Department of Energy

Wasninaton, DC 20585

April 21, 1993

Mr. Michael Thompson

Director, Government Relations

Whirlpool Corporation

Mail Drop 3004

2000 M-63

Benton Harbor, MI 49022

Dear Mr. Thompson:

This is in response to your letter of January 15, 1993, requesting

clarification of the Department of Energy (Department or DOE) clothes washer

test procedure regarding the wash/rinse temperature requirement in section

3.2.2.2 as published in the Federal Register on September 28, 1977 (42 FR

49808) and incorporated into the Code of Federal Regulations at 10 CFR Part

430, Subpart B, Appendix J.

Your letter is similar in content to your earlier letter of October 19, 1992,

which requested clarification of essentially the same issue. In DOE's

response, dated December 18, 1992 (copy enclosed), the Department stated: "DOE

does not agree with Whirlpool's interpretation of having the option to define

the normal cycle as excluding the hottest setting and thereby test clothes

washers only at cooler temperature settings... DOE believes that Whirlpool

must set the temperature switch to the hottest setting available (i.e,

hot/warm) after the normal cycle is selected as required in section 3.2.2.2.

This is followed by testing at the other wash/rinse temperature selectors

available that use hot water (i.e., hot/cold, warm/warm, and warm/cold) as

required in section 3.2.2.6 in order to test and certify clothes washers in

accordance to the DOE test procedure (Appendix J to Subpart B of Part 430)."

After a second extensive review regarding section 3.2.2.2, the Department

affirms its initial determination to reject Whirlpool's proposed test

compliance method where clothes washers that offer warm rinse are tested only

at cooler temperature settings (i.e., hot/cold and warm/cold). The clothes

washer test procedure is intended, inter alia, to provide an estimate of

annual energy consumption. To provide comparable annual energy consumption

among clothes washers, the Department believes that all of the temperature

combinations covered by the Temperature Use Factors (TUFs), and available to

the consumer, must be tested. Each TUF combination offered must-be tested

using the cycle which is normal or available for that temperature combination.

Locking out the warm rinse in the "normal" cycle and then offering it on

another cycle does not exempt the Whirlpool Corporation from the compliance

requirement in section 3.2.2.2 of the DOE clothes washer test procedure. DOE

believes that this "newly- named " cycle becomes the "normal" cycle for those

TUF covered temperature combinations that are not offered on the cycle labeled

as "normal."
2

The Department believes the above interpretation pertaining to the inclusion

of all available wash/rinse temperature combinations covered by the TUFs for

clothes washer test compliance will provide comparable test results among all

clothes washers.

If you should have any additional questions , please contact William Hui of my

staff at (202) 586-9127.

Sincerely,

rLr

M.i cha,&Yhl . McCabe, Director

Office'of Codes and Standards

Office of Building Technologies

Conservation and Renewable Energy

Enclosure

 EE-RM-93-701 COMMENT 0B