HET - Here We Go Again
On Jan. 24, 2007, the EPA began its HET program. HET stands for high-efficiency toilets. I find it somewhat annoying that our own government doesn’t know that the fixtures are called water closets, not toilets.
You probably thought that 1.6-gallon-per-flush water closets were already highly efficient. You are correct. But for the EPA, 1.6 gpf is not good enough. It wants better.
Some have asked if we are working our way down to a zero-gallon-per-flush water closet. Perhaps, but at zero gpf it wouldn’t be using water, so the name water closet would be inappropriate. We would have to rename the fixture as an “outhouse.”
So how low does the EPA want us to go? Good question. On cruise ships, they use a half a gallon of water in a vacuum drainage system. Does the EPA want all drainage systems to be vacuum systems? If they are vacuum systems, the vacuum equipment uses electrical power. So which is more important to save, water or electricity?
Unlike the change to 1.6-gpf water closets, the establishment of the HET is supported by some water closet manufacturers. The manufacturers have jumped on the bandwagon as a way to promote their fixtures as being better than the competition.
The federal government has basically ignored the consensus process, even though this has been the backbone of the plumbing profession. All fixtures, pipe, fittings and equipment are regulated by national consensus standards. The plumbing codes reference these consensus standards.
The EPA’s justification for not using the consensus standard process is that the HET is a voluntary program. It is simply a way for the government to identify high-efficient water closets that the public should buy. They are not mandated.
We seem to have heard all this before from the Feds. You may have noticed that over the past 30 years, the federal government has chipped away at construction code requirements. Federal do-gooders hope to eventually regulate everything in construction. After all, don’t they know better than us? They are in Washington, D.C.
EPA Regulations: The EPA issued specifications that manufacturers must follow to have their water closets listed as HETs. The first requirement is that the water closet must flush 1.3 gallons or less per flush. However, the test requirements specify an average flush of 1.28 gallons or less. (A volume of 1.28 gallons equates to 4.8 liters.)
When replacement flappers are installed, the water closet cannot flush more than 1.68 gallons when the tank is adjusted to the maximum setting. This test assumes that the homeowner will foul up the flushing performance of the water closet.
In an effort to not offend the consensus process, the EPA first requires the water closets to conform to ANSI/ASME A112.19.2. This is the standard that regulates water closets and other vitreous china fixtures.
The additional testing that is specified by the EPA is the flushing of soybean paste, rice and water media formed into a sausage weighing 50 grams. This is EPA’s attempt to develop the artificial turd. The flushing test requires seven of these media to be flushed at one time.
It is interesting to note that the ASME committee that writes the water closet consensus standard has looked at artificial media for testing water closets over the past 27 years. They have continually rejected soy paste as a test media because, contrary to popular belief, it does not simulate the real stuff. So far, the only thing that simulates the real stuff is the real stuff.
The current test media that is used to test water closets is media that has consistent results. Additionally, it is media that is reusable. There is no guarantee that these soy paste rice sausages have reproducible results. This means that a water closet could pass one set of tests, and fail another set. The EPA has assured everyone that it believes the tests are reproducible.
If these tests were so good, the EPA should have followed the normal protocol of submitting such tests to the ASME A112 Committee for consideration of inclusion in the consensus standard. But, this is a case of the EPA and the Feds knowing better.
Heart Of The Matter: Apparently, the EPA is responding to green building and the LEED program. The only problem is that they have ignored a very important part of green building: water reuse. Rather than trying to lower the flushing rate by 0.3 gallons per flush, the EPA should be supporting the concept of flushing all 1.6-gallon water closets with gray water. They don’t have a listing program for gray water reuse water closets.
Why not promote a Water Saver Technologies system that utilizes a tank under the lavatory to capture gray water to flush the water closet in the same room?
How about the Brac system that captures all of the gray water in a home and uses the water to flush the water closets? Both of theses systems are very innovative and will save a heck of lot more water than 0.3 gallons per flush. These are just two of the newer systems utilizing gray water for flushing in a small setting.
There are more complex systems used in commercial buildings. Some of these systems use storm water, as well as gray water.
If the government really wanted the public and the plumbing industry to respond, it would be better off doing the usual Washington concept, cutting taxes. Imagine letting homeowners deduct $300 from their taxes if they install one of these gray water systems. Plus, they could let the consensus process regulate these systems.
I have always been one who has opposed the federal government being involved in a listing program. We have plenty of listing programs already in place in the plumbing industry. The Feds don’t belong there. It is bad enough the Feds are in our pockets, we don’t need them in our water closets.