EPA clarifies Energy Star SSL test procedure accreditation requirements

EPA has received a number of questions about the current and near-future Energy Star testing requirements for lumen maintenance of solid-state lighting (SSL) products. It has issued a letter (below) which provides guidance on lumen maintenance testing requirements for LED packages, arrays, and modules for Energy Star qualification of SSL luminaires and integral LED lamps.

Among the main points are:

• The existing Energy Star Solid-State Lighting Luminaires v1.1 specification (SSL v1.1), which references IES LM-80-08, remains in effect until the Energy Star Luminaires v1.0 specification replaces it in the summer of 2011.
  
• As of March 31, 2010 EPA is only accepting data collected in compliance with the LM-80 standard. Data collected prior to publication of the LM-80 standard, not performed in compliance with the standard, will not be accepted for Energy Star qualification of solid state lighting products.
  
• As of September 30, 2010 the current SSL V1.1 specification requires that LM-80 test data come from a NVLAP-accredited laboratory. However, no labs have yet achieved this accreditation for LM-80 testing. An interim accreditation scheme has therefore been introduced.
  
• Under the forthcoming Luminaires specification, lumen maintenance projections using data collected in accordance with LM-80 will be governed by the forthcoming IES technical memorandum TM-21-11.

Letter in full (original text):

Dear ENERGY STAR Solid-State Lighting or Integral LED Lamps Stakeholder,

This letter is intended to clarify issues surrounding LM-80 lumen maintenance testing of LED packages, arrays and modules for the current ENERGY STAR Solid-State Lighting Luminaires program, and the forthcoming ENERGY STAR Luminaires program. These clarifications are also applicable to Integral LED Lamp partners electing to leverage the early initial qualification option using LM-80 test data when the specification becomes effective August 31, 2010.

The existing ENERGY STAR Solid-State Lighting Luminaires V1.1 specification (SSL V1.1), which references IES LM-80-08, remains in effect until the ENERGY STAR Luminaires V1.0 specification replaces it in the summer of 2011.

As of March 31, 2010 EPA is only accepting data collected in compliance with the LM-80 standard., with sample sizes as specified in the ENERGY STAR Manufacturer's Guide for Qualifying Solid State Lighting Luminaires. Therefore data collected prior to publication of the LM-80 standard, not performed in compliance with the standard, will not be accepted for ENERGY STAR qualification of solid state lighting products. Questions about laboratory changes in equipment should be directed to the NVLAP program at the National Institute of Standards and Technology (NIST), which is the accreditation body for LM-80 testing recognized in the current lighting specifications; other accreditation bodies may be added in the future.

As of September 30, 2010 the current SSL V1.1 specification requires that LM-80 test data come from a NVLAP accredited laboratory. Applications for recognition by EPA as an accredited lab for purposes of LM-80 testing are available at www.energystar.gov/testingandverification. As of today, EPA understands from NVLAP that no labs have yet achieved this accreditation. Given that accreditation takes 3 to 6 months, EPA recognizes that as of September 30 access to accredited labs will be limited. On an interim basis, EPA will recognize labs that have otherwise achieved ISO/IEC 17025 accreditation through NVLAP, have demonstrated competence in conducting LM-80 testing, and can demonstrate that they are in the process of obtaining accreditation for LM-80 testing. Labs seeking this interim recognition should contact Taylor Jantz-Sell at D&R International (see below). Progress towards LM-80 accreditation for these laboratories will be closely monitored, and products qualified through labs which do not complete the accreditation process or demonstrate progress towards accreditation will be disqualified.

Regarding lumen maintenance projections, current protocols outlined in the SSL V1.1 specification and the aforementioned Manufacturers Guide remain in effect for SSL fixtures until the Luminaires specification becomes effective in the summer of 2011. Under the forthcoming Luminaires specification, lumen maintenance projections using data collected in accordance with LM-80 will be governed by the forthcoming IES technical memorandum TM-21-11.

The Agency would also like to address the testing requirements for improvements to LED packages, arrays, or modules. EPA's understanding of the intent behind IES test procedures is that LED packages should be considered new if material changes have been made which result in any sizeable change(s) in performance; these new components would not be considered “successors”. New LED packages must be tested according to LM-80.

For purposes of initial ENERGY STAR qualification or maintenance of qualification status of a currently qualified fixture using successor components, until the Luminaires specification is final and effective please refer to guidance on "Lumen Maintenance -- Successor LED packages/modules/arrays" on page 4 in the aforementioned ENERGY STAR Manufacturer's Guide. A proposal about the handling of successor LED packages/arrays/modules under the new Luminaires specification will be included in a subsequent draft to be distributed this summer. All information related to the Luminaire specification development process can be found at www.energystar.gov/luminaires.

Finally, EPA is currently working to clarify requirements pertaining to LM-80 sample sizes and acceptable variations of correlated color temperature within those samples; direction will be provided in a separate forthcoming communication to partners and stakeholders.

While the SSL V1.1 specification remains in effect, questions regarding the above topics should be directed to Taylor Jantz-Sell at D&R International at [email protected] or (301) 588-9387; related Integral LED Lamp questions should also be directed to Taylor. Questions regarding the above topics as they pertain to the forthcoming Luminaires specification should be directed to me at [email protected] or (202) 343-9272. Finally, questions regarding the enhanced testing and verification program EPA is implementing across all ENERGY STAR products should be directed to [email protected].

Sincerely,
Alex Baker
Lighting Program Manager, ENERGY STAR
US EPA