2010-01-25 Comment concerning specific product testing

In this notice, DOE proposes to adopt new test procedures for determining the energy use of walk-in cooler and walk-in freezer equipment. Under the Act, the overall program consists essentially of the following parts: testing, labeling, and Federal energy conservation standards. Walk-In Freezer designs may vary dramatically resulting in various cooling performance and efficiency (energy consumption). Most walk-ins are made with prefabricated panels that have urethane insulation sandwiched between aluminum, stainless steel or other type of material, like high-density urethane or fiberglass. Lots of conditions can lead to loss in energy efficiency including Gasket Damage, Excessive Door Openings, Damaged Insulation, installation of non-standard Compressors, Fans, or Heat Exchangers. Damaged gaskets can cause significant losses in freezer's ability to expell heat and trap temperatures. These rules seem to adequately address concerns about setting standards for the design of walk ins and even more importantly, for testing them. Apparently DOE was unable to find a single, existing comprehensive test procedure for evaluating walk-in cooler and freezer envelopes.