6
Standards and Regulations for Product Noise Emissions

This chapter examines national, regional, and international standards setting, regulation, and compliance testing with regard to product noise emissions and their implications for U.S. manufacturers. The industrial sectors of interest include consumer products/home appliances; computers, printers, and other information technology (IT) products; portable power generation equipment; air compressor equipment; air-conditioning and ventilation equipment; yard care equipment; small engine manufacturers; and construction equipment. These are sectors for which there are significant variations in national and regional standards and regulation of noise emissions. Airplanes and road vehicles are not addressed in this chapter, since there are international bodies—the International Civil Aviation Organization for airplanes and Working Party 29 of the United Nations Economic Commission for Europe (UNECE) for road vehicles—that deal with the harmonization of noise emission requirements for these vehicles worldwide.

Over the past two decades Europe has been particularly active in the development of product noise emission standards (e.g., voluntary limits that have been agreed upon by a nongovernmental body), regulations (e.g., noise measurements that must be complied with and certified), and efforts to increase the amount of information provided to consumers with respect to product noise emissions, such as voluntary and mandatory product labeling requirements. During this time European standards organizations have exercised considerable leadership in international standards bodies, thereby making the International Organization for Standardization (ISO) and, to a lesser extent, the International Electrotechnical Commission (IEC) worldwide leaders in the product noise emissions standards community.

In contrast, since the early 1980s, the U.S. government’s interest in regulating product noise emissions based on evolving U.S. or international standards has advanced very little. Moreover, the participation and influence of U.S. standards organizations in the ISO and IEC in the area of product emission standards has been circumscribed by the structure and funding of U.S. standards bodies and the nature of ISO/IEC governance. America has only a single vote in ISO and IEC working groups and in the approval of standards—the same as every member country in the European Union.

European noise emission regulations are more stringent and more closely aligned with those of international standards bodies than their American counterparts, and European regulations based on these standards are more extensive than regulations in the United States. ISO standards committees have superseded many American-based standards committees and organizations that U.S. manufacturers have relied on in the past. To sell in global markets it has become increasingly important that U.S. manufacturers comply with European and ISO standards.

Different product noise emission regulations in foreign markets can drive up costs for a U.S. manufacturer seeking to sell in those markets by making compliance and certification more difficult. Adding to U.S. manufacturer’s challenges are costs not only for additional testing and documentation but also for the need to carry multiple “silencer” packages and parts inventories needed to meet the demands of multiple foreign regulations.1 If a market is too small to be worth the additional design and manufacturing costs, a company may decide not to compete there. The point is that the effect of national or regional differences in regulations can be to shut U.S. competitors out of markets.

At the same time it is important to recognize that, although more stringent noise requirements can sometimes be a burden for U.S. manufacturers, they can also encourage innovation. A U.S. manufacturer’s desire to design a low-noise machine for sale in European or world markets is a positive force that could lead to the introduction of “quiet” products into American markets and provide an incentive for manufacturers and purchasers to cooperate in “buy quiet” programs.

1

DeVries, L. 2007. Presentation at NAE workshop on Impact of Noise on Competitiveness of U.S. Products, Washington, D.C., June.



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6 Standards and Regulations for Product Noise Emissions This chapter examines national, regional, and interna- funding of U.S. standards bodies and the nature of ISO/IEC tional standards setting, regulation, and compliance testing governance. America has only a single vote in ISO and with regard to product noise emissions and their implications IEC working groups and in the approval of standards—the for U.S. manufacturers. The industrial sectors of interest same as every member country in the European Union. include consumer products/home appliances; computers, European noise emission regulations are more stringent printers, and other information technology (IT) products; and more closely aligned with those of international stan- portable power generation equipment; air compressor equip- dards bodies than their American counterparts, and European ment; air-conditioning and ventilation equipment; yard care regulations based on these standards are more extensive equipment; small engine manufacturers; and construction than regulations in the United States. ISO standards com- equipment. These are sectors for which there are significant mittees have superseded many American-based standards variations in national and regional standards and regulation committees and organizations that U.S. manufacturers have of noise emissions. Airplanes and road vehicles are not ad- relied on in the past. To sell in global markets it has become dressed in this chapter, since there are international bodies— increasingly important that U.S. manufacturers comply with the International Civil Aviation Organization for airplanes European and ISO standards. and Working Party 29 of the United Nations Economic Different product noise emission regulations in foreign Commission for Europe (UNECE) for road vehicles—that markets can drive up costs for a U.S. manufacturer seeking to deal with the harmonization of noise emission requirements sell in those markets by making compliance and certification for these vehicles worldwide. more difficult. Adding to U.S. manufacturer’s challenges are Over the past two decades Europe has been particularly costs not only for additional testing and documentation but active in the development of product noise emission stan- also for the need to carry multiple “silencer” packages and dards (e.g., voluntary limits that have been agreed upon by parts inventories needed to meet the demands of multiple foreign regulations.1 If a market is too small to be worth the a nongovernmental body), regulations (e.g., noise measure- ments that must be complied with and certified), and efforts additional design and manufacturing costs, a company may to increase the amount of information provided to consumers decide not to compete there. The point is that the effect of with respect to product noise emissions, such as voluntary national or regional differences in regulations can be to shut and mandatory product labeling requirements. During this U.S. competitors out of markets. t ime European standards organizations have exercised At the same time it is important to recognize that, al- considerable leadership in international standards bodies, though more stringent noise requirements can sometimes be thereby making the International Organization for Stan- a burden for U.S. manufacturers, they can also encourage dardization (ISO) and, to a lesser extent, the International innovation. A U.S. manufacturer’s desire to design a low- Electrotechnical Commission (IEC) worldwide leaders in the noise machine for sale in European or world markets is a product noise emissions standards community. positive force that could lead to the introduction of “quiet” In contrast, since the early 1980s, the U.S. government’s products into American markets and provide an incentive for interest in regulating product noise emissions based on evolv- manufacturers and purchasers to cooperate in “buy quiet” ing U.S. or international standards has advanced very little. programs. Moreover, the participation and influence of U.S. standards organizations in the ISO and IEC in the area of product emis- 1 DeVries, L. 2007. Presentation at NAE workshop on Impact of Noise on sion standards has been circumscribed by the structure and Competitiveness of U.S. Products, Washington, D.C., June. 8

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0 TECHNOLOGY FOR A QUIETER AMERICA The remainder of this chapter provides more detailed in- and CENELEC are the International Organization for Stan- formation about international noise emission requirements, dardization (ISO; http://www.iso.org) and the International standards for noise emissions, noise emission labeling, ac - Electrotechnical Commission (http://www.iec.ch), which set creditation and certification requirements, and the role of the product noise emission standards at the international level. Office of the U.S. Trade Representative in compliance and In this section standards-setting activities and associated enforcement issues.2 regulations are reviewed as they relate to noise emissions of machinery and equipment. IMMISSION VERSuS EMISSION Product Noise Emission Standards and Regulations To understand how noise standards and regulations af- in the united States fect the ability of manufacturers to compete in national and international markets, it is important to distinguish between American National Standards Institute noise emission and noise immission. Standards for noise emission—the sound emitted by a According to its website, “The American National Stan- product independent of its location—allow a manufacturer dards Institute (ANSI) is a private, non-profit organization to make a measurement of a specific piece of equipment that administers and coordinates the U.S. voluntary standard- under specified operating conditions and report the noise ization and conformity assessment system.” ANSI’s mission level, usually in the form of a “guaranteed level.” Usually, is “to enhance both the global competitiveness of U.S. busi- but not always, noise emission information is reported as the ness and the U.S. quality of life by promoting and facilitating A-weighted sound power level. Appendix A is a primer on voluntary consensus standards and conformity assessment quantities used in noise control and acoustics. systems, and safeguarding their integrity” (ANSI, 2009). Requirements related to noise immission—the sound ANSI represents the United States in the ISO and IEC. pressure level at a listener’s ear—have been promulgated to ANSI neither develops standards nor funds the U.S. address community noise worldwide. These requirements standards system. Rather it accredits and audits standards- have been summarized by the International Institute of Noise setting committees that are funded and administered by Control Engineering (I-INCE, 2009).3 engineering and scientific professional societies, industry associations, and other nongovernmental organizations. ANSI’s activities are supported by fees from these organiza- DETERMININg PRODuCT NOISE EMISSIONS tions (ASA, 2009b). A wide variety of policies, regulations, and standards When ANSI allows a standard to be called an “ANSI Stan- on noise emissions—local, national, regional, and inter- dard,” it is not making a technical judgment on the standard national—have been published, and most countries have but stating that the standard was developed in accordance national standards organizations. In the United States the with operating procedures that facilitate openness, balance, American National Standards Institute (ANSI) is the major and due process, and that the standard represents a consen- nongovernmental organization that deals with product noise sus among those substantially concerned with its scope and standards. In past decades the U.S. Environmental Protection provisions. Consensus is established when, in the judgment Agency (EPA) was responsible for regulating some product of the ANSI Board of Standards Review, substantial agree- noise emissions at the national level. For the purposes of this ment has been reached by directly and materially affected report, the most significant regional standards organizations interests. Substantial agreement means much more than a and regulatory body for product noise emissions outside the simple majority, but not necessarily unanimity. Consensus United States are in Europe. requires that all views and objections be considered and that a concerted effort be made toward their resolution. ANSI’s ap- There are three major European nongovernmental stan- proval represents approval of the process, not the content. dards organizations involved with product noise emission standards setting: the European Committee for Standardiza- The most important of these organizations are the four tion (CEN), the European Committee for Electrotechnical standards committees of the Acoustical Society of America Standardization (CENELEC), and Central European Ini- (ASA) on noise, acoustics, mechanical vibration and shock, tiative (CEI). The European Commission (EC) is respon- and bioacoustics. ANSI-accredited standards committees sible for regulating product noise emissions throughout the related to noise are listed in Appendix C, Part A. European Union (EU) using standards developed by CEN, Even though ANSI standards reflect a consensus and are CENELEC, and CEI. The international counterparts to CEN not mandatory, the procedures or criteria in those standards may be required by law, regulation, building code, or contract 2Vehicle noise emissions are not covered in this chapter. The World in specific situations. Thus, many federal regulations refer- Forum for Harmonization of Vehicle Regulations, a group in the UNECE, deals with vehicle standards (UNECE, 2009). ence ANSI standards. 3 Noise immission requirements in the workplace are discussed in Chap - ter 4.

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 STANDARDS AND REGULATIONS FOR PRODUCT NOISE EMISSIONS Adoption of International Standards sion and labeling standards of their own for the sources and products that EPA has already regulated (Shapiro, 1991). When a standard relates to international commerce (e.g., standards for product noise emissions), international stan - Product Noise Emission Standards and Regulations dards may be adopted. In these instances it is important that in the European union the American standard be identical (or nearly identical) to the international standard for a given product. If there is an European Standards Organizations ISO or IEC standard suitable for use in the United States and recommended by a U.S. technical advisory group (see There are several important differences between the or- Appendix C, p. 150), the ASA standards committees may ganizations and structures of standards-setting processes in adopt the standard as written (or with minor changes) as an Europe and the United States. In contrast to the decentralized American National Standard (ASA, 2009a). American stan- nature of standards bodies in the United States, European dards can also be used as the basis for international standards standards bodies at the national and regional (EU) levels are (i.e., early versions of the sound power standards). centralized in structure. European standards activities are organized by nation and region, whereas in the United States U.S. Regulation of Product Noise Emissions they are organized by sector. Standards-setting organizations are largely publicly funded in Europe, whereas they are most- U.S. regulation of product noise emissions is relatively ly privately funded in the United States. Finally, membership limited and outdated. Following enactment of the Noise in national and regional standards organizations in Europe Control Act (NCA) of 1972 (codifed in 49 U.S. 4901-4918), is restricted to European entities or those that have a busi- EPA’s newly established Office of Noise Abatement and ness interest or manufacturing presence in Europe (with the Control (ONAC) was given the authority to undertake a range exception of the European Telecommunications Standards of activities to reduce noise pollution. These included “iden- Institute, where participation is open to other nationals). tifying sources of noise for regulation, promulgating noise In the United States, membership in most full-consensus emission standards, coordinating federal noise research and standards-developing bodies is unrestricted, and in many noise abatement, working with industry and international, instances membership on U.S. technical committees can be state and local regulators to develop consensus standards, international in composition. disseminating information and educational materials, . . . Similar to ANSI standards, standards of European regional [and] sponsoring research concerning the effects of noise and and national standards bodies reflect a general consensus and the methods by which it can be abated.” With the passage of are not mandatory, and the procedures or criteria in European the Quiet Communities Act of 1978, ONAC’s mandate was standards may be required by European and/or national law, expanded to include provision of grants to state and local by regulation, by building code, or by contract in specific governments for noise abatement. During ONAC’s brief situations. Unlike in the United States, however, European existence, from 1972 to 1982, when it was defunded by Con- regulation of product noise emissions based on standards gress at the request of the Reagan administration, the office developed by regional and international standards bodies has promulgated only four product and six transportation noise been very active and expansive in recent decades. standards and was unable to implement product labeling or the Low-Noise Emission Product Program (Shapiro, 1991). European Regulation of Product Noise Emissions While Congress has repeatedly refused to restore funding to EPA for its noise abatement activities, the NCA and the The 1996 Green Paper (EC, 1996), which stated the authority it gives to EPA to regulate noise remain in effect. intent to extend the existing six directives on noise source Without resources to implement its mandate, however, EPA emissions to cover more than 60 types of equipment and to has been unable to promulgate any further product noise require the reporting of guaranteed noise emission levels of emission standards; and the four product noise standards it machinery and equipment, signaled a significant change in promulgated during the 1970s have not been subjected to EU noise policy (EC, 1996). One direct result of the Green critical evaluation since, despite advances in relevant science Paper was the publication in 2000 of the outdoor equipment and technology and improved understanding of the effects directive, 2000/14/EC (EC, 2000), and its amendment, of noise on people. Since 1982, EPA has also lacked the 2005/88/EC (EC, 2005). These directives set noise emis- resources to participate in private standards-setting efforts sion limits on a wide variety of equipment used outdoors, or to provide technical assistance to state and local govern- such as compaction machines, tracked vehicles, wheeled ments. (An exception is the efforts to improve the standard on vehicles, concrete breakers, cranes, welding and power gen- the performance of hearing protective devices described in erators, compressors, lawn mowers (Figure 6-1), and lawn Chapter 4.) By retaining its authority under the NCA without trimmers/lawn edge trimmers. Noise emission is expressed the funding to execute it, EPA has effectively preempted state as an A-weighted sound power level, and limits guarantee and local governments from adopting updated noise emis- the noise emission levels of these products.

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 TECHNOLOGY FOR A QUIETER AMERICA Sound Power Level (dBA) Cutting Width (cm) FIGURE 6-1 Permissible sound power levels (dB(A)) for lawn mowers, based on width of cut. Source: Directive 2000/14/EC of the Euro - pean Parliament (EU, 2000). The directives also set limits and require labeling of (EC, 2003). The EU has also issued a directive for noise from guaranteed sound power levels for a variety of other kinds of household appliances (86/594/EC) that allows member states equipment, such as building-site band saw machines, chain to label the level of noise emissions from household appli- saws, concrete and mortar mixers, conveyer belts, drill rigs, ances and establishes the A-weighted sound power level as and hedge trimmers. A more detailed list and further expla- a measure of noise emission (EC, 1986). nation of the directives have been published by TÜV-SUD America (TÜV, 2009a). The EC also maintains a database Noise Emission Limits in Other Countries of noise emission levels for equipment covered by the direc- tives (EC, 2006a). China has set noise emission limits (A-weighted sound Since the 1996 Green Paper, the EC has adopted a new pressure level) according to GB/T 7725-2004 and noise version of the machinery directive, 2006/42/EC, which sets limits for room air conditioners and heat pumps. In addition, standards for the safety of machinery (EC, 2006b). These noise limits have been set on household and similar electrical standards include noise emissions, and reporting of noise appliances according to GB 19606-2004. In India, immission emissions is required under certain circumstances: limits are spelled out in “Air Quality Standard in Respect of Noise.” Korea has also set noise emission limits (A-weighted • The A-weighted emission sound pressure level must sound pressure level) according to KS C9036. Japan, too, be reported at workstations when the value exceeds 70 has set noise emission limits (A-weighted sound pressure level) for package air conditioners according to JIS B8612.4 dB(A). • The peak C-weighted instantaneous sound pressure Canada has a standard (CSA-Z107.58-02) on declaration of value must be reported at workstations when the value noise from machinery, but it does not set noise limits. exceeds 63 Pa (130 dB re 20 µPa). Sweden’s noise standard (Statskontoret 26:6) spells out • The A-weighted sound power level emitted by ma- noise emission requirements in terms of guaranteed sound chinery must be reported wherever the A-weighted power levels for a wide variety of IT equipment, including emission sound pressure level at workstations exceeds equipment in data-processing areas, servers, printers and 80 dB(A). imagers, laptops, data projectors, and other desktop devices. The limits and test methods specified are suitable for inclu - Alternative test conditions are allowed under certain circum- sion in purchase specifications (Statskontoret, 2004). stances; this means that manufacturers must know at least the emission sound pressure level and peak instantaneous level of machinery and equipment. The EC physical agents (noise) directive sets noise immis- 4 Mézache, M. 2007. Presentation at the NAE Workshop on the Impact sion limits for workplaces and may indirectly influence the o f Noise on Competitiveness of U.S. Products. Washington, D.C., selection of low-noise machinery in manufacturing facilities June 20–21.

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 STANDARDS AND REGULATIONS FOR PRODUCT NOISE EMISSIONS INTERNATIONAL ORgANIZATION FOR ISO TC43/SC1 also maintains relationships with a num- STANDARDIZATION ber of other ISO and IEC TCs. These include TC72/SC8— Textiles (Working Group 2 on noise), TC 117—Industrial The ISO has an International Classification for Standards Fans (Working Group 2 on fan noise testing), and TC (ICS). Noise emission standards fall into the following 118—Compressors and Pneumatic Tools, Machines and category: Equipment/Air Compressors and Compressed Air Systems. ISO TC43/SC1 is just one of the ISO TCs that issue stan- 17. Metrology and measurement. Physical phenomena dards related to noise emissions. Many of the committees that 17.140 Acoustics and acoustic measurements cover work on standards for specific types of machines have 17.140.20 Noise emitted by machines working groups related to noise standards. One benefit of and equipment this arrangement is that the committees can specify realistic operating conditions in which noise measurements should A list of standards in ICS 17.140.20 can be found at http:// be taken and can anticipate special situations that should be www.iso.org/iso/iso_catalogue/catalogue_ics/catalogue_ accommodated. Nevertheless, the proliferation of commit- ics_browse.htm?ICS=7&ICS=40&ICS=0. tees greatly complicates the harmonization of measurement Many ISO technical committees are involved with setting standards for noise emissions. A partial list of ISO TCs with noise emission standards. One committee, ISO TC43/SC1 an interest in noise or sound can be found in Walters5 (2007) (noise), develops, among other standards, generic standards and in this report in Appendix C. for the measurement of noise emissions. In the United States, The EU and the European standards organizations have ASA manages the technical advisory group for this techni- made ISO a leader in the global standards community. Given cal committee. The ISO TC43/SC1 Secretariat in Denmark the one country/one vote governance of ISO activities and coordinates standards activities. European governments’ financial support for their national For the purposes of this report, the two most important nongovernmental standards committees in ISO activities, the series of standards are ISO 3740 and ISO 11200. The former member states of the EU exercise considerable influence on describes the methods of measuring noise emissions from ISO working groups. With only one vote, no public support, machinery in terms of sound power level, both A-weighted and only limited private-sector support for the participation and in frequency bands, such as octave bands. The latter of U.S. standards committees in ISO, U.S. manufacturers’ describes the measurement of emission sound pressure level. influence on ISO working groups is much less than that of Most standards written by other ISO technical committees to its collective European counterparts. determine sound power levels are similar to the 3740 series, As was pointed out in a presentation at the National Acad- and standards from this series (2000/14/EC and 2005/88 EC) emy of Engineering workshop in June 2007, most Western are used by the EU in its directives on noise emissions from countries that are members of ISO provide funding for a outdoor equipment. central standards office; national dues to ISO and IEC; fund- The ISO 11200 series describes methods of measuring ing for staff, including ISO or IEC committee secretariats and emission sound pressure levels (i.e., the level at the operator ISO working group secretariats; and funding or subsidies for or bystander’s position measured in a controlled acoustical travel for members of ISO working groups.6 In sharp contrast, environment). These measurements are important in deter- ANSI receives no federal funding and charges its accredited mining compliance with EU Directive 2006/42/EC, which standards-setting nongovernmental organizations fees to sup- sets emission sound pressure level requirements for machin- port a central standards office; national dues to ISO and IEC; ery and equipment and, under some conditions, A-weighted salaries for staff, including ISO or IEC committee secretariats sound power level according to the ISO 3740 series. and working group secretariats; and charges for IEC working Other standards related to noise emissions have been is- group members. This means that the United States depends on sued by the ISO technical committee (TC) 43/SC1. These nongovernmental organizations to raise funds to support U.S. include methods of declaring and verifying noise emission participation in international standards activities. values for machinery and equipment (ISO 4871) and sta- To influence ISO draft standards, individuals from inter- tistical methods of determining and verifying stated noise ested countries must be present at working group meetings emission values for machinery and equipment (ISO 7574, when decisions are made. Most product-specific noise stan- parts 1–4). In addition, there are standards for determining dards rely on “basic” or “fundamental” standards developed sound power through sound intensity (ISO 9614, parts 1–3), by ISO TC43 and TC43/SC1. U.S. companies do not fund noise emission in the IT industry (ISO 7779, ISO 9295), and noise from rotating machinery (ISO 1680). A complete list of standards under the jurisdiction of ISO TC43/SC1 (including 5Walters, J. 2007. Presentation at the NAE Workshop on Impact of Noise on Competitiveness of U.S. Products, Washington, D.C., June 20–21. some in ICS 13.140, Noise with respect to human beings, 6 S chomer, P. 2007. Impact of Noise on Competitiveness of U.S. and other classifications) can be found at http://www.iso. Products—the Role of Standards. Presentation at the NAE Workshop on org/iso/iso_catalogue/catalogue_tc/catalogue_tc_browse. Impact of Noise on Competitiveness of U.S. Products, Washington, D.C., htm?commid=48474. June 20–21.

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4 TECHNOLOGY FOR A QUIETER AMERICA fundamental or basic standards related to a by-product (i.e., mentation, and ongoing monitoring of production noise) the way they fund applied standards related to a prod- units. If the manufacturer has a certified quality assur- uct. Thus, the United States is at a significant disadvantage in ance system in place, only periodic audits by a notified terms of representation on ISO committees involved in basic body are required. or fundamental noise standards. A manufacturer incurs significant direct and indirect costs with each of these options. All notified bodies are based in INTERNATIONAL ELECTROTECHNICAL COMMISSION EU countries and are approved by the EC to carry out their The IEC develops and publishes international standards responsibilities; thus, U.S. manufacturers incur travel costs. for electrical, electronic, and related technologies. Like These costs can be avoided, but only if the manufacturer ISO’s standards, IEC standards are developed by TCs with takes on the cost of maintaining a quality assurance system, international representation. TC29, Electroacoustics, devel- as well as noise measurement systems to monitor noise-level ops standards for microphones, filters, sound-level meters, variances in production. h earing aids, and other electroacoustical devices. The standards produced by this committee are used in making u.S. ACCREDITATION measurements, and some modern instruments are described in Appendix E. The work of this committee is vital for the National Institute of Standards and Technology measurement of noise but will not be emphasized in this chapter. In addition, a number of other TCs have developed The National Institute of Standards and Technology noise standards for specific areas, such as consumer prod- (NIST) has four programs that can contribute to the devel- ucts. Examples of IEC TCs that develop standards related to opment of technology for a quieter America. The National noise are listed in Appendix C, Part E. In general, IEC TCs Voluntary Laboratory Accreditation Program plays an im- and ISO TCs with common interests have liaison programs portant role in the accreditation of laboratories for noise with varying degrees of effectiveness. emission measurements to meet national and international TC59 deals with standards for many products that use standards. a common descriptor for noise emission, the A-weighted The Global Standards and Information Group provides sound power level, which is not widely used in the United technical information to the federal government and indus- States. Nevertheless, if international efforts to develop a try. Although there are no known activities related to noise common noise label for consumer products proceed, it is emission accreditation, this group could become important likely that the sound power level descriptor will be used. when foreign countries seek U.S. accreditation. The National Center for Standards and Certification Information could play a role in informing American manufacturers about ACCREDITATION AND CERTIFICATION noise emission standards and requirements. The Calibration OF NOISE EMISSIONS Laboratory for Microphones is essential for accurate noise The EU Outdoor Equipment Directive (2000/14/EC) is emission measurements and noise measurements in general, the prime example of a noise emission regulation that re- and microphone calibration must be traceable to NIST. quires certification of product noise levels. This directive ap- plies to more than 50 types of equipment used outdoors, and National Voluntary Laboratory Accreditation Program manufacturers are responsible for initiating and completing the certification process. According to the directive, three op- The National Voluntary Laboratory Accreditation Pro- tions are available to a manufacturer that wants to document gram (NVLAP) accredits laboratories in the United States noise emission in compliance with the directive: and other countries for measurements according to an ac- cepted standard. The program is established under 15 CFR 1. Internal control of production with assessment. The 285. manufacturer takes full responsibility for initial cer- The Acoustical Testing Services, one of a wide variety tification, documentation, and ongoing monitoring of of available accreditation programs, includes laboratories production units. A “notified body” must be contracted that perform a variety of acoustical tests—mainly according to verify the manufacturer’s documentation and noise- to the American Society for Testing and Materials Inter- level conformance on a regular basis. national, ANSI, and ISO standards (NIST, 2009a). These 2. Unit verification. The manufacturer submits an appli- include evaluating hearing protective devices, the properties cation to a notified body, which is then contracted to of sound-absorptive materials, sound transmission loss, and examine the equipment and carry out the certification noise emissions from many sources. As of November 2008, and documentation process. 26 laboratories were accredited to perform measurements 3. Full quality assurance procedure. The manufacturer according to one or more acoustical standards, and, of these, takes full responsibility for initial certification, docu- 14 were accredited to perform tests according to one or more

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 STANDARDS AND REGULATIONS FOR PRODUCT NOISE EMISSIONS standards for noise emissions (NIST, 2009b). These include the United States and is the president’s principal advisor, independent testing laboratories, corporate laboratories, and negotiator, and spokesperson on issues related to trade. one government laboratory. In addition, one laboratory is The study committee investigated how USTR might help accredited in Canada and one in Japan. No list of standards U.S.-based companies compete more effectively in regions has been issued for which accreditation is available. Ac- with noise-related regulations. Within that framework, the creditation is available for any standard—presumably from committee asked two questions: Can the USTR ensure that a recognized national or international standards development the opinions of manufacturers have an impact on the writ- organization. ing of regulations/standards? Can the USTR help mediate The procedure for accreditation includes submission of disputes over the application of regulations and standards an application and payment of a fee to NVLAP, an on-site when U.S.-based manufacturers believe they are being used inspection by an independent technical expert, resolution to prevent them from competing in a market? of problems, and, if all problems are resolved, issuance of In answer to the first question, the committee found that a certificate. since 1974 the USTR has had private-sector advisory com- This program is not a certification of test data. It is de- mittees to provide expertise in their areas (USTR, 2009). signed to determine if a specific laboratory is qualified to However, because noise is a by-product (usually unwanted) perform measurements according to a specific standard or set of the equipment being regulated, and because the measure- of standards. Thus, it differs from the procedure followed by ment and reporting of noise is a complicated technical issue notified bodies that review data for the EU. Notified bodies that applies to multiple sectors, it is difficult to present a examine test data for a specific product, which is (or is not) uniform opinion that can be acted on in negotiations for certified. Evaluations by notified bodies are based on the trade agreements. following international standards: In fact, regulations and standards that apply to noise are developed and implemented separately from the general • ISO/IEC 17025, general requirements for the compe- trade negotiations conducted by USTR. Therefore, U.S. tence of calibration and testing laboratories manufacturers must be present and committed to participat- • I SO/IEC 17011, conformity assessment—general ing in trade organizations and standards-making bodies that requirements for accreditation bodies accrediting con- develop the regulations and standards for product noise levels formity assessment bodies (Schomer et al., 2008). In answer to the second question, which may involve mediating disputes, the USTR and NIST may be in a bet- Global Standards and Information Group ter position to become directly involved. NIST can provide The Global Standards and Information Group ( http:// technical support to document testing and certification and ts.nist.go/Standards/Global/ contact.cfm) is involved in can forward complaints/inquiries to USTR for notification. international conformity and assessment activities. Although In addition, if a manufacturer believes that a regulation is be- there is no known current activity related to noise emission, ing misapplied or is being used solely as a barrier to trade, the the mission of the GSIG is such that it could play a role in manufacturer can contact USTR for assistance and dispute determining if noise requirements in standards or regulations resolution. USTR also has many interagency connections are fulfilled. (e.g., in the U.S. Department of Commerce International Trade Administration) that can be called on for support. National Center for Standards Certification Information INTERNATIONAL ACCREDITATION The National Center for Standards Certification Infor- mation (NCSI) provides technical information related to Two international organizations accredit laboratories: standards activities. Although NCSI is not involved in any the International Laboratory Accreditation Cooperation activities related to noise emission, American manufacturers (ILAC, 2009) and the International Accreditation Forum would benefit from a database of information on national (http://www.iaf.nu). There are also regional accreditation and international standards and requirements related to noise organizations for the Asia-Pacific region (http://www.aplac. emission. org), the Inter-American region (http://www.iaac.org.mx), and Europe (http://www.european-accreditation.org/content/ home/home.htm). u.S. Trade Office The Office of the U.S. Trade Representative (USTR) is a Role of Notified Bodies cabinet-level agency with more than 200 professionals on its staff whose role is to facilitate and expand trade with foreign The EC has defined a notified body in the following terms: countries through trade agreements, trade policy, and trade “Notification is an act whereby a Member State informs dispute resolutions. The USTR reports to the president of the Commission and the other Member States that a body,

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6 TECHNOLOGY FOR A QUIETER AMERICA Voluntary Labeling in the united States which fulfils the relevant requirements, has been designated to carry out conformity assessment according to a directive” The Centers for Disease Control and Prevention has a (EC, 2009). The role of a notified body is to certify that the database of noise information for hand-powered tools that requirements of a particular directive have been met. If they have been tested by the National Institute for Occupational have been met, CE (Conformité Européenne) marking can Safety and Health (NIOSH). NIOSH is conducting ongoing be put on the product.7 research to “fill” the database. Of the European directives listed above (2000/14/EC, Sears has requirements on some but not all types of appli- 2006/42/EC, 2003/10/EC, 86/594/EC), only the 2000/14/EC ances; some labels include sound power values.8 Consumers outdoor equipment directive requires that sound testing be Union (CU) uses a five-level pictograph scale to rate product assessed by a notified body. If an equipment manufacturer noise for some types of products (e.g., vacuum cleaners). is ISO certified, it can perform sound power testing inde- Details of CU testing and methods of rating are not known to pendently; the notified body audits the testing and certifies manufacturers, nor are actual product emissions available. the results. Manufacturers that are not ISO certified have The Institute of Noise Control Engineering has a techni- two options. They can have a notified body perform the cal committee on product noise emissions and is working to required sound tests and write the reports and declaration develop a simple, easy-to-understand format for noise labels. of conformity. Or the manufacturer can perform the sound One proposal under consideration is a noise label similar to tests and have the notified body approve the resulting reports the EU energy label, which has simple graphic comparisons and declaration of conformity before selling the product in that enable consumers to make a quick judgment; they also Europe. provide simple numerical values for consumers who want Outdoor products covered by European Directive 2000/14/ more details. EC require a label of “Guaranteed Sound Power Level.” When the 2000/14/EC directive was published, TÜV SÜD Trade Associations and Industry-Specific Voluntary Labels America published an article, “The Father of All Noise Directives,” on the implication of this document for manu- To meet growing customer demand for standardized, facturers” (TÜV, 2009b). comparable product environmental information for IT and communications technology and consumer electronics, in LABELINg OF NOISE EMISSIONS 2006 IT Företagen and Ecma International harmonized their separate eco-declarations into ECMA-370 “The Eco Dec- The term noise label can be defined as information on laration—TED.” ECMA-370 does not include criteria, but product noise emissions provided to final customers. The the document enables reporting of environmental attributes, information may be on a label affixed to the product or on including product noise emissions. All claims in TED are the packaging, in a product brochure or user’s manual, or subject to verification. As of 2006, more than 6,000 eco- on a manufacturer’s website. Some noise-labeling programs declarations had been issued by the predecessor organiza- are mandatory, but most are voluntary. If uniform labeling tions. The declarations are available on company websites. appears on all products, it can be a benefit to consumers. If it The Home Ventilation Institute has administered a sound is not uniform, it can create confusion and be an unfair com- certification program for more than 35 years using a simple petitive advantage or disadvantage. This section describes noise value on packaging of ventilator fans. The Air Move- noise labeling in the United States, trade associations, and ment and Control Association and Air Conditioning and other organizations in the EU and other countries—including Refrigeration Institute have “certification programs” that “eco-labels,” which indicate “environmental friendliness.” include published noise emission levels. Mandatory Labeling in the united States Mandatory Labeling in Europe In the late 1970s, EPA established a noise-labeling Several European directives and their amendments require program for products (http://www.epa.go/history/topics/ that product noise emission values be included on product la- nca/0.htm). However, since funding for the EPA Office of bels or in product literature. The three primary directives are Noise Control was cut in 1981, no labels have been required 92/75/EEC—Energy Labeling for Household Appliances, for stationary noise-emitting products, with the exception of 2006/42/EC—Machinery Safety Directive, and 2000/14/ portable air compressors, which must have a label certifying EC—Outdoor Equipment. The provisions of the household compliance with the relevant EPA noise limit. Unlike other appliance noise directive are intended to provide consumers areas of the world, the United States has no other mandatory with information on noise in their homes, whereas the provi- requirements for reporting noise emission values of station- sions in the machinery noise directive are intended to provide ary products. information on machinery that may cause hearing damage in 7 For 8Vukorpa, V. 2007. Presentation at the NAE Workshop on Impact of Noise a list of notified bodies, see http://ec.europa.eu/enterprise/new approach/nando/index.cfm?fuseaction=country.main. on Competitiveness of U.S. Products, Washington, D.C., June 20–21.

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7 STANDARDS AND REGULATIONS FOR PRODUCT NOISE EMISSIONS the workplace. The outdoor equipment directive is intended MP3 players) without considering the differences in risk of primarily to reduce environmental noise and provide noise hearing loss due to different exposure times and preferred information to purchasers of outdoor equipment. listening levels. This unique GS requirement can act as a The EU Energy Label for household appliances is re- barrier to trade. quired to include sound power level values in addition to energy consumption information. Noise measurements are Voluntary Eco-Labels according to the IEC 60704 series for most appliances. The label must be prominently displayed on the product in stores Voluntary environmental labels, or “eco-labels,” signify and on packaging. Products with this label include refrigera- the “environmental acceptability” of a product. Eco-labels, tors, freezers, washing machines, dryers, dishwashers, and which are popular in many countries, include noise emission air conditioners. information. Although labeling or reporting product noise to The Machinery Safety Directive requires the publica- customers is not required, meeting the acoustical criteria and tion, in user documentation, of the A-weighted sound displaying the eco-label symbol on products and in advertis - pressure level at the workstation, if the level is greater than ing implies acoustical acceptability (and possibly superior- 70 dB(A), and the A-weighted sound power level if the level ity) of the product. Some eco-label programs are the German at the workstation is greater than 85 dB(A). The machinery Blue Angel (since 1977), the Nordic White Swan (since safety directive does not apply to products covered by the 1989), the Dutch Milieukeur, the Swedish TCO, and the EU low-voltage directive (2006/95/EC), which does not include Flower. Products with eco-labels with noise criteria include requirements for information on noise emissions of products, personal computers, printers, copiers, projectors, chain saws, either on labels or in user information. Office and home com- garden tools, and construction machinery. The same issues puter products, including personal computers and printers, that have been raised for other labels about uniformity of are not required to report noise emission values in Europe. testing and verification also apply to eco-labels. The outdoor equipment directive (2000/14/EC) requires a In contrast to eco-labels in other countries, the popular simple label with the declared sound power level. U.S. Energy Star program has no product noise emission criteria. EPA does, however, have the authority to label the noise emissions of products that emit noise capable of Mandatory Labeling in Other Countries adversely affecting public health and welfare (42 USC 65, China requires noise information, either on a label or in Section 4907). the user’s manual, for some domestic appliances. Experience Two different product groups have different ways of treat- has shown that no manufacturers put this information on a ing product noise emissions in the same eco-label program. label on the product. Since 2006, Argentina has required During the development of the EU Flower criteria for per- a label with noise information on some appliances. Brazil sonal computers and notebook computers, no consideration has no labeling requirements on some small appliances but was given to noise levels that are acceptable or “green” requires certifiable noise values on product packaging. in homes and offices. The primary consideration was an The German Equipment and Product Safety Law requires arbitrary decision that 25 percent of existing products be publication of noise emission values for all products, includ- required to meet the new criteria. Similarly, the German Blue ing IT products—even if they are not included in the EU Angel noise criteria for personal computers are the same Machinery Safety Directive. However, because the intent as for notebook computers. No consideration was given to of the machinery directive is to prevent hearing loss, the differences in product functionality, costs of compliance, or only requirement for most IT products is a statement that customer expectations. At the same time, the Blue Angel the sound pressure level emissions do not exceed 70 dB(A); noise criteria for construction equipment require only that this information does not describe the noise emissions of IT products meet the limits set in the EU outdoor equipment products used in businesses, offices, and homes. directive, 2000/14/EC. In Germany the “GS Mark” indicates that a product complies with the minimum requirements of the German Issues and Concerns Equipment and Product Safety Act (GPSG). The GS Mark is a licensed mark of the German government and may only The study committee is in favor of a uniform system for be issued by an accredited testing and certification agency labeling the noise emissions of products. This is reflected in (e.g., TÜV). Products in Germany routinely carry a GS mark Recommendation 6-1 below. However, there are issues with indicating that they are “safe.” However, in some instances, noise labeling that need to be resolved. The major concerns test houses that certify GS marks require additional provi- about noise labels are consistency of labeling requirements sions that are not included in GPSG, and this can cause and test standards (one test worldwide) and verification or problems for manufacturers. For example, GS test houses consistency of testing by manufacturers. Many manufactur- require voltage output to personal computer and notebook ers have expressed concerns about favoritism and inappro- computer headsets—requirements that are the same as for priate labeling by other manufacturers, especially those in personal portable music systems (Walkmans, iPods, and nearby countries. The lack of consistency from one product

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8 TECHNOLOGY FOR A QUIETER AMERICA group to another can cause confusion for customers. The form system of labeling product noise. The system should be lack of consistency from one country to another for the same self-enforced by manufacturers but should have strict rules types of products can cause problems for manufacturers who and penalties if products are deliberately mislabeled. The are required to perform different tests or provide different rules should specify standard methodologies for measuring information for different countries. product noise. Uncertainties in noise emission values should Information about the availability of noise values to the be acknowledged. Product noise labels should be prominent- public is also an issue. The public may not be aware that ly displayed so that consumers can make informed purchas- Web-based information, such as eco-declarations, is avail- ing decisions. In a world with proliferating eco-labels and able. Noise information that is available only in user’s manu- different requirements, international cooperation to develop als or other product documentation is of no help to consumers one label recognized worldwide would be of great benefit to making purchasing decisions. American manufacturers and consumers everywhere. The noise emission values of appliances and outdoor Recommendation 6-2: Government, trade associations, equipment are readily available in Europe, as required by law. However, they are not available (or not easily available) and industry should fund the participation of U.S. technical in the United States for the same products. Noise emission experts on standards bodies that develop international stan- values for some IT products used in homes and offices are dards for determining product noise emissions. available from some, but not all, manufacturers, and they Recommendation 6-3: The National Institute of Standards may not be readily available to potential customers. and Technology should take the lead in providing assistance to American manufacturers with noise regulation compli- FINDINgS AND RECOMMENDATIONS ance by establishing a database of information on U.S. Countries in the EU have recognized the importance of and international product noise emission standards and standards and taken the lead, making the ISO a leader in requirements. the standards community. ISO standards committees have Recommendation 6-4: To establish their credibility, orga- superseded many American-based standards committees and organizations that U.S. manufacturers relied on in the past. nizations that determine noise emission data according to America’s voice on the ISO standard committees is weak- a certain standard as part of a voluntary labeling program ened by the lack of U.S. manufacturers’ leadership in ISO should be accredited to test products. Managers at the working groups. America has only a single vote, the same as National Institute of Standards and Technology and its Na- every member country in the EU. The EU has been a leader in tional Voluntary Laboratory Accreditation Program should the development of noise regulations based on ISO standards. promote their accreditation program, especially in industrial Because these regulations are more extensive than those that laboratories. exist in the United States, European manufacturers have gained a competitive advantage over their U.S. counterparts REFERENCES in meeting consumer demand for low-noise machinery and ANSI (American National Standards Institute). 2009. Mission Statement. other products worldwide. Available online at www.ansi.org. At the time of purchase, consumers rank noise as one of ASA (Acoustical Society of America) Standards Secretariat. 2009a. Ameri - the top five characteristics when comparing product perfor- can National Standards Committees and US Technical Advisory Groups mance. Other concerns are energy efficiency, cost, reliability, (U.S. TAGs). 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