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FenStar Document Review

FenStar® Certification Program Document Review

FenStar staff requested feedback on proposed changes to FenStar Certification Program (FCP) documents from all stakeholders in February 2020.

We received three comments. However, those responses were not germane to the changes that were proposed. Each comment was fully responded to and is available for review below.

Note: Please use the form below or contact Dan Womer, FenStar Program Administrator, or Steve McDowell, Residential Program Manager, to submit general program questions or suggestions. 

To view the recorded FenStar Update Webinar from May 12, please click HERE.

FenStar webinar presentation is available here.

  • FS-1100:

Comment 1:  Section 4.4.3 Tests Graded as Unsuccessful

Products that are graded as unsuccessful tests per Section 4.3 are considered a failure per the EPA directives. This failure will then require licensee to submit an additional three units for hotbox testing at their expense. These additional units will be tested with same protocol above and graded. If all three units fail test tolerancing, EPA will be notified and disqualification may be required.

 

Staff Response: 

The concept brought forth in this change is that a failure should not be decided upon a single test. There are three reasons staff will not make this change:

  1. Scheme requirements. The purpose of verification testing is to ensure a consumer can reliably receive a product that meets the requirements of ENERGY STAR® for the product category. The EPA scheme does not automatically allow for additional testing to be used for a product that failed the verification test.
  2. Cost. Requiring testing of three additional units could be cost prohibitive for manufacturers. The cost of operating the FenStar program would also rise due to the increased oversight, possibly causing an increase in costs to all participants.
  3. Time. Testing three additional units would take too long to meet the EPA’s requirement of completing verification tests in the calendar year in which they were started.

Comment 2:  Section 4.4.1.i.a

Within five business days from the date of the licensee’s receipt of the notice from FenStar Operations Staff, the Licensee shall have the right to provide written notice to FenStar Operations Staff that the Licensee elects to inspect the intact unit. If the Licensee decides to inspect the intact unit,the Licensee shall not be entitled to appeal the unsuccessful test results to the FenStar Certification (this is penalizing the licensee and must be removed) Program, and all appeals by the Licensee shall be directed to EPA.

Staff response: 

The announcement of the public comment period stated that only those comments which pertained to the current changes would generate a response. However, since both sets of comments contained this same change, staff will address it.

 

Appeals to FenStar are procedural only. Appeals regarding pass/fail criteria, exemptions to those criteria, and determinations on why a unit may have failed already go to the EPA. Since the start of the FenStar program, staff has received no procedural appeals. There have also been no inspections of failed units. All appeals of failures have been to the EPA and have been handled through their processes. Therefore, staff believe there is no need to change this section at this time.


Comment 3: Staff response

The last comment requiring a response was one to increase the allowed response time for a manufacturer to acknowledge the verification testing selection notice. This comment was also not in response to the changes that are being made at this time. However, staff will take this comment under advisement and may suggest additional changes in the future. Internal procedures are written such that all manufacturers and labs are given multiple opportunities to respond to any notifications. As always, open and timely communication from all parties will contribute to meeting the deadlines required by the EPA.


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