the supply chain.
The best way for businesses to protect themselves, according to the ALA, is to avoid the three areas identified for potential violation:
Failure to register appliances in the appliance efficiency database
Failure to meet or comply with the efficiency standards in regards to testing, marking, or certification
Knowingly submitting false appliance efficiency information
Upon discovery of a potential violation, the executive director (or his designee) shall send a written Notice of Violation by certified mail (registered mail to non-U.S. destinations) or other means that ensure the person in violation is notified.
- When assessing monetary penalties, the CEC will take into consideration the following:
- The nature and seriousness of the violation
- The number of violations
- The persistence of the violation
- The length of time over which the violation occurred
- The willfulness of the violation
- The violator’s assets, liabilities, and net worth
- The harm to consumers and to the state that resulted from the amount of energy wasted due to the violation.
The ALA told its membership that the best way to avoid potential violations and the resulting civil penalties is to ensure that all regulated lighting products are listed on the CEC Appliance Efficiency Database.
For a list of products, compliance information, and a library of helpful links, visit www.americanlightingassoc.com/Members/Resources/Government-Affairs/CEC-Title-20-Enforcement.aspx.