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This is a draft document and does not represent a definitive view of the agency on the questions addressed
. This and other guidance documents are accessible on the U.S. Department of Energy, Energy Efficiency & Renewable Energy web site at: http://www1.eere.energy.gov/guidance/default.aspx?pid=2&spid=1
. Guidance Type: Certification and CCMS, Test Procedures Category: Residential Products Product: Refrigerators , re frigerator

- freezers, and f reezers Guidance Version: DRAFT Issued: July 29, 2014 Comment Period Ends: August 28, 2014 The following is a draft U.S. Department of Energy (DOE or the Department) guidance document regarding the test procedure for refrigerators, refrigerator

- freezers, and freezers (refrigeration products). This draft guidance document represents the Department’s interpretation of its existing regulations and is exempt from the notice and comment requirements of the Administrative Pr ocedure Act. See 5 U.S.C. § 553(b)(A). Nonetheless, the Department is accepting comments and suggestions from the public until August 28, 2014 . Comments and suggestions should be provided in WordPerfect, Microsoft Word, PDF, or text file format by sending an email to RefrigeratorFreezerGuidance2014GUID0028@ee.doe.gov
. Please also include the docket number EERE
2014
- BT
- GUID
- 0028 . At the end of the comment period, this draft guidance do cument may be adopted, revised, or withdrawn. Q: When testing using the Appendix A test procedure for refrigerators and refrigerator - freezers, or the Appendix B test procedure for freezers, a re manufacturers required to report use of a non standard temper ature sensor location if a sensor is moved only to achieve the required air gap and the compartment’s interior arrangements conform to the specifications cited in the test procedure? A: Reporting in the certification report of the use of a non - standard temperature sensor location is not required if the sensor was only moved in order to achieve the 1

- inch air gap required by section 5.5.4 of AHAM HRF

- 1
- 2008 and the interior arrangement of the unit under test otherwise conforms in all respects to those shown in Figure 5

- 1 and Figure 5

- 2 of AHAM HRF

- 1
- 2008. T he DOE test procedure s for residential refrigerators , refrigerator

- freezers , and freezers found in appendi ces A and B to subpart B of 1 0 CFR part 430 current ly require that if the interior arrangements of the unit under test do not conform with those shown in Figure s 5
- 1 and 5

- 2 of HRF

- 1
- 2008, the unit must be tested by relocating the temperature sensors from the locations specified in the figures to avoid interference with hardware or components within the unit, in which case , the specific locations used for the temperature sensors shall be noted in the test data records maintained by the manufacturer in accordance with 10 CFR 429.71, a nd the certification report shall indicate that non

- standard sensor locations were used. See Section 5.1 of both Appendix A and Appendix B. In the most recent revision to these test procedures, which was published on April 21, 2014 (79 FR 22349), DOE add ed a requirement in section 5.1(b) of both procedures that if any temperature sensor is relocated by any amount from the location prescribed in Figure s 5
- 1 or 5
- 2 of HRF

- 1
- 2008 in order to maintain a minimum 1
- inch air space from adjustable shelves or othe r components that could be2

relocated by the consumer, this constitutes a relocation of temperature sensors that shall be recorded in the test data and reported in the certification report. Since publication of the final rule, DOE has become aware th at a c onflict may exist for certain models in the AHAM test procedure incorporated by reference. S pecifically , the 1

- inch air gap requirement in section 5.5.4 appears to conflict with the required temperature sensor locations on the diagram in Figure 5
- 1, which addresses fresh food compartments, and F igure 5
- 2, which addresses freezer compartments. Due to the separate requirements applicable to ea ch compartment type, the specific issues involving the spacing requirements are discussed separately here : 1 ) Fresh food compartments . For products with f resh food compartment arrangements consistent with (c), (d), (g), and (h) in Figure 5

- 1 , placement of the bottom temperature sensor must be 1 inch above the compartment’s bottom shelf. However, the 1

- inch measurement is taken from the center of the sensor’s thermal mass to the shelf rather than from the lower edge of the thermal mass to the shelf, meaning that if placed as required in the diagram, the bottom of the thermal mass would be 0.5 inches from the shelf and in violation of the 1

- inch air gap required in section 5.5.4 (assuming the thermal mass has a 1

- inch diameter) . Because the bottom shelf for products with such an arrangement is fixed in place, it is impossible to comply with both the sensor plac ement and the 1
- inch air gap requirements
. DOE requires maintenance of the 1

- inch air gap in these cases. B ecause the sensor must be moved vertically from the location specified in Figure 5

- 1 in order to achieve the required 1

- inch air gap, DOE would not view this as a “ relocation ” due to the factors cited in section 5.1(b) of the DOE test procedure in Appendix A ( e . g. , interference with movable hardware)
– accordingly, this sensor positioning would not be reported as a non - standard location in the certification report. 2) Freezer compartments . Products with f reezer compartments consistent with any of the configuration types illustrated in Figure 5
- 2 must have the b ottom sensor placed 0.75 inches from the bottom of the compartment. Because the specified dimensions of the required packages are 5 x 4 x 1.5 inches, the 0.75
- inch spacing reflects the location of the sensor if the sensor is placed at the center of a frozen package, as required by section 5.5.5.3 of AHAM HRF

- 1
- 2008 for manual defrost freezers, and the package is placed at the bottom of the compartment
. In this case, the 1

- inch air gap requirement does not apply. Thus, the standard location for the sensor in that situatio n is 0.75 inches from the bottom of the compartment consistent with the Figure 5

- 2 requirements, making the reporting of such placement as a non - standard location unnecessary. For automatic defrost freezers or the freezer compartment of automatic defrost refrigerators or refrigerator

- freezers, testing with the compartment loaded with frozen packages is not required. Thus, placement of the bottom sensor with a 1

- inch air gap between the sensor’s thermal mass and the bottom of the compartment is required. Figure 5
- 2 specifies that the center of the thermal mass is to be position ed 0.75 inches from the bottom of the compartment. In such cases, the 1
- inch air gap requirement controls, and the sensor m ust be repositioned vertically from the location specified in Figure 5
- 2 in order to achieve the required 1

- inch air gap . As for fresh food compartments , this situation also would not be require d to be reported as a non - standard location in the certification report.