Does EISA Apply to Security Products?

SIA contends that provisions of the Energy Independence and Security Act of 2007 do not



Last year, Congress enacted the Energy Independence and Security Act, also known as EISA. The law was enacted to improve the nation’s energy efficiency. Among its provisions, EISA amended the Energy Policy and Conservation Act requiring certain consumer electronics manufactured after July 1, 2008 to adhere to more stringent energy savings standards and test procedures. It requires consumer electronics using Class A External Power Supplies that run in “active mode” to have the ability to revert to “off” or “standby” mode when not connected to a load. Many major players in the security industry have expressed serious concerns as to whether this law applies to security products. SIA believes that the EISA does not apply, nor was it meant to apply, to security and life safety devices.

SIA expressed its position during a recent Department of Energy (DOE) Notice of Proposed Rulemaking (NOPR) hearing by submitting both written and verbal comments. SIA contends that its members provide physical security solutions to protect the people and property of America in their homes and institutions. This includes schools, hospitals, airports, seaports, factories, offices and government buildings. If the EISA were deemed to apply to security solutions it would compromise the very protection that these products are intended to provide.

During the DOE hearing, Mark Visbal, SIA’s director of Research and Technology, noted, “The monitoring of fire, carbon monoxide, intruder detection sensors, access control readers and exit devices requires a constant supply of energy. The external power supply used in such security and life safety systems can never be operated in an off- mode because disconnecting them from the load destroys the intended functionality and integrity of the system. Additionally, security and life safety systems are continuously monitoring their sensor circuits. They are searching for problems with the functionality of control panels, the presence of voltage input, backup batteries and the communication channels used to relay critical information to the responding authorities.”

The definition of a Class A External Power Supply outlined in the EISA does not accurately describe security and life safety devices. It stipulates that a product is a Class A External Power Supply if it is “connected to the end-use product via a removable hard-wired male/female electrical connection, cable, cord or other wiring.”

“Under this definition, the legislation assumes that these power supplies are stand-alone and constitute a complete source of power that is separable from the end-user’s device,” Visbal contends. “This is not the case for security and life safety systems. The transformer connected to line voltage AC cannot be separated from the panel where the lower AC voltage is rectified and converted to DC voltage usable by the system. Essentially, a circuit within the security/life safety panel and transformer together constitute the entire power supply.”

Therefore, SIA does not believe that the provisions of the EISA are applicable to security and life safety products. We support the goals put forth by the Energy Policy and Conservation Act and the EISA; however, we believe it would be inappropriate for the DOE to require test procedures for “off” and “standby” modes for products that cannot be and were never intended to be used in those modes. They are always on. Complying with the test procedures outlined in EISA would add unnecessary expense to the manufacture and sale of these products without advancing the goals of the new law. Ultimately, such added costs will be passed on to end-users.

Tom O’Connor is a government relations representative for the Security Industry Association (SIA). For details on SIA’s legislative agenda, or to learn how to get involved with SIA’s government relations activities, contact him at toconnor@siaonline.org or call (703) 647-8483.