EPA Engineer choses Marketing over Safety

Ron George

Please review the following attachement the last 4 pages show the temperature variations with non-compensaing shower valves. This information was presented to the committe along with my presentation which is also atached.
You should find this ample evidence which was presented to the group.

Ron George

EPA chooses marketing over safety for WaterSense Showers

I just attended a meeting of ASME/CSA and other industry professionals where we were discussing the specifications for EPA Watersense requirements for showerheads to receive the watersense label.
I gave a presentation on the increased risk of thermal shock and scalding when you replace existing showerheads with low-flow showerheads.
I pointed out that with older homes (built generally before the 1980s) the codes did not require anti-scald shower valves (Pressure-balancing ot thermostatic valves that adjust for sudden changes in pressure or temperature associated with water use during a shower). Most older homes (over 50%) still have the old two-handled non-compensating type shower valves. I pointed out there are many water utilities starting to hand out free low-flow shower heads and many others will soon follow when this watersense specification is complete. This practice will lead to an increase in thermal-shock injuries (Slip and falls) and scald injuries without "warning" users that they are at an increased risk of scalding if they do not use anti-scald / compensating shower valves that conform to ASSE 1016 or CSA B125.
When I urged them to include "warning literature" about the increased risks of thermal-shock and scalding for installations with non-compensating type shower controls either in the box or on the packaging the Engineer from the EPA said she is the only Engineer for the EPA Watersense program working in an office full of marketing people and that none of the marketing people would agree to a warning on Watersense products because they want people to buy the watersense products and people won't buy the watersense product if there is a warning that you could get injures with it.
WOW! My jaw hit the floor and some other peoples eyebrows were raised. I could not believe what I was hearing. There were some engineers from manufacturer's that agreed with her and said their companies put them in the same position of fsupporting sales. I wondered to myself if the EPA gets a royalty or fee for the Watersense label or was she just trying to preserve her job by not fighting for the safety warnings?
She said she did not want to put warnings on their packaging because they felt it would likely affect consumers choosing the watersense products. She is aware of the issue as I explained it and as she wrote about it in a recent trade publication, (see the link below) but when it came down to including a warning, they chose to promote water savings over safety. (they could have done both)
(http://www.plumbingengineer.com/feb_09/watersense_feature.php)
What this reminded me of was the Ford Pinto situation where all of the management ignored the engineers warnings about the rear bumper being located directly in front of the fuel tank. It seems like they want to ignore the issue in hopes it will go away.
This is a an unfortunate turn of events that will backfire not if but when someone is scalded or injured with a watersense labeled showerhead files a lawsuit.
Ron George
www.rongeorgedesign.com

jackchips_2

Ron,

"This is a an unfortunate turn of events that will backfire not if but when someone is scalded or injured with a watersense labeled showerhead files a lawsuit."

Then the lawyers will put the warning on.

Jack, CPD

Unknown

of course

She works for the goverment and she won't get sued.. Only the lawyers will win in this and many other cases.

cattledog

Ron--

In the referenced article to Watersense Showerheads, the authors acknowledged the potential interaction between pressure changes and flow rates, and thereby increased scald potential.

They also promised data.

"As a part of the development of criteria for high-efficiency showerheads, WaterSense and the task force are actively evaluating the link between flow rate and temperature deviations associated with pressure and temperature changes. The task force has gathered and presented data to compare the temperature profiles that result from a drop in hot and cold water pressure for both conventional and high-efficiency showerheads under two scenarios: 1) installation with various types of auto-compensating mixing valves (thermostatic, pressure balancing or combination) designed for a flow rate of 2.5 gpm and 2) installation without the protection of an auto-compensating mixing valve. The task force will fully evaluate the data before it recommends a maximum flow rate designation for high-efficiency showerheads."

Clearly scald potential exists, but what experimental data was presented as to actual temperature changes under the different scenarios? They committed to a safety analysis, and they said they were doing one. Where is the data?

Regards,
Richard

nugs

I find it hard to believe that you were surprised at the EPA's stance on the subject. After all the environment is a whole lot more important than the people that inhabit it.

Constantin

Takes me back to the school showers...

... we all learned to announce entries and exits from the communal shower area so everyone could step out of the shower stream and wait for everything to settle down as a faucet was closed or opened. Otherwise, you'd be in for a rude surprise, hot or cold.

I agree that consumers should be made aware that low-flow showers under the right circumstances could have an easier time scalding them.

On the other hand, it's quite rare to find a home with a domestic hot water supply at 140*F, no? That's the limit of domestic water heater thermostats, IIRC, and then there are the thermal line losses.

Perhaps the utilities should be encouraged to also supply thermostatic valves to mix down water temps at the hot water tank to safe levels? That would be less expensive than opening walls to replace shower faucets and it would protect building occupants outside of showers also.

Lastly, where does the 50% number come from re: un-renovated bathrooms? I ask since one of our rulemakings deals with kitchen appliances and electrical outlets. If you have a data source re: the frequency of home repairs/renovations, I'd love to get that reference.

Ron George

Water Heater Temperature Controls

Please refer to slides 39 - 41 of the presentation I attached above which begins with 048...

You information about water heates only being able to deliver 120 degree water is wrong. Every one will deliver whatever temperature the thermostat is set to. The factories are shipping them with the thermostat pre-set to 120 to 125 depending on the manufacturer to address scalding concerns, BUT a water heater set at 120 degrees will still deliver 155 degrees or higher temperatures. Please see the slides on stacking or thermal layering.

So please note: The Water heater thermostat cannot be used to control the outlet temperature of a water heater! That is why a thermostatic mixing valve is the best wat to deliver hot water to the hot water system at a constant temperature between 115 and 120 degrees F.

Thanks

Ron George, CIPE, CPD

Constantin

Hear Hear!

Ah yes, I remember stacking tests well when I was certifying a water heater, the outlet temperature can legally rise well above the T-stat setpoint, that is the nature of the beast. Does the US storage water heater industry currently embrace the relatively small cost adder of requiring a thermostatic valve as part of the installation process? I'm not sure they did back in the 90's when I worked on the WeatherPro.

With a wider adoption of TXVs at the source of the hot water, perhaps the bigger additional cost of replacing ancient shower valves can be avoided... our house literally had two garden gate valves for the shower that had been retrofit as city water and sewerage services made it into our neighborhood 100 years ago. So, a source-focus re: the prevention of scalding could perhaps move the debate away from the shower heads?

Consider the many other places one can get scalded if a tank has stacked into the 180*F range... Getting scalded at the sink is no more fun than getting scalded in the shower, though the former is usually not as likely to be as fatal. However, thermostatic valves can, and have failed, so multiple layers of safety are pretty important. No such thing as a failsave thermostatic valve, is there?

Ron George

Thank You,

You covered many issues in your response. I broke your response down and have the following comments or answers following the many points you raised.

Q: ... Does the US storage water heater industry currently embrace the relatively small cost adder of requiring a thermostatic valve as part of the installation process?

A: My experience has been the Water heater manufacturer's generally are aware of the issue but they make water heaters and generally do not care what happens beyond the outlet of the water heater. However, lately there have been a couple of manufacturer's that have been trying to address this by offering an option for a thermostatic mixing valve as part of their water heaters.

Q:...With a wider adoption of TXVs [Thermostatic Mixing Valves or TMVs] of the hot water [at the water heater], perhaps the bigger additional cost of replacing ancient shower valves can be avoided...

A: you cannot really avoid the cost of replacing the shower valve if you want to solve the thermal shock issue. You can use a thermostatic mixing valve to regulate the temperature of the hot water to a relatively constant temperature as required in ASSE 1016 or CSA B125 standard. (Plus or minus 3 degrees at low flows of 3 to 5 GPM and up to 7 degrees at flows exceeding 40 GPM). This should address the scalding issue.
THE REAL PROBLEM IS a master Thermostatic valve located at the water heater cannot prevent thermal shock caused by pressure imbalances in the plumbing system. (water usage elsewhere in the building while showering) Thermal shock can be at temperatures below scalding, yet the sudden change in temperature can lead to a reaction that can lead to a slip and fall incident and broken bones. You must replace the old two-handled or non-compensating shower valve if you want to eliminate the possibility of thermal shock.

Q:...our house literally had two garden gate valves for the shower that had been retrofit as city water and sewerage services made it into our neighborhood 100 years ago. So, a source-focus re: the prevention of scalding could perhaps move the debate away from the shower heads?

A: I'm afraid the master thermostatic mixing valves located at the water heater do not completely solve the problems caused by low flow shower heads. Low flow shower heads are always going to increase the risk of scalding and/or thermal shock when installed on a two-handled shower valve as you described or when they are installed on a non-pressure or temperature compensating single handle shower valve. It is a matter of hydraulics and Physics. As the flow is reduced at the shower head, the other nearby fixtures such as a; water closet, washing maching, sink, lavatory or any other fixture that can use cold water can cause a drop in CW pressure that can become the point of low pressure or relief so the cold water no-longer flow to the shower head. The HW crosses over in the two-handle faucet and the CW both flow to the nearby fixture that is flowing at a greater volume (because of the new flow restriction at the shower head). This allows hot water to cross over in the mixing chamber of a two-handled shower valve and flow to the point of low pressure (the nearby open CW faucet) If the hot water temperature is 120 or below it will be a sudden blast of very hot but maybe not scalding water. If the hot water is well above 120 say around 155 as it is in most uncirculated water heaters near the top then severe disfiguring scalding will occur withing a second or two.

Another issue with the low flow shower heads is that many of the existing ASSE compliant shower valve manufacturers cannot control the temperatures properly when the flows drop below 2 Gallons per minute. The design of the shower control valves is such that there is a tolerance that allows for movement of the mixing or temperature control shuttle in the valve. As the maufacturing tolerances are larger, the valves cannnot control temperatures at the required temperature tolerances in the ASSE standard at lower flow rates.
Also many valve flow o bypass one-half GPM or more during the cold water failure test. This allows the ASSE compliant valves to still have a full shower spray pattern when there is a significant CW pressure drop caused by nearby fixtures flowing. 100% hot water can flow out of the low flow shower heads in this situation.
Another issue is there are anti-sclad devices that are designed to screw onto the shower arm ahead of the shower head and it is designed to shut the flow of water down to a drip or one half GPM when the the temperature of the water exceeds 115 to 117 degrees F. When a 2.5 GPM shower head is cut back to 0.5 GPM the flow is a trickle so it is not spraying on the bather. Many low flow shower heads are designed to deliver a full shower stream with very low flows. When they are reduced to 0.5 GPM many of them still have a full spray pattern. This will cause scalding hot water to spray on the bather even when an anti-scald device meeting the standard shuts down the flow to a trickle (0.5 GPM). (ASSE 1062 standard for Temperature Actuated Flow Reduction TAFR devices) The standard requires the device to flow 0.5 GPM to allow the bather to re-adjust the shower controls to a cooler setting. The cool water resets the device allowing water to flow again. There are many other issues with low flow showers. These issues are:
1. Increased Scald Risk
2. Increased thermal Shock Risk
3. Spray force,
4. Additional time in the shower that no shower valve manufacturer includes in their simple calaculations for payback,
5. Increased risk of legionellae with fine misting shower heads allowing you to inhale the mist.
6. The temperature gradient in the shower is hot near the shower head and cold at your feet.
7 Noise with some low flow models that entrain air.
8. Effects on other safety controls with flows below control levels.
9.User satisfaction

Q:...Consider the many other places one can get scalded if a tank has stacked into the 180*F range... Getting scalded at the sink is no more fun than getting scalded in the shower, though the former is usually not as likely to be as fatal...

A: It has been decided by numerous committees discussing this issue that sinks and lavatories do not need the anti-scald or thermal shock protection, (I do not agree with that position) They say it is because the body is not submerged in the water as in a tub/shower situation. Many people bathe infants in sinks and lavatories. I feel they should have protection. I include temperature limits in my designs designs when I can control that issue. The committees generally agreed that sinks and Lavatories were not intended for baathing infants and if the water suddenly became hot in a lavatory or sink someone could simply remove their hands.
If you are standing in a shower, it is not as easy to get out of harms way when water is flowing over your body and there is soap in your hair and your eyes are closed. If there is a sudden change in a shower temperature situation, you could slip and fall and still be in harms way. You could also have difficulty seeing or finding the control valve to readjust the temperature when there is soap in your eyes. That is why there are more strict requirements for showers or combination tub/showers.


Q: ...However, thermostatic valves can, and have failed, so multiple layers of safety are pretty important. No such thing as a failsave thermostatic valve, is there?

A: There are high temperature alarms that monitor the hot water temperature leaving the master thermostic mixing valve. These alarms can be installed to sound an audible alarm, flash a warning light, send an e-mail notice or Building management system alet to the facility engineer or dial an phone number with a recorded message if the thermostic mixing valve outlet temperature rises above a safe temperature. This would address maintenance if the mixing valve fails. . But it still would not offer much help if the valve fails while you are showering.
There are devices that you can install on the shower arm, tub filler spout or faucet aerator that will shut down the flow to a trickle when the temperature execeeds a safe temperature. (ASSE 1062 devices)

Ron George, CIPE, CPD
www.rongeorgedesign.com

Steamhead (in transit)

Lav as a baby bath

Ron, it's true that in general lavs are not meant to wash babies in. But some are marketed for this purpose- here's one, from Kohler:

http://www.us.kohler.com/onlinecatalog/detail.jsp?from=thumb&frm=null&module=Lavatories&item=163202&prod_num=2170-8S&section=2&category=16&resultPage=0--335940567

I'd say that at the very least, lavs of this type should have anti-scald. If we can't find a lav faucet with this feature, a separate anti-scald unit could be installed in the supply.

What is the "safe temperature" at which one of the aereators you mention would shut the water off?

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Ron George

They ASSE 1062 devices are required to shut off within two second of reaching 120 degrees F. However the manufacturers generally have the devices set to shut-off at 115 to 117 degrees F. An aerator with this feature would not protect a child from hot water on a sink with a hand held spray.
You would need to install a valve conforming to ASSE 1070. It is a point-of-use thermostatic mixing valve that could mix the hot water temperature down to a safe temperature and limit the maximum temperature to 120 degrees F or below. (Whatever you feel comfortable setting it at)