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 U.S. DEPARTMENT OF ENERGY 

+ + + + + 

PUBLIC MEETING FOR TEST PROCEDURE GUIDANCE 

FOR ROOM AIR CONDITIONERS, RESIDENTIAL 

DISHWASHERS, AND RESIDENTIAL CLOTHES WASHERS 

+ + + + + 

FRIDAY 

JUNE 1, 2012 

+ + + + + 

The meeting came to order, in room 

8E-089 of 1000 Independence Avenue, SW, 

Washington, D.C. at 9:00 a.m., Ashley 

Armstrong presiding. 

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PRESENT 

ASHLEY ARMSTRONG, Department of Energy

LAURA BARHYDT, Asst GC for Enforcement, 

Department of Energy

ELIZABETH KOHL, Atty Advisor Department of 

Energy

AMANDA STEVENS, Program Manager, Energy Star

Appliances, EPA

KATHLEEN VOKES, Energy Star Product 

Development, EPA

PAUL RICHTER, AB Electrolux 

JENNIFER CLEARY, AHAM 

RALPH HUDNALL, AHAM 

STEPHEN B. LEYBOURN, AHAM 

WAYNE E. MORRIS, AHAM 

PHILIP J. MANTHEI, Alliance Laundry Systems

JOANNA MAUER, ASAP 

MIKE EDWARDS, BSH Home Appliances Corporation

DAVID J. LINGREY, Friedrich Air Conditioning

Co. 

BRICE BOWLEY, GE Consumer and Industrial 

PHIL HOMBROEK, GE Consumer and Industrial 

KELLEY KLINE, GE Consumer and Industrial 

KEVIN CHURCHILL, Intertek 

LINCOLN BILLINGS, Intertek 

MARK MENZER, Intertek 

JOHN I. TAYLOR, LG Electronics 

JUDITH REICH, Navigant Consulting

ED OSANN, NRDC 

RAVEENDRAN VAIDHYANATHAN, Samsung Electronics

America, Inc. 

DONALD BRUNDAGE, Southern Company

JULIA FARBER, UL, LLC 

VINCENT P. ANDERSON, Whirlpool Corporation

WAYNE KLUG, Whirlpool Corporation

DANIEL E. TEICH, Whirlpool Corporation 

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ALSO PRESENT 

MICHAEL WOODFORD, AHRI 

KEVIN MESSNER, AHAM 

WES ANDERSON, Appliance Standards

MIZANUR CHOWDHURY, CSA International 

JOHN CYMBALSKY, DOE 

TIMOTHY BALLO, EarthJustice 

GEORGE HAWRANKO, Electrolux North America 

AMANDA GONZALEZ, Energy Solutions

EDWARD WUESTOFF, Friedrich Air Conditioning

Co. 

CHRIS ROBERTS, GE 

YOOLANDA WILLIAMS, GE Appliances and Lighting

ANGELO CACCIATORE, Haier America 

DANIEL WOODCOCK, IAPMO R&T 

SEAN SOUTHARD, ICF International 

MAX WILBAND, LG Electronics 

STEVE POLINSKI, Miele USA 

JAVIER BURGOS, Navigant Consulting

JUSTIN SCHMIDT, Navigant Consulting

RICHARD SHANDROSS, Navigant Consulting

TIMOTHY SUTHERLAND, Navigant Consulting

DETLEF WESTPHALEN, Navigant Consulting

TROY WATSON, Navigant Consulting

MVUALA SUAMI, NRCan 

SAI ARIDI, NSF International 

WAYNE MYRICK, Sharp Electronics

EVA MILAKOWSKI, Ontario Ministry of Energy

MIKE SHOWS, UL 

CURT TREMEL, UL Springboard Engineering

DEBRA BENGSTON, Viking Range Corporation 

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 C-O-N-T-E-N-T-S 

Call to Order and Opening Remarks 6 

Ashley Armstrong 

Department of Energy 

AHAM 

Introductions 9 

Opening Remarks 13 

Jennifer Cleary 13 

General Cross-Cutting Test Procedure 

Discussion 22 

Basic Model Definition and New Basic 

Model Requirements 

22 

Model Number 26 

Industry Test Procedure Version and 29 

Revisions 

Discussion 

Guidance Procedures and Policies 31 

Rounding Policies 36 

Other Issues/Open Forum 41 

Room Air Conditioner Test Procedure 43 

Installation of Test Unit in Wall 44 

Cavity of Test Chamber 

Initiation of Test 

Adding Water to Drip Pan Prior to 55 

Run-In Period 63 

Air Sampler Placement 73 

Other Issues/Open Forum 83 

C-O-N-T-E-N-T-S (CONTINUED) 

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Dishwasher Test Procedure Discussion 85 

2010 Test Procedure Guidance 85 

Regarding Cycle Selection 

Detergent Volume Calculation 93 

Substitutions 100 

Preconditioning 108 

Soiling and Loading Procedures 124 

Rinse Agent Container 135 

Water Pressure Measurement 138, 158 

Drain Height 142 

Upper Rack Position 143 

Water Hardness 147 

Ambient Temperature 152 

Differences in Food Soils 156 

Clothes Washers 160 

Testing Anomalies 161 

Drum Volume Measurement 180 

Energy Test Cycle 200 

Test Cloth Loading Method 202 

Water Pressure 208 

Recording of Ambient Conditions 211 

Standby Measurement 216 

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 P-R-O-C-E-E-D-I-N-G-S 

9:05 a.m. 

MS. ARMSTRONG: All right. Good 

morning, everyone. 

For those who don't know me, my 

name is Ashley Armstrong. I work here at the 

Department in Buildings. I oversee the 

testing procedures, the certification, 

enforcement, and the Energy Star testing that 

we do in the Buildings Program for appliance 

standards. 

I would like to welcome you today 

to our discussion, hopefully a productive one, 

about some of the testing questions and issues 

that have arisen with respect to dishwashers, 

clothes washers, and room air conditioners. 

This is really a forum for you guys 

to speak, to bring your issues to the 

Department. We are really here to listen. 

You will notice that most of the times today 

we will not be issuing an opinion on most 

matters. We are going to be listening. We 

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will be taking all the different questions and 

clarifications and requests back and probably 

come out with some to-do's from this meeting. 

But we really appreciate you 

coming. I encourage you to speak up. This is 

your opportunity. 

Just a couple of ground rules. I 

think you guys know, when you come up to the 

microphone, either the ones on the side or 

this one, please push to talk. State your 

name clearly for the record. There will be a 

transcript of this posted on the website. 

Also, state your company affiliation each time 

you speak, so not just the first time, but 

each time. 

Another thing we are going to do, 

for the participants on the webinar, I welcome 

you as well. We are going to try to 

incorporate a two-way dialog with you. So, if 

you want to talk on the webinar, there is a 

way you can raise your hand. I will know 

that, and we will try to integrate you into 

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the discussion by unmuting your line and 

calling on you. 

Just as with the participants in 

the room, I ask you that you state your name 

for the record as well as your company 

affiliation before you talk, even if you are 

speaking on the webinar. 

This is a new webinar thing for the 

Department as far as the two-way communication 

goes. So, if it doesn't work too well, we 

will go back to listening-only mode. But we 

are hopeful. We tried it out yesterday. We 

are moving in that direction at least. 

So, for anyone else who wants to 

come join the table, feel free to do so, now 

that we are starting the meeting and it looks 

like we have a couple of open spots. 

Other than that, we are going to go 

around the room and do introductions of 

everyone. As soon as Kelley gets seated, we 

will let her start. You could you just start 

with introductions, with your name and your 

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company affiliation. 

MS. KLINE: Hi. Kelley Kline, 

General Electric appliances. 

MS. ARMSTRONG: Great. 

MR. RICHTER: Hello. My name is 

Paul Richter, AB Electrolux. 

MS. ARMSTRONG: Okay. 

MR. LINGREY: David Lingrey from 

Friedrich Air Conditioning. 

MR. EDWARDS: Mike Edwards with BSH 

Home Appliances. 

MR. ANDERSON: Vince Anderson with 

Whirlpool. 

MR. OSANN: Ed Osann, Natural 

Resources Defense Council. 

MR. VAIDHYANATHAN: Ravee 

Vaidhyanathan, Samsung Electronics. 

MS. CLEARY: Jen Cleary with AHAM. 

MS. FARBER: Julia Farber with 

Underwriters Laboratories. 

MR. MANTHEI: Phil Manthei, 

Alliance Laundry Systems. 

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 MR. MENZER: Mark Menzer with 

Intertek Labs. 

MS. KOHL: Betsy Kohl, Department 

of Energy General Counsel. 

MS. ARMSTRONG: Ashley Armstrong, 

Department of Energy, Buildings. 

MS. BARHYDT: Laura Barhydt, 

Department of Energy General Counsel. 

MS. ARMSTRONG: If we could also 

start on that end in the back, if you guys 

could actually make your way to the 

microphone, we are going to get for the record 

everyone who is in the room. 

MR. BOWLEY: Brice Bowley, General 

Electric. 

MS. CHINGOS: Abigail Chingos, 

Office of General Counsel, and I work in 

Enforcement with dishwashers and clothes 

washers, among other things. 

MR. CASE: Dave Case, DOE Office of 

Enforcement as well, and I work with room air 

conditioners. 

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 MS. STEVENS: Amanda Stevens, EPA, 

Energy Star. 

MS. MAUER: Joanna Mauer, Appliance 

Standards Awareness Project. 

MS. SWOGGER: Denise Swogger, 

Alliance Laundry Systems. 

MR. BRUNDAGE: Don Brundage, 

Southern Company. 

MR. TAYLOR: 

Electronics. 

John Taylor, LG 

MR. TEICH: Dan Teich with 

Whirlpool. 

MR. KLUG: Wayne Klug, Whirlpool. 

MR. CHURCHILL: Kevin Churchill, 

Intertek. 

MR. BILLINGS: Lincoln Billings, 

Intertek. 

MR. MORRIS: Wayne Morris with the 

Association of Home Appliance Manufacturers. 

MR. HUDNALL: Ralph Hudnall, 

Association of Home Appliance Manufacturers. 

MR. LEYBOURN: Steve Leybourn, 

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Association of Home Appliance Manufacturers. 

MS. ARMSTRONG: Okay. Did we get 

everybody in the room? If not, please 

introduce yourself. 

MS. VOKES: Hi. I'm Kathleen 

Vokes. I am with the EPA. 

MS. ARMSTRONG: Okay. Sorry. 

MS. REICH: Judith Reich from 

Navigant. 

MS. BRUNK: Debra Brunk from 

Navigant. 

MS. ARMSTRONG: All right. Well, 

right before we do opening remarks, I just 

want to make one further comment. For 

dishwashers, we have an open rule right now. 

So, I just want to make clear that any of the 

issues brought up today, the Department 

doesn't plan to address those. Those will be 

addressed through the rulemaking process. We 

encourage you to submit comments to that 

docket as they may relate to that. You can 

certainly bring up issues, or if there are 

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issues that haven't been brought up as part of 

that rulemaking, you can bring them up here, 

but they will be addressed in that docket, in 

that rulemaking. So, just to make that clear 

before we start. 

With that, I am going to open it 

for opening remarks. I know there is someone 

down there who wants to go first. 

MS. CLEARY: I will volunteer. 

(Laughter.) 

I just wanted, first of all, to 

start by thanking DOE, and Ashley in 

particular, for holding this meeting today. 

MS. ARMSTRONG: Can you do me a 

favor and state your name? 

MS. CLEARY: Oh, I'm sorry. Jen 

Cleary with AHAM. 

We think this is a very important 

meeting, and we are grateful to have the 

opportunity to discuss these issues today. 

In particular, a combination of 

factors is making correlation and common 

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understanding of DOE's test procedures more 

critical than ever before. 

One, standards are becoming more 

and more stringent, which leaves less room for 

error during testing. 

Second, we have increased DOE 

enforcement testing. 

And third, third-party verification 

testing by different laboratories for Energy 

Star, also, through DOE and certification 

bodies. 

So, accordingly, like I started out 

saying, we thank DOE for holding this meeting. 

We see it as a very important opportunity for 

an open dialog to discuss these issues, and we 

look forward to future meetings like this. 

Hopefully, today will be successful. 

In particular, there are several 

lab processes that I think we will discuss 

today that are difficult to characterize in 

the limited wording in the test procedures. 

The result is that different labs, you know, 

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we have witnessed, are interpreting procedures 

different, certain procedures in the test 

procedure differently, which means different 

results. And the outcome could be false 

findings of compliance or non-compliance. 

Some examples of these types of 

issues that cut across all products: 

significant digits and rounding. I think 

there is some significant confusion about 

DOE's procedure for that for each product. 

There are provisions in different areas of the 

rules. And so, we would be looking today if 

DOE is able to kind of walk us through that so 

everybody is clear. 

And also, this is coming up now in 

Energy Star specifications. I think we would 

look for those to be the same as DOE, whatever 

the process is. 

The approach to new basic models 

should be the same for DOE and for Energy 

Star. So, we would hope that there is only a 

need to report changes that result in a 

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measured energy that is less efficient than 

the reported value. 

The approach for the change in 

model year also needs some clarification. If 

there is a placeholder for the model year in 

the model number, we don't think there should 

be a need for retesting or certification, once 

that placeholder value is changed for the 

year. 

Also, there has been great 

improvement in the way that DOE has been 

posting and issuing its guidance, but we still 

look for a little bit of clarification around 

the significance of when DOE maybe posts 

guidance on its guidance website and then 

later pulls it down. What should we be doing 

as an industry in that type of situation? 

Some just examples of why this 

meeting is necessary for each product. And we 

plan to go into these issues in depth today. 

But for dishwashers there are several 

questions around cycle selection and 

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identifying whether a cycle is soil-sensing. 

There is some interpretive confusion regarding 

the detergent volume calculation. There is a 

significant need for substitutes, both in the 

soils and the dishware. Flatware is being 

addressed, but dishware as well. And the need 

for these substitutions to be specified 

through a quick and clear procedure as they 

arise, because these issues will continue to 

arise. And also, the definition of 

preconditioning needs some clarification, 

among other issues. 

For clothes washers, one main issue 

is how to address testing anomalies, like an 

unbalanced load during testing. Also, some 

further need for clarification on drum volume 

measurement. Particularly, I know J2 

addresses many of them, but we are still under 

J1. And so, we need some more guidance in 

addition to what is already out there with 

regard to bad design, the weight used to 

determine volume, unique design features, and 

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shipping bolts. Also, there is a need for a 

more detailed description of the test cloth 

loading pattern and sequence. 

With regard to room air 

conditioners, there are some questions 

regarding there is some variability in the 

installation of the unit from lab to lab. 

Also, some labs add water to the drip pan to 

speed up the time to reach equilibrium, and we 

would like to discuss that. The placement of 

the air sampler and, also, the run-in period. 

Again, just stressing the need for 

the open dialog which this meeting addresses. 

We think that we should continue to work 

together on these test procedure issues. AHAM 

is constantly working to improve our test 

procedures, many of which DOE incorporates by 

reference into its test procedures. And so, 

correspondingly, we would hope that DOE would 

revise its appendices to incorporate by 

reference the most recent version of the AHAM 

test procedure, where relevant. This will 

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greatly reduce the variation. Many of our 

changes are to address variation that we see, 

and there should be a quick process for doing 

that and to evaluate the impact on measured 

energy. 

DOE should also consult 

stakeholders before issuing final guidance. 

We think this is the best way to have good, 

clear guidance and, also, give industry some 

lead-in time for that guidance, as if it was 

unclear, there may be some who were not doing 

it the way the guidance indicates. 

Also, this guidance should be made 

publicly available to all stakeholders, so 

that the tests can be run by all labs in the 

same way. That is critical. 

Finally, we would ask, does the 

Department have some clear criteria that we 

could evaluate whether it is best to seek 

clarification through a guidance request, 

through maybe a petition for a test procedure 

change. If there aren't such criteria, could 

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they be developed? And we just see this as 

important for us to help you make the test 

procedures as clear as possible. 

So, thank you again for this 

meeting today, and we have several specific 

issues that I know our members wish to raise. 

MS. ARMSTRONG: Great. This is 

Ashley from DOE. Thanks, Jen. 

Does anyone else have opening 

remarks that they would like to make at this 

time before we get into the details of each of 

the issues? 

(No response.) 

No? Wow. This could be a really 

quick public meeting. 

(Laughter.) 

Okay. So, I will say, like I said 

at the outset, really I don't have anything 

but a simplified agenda because this really 

isn't a presentation of the Department that 

the Department is making for comment. This 

really is a forum for you guys to discuss the 

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details, especially examples of what you think 

or how things are being conducted differently, 

where the clarifications are needed, where the 

ambiguities lie. The more details you can 

provide to us, the more helpful it will be to 

us, and, hopefully, the more helpful we can be 

to you, once we get a chance to evaluate 

things as they come through. 

So, with that, I am going to move 

on. Okay. So, the first thing we are going 

to talk about today is some of the more 

general items that have been brought up. And 

granted, I have listed here on the agenda the 

items that I am aware of today that have been 

brought to my attention, but by no means does 

this mean you need to limit your questions or 

clarifications or requests to these items 

alone. Feel free, when we get to the end 

where there are open issues, to bring up any 

other questions or concerns you may have. And 

we encourage you to do so. 

So, the first questions that we 

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have gotten surround the basic model 

definition and what actually constitutes a new 

basic model. I am actually going to open the 

floor for discussion first around what 

questions may lie or what concerns there are, 

just so that we can understand. 

Anybody? 

MS. CLEARY: This is Jen at AHAM. 

I don't know if we so much have 

questions about the basic model definition, 

but we do think it is important that it be the 

same, you know, part of correlation I think is 

that it is the same for Energy Star, which 

certainly since we initially raised this issue 

that has definitely been incorporated into the 

specifications. I think AHAM would continue 

to believe it would be better if DOE's regs 

were cited instead of the language copied, so 

that they would always be the same. But I 

think that was maybe our main concern there. 

And with regard to new basic model, 

as I mentioned in my opening statement, I 

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think we just want to make sure that it is 

clear that there is only a need to report 

changes to a product that would result in 

less-efficient measured energy, that there is 

no need to report certainly things like a 

color change. Or more germane would be 

changing like a part in the product that 

either would not change the measured energy at 

all or would change the measured energy to be 

more efficient. Because the manufacturers 

have the ability to conservatively rate, there 

shouldn't be a requirement to report that type 

of a change or to institute a new basic model. 

MS. ARMSTRONG: Okay. So, this is 

Ashley from the Department. 

Jen, I think what you just said is 

fairly consistent with the Department's 

position as far as its regulatory program goes 

with respect to basic model. And I think 

Kathleen can confirm that DOE and EPA are both 

working together on a regular basis. So, to 

the extent there are differences there, I 

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think we are committed to working through 

those. I think we think we are harmonized. 

MS. VOKES: This is Kathleen Vokes 

from EPA. 

I am not aware of a requirement for 

Energy Star to make people report. You know, 

if it is a basic model, it is part of the 

family. So, it is just treated the same way 

in our specifications. 

So, if you have any examples of 

instances where you believe that we are not 

harmonized and we are not doing it the same 

way, please bring it to our attention. 

MR. ANDERSON: This is Vince 

Anderson at Whirlpool. 

Just to be terribly clear on this 

-- and, Jen, in your verbiage there, there is 

a distinction that I want to make sure is 

clear. Jen said that we would not have to 

report the change as long as it was equal or 

more efficient. Actually, what we have 

proposed is that so long as it essentially 

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meets the rated value. So, there could be a 

design change that we make that makes the 

product less efficient; yet, it still meets 

its rated value. So, I just want to make sure 

I am terribly clear on that. The rated value 

is the key parameter to focus on. 

MS. ARMSTRONG: Okay. This is 

Ashley Armstrong from DOE. 

Once again, for the DOE regulatory 

program, that is correct. As long as your 

test data still supports your certified rating 

-- so, for example, if you rate 

conservatively, if you make changes, it might 

be slightly less efficient, but that certified 

rating is still supported; you are good to go. 

Now I will say, with one caveat, 

that if you make changes to make a model more 

efficient and you want to claim that more 

efficient rating, you do need to recertify 

your product. But if you do not want to claim 

that more efficient rating and you still want 

to go with a conservative rating, you are good 

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to go. 

MS. VOKES: And I would just add 

for that, for EPA for the Energy Star Program, 

we have a specific clause in our conditions 

and criteria for certification bodies that 

says they have to do a reevaluation in the 

event of significant changes. And the 

specific language says that they have to have 

procedures to reevaluate product performance 

in the event of changes that could affect the 

Energy Star qualification status of the 

product the CB has certified. 

So, the example that you gave is 

not something that would impact the 

certification qualification status. And so, 

you would be fine. 

MR. ANDERSON: Okay. Thank you. 

MS. ARMSTRONG: Okay. Issue two, 

the next issue, we have gotten questions about 

model number changes and when a model number 

needs to be changed in terms of DOE's 

regulatory program. 

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 So, do you guys want to speak to 

any issues regarding or questions regarding 

that specifically? 

(No response.) 

No? Okay. 

MR. MANTHEI: Phil Manthei from 

Alliance Laundry Systems. 

Okay. If the model efficiency were 

to go down, be less efficient, and we would 

like to change the certified rating, then does 

the model number actually have to change? 

Let's say we are not making any significant 

change to the model, but we have found through 

verification and audit testing that the model 

doesn't meet what we originally certified. 

MS. BARHYDT: So, again, I can't 

speak to Energy Star or FTC's requirements. 

But with respect to DOE's regulatory program, 

the only time that we require a model number 

to change is when the product has been found 

to be non-compliant with the standards. 

MS. VOKES: I can confirm that is 

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similar for Energy Star. So, if find that a 

model is disqualified from Energy Star, if you 

wanted to recertify that it is Energy Star, 

then we require a new model number. But, 

otherwise, we don't. 

MR. MANTHEI: Okay. Thank you. 

MS. KLINE: Kelley Kline with GE. 

One question I have seen come in 

the past is the extent or any guidance around 

what needs to change in a model number when 

you are making a change. You know, sometimes 

it is a question of, can you change 

engineering digits or is a change in the model 

year sufficient. Or is there any thinking 

around how significant the change needs to be? 

MS. BARHYDT: Okay. So, if DOE has 

found a product to be non-compliant, it needs 

to be a change that is going to be visible and 

noticeable to a consumer. The whole point of 

that requirement is to ensure that consumers 

don't get confused between a new model and an 

old model that was not compliant. 

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 MS. KLINE: Okay. And I guess I 

wasn't thinking about that example in 

particular where DOE has the non-compliance. 

I was thinking more of a change in the normal 

course of things. 

MS. BARHYDT: Since we don't have 

any regulatory requirements with regard to 

those, it is not impacted. 

MS. KLINE: Okay. Thank you. 

MS. ARMSTRONG: Okay. Moving right 

along, the next issue that has been brought up 

is industry test procedure versions as well 

revisions when they have been revised, either 

industry standards, ANSI standards, ASHRAE 

standards that may be applicable, but DOE has 

not yet gone through the rulemaking process, 

but they are available publicly. 

There have been some questions as 

to what version should be used. So, for the 

DOE regulatory program, the version that 

should be used is always the version in the 

Code of Federal Regulations. It is that 

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specific version, that specific year. And 

even if there are more recent substitutes, 

they cannot be substituted unless we have gone 

through a rule to update the proceeding. So, 

I think that is fairly clear. 

And to Jen's point and her 

presentation this morning as to DOE adopting 

the most recent version, we are trying to do 

that. We have a seven-year lookback provision 

in our statute to review each test procedure 

at least once every seven years. If we had a 

strong need to do so earlier, we could always 

have that discussion when it arrives. But we 

are committed to trying to review the test 

procedures on a regular basis. 

So, I am going to open the floor if 

anyone has any questions. 

MS. CLEARY: This is Jen with AHAM. 

I think we are revising our test 

procedures much more than every seven years. 

So, what would be the best way for us to ask 

you to update the DOE test procedure? 

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 MS. KOHL: You can always submit a 

petition for rulemaking. 

MS. ARMSTRONG: Okay? So, the next 

issue is guidance procedures and policies. 

When we issue guidance, as you are well aware, 

our guidance system is relatively new. It is 

on the website. It is by product. It spans a 

variety of different categories, some of which 

is applicability of standards, global 

coverage, enforcement, certification, and some 

of which is test-procedure-related, which is 

probably more applicable to today's meeting. 

That being said, some of them we do 

put out for a draft; others we do not put out 

for a draft because they are the Department's 

interpretation. That being said, it is our 

policy, if we put out as draft, to provide a 

comment period, to send the blasts to 

everyone. It will also be posted on our 

website. So, that is basically the guidance 

procedures more or less. As far as the policy 

goes, I am turning it over to my lawyers. 

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 MS. BARHYDT: We had received one 

question about the binding effect of the 

guidance. The guidance that we issue, when we 

issue a final guidance document, obviously, it 

is not a legal requirement. It is an 

interpretation of our existing regulations. 

But we do say exclusively on every single 

final guidance that manufacturers may rely on 

that guidance. 

MS. KOHL: And that was Laura 

Barhydt from DOE. 

MS. ARMSTRONG: So, with that, does 

anyone have any questions about guidance 

specifically? 

This is Ashley from DOE. 

MS. CLEARY: This is Jen with AHAM. 

I think lead-in time is 

particularly important when there is guidance. 

So, I mean, sometimes it seems like there is, 

for example, like a 30-day lead-in time to the 

guidance or there is a specific date that is 

indicated on the guidance. Is that uniform 

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across all guidance? Or, I think, could it 

be? 

MS. BARHYDT: Well, if you are 

interested in it being a standard amount of 

time, I would be interested in hearing about 

that. My expectation would actually be that 

manufacturers may want variable amounts of 

time, depending on what they believe the 

impact of the guidance is. If their 

interpretation has been radically different 

from how the Department reached the guidance, 

it seems to me manufacturers may actually want 

different amounts of time for the guidance. 

But, in any case, whenever we put 

out a draft guidance document, anyone can 

always comment on what they believe is a 

necessary amount of time before it goes into 

effect, whether we specifically ask about that 

or not. 

MS. CLEARY: This is Jen with AHAM. 

Thank you. And certainly, I think 

when we know there is a certain amount of time 

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and there is an ability to comment, we will. 

But when there isn't draft guidance and it 

comes out just final, certainly, we would hope 

that lead time is always considered. I think 

there have been some cases where industry 

would consider the guidance to be a change, 

and there has been either very little lead 

time or the lead time hasn't been expressly 

stated. And so, then, there is confusion 

about would it be like a standard 30 days or 

is it today that the guidance was issued? 

So, I have certainly noticed that 

guidance has started to have like more of a 

format. So, that is helpful. I think we 

would agree that it shouldn't be like 30 days 

across the board because in some cases that 

may not be enough. But it is probably never 

enough to have it be that day. 

So, I think that would be a 

situation we would say categorically we 

wouldn't want to see. I think we would want 

to have at least like maybe a standard minimum 

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time and more time could be allowed. 

MS. BARHYDT: So, I know there have 

been some growing pains with the guidance, but 

our policy and practice now is that all test 

procedure guidance goes out for comment. And 

I might put one little caveat on that. There 

have been several test procedure rulemakings 

that have had in the body of the rulemaking 

guidance and in the preamble. And so, we may 

immediately just post that out in the guidance 

document, so that somebody doesn't have to go 

back and find The Federal Register. But since 

it was published in The Federal Register, that 

we wouldn't put out for comment. 

But any new guidance is going to be 

put out for comment for test procedures. As 

Ashley said, we do send out blasts to all the 

people on our regular mailing list or people 

who have been interested in the rulemakings. 

And so, we are trying to make sure that 

everyone is aware whenever we put out a 

document for comment. 

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 MS. CLEARY: Jen from AHAM. 

And we thank you for that. That 

has been very helpful. 

MS. ARMSTRONG: All right. Moving 

right along -- this is Ashley from DOE -- is 

the rounding policies. We have just gotten 

some questions generally about how is rounding 

conducted. It is in different places in the 

CFR. 

So, as a general policy, before I 

open the floor, if there are specific rounding 

provisions in the appendices, in the test 

procedures themselves, they obviously are 

required to be followed. If there are 

specific rounding provisions in the industry 

standards that are incorporated by reference 

or the sections of the industry standards that 

are incorporated by reference, those are also 

required to be followed. So, that would be on 

a unit-by-unit basis. And then, if there are 

different additional provisions in the test 

procedures themselves about multiple units or 

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averages that they may apply, those are 

required to be followed. 

There are also rounding provisions 

in 430.23. So, I would encourage you to check 

those as well. That is the general section 

that talks about the test procedures as well 

as some of the requirements for the annualized 

use for FTC labels. There are rounding 

provisions there. 

Now I realize that the rounding 

provisions are not harmonized in our 

regulations across the board as far as 

location and whether they are or are not 

there. So, where we do have rounding 

provisions, they should be followed. Where we 

don't have founding provisions at all, DOE, as 

far as those certified ratings go in terms of 

we look at the number of significant figures 

in the actual standard, the energy 

conservation standard -- that's all -- against 

their certified rating. So, that is the 

general matter of practice. 

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 That issue is still ongoing, and we 

will be grappling with it in a future 

rulemaking to try to kind of standardize the 

way that it is treated as well as the location 

to make it a little bit easier. 

So, I will open the floor at this 

time. But that is pretty much for the DOE 

regulatory program. 

MR. OSANN: This is Ed Osann from 

Natural Resource Defense Council. 

Could you just restate the last 

point you made about what you are intending to 

do in the future? 

MS. ARMSTRONG: Oh, just generally 

that we are going to plan to address rounding 

provisions where they either do not exist or 

generally how they are applied to the 

certified ratings in a future rulemaking. 

This is Ashley from DOE. 

MR. OSANN: This is Ed Osann again 

from NRDC. 

There would be a future rulemaking 

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specifically on rounding? 

MS. ARMSTRONG: This is Ashley from 

DOE. 

No, it would likely be part of a 

larger rulemaking. So, for example, if we do 

another certification and enforcement 

rulemaking, it may be part of that, yes. 

MR. BOWLEY: Hello. This is Brice 

Bowley at GE. 

I guess the one question I had, and 

you answered it somewhat, is that if the 

appendices or test procedures have a rounding, 

it should be followed. I guess my question 

is, if it is part of the test procedure, does 

it need to be applied on basically a unit-byunit basis, that if a unit is tested four 

times for certification, it should be rounded 

each time that the value is calculated? And 

then, an average is calculated at the end with 

the rounded values? 

MS. ARMSTRONG: This is Ashley from 

DOE. 

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 And I caveat this with you should 

read the specific language in the test 

procedure just to make sure they don't have 

additional rounding provisions for like the 

sample as a whole. And I think you meant if 

four units are tested, not one unit tested 

four times? 

But, okay, so if your sample, 

though -- most of the test procedures are 

written on a per-unit basis. If there are 

rounding provisions in the test procedure, 

they are applied per unit, each unit. And 

now, if there is additional sampling or 

rounding provisions applied to the sample, 

they would be specified for like the averages 

or the UCL/LCL, those types of things. Those 

mostly do not exist right now, though. 

All right. So, I think that is it 

with rounding, unless anyone has any other 

issues. 

(No response.) 

Okay. With that, I am going to 

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open the floor to just any other general 

questions you may have that are not specific 

just to room air conditioners, dishwashers, or 

clothes washers, or maybe across the board, 

before we move into our product-specific 

section. 

MR. OSANN: This is Ed Osann with 

NRDC. 

One more on rounding. This is 

actually on significant digits. I think the 

statement was made that significant digits are 

based on the metric that is in the standard. 

Just to be clear, would that mean, 

for example, that if a standard were expressed 

as, say, an efficiency of 97.6 percent, that 

the significant digit would be one decimal 

place? 

MS. ARMSTRONG: This is Ashley from 

DOE. 

Unless there are specific rounding 

provisions that prevail, DOE would compare the 

certified rating to the tenth decimal place, 

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as expressed in the standard, correct. 

MR. ANDERSON: This is Vince 

Anderson with Whirlpool. 

I am just kind of curious. That is 

the first time I have heard at least that, in 

the absence of any guidance in the test 

procedures relative to rounding, we would go 

to the standards provision. I just wonder if 

that ought to be documented perhaps as a 

guidance, so that it is clear how that should 

be applied. 

MS. ARMSTRONG: Thanks for your 

comment. We will consider it. 

MR. ANDERSON: Okay. 

MS. ARMSTRONG: Any other remaining 

questions or open, cross-cutting-type issues 

that may apply to all the products before we 

move on to room air conditioners? 

(No response.) 

Okay. Does anybody want to change 

seats? I know that we had a couple of 

requests at the beginning. So, before I move 

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right into room air conditioners, does anybody 

want to move around? If anyone else wants to 

join the table, there are three seats 

available. I promise I am not that bad. 

All right. We are moving ahead. 

We are ahead of schedule here. 

So, with this, I am going to 

strongly encourage that everyone speak up and 

talk because the more details we have about 

where the variances may lie between different 

labs, the more it will help us. So, the more 

details that you can explain, unlike the first 

section, we really don't have a lot of 

opinions on the next three at this point. It 

is really we need to hear from you guys what 

is happening, where the ambiguities exist, 

what is going on. So, I strongly encourage 

you to please come up and please speak up 

freely as you may wish. 

So, the first issue that was 

brought to our attention has to do with the 

actual installation of the room air 

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conditioner and the test chamber itself. 

So, with that, I am going to open 

the floor. I don't know whowants to speak 

first. Hopefully, a lot of you want to speak, 

as well as I will be monitoring the phone or 

the webinar in case anybody else wants to 

speak on that. Feel free to raise your hand, 

and we will call on you as we cycle through. 

But, yes, open the floor. 

MS. CLEARY: This is Jen with AHAM. 

We have a handout that we brought 

which goes through some of these issues that 

are on the agenda. Would it be helpful to put 

it on the screen? We have it there as well. 

MS. ARMSTRONG: Do you want to 

describe what the general issue is, or 

somebody? And then, maybe different people 

can speak to different potential 

interpretations or that type of thing with 

additional details other than what is in the 

box, just to help us understand. 

MS. CLEARY: Sure. I mean, maybe 

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some of the companies want to speak, too. 

MR. LINGREY: Yes, this is David 

Lingrey from Friedrich Air Conditioning. 

There are basic types of room air 

conditioners with regard to chassis design. 

There are fixed chassis designs where the unit 

is contained as one fixed unit. You can't 

pull out the internal parts of the unit. It 

just gets mounted in the wall. 

Then, there are slideout chassis 

designs where you would mount the shell into 

the window, and then you could slide in the 

internals. When that is slid in, there are 

some sealing gaskets that normally need to be 

put in place. 

The standard, of course, says that 

no effort shall be made to seal internal 

construction of the air conditioners. I think 

that is meant for where there are bulkheads or 

passthroughs where we seal for piping and 

electricals and that sort of thing. I can see 

that that makes sense not to do that because 

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that would be, in effect, probably a 

manufacturing deficiency if those weren't 

sealed properly between the indoor and outdoor 

cavities. 

But when there is a slideout 

chassis, the gaskets need to be applied 

properly obviously. Otherwise, there can be 

some air changes or exchanges from indoor to 

outdoor, and vice versa, which would affect 

the efficiencies. And obviously, those need 

to be put in place with regard to the 

manufacturer's instructions and that sort of 

thing. 

I think there have just been some 

cases where, because of placements, optimum 

placement, it is not necessarily conveyed or 

understood by the testing lab. In some cases, 

there have been noticed errors. Okay? 

And then, for example, an air 

conditioner may be able to be slid right or 

left inside the chassis and it tests in 

performance better when it is on, say, the 

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left side than the right side. That is where 

things are optimized. 

Now, in the general public 

installation instructions, those testing 

optimization points are not necessarily 

conveyed because of marketing language 

simplicities, if you will. So, it is the 

matter of having a separate document or 

appendices that could be used by the testing 

lab to understand that better. 

Do you follow me? 

MS. ARMSTRONG: Oh, I follow. Do 

you know what's coming? 

This is Ashley from DOE. 

I guess I want to understand why 

you feel it is necessary to have additional 

testing instructions that an actual consumer 

wouldn't follow when it is installed in the 

field. In other words, you are not going to 

get that performance if you don't tell them to 

install it, as your example, on the left or on 

the right. If there is an optimal performance 

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location in a window, why should that be used 

for testing? 

MR. LINGREY: It is just an example 

of some of the things that could happen 

because the consumer doesn't test the product. 

They install it and they operate it. Okay? 

And it is just the way it goes. 

MS. CLEARY: This is Jen Cleary 

with AHAM. 

I think what we would be suggesting 

is that, if the manufacturer's instructions 

indicate sealing around the unit, for example, 

then that should be done during the testing. 

So, that would be something that the consumer 

would be seeing. I don't think that AHAM 

would be suggesting anything -- I don't know; 

I don't think David was suggesting, either --

that the unit should be tested on the right or 

on the left. I think what we are looking for 

here is that there should be consistency from 

lab to lab in how the units are installed. If 

the consumer would be installing it, sealed 

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around the edges, then that should be done 

during testing as well. That is how the 

consumer will see the product. 

MS. ARMSTRONG: Okay. So, this is 

Ashley from DOE. 

And I don't know; we have several 

labs in the room. And so, I encourage you 

guys to also speak freely. 

But I think, from the Department's 

position, in most cases in our test procedures 

we follow the installation instructions that 

are shipped with the unit. And so, that being 

said, if there are additional specifications 

that are not shipped with the unit, those are 

outside the bounds. So, if there are specific 

instructions you want DOE to follow, they need 

to be in the installation manual available to 

the consumer as well as anyone who may buy the 

unit. 

Yes? 

MS. CLEARY: This is Jen at AHAM. 

I think another issue we have here 

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in this first issue is that some labs may add 

thermocouples to be able to get some extra 

information about performance, and some labs 

may not do that. And so, what we would 

propose, I think, is that that should be 

permitted so long as it is not interfering 

with the airflow or the test results, that 

there shouldn't be anything to stop a lab from 

gaining that extra information about 

performance. 

MS. ARMSTRONG: This is Ashley from 

DOE. 

And, Ed, hang on one second on the 

line, and I will open it up as soon as I ask 

Jen a question. 

Can you just explain to me, I mean, 

I have an assumption, but can you explain to 

me what you would use the data from those 

thermocouples for? 

MS. CLEARY: I will open that up to 

companies to share. 

MR. LINGREY: You know, the issue 

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with regard to thermocouples, I don't know 

where that originated. I wasn't in all those 

original discussions. But, from a unit-undertest aspect -- this is David Lingrey, again, 

by the way -- we would monitor beyond what is 

done or entered into the ASHRAE 16 standard. 

For example, we monitor suction pressures and 

temperatures and discharge pressures and 

temperatures and some other things. 

So, we understand how the unit is 

operating beyond what can be measured in a 

calorimeter room just by measuring input watts 

into the space. And so, those are just some 

things, I think that that is why that was 

added there. 

But if that was the case, it should 

be done in every instance and it should be 

added in through ASHRAE 16 testing or SPC 

process. 

MR. CHURCHILL: Hello. This is 

Kevin Churchill from Intertek. 

As far as the thermocouples go, 

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they can be installed on units, and we 

generally do. They are used just an 

indication-only purposes. They are not 

installed internally as far as pressures go. 

Not all the units come with the availability 

of hooking on gauge lines or have ports for 

gauge lines. 

Also, I would like to speak on the 

insulation of the units. As far as we go, we 

can only follow what we are given by 

manufacturers for the insulation instructions, 

which those insulation instructions that we 

follow, we follow them just as the consumer 

would, step-by-step. So, if they have a 

right- or left-orientation, if they have a 

foam-orientation or a sealing-orientation, 

that is what we follow, which is directly what 

the consumer would follow. 

As far as the taping goes, when we 

do tape, there is a pressure that we must 

maintain constant between indoor and outdoor. 

So, the taping is just for a barrier wall 

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purpose, making sure that there is no air 

infiltration from indoor to outdoor. 

We do have to make sure to ensure 

that the taping is not over any sealing of the 

unit from the chassis itself to the cabinet. 

I think that is a major point to make there on 

that, of the insulation and the use of the 

taping. 

Thank you. 

MS. ARMSTRONG: Okay. Emily, do 

you mind unmuting Ed? 

MR. WUESTHOFF: Yes, this is Ed 

Wuesthoff at Friedrich. 

MS. ARMSTRONG: Go ahead. 

MR. WUESTHOFF: The only point I 

wanted to make had to do with listening to, 

reading the manufacturing instructions, and 

then reviewing some of the pictures after the 

test. Sometimes it takes like where you can 

see that maybe a sleeve was used that had been 

used repeatedly with the test facility, and it 

does not represent what is actually 

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manufactured, from what the customer would 

get. 

So, sometimes maybe the opportunity 

to balance the way a unit has been tested may 

be something that we want to consider because 

there are cases that you witness the test 

setup for certain products that we build when 

being tested for AHRI, for example. 

Ed. 

MS. ARMSTRONG: Okay. Thank you, 

MR. WUESTHOFF: You're welcome. 

have 

about 

MS. ARMSTRONG: 

any comments or que

specifics regarding 

Does anybody else 

stions or details 

installation and 

thermocouple placement or the addition of 

thermocouples, before we move forward? 

(No response.) 

Okay. This is Ashley from DOE. 

The next issue -- and, Jen, I don't 

know if my agenda follows yours exactly, but I 

tried to do it this morning when I got in. 

But, anyway, the next issue on my agenda is 

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the addition of water to the drip pan -- it 

should say "drip," not "drop"; sorry -- prior 

to the initiation of the test. And that does 

follow No. 2. So, we are good to go there. 

So, I am going to open the floor 

about that, discussion of that issue. 

MR. BOWLEY: This is Brice Bowley 

at GE. 

Yes, I think looking at this, and 

trying to understand why someone would want to 

add the water, partly comes into the run-in 

and operation. A lot of times when the units 

are being run-in as far as for the unit to 

come to equilibrium, they are not being run-in 

under standard conditions. They are being 

run-in in any room that is available to allow 

the compressor components to wear and to 

basically come to a stable efficiency. 

So, even though the units run for, 

let's say, 24 hours, it may not have generated 

any moisture and accumulated in the drip pan. 

So, that being said, when it is put in the 

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room, it is not at a stable condition that 

represents it running for 24 hours. So, 

adding water to it allows it to come to a 

stabilized operation quickly. 

MS. ARMSTRONG: Thanks. This is 

Ashley from DOE. 

Just a question to you. If you 

were to add water to the drip pan before you 

start the run-in in a condition, would then 

you still not have to use the conditioned 

space or you would still have to use the 

conditioned space? Then, how long would that 

decrease the potential run-in? Does that make 

sense? 

MR. BOWLEY: Well, the run-in --

this is Brice Bowley at GE again -- the run-in 

and the effect from the water are different 

effects. The run-in, as far as if you added 

the water before the run-in and you run in a 

non-conditioned space and the humidity is low, 

you are going to remove the water. 

MS. ARMSTRONG: So, I guess the ask 

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here, then, if I understand you correctly, is 

run-in is down on my list, but to add water 

for what period of time? Just when the test 

is being initiated or for a certain period of 

time after run-in, before the test, to allow 

for stabilization? What exactly are you 

asking? 

MR. BOWLEY: Yes, to be added prior 

to the equilibrium, you start the hour 

equilibrium. So, there is an hour-long 

equilibrium. You add the water before the 

equilibrium, let it run, and spray water. If 

there is too much water, it will spray off on 

the condenser and it will evaporate away, and 

would, hopefully, come to a stabilized 

condition. 

And I know Jen's also comment is 

there may need to be additional work done as 

far as unit equilibrium, because right now the 

equilibrium is room equilibrium, but there is 

no definition around is the unit running at 

equilibrium. 

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 MS. ARMSTRONG: This is Ashley from 

DOE. 

So, do you have information as to 

what you would suggest what a unit equilibrium 

is as compared to a room equilibrium? I mean 

not for GE, but generally that would be 

applicable across the board? 

MR. BOWLEY: Yes, I don't have one 

today, but we talked about that at our last 

meeting, that we need to basically develop a 

method of determining unit equilibrium. 

MS. CLEARY: This is Jen at AHAM. 

So, I think we would probably be 

talking about this within AHAM and be glad to 

submit a suggested definition to DOE, if we 

are able to find one. 

MR. LINGREY: This is David 

Lingrey. 

Yes, I agree with that as well. 

MR. OSANN: This is Ed Osann with 

NRDC. 

Just to be clear, is the addition 

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of the water to reduce the time to prepare the 

unit for testing or to reduce the running time 

of the test? 

MR. LINGREY: It is to reduce the 

running time of the test, because it takes "X" 

number of minutes or hours to condense the 

water out of the air and direct it from the 

condensate pan into the water slinging area in 

the condenser, where it is used to help 

optimize efficiency. Because we pull out "X" 

pints per hour or grams per minute, or however 

you want to measure it. So, we are just 

trying to short-cycle that by adding some 

volume of water. Whether that water has the 

right volume or the right temperature, and 

that sort of thing, needs to be addressed to 

keep being stable. 

MR. OSANN: Just to follow up --

this is Ed Osann from NRDC again -- are there 

any characteristics of the water that affect 

that at all, either the chemistry or the 

temperature? 

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 MR. LINGREY: The water that is 

condensed, it is condensed water. So, it 

doesn't have a lot of any mineral content or 

anything of that nature as well. So, it needs 

to be distilled-type water you are adding. 

But it is so minor, I would imagine, unless 

you have really terrible water -- as far as 

temperature goes, you don't want to add in 

100-degree water, and you don't want to add in 

40-degree water. It needs to be something in 

the middle, and wherever that is, I guess the 

unit would reach equilibrium with the water 

temperature and with the environment. So, 

that you would need to interpret as part of 

that definition of equilibrium. 

MR. OSANN: One last question. Ed 

Osann with NRDC. 

What is the potential reduction of 

running time of the test? Is this a matter of 

reducing the time by a few percentage points 

or is this reducing it by a third? Or what is 

the sense of how much value this adds in terms 

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of reducing testing time? 

MR. LINGREY: This is David Lingrey 

at Friedrich again. 

I think it varies with unit type 

and size. I mean, I guess maybe the lab 

testing people can convey that as well. 

MR. CHURCHILL: Kevin Churchill 

with Intertek. 

As far as adding the water, we 

talked a little about hours up to days of what 

the unit would actually have to condense out 

of the air to actually fill up the drip pan 

enough to actually get the slinger working up 

to the conditions that they had it at design. 

So, adding the water to the beginning of the 

test would certainly decrease the time that 

you would have to wait for the condensate to 

actually be produced from the actual unit. 

And thus, that would help the unit to actually 

get itself into the equilibrium point of the 

unit and stabilizing out the room. So, 

addition of the water would help just to get 

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the room to the point quicker and the unit 

running properly quicker, rather than waiting 

for it to actually produce the water itself. 

MR. LINGREY: Thank you. 

MS. ARMSTRONG: Okay. Anything 

else on water? 

(No response.) 

I am actually going to skip one and 

just go ahead. This seems like a good segue 

into run-in time before we actually talk about 

air sampler placement, my favorite topic. 

So, run-in time, I am going to open 

the floor. As you know, DOE does not have a 

run-in time right now specifically in its test 

procedure for room AC. So, open the floor for 

a discussion of run-in time, including any 

specifics. And I am going to ask you to 

submit data over what that should be. 

MR. BOWLEY: Brice Bowley, GE. 

Our past experience has shown that, 

obviously, the first 24 hours you get the most 

reduction in energy usage as the compressor 

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components wear, but it continues to drop off 

up to like 72 hours. But it is an exponential 

curve, so you are dropping dramatically from 

zero hours to 72 hours. 

I think what it is similar to is 

the EPA measurement for automobiles, which has 

a 5,000-mile run-in. So, when you look at the 

two, they are very similar as far as the 

amount of hours under operation. So, 72 hours 

for an AC or 5,000 miles for an automobile. 

MS. ARMSTRONG: So, one question 

back to you. This is Ashley from DOE. 

There are a couple of variations, 

24 all the way up to 72. Are you advocating 

that 24 is sufficient because most of the 

benefit is gained in that 24 hours? 

MR. BOWLEY: I think 24 is 

sufficient, yes. 

MS. ARMSTRONG: Does anyone else in 

the room have thoughts on that or anyone else 

on the phone? 

MR. LINGREY: This is David 

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Lingrey, Friedrich. 

Yes, run-in times do vary by 

compressor size and manufacturer. But, again, 

it is important to loosen-up and wear-in those 

components. So, in 24 hours, we have found 

that is a good run-in period with a brand-new 

product. 

MR. OSANN: Ed Osann with NRDC. 

Perhaps either AHAM or any of the 

manufacturers can answer. Is it standard 

practice for room AC units to be shipped 

without any running time on them at all? 

MR. LINGREY: This is David at 

Friedrich. 

In most manufacturing -- and I 

don't know of everybody's manufacturing 

facilities -- but there is a run test that is 

performed, but it is certainly isn't of that 

duration, obviously, because of trying to get 

the product out. 

So, we run units for "X" minutes 

and that's it. But it is really not anything 

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that would be that long. 

MR. BOWLEY: This is Brice Bowley 

at GE. 

The operation time would be five or 

ten minutes. So, it certainly wouldn't wearin the compressor components. 

MS. ARMSTRONG: Okay. Does anyone 

else have anything they would like to say on 

run-in before we move on? 

All right, Detlef, you are on the 

phone. 

MR. WESTPHALEN: Hi. This is 

Navigant Consulting. 

The only question I have in regard 

to the run-in is I am aware -- I haven't 

really looked this up myself -- but I have 

been told that (phone cuts out) for run-in up 

to not more than --

MS. ARMSTRONG: We can kind of hear 

you. I don't know if you are on speaker on 

your phone, but if you could take it off? You 

are kind of cutting in and out. 

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 MR. WESTPHALEN: Okay. I took it 

off speaker. 

MS. ARMSTRONG: Everybody in the 

room can mute their microphones, if possible. 

MR. WESTPHALEN: Okay. Is this 

better? 

MS. ARMSTRONG: Much better. 

MR. WESTPHALEN: Okay. The 

question is in regard to the AHRI standards 

for some air conditioning products, commercial 

products, where they talk about a run-in of up 

to 24 hours and not more. And I guess I am 

just wondering about the inconsistency of 24-

hours-plus versus up to 20. 

I know that there is a rulemaking 

getting started on packaged terminal air 

conditioners, which are very similar, 

obviously, to the room AC. They use the same 

ASHRAE 16 standard for the testing. 

So, the question comes up, what is 

the appropriate run-in time and why would the 

AHRI recommendation be up to 20? Back to 

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Ashley's comment about whether there is any 

test data that would be used to really 

demonstrate what the right amount of time is. 

MR. BOWLEY: This is Brice Bowley 

at GE. 

I am not sure why AHRI posed a 

maximum. I mean, again, the units are going 

to reach a maximum efficiency and continue 

that maximum efficiency for what would be the 

equivalent of years after the initial run-in. 

My suspicion would be that they put 

a maximum on it to limit test time in the 

labs. 

MS. ARMSTRONG: So, this is from 

Ashley from DOE. 

I can't speak to AHRI's program and 

how they run it themselves. I can tell you 

that DOE just adopted for commercial air 

conditioning units an up-to limit of 20 hours. 

An up-to limit, we say we will at least just 

for commercial, and we did it through a 

rulemaking, not through guidance, we said that 

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we would do whatever the manufacturer did to 

certify their products up to 20 hours. 

So, in other words, if you guys, 

when you came up with your certified rating, 

put in the lab time to do 20 hours, we would 

match that for any DOE-initiated testing that 

we did. And that is only for commercial, and 

that was dealt with through the rulemaking. 

And like Detlef said, I would 

encourage you to submit test data for room air 

conditioners or for certain types of 

compressors that shows over time what the 

appropriate run-in period may be. Because, as 

you have heard today, there are a variety of 

different numbers that are being tossed 

around. What the appropriate one would be 

would be something the Department would have 

to consider. 

MR. MENZER: This is Mark Menzer 

from Intertek. 

I cannot speak for AHRI, certainly 

on the program, although we do some of them. 

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I don't know of which program you speak. AHRI 

has about close to 40 programs with 40 

different sets of rules. But they also do 

about 2500 tests a year, and the problem just 

becomes when every unit, 2500 units are being 

looked at doing run-in. You just run out of 

time and you run out of space. So, they 

sometimes put some limits on it, but certainly 

24 hours or much more than that is not unusual 

for certain product classes for AHRI programs. 

MR. ANDERSON: This is Vince 

Anderson, Whirlpool. 

I am just curious, when you have a 

maximum run-in time, then how do you conduct 

comparison tests between labs? And how was 

that addressed for those commercial products? 

In other words, test the product in Lab A and 

then send it to Lab B and test that same 

product again to make sure they correlate. 

MS. ARMSTRONG: Yes. So, this is 

Ashley at DOE. 

If we were to do a DOE-initiated 

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round robin for commercial, we would uniformly 

specify that across the board. So, say, for 

example, we might use 20 across the board for 

that unit or those units that we were testing. 

Does that make sense? So, the same unit will 

get the same run-in or we would specify the 

provisions. 

If it is DOE-initiated testing for 

verification or enforcement purposes, we are 

testing at one third-party lab, and that would 

follow whatever the duration was that was 

certified with the unit when it was submitted 

to the Department. 

MR. ANDERSON: I still didn't 

understand how you would address that in the 

round robin. Because when it goes to the 

second lab, it is going to have 40 hours of 

runtime on it then. 

MS. ARMSTRONG: Oh, yes. It is 

like how are you going to --

MR. BOWLEY: So, this is Brice at 

GE. 

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 I think, normally, a round robin is 

run, like in air conditioners, it is run for 

an extended period of time and then sent from 

lab to lab. So, it is at stabilized operating 

conditions. 

MS. ARMSTRONG: So, you would 

advocate running it in first and then starting 

the round robin extensively, apparently? 

Okay. 

Anybody else. Sorry, this is 

Ashley. Anybody else or anybody else on the 

phone for a run-in period? 

(No response.) 

If not, we are moving to our last 

issue for room ACs perhaps. 

Okay. The placement of the air 

sampler. I am going to open the floor for 

that one. 

(No response.) 

Okay. Well, quietness means 

everything is being done right. Because, 

then, we can take it off the issues list. And 

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uniformly across from lab to lab, 

manufacturers alike. 

MR. MORRIS: This is Wayne Morris. 

Jen had to step out. 

This is an issue that has come up 

on a few occasions where the air sampler is 

placed near the unit. The ASHRAE standard 

actually specifies a different circumstance, 

but our question is making sure that the labs 

are all doing it the same way. Our intention 

is to make sure that the air sampler is placed 

in a sequence or in a location where it does 

not interfere with the movement of the air, 

but which you actually get a good sampling of 

the air near the unit. 

There are units that are, of 

course, different sizes. And so, specifying 

one particular distance away may not work in 

all cases. 

So, we would just like to know if 

the Department has any guidance in terms of 

this or if we could use language as is 

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suggested there on the screen with the request 

that we have made. 

MS. ARMSTRONG: This is Ashley from 

DOE. 

I am actually going to turn that 

around to other people in the room. What do 

you currently do, both the labs and the 

manufacturer labs? 

(No response.) 

I could start calling you by name. 

You have name cards. 

(Laughter.) 

MR. CHURCHILL: Kevin Churchill 

from Intertek. 

Obviously, right now, the way we 

have it is with the sampler trees, every unit, 

it is taken from a unit basis. Some units do 

have one inlet; some have two. Some have 

different placements, depending on the unit 

style, whether it be a built-in unit or a 

regular unit. 

Obviously, the main intent is to 

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try to get the sampling of the air going to 

the inlet of the unit without restricting any 

of the airflow to it. So, with that said, we 

try to get it as close as possible without 

restricting the air. 

We use one air sampling tree on the 

single inlets, two on the dual. We try to 

place them far enough away from the unit. We 

have it about three to five feet, is in our 

procedure. In that comes a point where you 

need to try to keep it away from the 

condensing air as well, so you are not 

recirculating the air. 

Currently, in the standard I 

believe they are in the process of updating 

the picture that they have in there of the 

actual placement of the unit. Obviously, for 

manufacturers, they can always step in on that 

guidance as well on placement of the air 

sampler tree. 

Thank you. 

MS. FARBER: This is Julia Farber 

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from UL. 

We actually completely agree with 

what Intertek just said, and we are also 

running our tests in a similar fashion. 

MR. LINGREY: This is David Lingrey 

at Friedrich. 

Obviously, the sampling tree is a 

device that can impede airflow. And we feel 

that there is a location minimum, so to speak, 

that you don't want to impede on. If there 

would be something placed in the certification 

document perhaps that would indicate a stayaway zone or to prevent recirc or prevent 

impediments there, that might be appropriate. 

MS. ARMSTRONG: So, this is Ashley. 

Does anybody do it a lot 

differently than what Intertek or UL 

described? 

(No response.) 

I guess I am trying to understand 

what the actual issue is. It seems to be just 

general agreement with the description. 

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Page 76

 MR. MENZER: Yes, this is Mark 

Menzer from Intertek. 

I think it is just one of these, it 

is an engineering judgment call. In these 

standards, for consistency, you want to 

minimize engineering judgments and maximize 

specificity. 

MS. ARMSTRONG: Okay. So, thank 

you. 

This is Ashley. 

So, with that in mind, I can 

appreciate that. To the extent that you all 

can work together to articulate what that 

engineering judgment is in a fashion, whether 

it be through the ASHRAE process, through the 

AHAM process, through a voluntary consensus 

process, and submit those to the Department, I 

think that is something that we would need 

those details to be able to flesh out some of 

these issues that you are asking for. 

Otherwise, I just put my engineering judgment 

in there. And, well, that might not be a good 

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idea. 

MR. MORRIS: Ashley, it is Wayne 

again, Wayne Morris with AHAM. 

We appreciate that and understand. 

I think part of the concern has come that the 

AHAM standard doesn't specify, shall we call 

it, a minimum or a setback, as David said. 

The ASHRAE really was not intended for this 

kind of circumstance. And so, it doesn't do a 

very good job of specifying. 

I think that it is not something 

that we have found that it makes an enormous 

difference, but it is one of those where it 

could affect, as we narrow down the amount of 

deviation or differences that occur, the 

significant digits of the actual values, this 

becomes a potential area. So, as we get 

differences in laboratories that laboratories 

are testing, we want to try to reduce it. 

So, I think that your suggestion is 

probably a good one, that AHAM would take on 

as a responsibility to make a suggestion of 

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what we believe is the right way to organize 

this. Whether it be a range or whether it be 

a minimum distance, we will look at that. 

I think that you are dealing, also, 

as Kevin said, with a 3-dimensional kind of 

situation. It is that optimization where you 

want to make sure you don't interfere with the 

airflow, but you also need to get it close 

enough that you don't have outside influences 

on this. So, we will look at this and see if 

we can come back with a suggestion on this. 

MS. ARMSTRONG: Thank you. 

MR. MORRIS: Good. Thanks. 

MS. ARMSTRONG: Okay. So, this is 

Ashley. 

We have a question from the table 

to ask. So, the issue of recirc has come up. 

So, I am going to ask the labs in the room, 

all those, as well as anyone else that would 

like to chime in on this, how do you check for 

recirc? What do you do now? 

MR. LINGREY: David Lingrey, 

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Friedrich. 

There are several ways to do 

recirculation assessments. One of them is use 

smoke traces and some different things. Of 

course, that would be something that would be 

done in development. 

Another is computational fluid 

dynamics and things of that nature. But, 

again, that wouldn't be something that would 

be done through --

MS. ARMSTRONG: I haven't done that 

since grad school. 

(Laughter.) 

MR. LINGREY: Yes. But just from a 

research standpoint, there are some methods 

that are used to come at it. From a design 

perspective, we add some things to prevent it. 

MS. ARMSTRONG: So, I am going to 

come back and say, research aside, when we get 

into audit checking, or whatever you do in 

terms of testing, just to check to make sure 

parts off the line are performing the way they 

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are supposed to; there has been no variation. 

Do you do any recirc checks then? 

And if you do, how do you do it? 

MR. LINGREY: It is David from 

Friedrich again. 

We do add instrumentation on units 

under test that is outside the scope of the 

test protocols, you know, some thermocouples 

and some different things that are generally 

placed to understand if we are getting some 

recirc. But that is something that I am not 

sure that the labs are doing. 

MS. ARMSTRONG: Would you be 

willing to describe that general placement for 

me? Like what exactly is it? Where do you 

put them? What do you do? 

MS. FARBER: Can I interrupt for 

just one second. I'm sorry. 

One of our folks on the phone, he 

keeps saying that your microphone is going in 

and out. So, he can't hear what you are 

saying on the phone. 

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 MR. ANDERSON: I think when the 

light is on --

MS. ARMSTRONG: Yes, so just come 

close to it. Light on means it is on. 

MS. FARBER: I am sorry. They are 

really interested. He is like it sounds like 

it is active there; I just can't hear. 

(Laughter.) 

MR. LINGREY: I don't know what I 

cut off on. 

MS. ARMSTRONG: Whatever she asked 

about. 

MR. LINGREY: Well, the guy on the 

back-end. 

Well, thermocouple placement can be 

placed on the inlet and discharge areas of the 

unit, and maybe even in a grid array, to 

sample over the aspect, the cross-sectional 

area of 

temperature 

recirc. 

that inlet, to 

differential 

see if there 

that is caused 

are 

by 

MS. ARMSTRONG: This is Ashley. 

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 And that wouldn't impact the 

airflow? 

MR. LINGREY: Well, thermocouples 

are just a wire with a small thing. 

MS. ARMSTRONG: I understand. 

MR. LINGREY: They are very small, 

and they probably in most cases will not have 

any sort of impact. 

MS. ARMSTRONG: Okay. Thank you. 

Anybody else? 

(No response.) 

So, I am going to open the floor to 

other issues, if anybody has any, with regard 

to room air conditioners testing. For those 

that they want to do an open floor, we are 

probably going to take a break before we move 

on to the next product of the day. 

MR. MORRIS: Ashley, I don't know 

whether there was a fourth one on that sheet. 

MS. ARMSTRONG: Yes. I popped that 

one in front. Yes, that is all the ones I 

have, I think. Yes, sorry. I could have 

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stood it up. Okay. 

Yes, run-in we got. 

So, anybody else have any other 

issues with regard to room air conditioners 

that they would like to discuss? 

(No response.) 

Okay. At this time, I am going to 

propose a 15-minute break. There is a coffee 

shop all the way on the ground floor or, for 

anyone interested, bathrooms are to the left, 

elevators to the right. 

For the room air conditioner 

manufacturers that are leaving, I thank you 

for your participation. Should you have 

additional questions or think of additional 

things, feel free to email me after the 

meeting or subsequently. 

And we will see you back in about 

15 minutes. 

(Whereupon, the foregoing matter 

went off the record at 10:24 a.m. and went 

back on the record at 10:47 a.m.) 

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 MS. ARMSTRONG: Okay. All right. 

We are going to start back now. We have 

almost everyone. 

So, we are going to move right 

along to dishwashers. 

Like I said before -- this is 

Ashley from DOE -- but, like I said before, I 

strongly encourage everyone in the room to 

stand up and provide us details. It is hard 

for the Department to take action items away, 

at least to further understand and investigate 

here with what we need to do, without 

additional details of what is actually being 

done different and how things are being done 

different. 

So, I am once again going to 

reiterate the strong importance to stand up 

and, if you all do it the same way, that is 

great. If it is just that you all do it the 

same way and that way is not detailed enough 

in the procedure, that is great, too. I mean, 

any details, anything that you can provide is 

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helpful. 

So, with that, moving right into 

dishwashers, the first question we had was 

regarding the 2010 Test Procedure Guidance 

regarding cycle selection. 

And, Jen, you are going to have to 

help me out with these, if you don't mind, 

just walking through. I will put your actual 

dishwasher one up there, and if you could walk 

through at least the introductory issue, and 

then if everyone else could chime in 

appropriate, that would be great. 

MS. CLEARY: Sure. This is Jen 

as 

with AHAM. 

While you are putting that 

actually, I can just start with the first 

up, 

issue, which is there was some guidance issued 

in response to a question from a company in 

2010 on cycle selection. It stated that a 

soil-sensing cycle is to be used, even if the 

normal cycle is fixed. And to some, this 

guidance changed the interpretation of the 

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test procedure. 

And so, I think one issue that we 

had at the time, which with passage of time 

may be less relevant at this time, although we 

wouldn't want to see it in the future, is that 

it would have been better prior to finalizing 

that guidance if you had sought input, which 

they are now doing. You are now doing it. 

So, we appreciate that. 

This issue, DOE is proposing to 

address this in the SNOPR that was issued this 

month. So, we are still reviewing that 

proposal. We appreciate that DOE is taking 

the initiative to address it. And we will 

certainly provide written comments on the 

issue. 

But a major concern here is how 

different labs will do this testing. And so, 

we do think that there should probably be an 

interim solution of some kind while the 

rulemaking is ongoing. 

This is really a complex matter. 

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So, what AHAM would propose is that, if it is 

possible for DOE to require or permit 

manufacturers to indicate on their 

certification statement the cycles and options 

that were used during the energy test, that 

might be a way to address this and to ensure 

that DOE and other third-party labs that might 

be doing verification testing would be using 

the same cycles and options that were 

selected. 

It might also be useful to identify 

in the certification report whether or not the 

unit is soil-sensing, whether the cycle is 

soil-sensing. That goes into kind of our next 

issue as well, but I think that issues 1 and 2 

on our sheet are connected and stem from the 

same guidance. 

So, issue 2 is, how does a lab 

identify if the cycle is soil-sensing? Again, 

this is complicated. I am sure companies have 

more details to share, but that is the general 

issue. 

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 MS. ARMSTRONG: Go ahead. Like I 

said, I do encourage you -- this is an open 

rule. I will remind you DOE will not probably 

at this point, because it is an open rule, 

make comments. We have proposed stuff. To 

the extent you have comments on our proposal 

or further clarification, I strongly encourage 

you to submit them to this docket. You are 

welcome to speak in this forum as well, but, 

also, please submit them to that docket as 

well. 

MR. KLUG: Well, good morning. 

Wayne Klug at Whirlpool. 

Certainly, the SNOPR content is 

very helpful in regard to this topic. As I 

look at the definition of the normal cycle in 

the SNOPR, and I don't think that has changed 

very much from the original language of the 

current procedure. It talks about the cycle 

type that includes wash-and-dry options 

recommended by the manufacturer for completely 

washing a full load of normally-soiled dishes, 

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including the power dry option. 

As I look at the SNOPR content that 

is being proposed -- and this is 2.6.3.2; 

sorry about the chapter-and-verse reference 

here, but I think it is helpful to have that 

context -- it looks like that if a normal 

cycle does not contain a soil-sensing 

capability, then another cycle that may 

contain that soil-sensing capability is used 

or would be used for the testing. 

And so, really, more for 

clarification, it sounds like a manufacturer 

may be able to recommend or identify a normal 

cycle, but you could have a non-normal cycle 

of, say, pots and pans on a more heavy-load 

end of the spectrum or a cycle on the other 

end of the spectrum that is not as heavy in 

terms of cycle behavior that could be used for 

the actual soil-sensing load and not the 

normal, everyday cycle that would be 

specified. 

So, really, I was just looking for 

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more clarification around that topic. Sorry 

about the long wording and description. 

MS. REICH: Judith Reich from 

Navigant. 

Yes, you are correct, the SNOPR 

does address that particular topic, and it 

does, indeed, follow the approach in the 

guidance that was provided to the 

manufacturer. And you are also correct in 

that, if the normal cycle does not have soilsensing capability, it is the proposal that 

the alternate cycle that does have soilsensing capability be tested because the 

provisions in the test procedure for testing 

under varying soil conditions are intended to 

be used for soil-sensing dishwashers. 

MR. KLUG: All right. Thank you. 

So, really, just probably more of a 

footnote would be that the normal cycle may be 

an everyday use sort of cycle. But one of 

these other cycles may be less common, less 

commonly used by customers, but that could end 

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Page 91 

up being used for the actual test procedure. 

MS. ARMSTRONG: Good. Thank you. 

MR. EDWARDS: Mike Edwards, BSH. 

So, how would the verification labs 

determine if it is a soil-sensing cycle unless 

we tell them something? 

MR. BILLINGS: Lincoln Billings 

from Intertek. 

The only methods we have to 

determine whether or not a unit has soilsensing capabilities is through what is 

provided via the use-and-care manual of the 

unit. 

MS. ARMSTRONG: So, this is Ashley 

from the Department. 

So, you are advocating Jen's 

position of perhaps writing more information 

upon the certification of the products, about 

its features? 

MR. EDWARDS: Mike Edwards from the 

BSH team. 

Yes, that is correct, either in the 

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certification report or the manual. 

MS. ARMSTRONG: Okay. 

MR. EDWARDS: I think we have to 

include additional information. 

MS. ARMSTRONG: So, a question 

about what you do currently, because, 

obviously, open rule, but do you all, if it 

has a soil sensor, is that clearly indicated 

in the manual shipped with the unit now? 

MR. EDWARDS: For BSH, it is now. 

MS. ARMSTRONG: Okay. 

MR. EDWARDS: But it hasn't always 

been. 

MS. ARMSTRONG: Okay. 

MR. KLUG: I believe that is the 

case for Whirlpool as well. 

MS. ARMSTRONG: Okay. All right. 

Any other issues with the first couple? 

(No response.) 

Okay. The next issue I think we 

are going to go to is the detergent volume 

calculation. 

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 MS. CLEARY: Hi. This is Jen with 

AHAM. 

Some interpretative confusion 

exists regarding the detergent volume 

calculation. I think there maybe has been 

some guidance around this. In any case, it is 

now addressed; DOE is proposing a solution to 

this in a SNOPR. So, we will certainly submit 

some written comments. We are reviewing that 

proposal. 

We had also raised an issue about 

the actual detergent itself, and that has also 

been addressed in the SNOPR, the Cascade with 

the Grease Fighting Power of Dawn. So, we 

certainly support that. 

Upon first review of the proposal 

with regard to the calculation, though, we 

think there may still be some room for 

interpretation that would make verification 

testing challenging. So, we will detail that 

in our written comments. 

Kind of a connected issue here, 

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recently, phosphates are no longer allowed in 

the detergent and, also, we believe that 

consumers may be using the tablet form of 

detergent that could have rinse aid in it as 

well. And it is a dosage that is the same 

every time. So, we think consumers are using 

those more and more, and it may be necessary 

to do some kind of consumer use study on how 

those different detergent types should be 

incorporated into the test procedure as well. 

That is, obviously, a longer-term thing, and 

we can provide some more detail on that in 

written comments as well, but wanted to raise 

that here today. 

MS. ARMSTRONG: All right. Thank 

you. 

MR. EDWARDS: Mike Edwards, BSH. 

I think one point of confusion is 

that, if you run the preconditioning cycles 

and determine your detergent calculation, and 

then when you run the actual test, if the 

water usage comes out differently, what do you 

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do in those cases? 

And one other one would be that, if 

you determine from the precondition cycles to 

use detergent in the pre-wash and the main 

wash, and then the sensors take out the drain 

so that they become one and the same, how 

would you interpret that detergent usage? So, 

just a couple of things to keep in the back of 

your mind. 

MS. ARMSTRONG: Do you have a 

suggestion? 

MR. EDWARDS: No, not at this 

point, but I think it is something we could 

try to work on. 

MS. REICH: Judith Reich from 

Navigant. 

I just wanted to point out that in 

the SNOPR one of the proposals would be to 

require that the preconditioning cycle be run 

with the same cycle setting as for the energy 

test to try to ensure that the water 

consumption that is measured to determine 

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detergent dosing is as close as possible to 

what is used during the energy test. 

MR. EDWARDS: Mike Edwards, BSH. 

So, you do the preconditioning 

cycles with food soil? Is that what I am 

understanding? 

MS. REICH: The proposal right now 

is for no load during preconditioning. 

MR. EDWARDS: Mike Edwards again. 

The sensors and the food soil will 

impact each other. 

MS. REICH: I recognize that, and 

it was an issue of test burden to do the 

preconditioning without the soil load. 

MR. KLUG: Wayne Klug at Whirlpool. 

I think, on that topic, Jen's 

earlier point and Mike's point, as we look at 

potentially the use of tablets, which are more 

commonly-used today perhaps as we migrate in 

that direction, or look at migration in that 

direction, that may allow us to move away from 

that percent concentration approach/concern 

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and use really what the customers are doing 

when they are putting a tablet or a uni-dose 

or a set amount of detergent in their machines 

more and more. It is just an option for us to 

look at. 

MS. ARMSTRONG: Okay. Chris 

Roberts on the phone, I think your line should 

off mute now. And I am going to ask everyone 

in the room to mute their lines, if they don't 

mind. 

Chris? 

MR. ROBERTS: Yes, ma'am. 

MS. ARMSTRONG: There you go. 

MR. ROBERTS: I just wanted to send 

in a comment. We were talking about the useand-care books. And our use-and-care books do 

not indicate if a cycle (phone cuts out). 

MS. ARMSTRONG: So, can you get 

closer by chance to the phone? Or take me off 

speaker and then speak? Because you are 

cutting in and out when you are on speaker, 

please. 

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Page 98

 MR. ROBERTS: How about now? Can 

you hear me now? 

MS. ARMSTRONG: Much better. 

MR. ROBERTS: All right. Yes, 

there were the comments going about the sensor 

cycles versus the fixed cycles, and I was 

trying to just comment that our use-and-care 

books do not necessarily indicate which cycles 

are sensor-based and which are fixed. And 

that is why I shot you that note on the 

webinar notes through the questions. I think 

everybody else was commenting that they 

typically did indicate that. 

MS. ARMSTRONG: Okay. Thank you. 

MR. ROBERTS: Thank you. 

MR. OSANN: This is Ed Osann from 

NRDC. 

What company was the speaker with? 

MS. ARMSTRONG: GE. 

Okay. Anything else on detergent 

volume? Go ahead. 

MR. EDWARDS: I was just going to 

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make a comment. The detergent can influence 

the sensor decision. So, it is a 

fairlycritical subject. 

MS. ARMSTRONG: Okay. Thank you. 

Like I said, to the extent in your 

comments in response to the SNOPR, if you have 

a specific proposal -- I realize the SNOPR 

recently came out. So, you may not have time 

to fully have read it, et cetera. But to the 

extent you have any specific proposals or 

definitely proposals other than the ones we 

have, I encourage you to submit those in 

addition to your comments. 

Okay. The next one is 

substitutions. I think there is a variety of 

questions regarding this, whether it be 

flatware substitutions, soil substitutions, as 

well as table, for lack of a better term, 

tableware substitutions. 

So, Jen, I will turn it over to 

you. 

Some of this is also addressed in 

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the SNOPR as well. To the extent there are 

other things that need to be addressed, please 

let us know. 

MS. CLEARY: Jen with AHAM. 

Yes, flatware I know is being 

addressed in the SNOPR. We appreciate that. 

We made a recommendation to DOE, and we 

appreciate that the proposal is to adopt that 

recommendation. 

Then, there are, though, some other 

substitutions that we can see right now need 

to be made. And also, we anticipate that, 

because like the food soils and the dishware 

and the flatware are all specified, you know, 

exactly, that as those things change and they 

are outside of our control, this is an ongoing 

issue that things become obsolete. 

And so, I would think the broad 

issue with substitutions is that there needs 

to be some kind of quick and clear process for 

getting substitutions. 

Rulemaking, probably while it was 

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very handy that this time around there was an 

open rulemaking to address flatware, and, 

hopefully, we can get some of these other 

issues that we have to raise today taken care 

of through that rulemaking as well, that is 

not always the case. If it is no longer 

available, it is hard or impossible to do 

testing until there is something uniform in 

terms of the substitution. So, I think that 

is the overarching comment. 

Specifically, for soils that are 

not available now exactly as DOE has 

specified, I think one example would be the 

margarine. I think we have seen some guidance 

to use the Fleischmann's Original margarine, 

but would look to see if DOE has guidance on 

that. 

AHAM's Task Force will certainly be 

evaluating substitute food soils and would be 

glad to make recommendations to DOE, but we 

would request those substitutions be made 

clearly and quickly. 

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 Also, the dishware -- this is No. 

5 -- the dishware that is currently -- 

MS. ARMSTRONG: Can I jump in real 

quick before we move on for margarine? 

MS. CLEARY: Yes, yes. 

MS. ARMSTRONG: So, obviously, any 

guidance DOE issued will be posted on our 

website and is only applicable for the 

regulatory program or is the guidance 

applicable for the regulatory program. 

What are manufacturers, third-party 

labs, doing now if there is unavailability of 

this margarine? Are you not testing? 

MR. EDWARDS: Mike Edwards, BSH. 

We have dishwasher dishes that are 

in specification. But if we have to get new 

ones, we could --

MS. ARMSTRONG: Margarine? 

MR. EDWARDS: Not margarine, no. 

We are using the margarine that we agreed to 

in the AHAM group. What is it, Wayne? Do you 

remember? 

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 MR. KLUG: Well, I think that, for 

example, the margarine, there is a stick 

original Fleischmann's original that is called 

or available that is kind of the closest 

representation of that margarine. So, we 

really kind of go out, whether it is the 

detergent or the margarine, we try to find 

that substitution that is really the closest 

match, and we talk about it within industry. 

Go ahead. 

MR. EDWARDS: We discuss it within 

AHAM and try to do the same thing. 

MS. ARMSTRONG: Right. Jen, or 

whoever, is this an AHAM thing that you guys 

discuss it and say, okay, we all agree to do 

this? At what point could you come to the 

Department? I mean, could you tell us 

upfront, "Hey, either this is almost obsolete 

or at least some of our members are having 

trouble finding it right when it happens."? 

And then, "Oh, we are working on a solution or 

an agreement internally." 

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 Because the earlier we know about 

it, the better. Obviously, I don't know how 

this affects -- we can talk about this 

internally as far as what pathway might get us 

to an answer the quickest. 

But, like I said, to the extent you 

are using something other than what is in DOE 

guidance and/or CFR that hasn't been approved 

specifically by the Department, that would be 

at your --

MS. CLEARY: Yes, so I think that 

is why we are raising these issues today, 

certainly. I think in the future, yes, we 

probably should notify you when we become 

aware of the issue, let you know we are 

working on it, as we did with flatware. I 

think that would be what we would continue to 

do. 

This is Jen from AHAM. 

MS. ARMSTRONG: And I would also 

encourage for anyone on the phone or any 

third-party labs in the room, if you have 

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similar issues, whatever lab it is, that you 

come to the Department and ask the question 

when it has to do with a DOE regulatory test 

procedure. That way, we can issue regulatory 

guidance and it will apply across the board. 

MR. KLUG: I think just to 

underscore Jen's comments, and I think she 

stated this very well, in that from time to 

time these items do show up. And a lot of 

times, there are surprises, like, "Oh, crud, 

we can't order this fork anymore." And so, we 

work to try to identify those substitutes and 

work diligently with AHAM, with the 

stakeholders, to try to find the right 

substitution. 

I think the point to underscore is 

just that process for substitution, whether it 

is a guidance approach or an industry-wide 

waiver. Because, really, the rulemaking is a 

great process, but it takes time to go through 

that process. And so, really looking for 

something that can expedite this, because it 

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is going to come up over and over. 

Even though we work with the 

suppliers of, let's say, cutlery and we ask 

them, "How long will you have the cutlery 

available," and they say, "Forever," or at 

least for a fairly long period of time, but, 

in reality, these things are going to come up 

over and over for us. 

MS. ARMSTRONG: Okay. We 

understand, to the extent we need to talk 

internally here, but we understand the issue. 

MS. CLEARY: Jen from AHAM. 

I think the only other detailed one 

that we would share today would be the 

dishware. This would be an example where we 

are giving you an early heads-up that it is 

not obsolete yet, what is referenced in 

Appendix C, but it is getting very difficult 

to source. So, we will be working on 

suggesting some substitutes and we will share 

that with the Department once we have a 

suggestion. 

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 MR. EDWARDS: Mike Edwards, BSH, 

again. 

More of a general comment, we need 

to try to make sure as best we can that we 

work with Canada and try to get consensus on 

the interpretations. We are seeing that 

Canada has a couple of different 

interpretations in some cases than DOE. That 

would be very burdensome. 

MR. KLUG: Yes, just to extend 

that, that is a good thought, Mike. To extend 

that a step further is there is a test 

procedure that Canada uses for energy testing 

as well. I know there are efforts to have 

those procedures be common and similar. But 

it does come up for really both countries. 

MS. ARMSTRONG: Okay. Moving 

along, preconditioning is the next issue. 

MS. CLEARY: This is Jen with AHAM. 

The issue that we have identified 

is that the definition of preconditioning is 

kind of vague, and it is not adequate for the 

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way some products operate today. The SNOPR 

published this month does make a proposal to 

address this issue, and Judy was discussing 

this earlier, which is that the 

preconditioning cycle would be the same as the 

one, the cycle or cycles used for the energy 

test. 

AHAM does agree with that. That 

was what our suggestion would have been. 

However, our first glance at the SNOPR, we 

think that the language in there may be a 

little too confusing, and it could just be 

more simply stated that the cycle used for 

preconditioning shall be the same as the 

cycles used for the test. So, we will 

certainly provide some more detail on that in 

our written comments. 

concerns 

time? 

MS. ARMSTRONG: Okay. Thank you. 

Any other comments or specific 

regarding preconditioning at this 

MR. KLUG: Wayne Klug at Whirlpool. 

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 Probably the only thought that 

comes to mind is the previous language 

associated with or in the existing DOE 

procedure seems to allow for a partial cycle 

to be used. The language, as I read it, in 

the SNOPR, 1.1.5, reads, "Preconditioning 

cycle means the cycle that includes a fill, 

circulation, and drain to ensure that the 

water lines and sump area of the pump are 

primed." And certainly, that is a very 

important aspect of the preconditioning cycle. 

But, as I think about this, we 

really want to ensure that there is an 

allowance for a complete cycle to be 

performed, so that sensors can be calibrated, 

so that the water usage can be established for 

the amount of detergent used. And so, perhaps 

as we look at the wording here, we can adjust 

it to reflect that a complete cycle or cycles 

be used/allowed for preconditioning. Because 

I am aware of some laboratories that actually 

perform more than one preconditioning cycle 

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just to be sure that the machine is cleaned 

out and they have understood the amount of 

water usage. 

MS. ARMSTRONG: Thank you. 

I actually just have a general 

question regarding soil sensors for you all. 

At what point are you sure that the soil 

sensor has actually been engaged? So, is it 

clear that, if it runs once in the 

preconditioning cycle -- and this may just be 

my lack of knowledge -- but is it clear that, 

if it runs once, that the soil sensors are 

engaged or does it actually need to run 

multiple times when it is first plugged in to 

make sure that soil sensor is working properly 

as it was intended? 

MR. KLUG: I can speak for the 

Whirlpool product, and the design intent is 

that one cycle is sufficient to establish the 

sensor behavior. Now we do have repetitions 

built in. If, for some reason, that first 

cycle doesn't calibrate, then it takes another 

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look at the next cycle as well. 

MS. ARMSTRONG: So, if that one 

cycle is used for preconditioning, how would 

you know, in other words? You can chime in 

here. 

MS. REICH: Judith Reich from 

Navigant. 

I wanted to add to that question. 

Does that first cycle require a soiled load in 

order to properly calibrate the sensor? 

MR. KLUG: For Whirlpool, no, we 

are really looking at the clear-water base. 

MR. EDWARDS: Mike Edwards, BSH. 

I agree with Whirlpool's comments, 

but in our lab we run two preconditioning 

cycles, one to clean out anything that may be 

in the machine, the oils or things like that 

were used in the manufacturing process, and 

then the second to actually get the 

calibration with the clean water. So, we are 

trying not to use the energy test calibration 

from something that may be influenced by 

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external stuff. 

MR. OSANN: This is Ed Osann with 

NRDC. 

Just an observation. It is not 

clear whether this calibration is something 

that is required, is a self-calibration of the 

sensor or this requires a tech to actually do 

something to the machine. 

MR. KLUG: For Whirlpool, it is a 

self-calibration. 

MS. ARMSTRONG: This is Ashley from 

DOE. 

I will say the Department has seen 

instances where the first cycle doesn't engage 

the sensor, for whatever reason. So, there 

are at least some products out there the 

Department has come across in testing where we 

have not been able to engage the soil sensor 

on the first run. 

That being said, if there is 

variation in the industry or even within a 

given manufacturer's model offerings, I would 

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ask, how do we ensure that the soil sensor is 

engaged? 

(No response.) 

Everyone is staring at me, for 

those on the phone who don't have the benefit 

of seeing the room. 

MR. EDWARDS: This is Mike Edwards, 

BSH. 

We have equipment in our labs, and 

we can tell that very easily in our internal 

tests. But I don't know how to describe it 

for you to tell that. 

MS. ARMSTRONG: So, how would DOE 

figure that out if it was running a 

verification test at a third-party lab? How 

would a third-party lab figure that out? 

MR. KLUG: Wayne at Whirlpool. 

I think my answer is the same as 

BSH, as Mike's. With our internal equipment, 

monitoring some connection to the controls, 

and so forth, we can get varying levels of 

that detail. But, for an outside lab, I am 

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not sure there is a clear way of determining 

that. 

MS. ARMSTRONG: So, then, our 

question would be, if there is variation -- I 

realize there may not be variation between 

those in the room here -- but if there is 

variation within the industry, is it 

worthwhile running multiple preconditioning 

cycles or a number of them, or maybe the 

manufacturer specifies that certification 

represents how many cycles that may take for 

you to ensure that the soil sensor actually is 

engaged, or whether or not it needs soils 

versus clean water, or the characteristics 

that would perhaps, maybe not ensure 100 

percent of the time, but for the most part it 

would be engaged? 

MR. KLUG: I think there is benefit 

to the additional cycles. For example, if the 

machine is taken out of the box, and maybe 

there is some sort of residual dirt in a 

factory process, something, that first cleanNeal R. Gross & Co., Inc.

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out cycle or first cycle could be used to 

clean the machine, if you will. 

So, additional cycles, at least the 

way our machines are set up, if it doesn't 

calibrate on the first cycle, an additional 

cycle would give it that opportunity to 

calibrate. So, more is better, although we 

try to make sure it functions as intended 

within that first cycle. 

MR. EDWARDS: Mike Edwards. 

I will just add to that some. 

Depending on how the manufacturers write in 

their program logic, it could receive a 

calibration error. And what they do after 

that could depend on whether you are getting a 

sensor response or not. So, if it gives a 

calibration error and they just stop the 

process, then it will have a default path that 

it would go to. So, it kind of depends on 

what the manufacturers are doing and their 

philosophy. So, you can't really answer for 

all the manufacturers. 

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Page 116

 MS. BARHYDT: This is Laura Barhydt 

at DOE. 

If there is some kind of a 

calibration problem, is there a light or a 

readout or something on the unit that would 

indicate that? 

MR. EDWARDS: No. Again, it 

depends on what the manufacturer decides to 

do. It doesn't mean that they can't ask for 

another calibration within that same run. So, 

there could be multiple calibration requests 

in that same cycle. 

MS. ARMSTRONG: Okay. So, it would 

just keep trying to calibrate, even though you 

are running the same first preconditioning? 

MR. EDWARDS: I know what we do, 

but I don't know what everyone else --

MS. ARMSTRONG: Right. That could 

be the case, though? I got it. Okay. 

MR. KLUG: Yes, similar with 

Whirlpool, it will work to calibrate on the 

subsequent cycle. 

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 MS. ARMSTRONG: Okay. 

MS. BARHYDT: This is Laura Barhydt 

at DOE. 

One other thing that we have 

encountered is that some units don't run the 

selected cycle, depending on what feedback it 

is getting through its sensors. Is there any 

way for a test lab to know whether it is 

really running the cycle that has been 

selected or not? Does that not make any sense 

to you? 

(Laughter.) 

So, my understanding --

MS. ARMSTRONG: Like an override --

MS. BARHYDT: Yes. 

MS. ARMSTRONG: -- is the best way 

to say it. 

MS. BARHYDT: Something didn't 

calibrate or some issue was detected. And so, 

the unit defaults to some kind of set cycle 

that it knows to run in order to remedy the 

issue. 

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 MR. EDWARDS: Mike Edwards, BSH. 

It is obviously difficult to 

comment because I don't know exactly which one 

you are talking about. But the complexity of 

cycles is increasing, and there are multiple 

sensor decisions and there are multiple things 

the sensors are doing now. They are speeding 

up motors. They are changing temperatures. 

It is not just about water fills. 

I think it would be, again, very 

difficult for labs outside the manufacturer to 

know exactly what is happening within the 

cycle. We watch it very carefully when we run 

tests, and we know what paths we wanted to 

take when we do certain things. 

That didn't answer your question, 

but maybe it helped. 

MS. BARHYDT: This is Laura Barhydt 

at DOE again. 

I think what I am wondering is, is 

there some kind of information you could 

provide that would be something that the lab 

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could see and say, I don't know, "It ran for 

20 minutes. Clearly, it didn't do what it was 

supposed to do."? Or "It ran for 45 minutes. 

Clearly, that was not the normal cycle that 

was supposed to be the energy test cycle."? 

So, is there some kind of 

characteristic that you could convey possibly 

in a certification report or through some 

mechanism that the lab would know whether or 

not it is getting what it thinks it is 

getting? 

MR. KLUG: Wayne at Whirlpool. 

For example, if you were to watch 

the cycle behavior, there are indicators that 

are in, for example, the wattage chart and the 

water usage results of that product that would 

be indicators of how that machine is operating 

or behaving. But that would be dishwasherspecific, and I know within our various 

products we build, that there is a lot of 

different approaches. And so, the one-sizefits-all would probably be difficult. You 

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would have to look at it product-by-product. 

MS. BARHYDT: Okay. Thank you. 

MS. ARMSTRONG: We have somebody on 

the line who would like to speak. So, Debra, 

can you --

MS. BENGSTON: Sure. 

MS. ARMSTRONG: Make sure you are 

off speaker and you should be ready to go. 

MS. BENGSTON: I will try to speak. 

One of the things I can recommend is that 

usually if the lab will read the use-and-care, 

I believe there are charts that have an 

overview of the cycle which talk about how 

cycles should be, approximate (phone cuts 

out). That would give the lab a clue to the 

sensor may have run. And if it did not meet 

the energy cycle, if it was listed in the 

manual, the temperature, the main wash, then 

they would know most likely that the 

calibrating sensor did not happen. 

MS. ARMSTRONG: Okay. So, you 

broke up just slightly during that. So, I am 

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going to repeat what I think I heard, just so 

you can confirm. 

Basically, I thought you said that 

within the manuals there are various 

descriptions/characteristics of the different 

cycles that would be run, that the labs could 

compare what actually happened to ensure or 

give some indication whether the actual 

correct cycle was actually run or if there was 

some overriding function that took place and 

something needed to be rerun. Is that fair? 

MS. BENGSTON: That is fair. 

MS. ARMSTRONG: Okay. And can you 

just remind us who you are with? 

MS. BENGSTON: Viking Range 

Corporation. 

MS. ARMSTRONG: Thank you so much. 

Anybody else? 

MR. EDWARDS: This is Mike Edwards. 

manual, 

chart. 

We do put water usages in our 

but we normally do not include a 

So, I mean, you give the min and the 

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max water usages. If it is between those two 

figures, then most likely --

MS. ARMSTRONG: Well, one could 

argue, though, I mean, obviously, most people, 

everyone in the room gets those numbers right. 

But if it happens to be a maximum water usage 

that exceeds that table, it is not necessarily 

indicative of the wrong cycle, correct? 

MR. EDWARDS: Correct. That is 

correct. 

MS. ARMSTRONG: Okay. So, we would 

like some indicator maybe other than one that 

would also potentially indicate that there is 

an issue with compliance, if possible. 

MS. FARBER: This is Julia Farber 

from UL. 

I just wanted to go back to the 

preconditioning question about how 

laboratories are running. At the moment, our 

laboratories are running one conditioning run, 

and that is because of DW-1, your 

recommendation. 

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 MS. ARMSTRONG: All right. Anybody 

else? 

(No response.) 

We are going to move on to drain 

height. And I am going to quickly pass this 

one to Jen. Or do you want to do yours, soilloading procedures? That is fine, too. Do 

you want to move -- MS. CLEARY: Yes, 

if you don't mind, I think we tried to 

prioritize. 

MS. ARMSTRONG: Yes, that's fine. 

MS. CLEARY: Okay. 

MS. ARMSTRONG: Please do. 

MS. CLEARY: So, there are a number 

of these issues with the soiling details and 

loading procedures. I think the overall 

comment we would have is that anytime there is 

soiling involved or loading being done of 

soiled and non-soiled dishes, it is really 

helpful for labs to have like a visual of what 

other labs are doing. So, some of these 

issues, the best way to solve them may be for 

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DOE to allow other labs, including 

manufacturing labs, to view how DOE's labs are 

doing the testing because that would be the 

best way for everyone to know if they are 

doing it the same way. 

That could be done through like a 

YouTube video or something or to actually go 

to the lab. This is something, the YouTube 

video is something we are sort of starting to 

use in AHAM to know if everybody is doing 

things the same way, because we may actually 

be using the same words to describe something, 

but in actual practice, when you see it being 

done, it is different. 

So, that is a tool that we are 

finding to be useful, and we might suggest 

that DOE do the same thing as well. I know we 

have also made this recommendation with regard 

to the Energy Star test procedure development 

right now for dishwashers. So, that is sort 

of an overarching comment. 

Then, we have some very detailed 

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soiling questions I think here, as well as 

some recommendations. So, No. 8 on our issue 

list here --

MS. ARMSTRONG: Let's go back for a 

second. 

MS. CLEARY: Yes. 

MS. ARMSTRONG: This is Ashley from 

DOE. 

So, for the most part, I will say, 

as of now, we are using the same third-party 

labs that everyone in this room has access to. 

So, to the extent you know there are 

differences between the way the soils are 

being applied, the way the loading is being 

done, I ask that you, rather than -- well, the 

YouTube video site, I actually ask that you 

point it out. 

Obviously, we would like to 

articulate something to the extent we could or 

to the extent that it is necessary. What 

specific instructions are needed in addition 

to what already may be provided, either in the 

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AHAM method or outside of that? What is 

actually being done different from lab to lab 

in terms of soiling or how they are being 

applied or how they are being loaded? 

Because, like I said, for thirdparty replication, we are using third-party 

labs, and at that point we want the test 

procedure to be fairly standalone -- to be 

standalone. 

MS. CLEARY: This is Jen with AHAM. 

We want the same thing. 

Unfortunately, I think we are suggesting the 

video because there are some times where we 

may think everyone is doing it the same way, 

and that isn't the case. That is where the 

actual witnessing can be very helpful, to know 

that information. 

But to address your other issues 

about instances we do know about, we have some 

of those today to share. 

MS. ARMSTRONG: Who wants to share 

those instances? 

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 MS. CLEARY: This is Jen from AHAM. 

I would be glad to share those instances. 

(Laughter.) 

So, the first would be there have 

been some questions about the use of a brush 

versus a spatula for soiling the dishes. 

DW-1-1992 actually makes some reference to the 

utensils, but it doesn't provide specific 

details beyond like the order of the 

application of the soil. So, this is one 

where certainly things should be discussed. 

We will work to develop some 

uniformity there and suggest them to AHAM. I 

am not sure if companies want to give any more 

detail on this point today. 

MR. KLUG: I think that, first of 

all, I like the idea of a video. I like the 

idea of lab-to-lab visits. As we look at 

procedures such as this, repeatability and 

reproducibility become very significant. And 

many of those sources of variation are subtle, 

and many of them have no significance, but 

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some may or some do have some significance. 

Just to select one, oatmeal, for 

example, how well it is spread out on the 

plate, the clumps of oatmeal, how long the 

oatmeal may sit before it is used, all of 

those may or may not have some significance. 

And you can really go through all of the 

soils, all of the instruments set up, and find 

a number of things that can bring variation to 

the procedure. 

Really, the challenge is, which of 

those are the most significant? We are aware 

of some that are of no significance. There 

are some we are currently exploring that we 

think have some significance. 

So, the challenge is how to 

communicate those, and often doing that in 

words is very difficult to do. And so, the 

picture is worth a thousand words. The video 

is worth, well, maybe a few more than that. 

And so, that sort of approach will help us 

move, I think, in the direction of less 

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variation. 

And some of the things we have also 

talked about here today, and some of the 

callouts of the margarine, for example, may 

introduce some differences if an alternate 

soil is selected that may not match the 

original callout. And so, there is really a 

lot of places where that variation can creep 

in. 

So, I don't think a simple 

explanation or even in a list necessarily gets 

us to that solution. It certainly helps. It 

certainly is helpful, but I like the idea of 

something that photo-video-documents the 

procedure, the application method of soils, 

how that takes place. 

MR. EDWARDS: This is Mike Edwards, 

BSH. 

I also agree with the comments from 

Whirlpool. I just wanted to give a couple of 

examples. 

I have been to labs that had the 

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refrigeration equipment to keep the food soils 

in located three floors away. So, every time 

when they are working to prepare the food 

soils, they would have to stop, go get 

something, come back. The same labs, the 

kitchen facilities were not where the 

dishwashers were tested. So, things were 

being transported. 

This all adds time to the process. 

It takes longer for the techs to do the 

process, and then it increases the drying time 

of the food soils, actually. So, things like 

that are hard to capture in a written test 

procedure. And I agree again, that the video 

would be a helpful tool. 

It can be subtle as well. Just 

soiler-to-soiler variation, you can have two 

people -- and we see this frequently within 

our labs -- two people that are following the 

exact same procedure, have different 

applications of the soils. I know we call it 

a measurement system evaluation within our lab 

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where we have multiple people do the same task 

at the same time over and over, so we work to 

commonize a method that is consistent. And 

certainly, that becomes more challenging as 

you look at interlaboratory, across-laboratory 

type procedures and protocols. 

MS. ARMSTRONG: So, two questions. 

One, I think we would be interested in what 

exactly you are identifying that is different 

in your lab? I mean, what are the details? 

What is being put on differently? 

I assume you are using the same 

materials in the same kitchen with the same 

drying times, but what is being done 

differently really than what is in our test 

procedures? That is (a), maybe an ask for you 

guys. 

And then, to your point, I am not 

clear how drying time, temperature of the food 

applications, whether it comes from the third 

floor or around the corner, or whatever, how 

really that would be solved by a video, 

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because the video would just show you grabbing 

the food. In other words, I am not 

understanding how it would solve that issue. 

Temperature of the food being put 

on, a specific drying time, something like 

that, maybe, but I am not sure how a video 

would show me grabbing something out of the 

refrigerator right next door, should I be 

lucky enough to be in the so-called video. 

No, I am just saying --

(Laughter.) 

But, you know, I guess I am trying 

to understand exactly. Maybe it is pictures. 

Maybe it is additional specificity with the 

actual conditions. What it actually is that 

is needed? 

So, I don't know if anybody else 

needs to say anything. I know we have someone 

on the phone. Debra, again, wants to say 

something. 

So, Debra, we are going to try this 

one more time because I heard there is a lot 

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of feedback on the line. So, I do ask that 

everyone has their microphones off in the 

room, and that you not use speaker, and speak 

as loudly as you can into the phone so that 

you don't cut out this time. 

MS. BENGSTON: Okay, I will try. 

Ashley, one of the main things that 

when I have visited outside labs, the 

differences I have seen in soiling, soiling 

mixture, one was (phone cuts out) or the lack 

of knowledge of what reconstituted milk 

actually was. I have seen and witnessed 

outside labs not put the water back into the 

milk directly (phone cuts out) or measure dry 

milk into the oatmeal mixture. That is one 

(phone cuts out). 

No. 2, when a lab has measurement, 

the actual leveling of the food soil spoons 

(phone cuts out) because it affects the amount 

of soil that is placed on the dish. I have 

also witnessed like (phone cuts out), the time 

factor. 

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 And I also was in labs that I have 

worked in myself. I have seen individuals 

interpret the soil methodologies differently. 

I am (phone cuts out) the video to 

try to eliminate (phone cuts out) the 

discrepancies within the soiling procedure. 

MS. ARMSTRONG: Okay. Thank you. 

MS. BENGSTON: You're welcome. 

MS. ARMSTRONG: Anyone else on 

soiling or loading procedures? 

(No response.) 

No? All right. Moving along, Jen, 

I assume you wanted to go ahead and discuss 

other issues. It seems like we are moving 

fairly quickly. 

MS. CLEARY: Yes. So, I mean, it 

seems like maybe we didn't need -- you know, 

we gave very detailed explanation I think of 

the specific soiling issues up above in the 

chart. So, maybe we don't need to read 

through them today --

MS. ARMSTRONG: Sure. 

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 MS. CLEARY: -- is the sense I am 

getting. It sounds like no one else thinks we 

need to verbally go through them. 

Okay. So, the other issues, I 

think these just we couldn't group them 

together. But the first one would be rinse 

aid. I think some labs have been observed to 

fill their rinse aid container with water 

before starting the test cycle to prevent the 

indicator light from turning on. But the test 

procedure does not address this practice. 

AHAM would suggest that the rinse agent 

container should not be filled with water at 

the start of the test run. 

MS. ARMSTRONG: Okay. So, this is 

Ashley. 

Can you explain why, why or why 

not? 

MS. CLEARY: So, I will leave that, 

I think, a little more detail to the 

companies. 

MR. EDWARDS: I think the reason 

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that this was done is to get the LED light to 

go off, so it would not be included in the 

power consumption evaluation, is how it was 

explained to me. 

I guess I would just say that, to 

me, if it says don't use rinse aid, you 

shouldn't use rinse aid. You shouldn't put 

anything else in there. 

MS. CLEARY: So, I think that is 

why AHAM's suggestion is what it is, you know, 

for an anti-circumvention type of measure. 

MS. ARMSTRONG: Okay. The next 

one? 

MS. CLEARY: Okay. The next one, 

No. 14 on our list deals with water pressure 

and where it is measured. This is partly 

addressed in the May SNOPR where AHAM had 

suggested that the pressure should be measured 

as the water is flowing, and that is the 

proposal in the SNOPR as well. We support 

that and will indicate such in our written 

comments. 

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 But there is also an issue -- and I 

definitely would leave this to better be 

described by technical experts here -- but 

that the pressure is expected to drop when the 

valve opens, and the length of time where the 

pressure would be different than what is 

required in the test procedures should be 

limited. And the test procedure right now 

does not have a required amount of time for 

that limit. So, AHAM would suggest a twosecond limit for that transient pressure drop. 

MS. ARMSTRONG: Do you know what I 

am going to ask? 

MS. CLEARY: You want to know why 

two seconds instead of any other time? 

(Laughter.) 

We will address that in our written 

comments. 

MS. ARMSTRONG: Thank you. 

MR. KLUG: Wayne, Whirlpool. 

Maybe one other thing we may want 

to think about, just to plant the thought, is 

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the height at which the pressure measurement 

is made. I have seen some measurements made 

at a height further above the dishwasher. And 

so, really, your pressure per foot of height, 

it is approximately .4 or .5 psi. And so, we 

may want to look at just prescribing where 

that measurement takes place. I don't think 

it introduces a lot of significance, but it 

may allow us to tie down where that pressure 

is actually measured. 

MS. CLEARY: This is Jen with AHAM. 

Oh, I'm sorry, did someone else 

raise their hand? Yes, they should go first. 

MR. OSANN: Yes, I had a question. 

This is Ed Osann with NRDC. 

I had a question on the AHAM 

handout with regard to pressure. It indicates 

that the length of this drop should be limited 

to assure that water flowing into the unit is 

at the proper pressure. I am not sure why --

I don't know how that relates to the two 

seconds, and if it were five seconds or twenty 

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seconds, how would that affect the water 

flowing into the unit at the proper pressure? 

And either it is flowing pressure 

or it is static pressure. If you are 

measuring flowing pressure, does that matter 

whether it is seconds after the valve is 

opened or twenty seconds after the valve is 

opened? 

MR. KVAIDHYANATHAN: The question 

here is flowing pressure needs to be measured. 

But what really happens is, if you look at, 

monitor the pressure, the flowing pressure, 

you know, it changes when the valve opens. It 

drops down and then gets back to the normal 

level. If it drops down for a longer time, 

what it really means is the valve float is 

going to change, too. So, you don't want to 

have a longer drop. 

So, what we are saying is, I would 

say the stable condition should happen sooner 

than later. I think that is what is behind 

this comment. If it does happen after a long 

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time, that may impact how much it fills as 

well. 

Yes, generally, now the fill time 

can be like one minute. 

MR. OSANN: Right. 

MR. KVAIDHYANATHAN: So, if it is 

one minute, and if they are losing twenty 

seconds of one minute, that can be quite 

significant. You are not maintaining the 

pressure at the right level during that time. 

MS. ARMSTRONG: Okay. Thanks, 

everyone. 

Anything else on water pressure 

before we move on to rack position? 

(No response.) 

Okay. Moving along --

MS. CLEARY: This is Jen with AHAM. 

Actually, before we get to rack 

position, if it is okay, I think I had 

something on the drain height, which is not 

currently specified in the DOE test procedure. 

AHAM would propose that this should 

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be specified and that it could be indicated 

that the installation shall be per the 

manufacturer's installation instructions. If 

there are no such instructions, then AHAM 

would suggest that the height shall be a 

standard level of 20 inches, which is what we 

have observed to be the standard. 

MS. ARMSTRONG: Okay. Keep going. 

MS. CLEARY: Okay. No. 16, the 

rack position, this is the upper rack. The 

position of that can -- and I will leave this 

to experts in the room to further describe, 

but to just give a brief description -- it can 

impact the water pressure and the consumption 

during the test. But the test procedure does 

not indicate what position that rack should be 

in. And some dishwashers do have multiple 

positions that it could be in. 

So, we think this is a complex area 

that needs to be resolved. AHAM would be glad 

to work with the Department to do so. In the 

interim, what we would suggest is that this 

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Page 142 

could be indicated as part of the 

certification statement, like which position 

the rack was in during the test. And then, we 

could work as a longer-term solution to 

identify what the best position would be in 

the test procedure. 

MS. ARMSTRONG: Two questions. One 

would be, is there a reason that it should be 

different than the as-shipped position? And 

No. 2 would be, if it is a big issue that 

shows high variation, and you allow 

manufacturers the discretion to choose what 

that position is, what is to say that they are 

doing it uniformly or at least equitably? 

MS. CLEARY: I would definitely --

this is Jen with AHAM -- open this up. I 

think individual companies may be able to give 

you more information. But my understanding is 

that the as-shipped position may not always be 

the same and/or how the consumer is getting it 

may not always be in the same position. There 

may not be a way to make that uniform. Now 

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that may not be the case for all companies, 

but for some that may be the case. So, that, 

I think, is part of the difficulty. 

MS. ARMSTRONG: And then, one other 

just before your time ends, you can address 

this, too. If it is not the as-shipped 

position, are there actually instructions in 

the installation manual telling the consumer 

that this is the default position that the 

rack should be in? 

MR. EDWARDS: Mike Edwards, BSH. 

It is true that the varying 

positions of the rack may impact the pressure 

slightly. That could influence the rate the 

food soil falls off the dishes and the sensor 

decisions. 

I don't consider it a critical 

issue, but it could cause testing problems 

when a verification lab runs a test. So, it 

could show up. 

Yes, it is in our manual, but it 

has been recently added. 

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 MS. ARMSTRONG: And is it different 

than the way you ship? 

MR. EDWARDS: That one I cannot 

answer. 

MS. ARMSTRONG: Okay. 

MR. EDWARDS: And it varies from 

product to product. We have several 

platforms. So, they are not all the same. 

So, my suspicion would be they are all shipped 

the same, but the manual is telling you to do 

different things with it when you run the 

energy test. 

MS. ARMSTRONG: The manual actually 

has a position for the energy test and --

MR. EDWARDS: It is now in our 

manuals, yes. 

MS. ARMSTRONG: Wow. 

MR. KLUG: Wayne at Whirlpool. 

I am not sure what is in our 

manuals. So, I have got to go look. And I 

have to check on what our shipped position is. 

I would share Mike's comments that 

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there might be a slight difference in water 

pressure, again, due to height, and how that 

feeds the upper spray arm. 

The consumption piece, I am kind of 

scratching my head because I am not sure there 

is an impact there. And so, I think we 

probably want to look at that, that word, and 

see if that needs to be pulled out of here. I 

think it is more of a water pressure, soils 

coming off the dishes topic. 

MS. ARMSTRONG: Anybody else have 

anything else with this? 

(No response.) 

Do any of the labs want to say what 

you currently do when you set up a dishwasher? 

Do you follow the installation instructions? 

Do you do as-shipped? 

MR. BILLINGS: Lincoln Billings at 

Intertek. 

We currently typically test under 

as-shipped conditions. 

MS. ARMSTRONG: Thank you. 

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 MR. KLUG: I have to check what we 

do. 

MS. ARMSTRONG: Okay. Jen, do you 

want to move on to water hardness? 

MS. CLEARY: Jen with AHAM. 

As I know everyone is aware, 

Appendix E does not have a water hardness 

requirement. As part of the Energy Star test 

procedure, DOE did propose to adopt a water 

hardness requirement. And I believe the 

proposal was to adopt the requirement in 

DW-1-1992. 

And then, there was a question 

about whether the 2009 should be cited 

instead. And I believe in AHAM's comments on 

that we indicated that that proceeding was not 

the time to change the DOE test procedure. 

But, now that there is an open rulemaking, 

perhaps this would be an opportunity to 

address this. 

AHAM would propose that DOE adopt 

the DW-1-2009 water hardness specification, 

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which is similar to 1992 but more detailed. 

And there was a study to support those 

specifications, and we would be glad to share 

the details in some written comments and 

feedback. 

MR. OSANN: This is Ed Osann from 

NRDC. 

What is the objective of the AHAM 

standard, either the 1992 version or the 2009 

version? Is it to provide not just 

standardization, but standardization around 

what? Is this chemistry supposed to be 

representative broadly or is it supposed to be 

challenging? Or what is the point of the 

specification? 

MR. KLUG: Lab consistency. 

MR. OSANN: Consistency? 

MR. KLUG: From lab-to-lab, yes. 

MR. ANDERSON: Are you talking 

about for water hardness in particular? 

MR. OSANN: Yes. 

MR. KLUG: Yes. 

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Page 148

 MR. OSANN: And is the 

specification that is in the AHAM standard, is 

it consistently hard or consistently soft, or 

where does it land on that spectrum? 

MR. KLUG: The current callout in 

both 1992 and 2009 versions of DW-1 call out 

zero to 85 ppm of water hardness, which is 

about zero to five grains. 

The clarification or the detail 

that Jennifer was referring to for the 2009 

version is that it also calls out that that 

PPM level is based on the calcium carbonate 

content. 

MR. OSANN: Just a follow-up 

question. I was wondering whether AHAM has 

any data as to how representative that level 

of hardness is. 

MS. CLEARY: Yes, as I mentioned, 

we did have a study to support selecting that. 

Maybe Wayne can indicate exactly who did the 

study. I can't remember off the top of my 

head. 

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Page 149

 MR. MORRIS: This is Wayne Morris 

with AHAM. 

The work that the DW-1 Task Force 

did prior to 2009 was in contact with the 

American Water Works Association to try to get 

the most general range of water hardness that 

they felt was in municipal supplies. 

Obviously, if you are dealing with well water 

or something like that, the consumer may vary 

considerably. But this was their way of 

detailing it, and their suggestion was not 

only to detail the grains, in this case the 

PPM, but also to do it based on calcium 

carbonate, since there are some other methods 

of specifying it, in addition to that. They 

felt this would tie down more specifically and 

leave less lab-to-lab variation. 

MR. OSANN: This is Ed Osann again. 

This was felt to be representative 

of publicly-supplied water? 

MR. MORRIS: Yes. The range that 

they had asked for us to do, which is, as 

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Vince indicated, zero to 85 PPM is considered 

to be, shall we call it, the normal range that 

occurs in municipal-supplied water. 

MS. ARMSTRONG: Okay. Any last 

comments or questions regarding water 

hardness? 

(No response.) 

If not, we are going to move on to 

ambient temperatures. 

MS. FARBER: This is Julia Farber 

from UL. 

I just have a note here that in our 

experience as well, the difference between 

varying soft and hard water could potentially 

impact your results. And that is dictated 

based on the hardness of the water. 

And also, similar to Intertek, we 

are performing all of our testing standards 

based on the manufacturer instructions. 

MS. ARMSTRONG: Moving on to 

ambient temperature. 

MS. CLEARY: This is Jen with AHAM. 

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Page 151

 Ambient temperature in Appendix C 

is expressed as a range, 75 plus or minus five 

degrees Fahrenheit. And we think that that is 

fine, but it would be better if the test 

procedure or guidance could expressly state 

that the intent of the procedure is actually 

to maintain the 75 degrees, not to go anywhere 

in that range. So, you shouldn't be aiming to 

run the test at 70 or 80, and that, in fact, 

the test is intended to be run at 75 degrees 

Fahrenheit. 

MS. ARMSTRONG: Okay. I mean, 

technically, then, would you be in favor of 

tightening the range, tightening the 

tolerance? Even if you shoot for the 

midpoint, I mean, it is a valid test in that 

range. 

MS. CLEARY: Right. So, this is 

Jen with AHAM. 

I think that tightening the range 

maybe could be a possibility. The difficulty 

would be every lab is going to have a 

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different test chamber, and there may be 

varying abilities to have a tighter range than 

five. So, I think that might be something 

that you might need to find out. 

I know we did submit comments with 

regard to DOE's proposal to widen the range, 

and we would oppose that. We think at least 

it needs to be this tight. 

So, we could look at if a tighter 

range would be possible, but right now I think 

our sense is that, because labs are different, 

maybe the plus or minus five, that this is 

kind of the best that we can think of to do 

with those variabilities. 

MS. ARMSTRONG: Yes. So, I may 

request that if you could think of some 

specific language that would achieve your goal 

of shooting for 75 but allowing dips above and 

below that, we would welcome that. Because 75 

plus or minus five, I mean I read that and I 

think it is fairly clear you shoot for 75, but 

if you go above or beyond, there is a 

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tolerance there for that reason. 

MS. CLEARY: Jen from AHAM. 

Yes, we will work on some language. 

MS. ARMSTRONG: Thanks. 

MR. KLUG: Wayne at Whirlpool. 

I think that the lab impact that 

Jen spoke of is probably the key challenge to 

overcome on the value of the temperature. 

Certainly, centering is very important, and we 

would support language around centering those 

values. 

I think, from our perspective, even 

tightening those values does have a lot of 

benefit. But, again, that comes up against 

what the lab equipment might be capable of. 

But certainly, tighter is better. Centering 

is better. And language to make sure that you 

are actually targeting 75 and not some other 

within the range would be beneficial. 

MS. REICH: Judith Reich from 

Navigant. 

It would be helpful if you could 

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provide information on this issue, whether the 

key issue is the capability of the lab or 

really how much the temperature affects the 

performance, whether if you are operating it 

at 70 or 80 degrees really has a difference on 

the performance of the unit. 

MR. BILLINGS: Lincoln Billings 

from Intertek. 

We do understand fully that the 

intent is to target 75 and do aim to maintain 

that condition. Also, I think it is important 

that that condition is met prior to the test 

for the soil drying as well. 

MS. ARMSTRONG: Okay. Any other 

dishwasher issue, whether it be those on the 

sheet, other issues? Any other comments as 

they relate to dishwashers before we break for 

lunch? We are about an hour ahead here. 

MS. CLEARY: This is Jen Cleary 

with AHAM. 

I hate to get in the way of lunch, 

but just the last issue on our sheet. 

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 MS. ARMSTRONG: Okay. 

MS. CLEARY: I think we have 

addressed this in a general way already, but 

this would be one specific instance where 

there is a more recent version of DW-1, which 

is incorporated by reference in Appendix C. 

We would recommend DOE incorporate by 

reference the 2009 version of DW-1. There are 

some differences in the food soils there. So, 

clearly, in order to do that, DOE would need 

to determine whether there would be an impact 

in measured energy from those changes. And 

AHAM, we don't know for sure right now, but we 

would be glad to work with DOE on figuring 

that out. 

MS. ARMSTRONG: Thank you. 

MR. KLUG: Yes, Whirlpool would 

support that as well. The differences are 

fairly subtle, soiling order, how the egg is 

prepared, a couple of other minor items. But 

it would be beneficial to cite the most recent 

reference, primarily because some labs perform 

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both the 1992 and 2009 procedures, and it 

would be certainly convenient to be able to 

have one size fit all. 

MR. EDWARDS: Mike Edwards, BSH. 

We also support it, but we would 

want to go in and check to make sure it didn't 

influence sensor decisions. 

MS. ARMSTRONG: Okay. I think we 

would welcome any data that you would be 

willing to share with us, once you did that 

comparison. 

MR. EDWARDS: If you guys are 

serious about accepting the proposal, then we 

will go in and test. 

MS. ARMSTRONG: We are always 

serious here at the Department. 

Okay. So, I take it there are no 

other dishwasher issues. I have had a request 

to at least -- oh, one more? Oh, go ahead. 

Go. 

MR. BILLINGS: Lincoln Billings 

from Intertek again. 

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 I hate to jump around, but going 

back to item 14, referring to the pressure 

drop issue, it seems that, judging by the 

suggested two-second limits indicates that 

there may or may not be, I will say, an 

industry-accepted allowance for transient 

conditions. If that is the case, I would just 

like to ask where that is aligned or 

specified, because we run into the same issue 

and generally throw any transient condition 

test. 

MS. ARMSTRONG: They ask for 

industry-accepted positions. 

MR. EDWARDS: I can tell you where 

the two seconds came from. It is what we all 

felt our labs were capable of. 

MS. ARMSTRONG: Okay. So, any 

other dishwasher? Free feel. 

(No response.) 

I have been asked to ask everyone 

in the room, if you want to move straight to 

clothes washers to get out of here early or if 

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1 you want to break for lunch. I don't know how 

2 long the clothes washer one -- I will take a 

3 vote. I mean, majority rules here. I will 

4 sit here with you if we want to keep going. 

5 Anybody? 

6 So, how about this, 10-minute 

7 break? Or a 15-minute break is fine, 

8 whatever. Reconvene at 25 after or so, 20 

9 after. Is that okay? So, 20 after, and we 

10 will go right to clothes washers. 

11 (Whereupon, the foregoing matter 

12 went off the record at 12:08 p.m. and went 

13 back on the record at 12:33 p.m.) 

14 

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 A-F-T-E-R-N-O-O-N S-E-S-S-I-O-N 

1:33 p.m. 

MS. ARMSTRONG: Okay. I would like 

to welcome everyone back from that quick lunch 

break we just had. 

(Laughter.) 

We are going to move through to 

clothes washers. We are running quite a bit 

ahead of schedule, and it may be perhaps that 

we can end quite early and get everyone home 

to enjoy their weekend, even if they have to 

travel by air. 

So, with that, we are going to 

segue into clothes washers. I am going to go 

ahead and turn the first issue over to Jen to 

introduce. 

Like I said, I am going to keep 

saying the same thing. I encourage you to 

provide detailed data, ask each other 

questions, so that we can really identify 

where there might be differences of 

interpretations that the Department really 

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needs to consider what action it can take. 

MS. CLEARY: Okay. Jen, AHAM, 

again. 

I know that the manufacturers in 

the room will have more details to share, 

particularly on this first issue. So, I will 

just tee it up a little bit. 

Essentially, what we are dealing 

with here is how to handle testing anomalies. 

One example would be an unbalanced load. You 

know, DOE's test procedure doesn't address 

exactly how to handle those situations, if 

there is like a certain threshold of 

acceptability, for example, or when a test 

might need to be disregarded and a new test 

run. 

We believe that labs probably are 

making different determinations as to when to 

invalidate a test run and restart it. Both 

third-party labs and manufacturer labs may 

have different processes that they follow 

there. 

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 So, this is a pretty complicated 

issue because the anomalies could be 

different. But what AHAM is suggesting is 

that, in the case of an obvious unbalanced 

load, the test should be invalidated and 

restarted because the test results should not 

be based on a run that the consumer would 

notice as abnormal. 

We also think that a more general 

way to handle this in a uniform way would be 

something similar to -- I have the wrong IEC 

number there, but it should be 60456, similar 

to that approach which we have included in 

this handout. 

Now the exact wording in the IEC 

version, it can't just be cut and pasted into 

DOE's procedures. So, AHAM certainly would 

like to continue to work on this and make some 

suggestions in more detail to DOE. But we 

wanted to put out there today that this could 

be one way of handling it. So, I would 

certainly ask the experts in the room to give 

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some more detail around exactly what the issue 

is and what different labs have been seen to 

do, and what our suggestion is here as well. 

MS. ARMSTRONG: Everyone is looking 

at me. 

So, I just have a question before 

we jump into this. Perhaps some of the 

manufacturers and/or the labs can say what 

they do. 

If it is an unbalanced load, will 

the cycle automatically prematurely terminate 

in all cases or is it possible that it will 

actually finish? 

MR. HOMBROEK: This is Phil 

Hombroek from GE. 

It really depends on the machine 

and the complexity in the machine. Some will 

completely terminate and others will have 

other unbalanced algorithms to try to regain 

balance and try to restore the machine to 

normal operation. 

MS. ARMSTRONG: So, to Jen's point 

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earlier, how would a consumer and the 

Department know that it is unbalanced if it 

doesn't prematurely terminate? 

MR. BILLINGS: Lincoln Billings 

from Intertek. 

We have seen units that actually 

have an indicator light where we will give the 

user instructions as per the use-and-care 

manual. 

MS. ARMSTRONG: And if it doesn't? 

MR. HOMBROEK: Then, you're right, 

in most cases it would terminate. But it 

depends on the complexity of the machine. We 

have some that certainly have out-of-balance 

algorithms that will take additional action, 

and they will inform the consumer that it is 

rebalancing or stop the machine and 

redistribute your cloths. 

So, this is something that kind of 

needs to be considered, contrary to probably 

your thoughts. But the DOE cloth load is a 

complicated load to wash. It is in some cases 

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more difficult than a mixed load. When you 

lay those DOE cloths completely flat, one on 

top of another, and you pour water right over 

the top of it, especially in some of the newer 

machines, what you do is create a solid, 

concrete pancake, if you will, of DOE cloth, 

and your machine needs to be able to agitate 

it enough and to have the right kind of 

routine to mix it up and not create any kind 

of out of balance. 

And this is coupled with the fact 

that, obviously, we are trying to reduce the 

amount of water over and over again as much as 

possible. So, we use these routines on a lot 

of higher-end machines to try to regain the 

balance. 

But in the case of some machines, 

we may stop the machine and go through an 

entire new fill. Okay? And filling the 

machine again in that kind of condition, the 

consumer is not like the DOE and causes 

probably more use of water than we would like. 

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 In the case where everything is 

working properly and we load the cloth just 

the way that we would like to, obviously, more 

often than not, we don't have these types of 

conditions, but there are occasions that we 

do. And we just ask that the DOE consider it. 

MR. MANTHEI: Phil Manthei from 

Alliance Laundry Systems. 

With the front-loading washers 

predominantly, of course, gravity prevails. 

And so, the load will tend to always be on one 

side. So, the machine has routines, you know, 

software, to try to balance that load out. Of 

course, the test procedure, one of the things 

that we did years and years ago was to make 

sure that the test procedure tested the 

maximum load size to allow for less unbalance 

to occur during the test. 

What can happen is in some units 

the software will say, okay, I cannot take 

this load; it is unbalanced; I cannot take it 

up to high-speed spin. And therefore, it will 

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drop down to a lower-speed spin. 

What could be done, I suppose, is I 

don't know that everybody puts in their user 

instructions what the actual spin speeds are 

of high, medium, and low speeds, et cetera. 

Oftentimes, that is only in the promotional 

material, the sales spec material. But 

knowing what the intended maximum spin speed 

is for the energy test cycle certainly could 

be one thing that would help the test labs to 

know whether it was an appropriate cycle run. 

MS. ARMSTRONG: Anybody else? Any 

other characteristics that would help 

determine unbalanced load outside of just an 

indicator light or a premature termination? 

MR. KVAIDHYANATHAN: This is Ravee 

from Samsung. 

Unbalanced is one of the specialcause type of issues. You know, it can 

happen. And there are other types of 

situations, too, where a single test run may 

not represent the system behavior. So, 

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unbalanced is definitely one of the issues in 

the examples that we wanted to cite. It is 

both on horizontal and top-load and front-load 

washers. It can change the cycle. 

And how the machine reacts depends 

on the system. Some machines, you know, they 

can continue the cycle at lower spin speed. 

Some add water. I think the MEF and Water 

Factor numbers, for example, are going to be 

different for the specific run where it went 

through an off-balance or other type of 

special-cause issues. 

So, given that fact, how do we 

identify that? And how do we separate it from 

one of the runs which are special-cause runs 

and take it out of the calculation? 

MS. ARMSTRONG: Right. That is 

kind of the question I just asked you, too. 

(Laughter.) 

You know, we are trying to 

understand how will we differentiate between 

what one would call an anomaly for which you 

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wouldn't have a light, you wouldn't have a 

premature termination. The consumer may not 

know it would finish its cycle, but it would 

use more energy or water, or whatever it is. 

It would use the different cycle than it 

normally did or it would use a different spin 

speed, or whatever it may be. How do we 

determine that without going through this 

whole process, getting the test results, 

saying, hey, DOE has these test results that 

show that your unit uses 50 percent more 

energy? And you say, "Oh, no, it had an 

unbalanced load." I mean, how do we get to 

the point where we can recognize that at the 

forefront rather than after we have finished 

verification testing or enforcement testing? 

Where do you draw the line between 

something that is using more energy and water 

consistently versus something that was tested 

with what you guys are calling an anomaly? 

Are there any characteristics specifically 

that we could look at in the test or the test 

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data that would give an indication of that, 

other than just the lights are the easy ones, 

but it won't finish the cycle is an easier 

one. We don't just necessarily throw test 

data out per se. 

So, I am asking you guys. How do 

you determine what to do when you come up with 

your ratings? 

MR. MANTHEI: This is Phil from 

Alliance Laundry Systems. 

With the spin speed, that one is 

fairly obvious. You can measure the spin 

speeds and compare them to what the product 

literature or specification is for that model, 

and know if you are at the right one. 

MR. OSANN: This is Ed Osann with 

NRDC. 

I think there is a concern here 

about, or we would raise a concern about to 

what extent these conditions really are 

anomalous. As the control logic of these 

machines becomes more sophisticated over time, 

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you could envision sort of a gradation of what 

you might consider intervention in rectifying 

non-standard conditions. And it might be 

that, for marketing purposes, a machine, a 

design would intentionally intervene more 

often. 

I think, as presented, it is hard 

to argue against the ability to throw out 

truly anomalous results. But it seems like 

there ought to be more on the record here 

about how often this occurs and how to 

distinguish this occurrence from what 

consumers are likely to encounter more 

frequently. 

MR. KVAIDHYANATHAN: This is Ravee 

from Samsung. 

There are potential ways of 

addressing and understanding the special-cause 

situations. In the test tunnel, for example, 

for the water factor, multiple units are 

tested and multiple runs are done at different 

load sizes, too. 

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 So, when we look at the data, it is 

probably we can do some types of statistical 

validation or analysis to see which runs are 

out of the norm. When we have multiple data 

points, it is easy to find the special-cause 

runs from the normal test runs. So, that is 

one way of addressing that in terms of taking 

it out. 

Again, if all the runs seem to be 

like special-cause runs, that is the typical 

behavior of the system. So, we can't take 

anything out. But if a few runs are out of 

spec in terms of what the other runs are, it 

may be easy to use statistical 

separate the data out. 

MR. TEICH: This is 

means 

Dan 

to 

from 

Whirlpool. 

So, Ravee, are you suggesting that 

a limit, some kind of a statistical level be 

set, that if special-cause runs occur, if we 

hit this level, then we would be allowed to 

take those out of the equations, out of the 

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calculations? Or are you talking about 

addressing the question of gathering data to 

determine statistically how many times that 

happens? I am not sure. 

MR. KVAIDHYANATHAN: I was just 

imagining the washing machine testing. You 

know, we test multiple units and multiple load 

sizes, multiple temperatures. So, we do have 

a good dataset in terms of what each of those 

test runs resulted in, you know, water 

volumes, energy consumption, recycle time. 

All this information is out there, and if we 

want to identify those specific runs which are 

anomalies, there is the possibility to treat 

this, you know, look at the data to understand 

which one is out of the norm. We can maybe 

define some limits, some statistical limits, 

to determine which one might be out of the 

norm. 

MR. HOMBROEK: I was just going to 

state that GE would certainly be in favor of 

setting some type of limit to the number of 

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anomalies that is described in the IEC example 

that has been provided. 

We also would like to state that 

different labs are interpreting this in 

different ways. You may go to one third-party 

lab and they may throw out information giving 

a certain set of criteria versus another lab 

may do it differently. And this is an area 

where I believe that harmonization needs to be 

in place. 

MS. ARMSTRONG: Okay. So, I am 

actually going to turn to AHAM and the labs. 

So, I want to know if you would be willing to 

share how AHAM in their verification program 

is going to determine an anomaly like this. 

What set of criteria do you plan to use? And 

then, for the labs, if you could speak to that 

as well in terms of what you do now? 

MS. CLEARY: This is Jen with AHAM. 

I think we could provide that 

information to you later. 

MS. ARMSTRONG: Thank you. 

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 MS. FARBER: So, this is Julia with 

UL. 

We have noticed that there is 

definitely a difference between the toploading and the front-loading washing 

machines. We tend to see that unbalanced 

loads in front-loading machines are often just 

redistributing the loads. We usually will 

keep those in the test run, and we have a 

tendency not to see anomalies in that 

situation. 

But in the top-loaders, we will say 

that there are a couple of different 

situations where we do see either an indicator 

light or we notice that the cycle is changing 

or we will see an additional amount of water 

entering the machine. That will give us an 

indicator that there is something amiss, and 

that leads us to possibly question whether or 

not it is an anomaly. 

We do want to ask, though, if there 

is a possibility to get a little bit of 

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Page 175 

additional clarification from the DOE and/or 

from AHAM on what situations you would prefer 

us to keep those test data and when you would 

like us to throw it out. We are totally open 

to hearing your thoughts on that. Of course, 

we are a test laboratory that is here to serve 

our clients and you guys as well. So, 

whatever guidance you offer to us is going to 

be the one that we use. 

Thank you. 

MS. ARMSTRONG: Anybody want to 

speak to the specific sets of criteria that 

they know are different? 

(No response.) 

We can't consider a uniform 

specification without knowing some ideas of 

what that should look like or what is actually 

being done differently. It is pretty hard. 

So, if you want to think about it 

and suggest things later, that would be fine. 

But it is hard to understand. 

MR. TEICH: This is Dan from 

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Whirlpool. 

I am just struggling right now, and 

I think we need to work as an industry to 

define what is the definition of an anomaly, 

the level at which one type of an anomaly may 

become enough that we throw out that cycle. 

And so, sitting here today, I don't 

think we can list each one of those, give any 

specifics. But I am not opposed at all to 

doing that as an industry and coming together 

and agreeing on some different levels. I 

think it would be a great idea because we do 

have quite a bit of interpretation among all 

the manufacturers, I think, Whirlpool 

included. When do we include that cycle; when 

don't we? 

And we have different ways of 

informing our consumers, whether we tell them 

in owners' manuals go ahead and re-adjust, do 

something, or we indicate via lights. So, I 

think it is way too broad to try to address 

right now. 

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 MS. ARMSTRONG: Okay. I am going 

to make -- this is Ashley from DOE -- I wanted 

to make one request that you keep in mind when 

you do this. 

For assessment testing, when we 

test one unit, we don't have the luxury of a 

large dataset to see where an anomaly may lie. 

Just because the ratings are off by a certain 

percentage, doesn't necessarily indicate an 

unbalanced load. We have had a unit 

consistently fail by 200 percent, I mean over 

many units tested. 

So, just because there is a 

threshold -- so I ask you to consider that. I 

think, from the Department's point of view, we 

are sensitive to the fact that there are 

testing anomalies and we would like to be able 

to articulate better. But, on a single test 

deviation from the ratings is not a unique 

indication that it is a test anomaly or a 

defective unit. So, when you think about 

that, that is the challenge from our 

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perspective. 

Okay? 

MR. MANTHEI: This is Phil Manthei 

from Alliance Laundry Systems. 

On the unbalanced load situation, 

when you are testing one unit, right now the 

test procedure for the RMC only requires 

recording the RMC for the maximum test load at 

the cold cycle. I think it has the same 

cycle, and wash and rinse have the same 

temperature. 

If you did that for the other 

cycles that you are testing, because you are 

testing like at the maximum load size, the 

average load size, minimum -- so, you have got 

three, and then you have got three 

temperatures. You could actually have like 

nine cycles. If you recorded the spin speed 

and RMCs from those other ones, you would have 

the kind of statistical information, I think, 

even on just testing one unit, to know that 

that one that is critical that you are using 

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right now is the one test at maximum load and 

cold wash is an anomaly. 

MR. TEICH: This is Dan from 

Whirlpool. 

I think that is somewhat, Ravee, 

what you were getting at. We run enough 

cycles in one test to determine just from 

those if there is an anomaly that stands out. 

MR. KVAIDHYANATHAN: We need to 

prepare a good proposal and communicate to you 

as the industry. 

MS. ARMSTRONG: I think that would 

be very helpful. 

Okay. 

MS. CLEARY: This is Jen from AHAM. 

I think the next several issues 

have to do with the drum volume measurement. 

We know that this has been a topic that we 

have sought guidance on in the past. There is 

existing guidance on drum volume measurement 

for Appendix J-1, and Appendix J-2 also gives 

some more detail. So, many of the issues have 

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been addressed. 

However, there are still some 

questions that we would seek further guidance 

on from DOE. That is what these questions are 

intended to do. 

Issue No. 2 has to do with the bag 

design, that the test procedure specifies use 

of a poly sheet, but it doesn't go into more 

detail than that. A flat sheet is going to 

result in some folds in the material, which 

can lead to an inaccurate measurement. 

So, what AHAM would suggest is that 

a bag be used to reduce folds in the material, 

and we would ask that this be clarified in the 

procedure, maybe as a recommendation of best 

practices or whatever the Department, if you 

agree, find the best for doing that, if there 

is any more detail. 

MR. MANTHEI: This is Phil Manthei 

from Alliance Laundry Systems. 

I think most of the manufacturers 

have been using bags for years and years and 

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years. But we are aware that at least one lab 

attempted to do it using plastic sheets, and 

it was a disaster. 

MS. ARMSTRONG: Here is where the 

fun part starts. DOE used sheets -- look at 

the faces -- when we did testing. I ask, have 

you done any round robin or activities within 

each lab to show that there is a significant 

difference between sheets and a bag? We did 

our round robin. The results yet are not 

public. They will be at some point. But I 

think we didn't see a whole lot of difference 

attributable to that issue. 

MR. TEICH: This is Dan from 

Whirlpool. 

To my knowledge, I have never seen 

a round robin done. I am anxious to see the 

results of what you are talking about. 

But I think for the manufacturers, 

when we attended the verification visits, it 

just stood to us -- since most of us, and I 

think all of us, have used bags for years, 

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like Phil said -- it just stood out as a huge 

area of variability. 

MS. ARMSTRONG: Potential? Or you 

have data that shows it is? 

MR. TEICH: We do not have data. 

MS. ARMSTRONG: So, potential? 

MR. TEICH: Potential, yes. 

MS. ARMSTRONG: Okay. 

MR. TEICH: And that is why I said 

I am anxious to see your results on the round 

robin, if it was done. 

MS. ARMSTRONG: I mean, to the 

extent -- well, just one second -- to the 

extent we have done any verification testing 

and used sheets, I mean, we haven't come 

knocking on your doors. The ratings are 

coming out pretty similar. 

(Laughter.) 

Not to say that that doesn't mean 

we shouldn't look into it, but I am just 

saying --

MR. TEICH: Right. Okay. 

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 MS. CLEARY: This is Jen from AHAM. 

I think, as I mentioned in my 

opening remarks, as the standards get more 

stringent, this could become an issue. So, I 

think that that would be our concern as well, 

that as the requirements are tighter and 

tighter and there is less room maybe even for 

conservative ratings, which may be helping 

variability right now, this may become a more 

important issue at that time. 

So, the results of the current 

round robin may not show that as much. I 

don't know. We will need to look at the data 

and evaluate that as well. 

MR. HOMBROEK: This is Phil from GE 

again. 

When this came up, it was during 

our AHAM round-robin testing, finding out 

which lab we wanted to choose for verification 

testing. As I recall, in this particular 

incident the lab in question, when they 

measured it, ended up putting that particular 

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washing machine in a new category. So, it did 

even have an impact in that result. 

I will have to look through some 

material, but I can look back, I guess it was 

about a year ago, at the data that we took at 

each individual third party. But it certainly 

did change the load size for this one third 

party. 

MR. TEICH: And this is Dan from 

Whirlpool. 

I guess I would ask, since the 

industry has used bags for many years, is 

there a particular reason why a bag wouldn't 

be considered as something to be standard? 

MS. ARMSTRONG: I am just trying to 

understand. So, if we go through a uniform 

requirement, we are going to have to have a 

rationale for doing such things. So, I am 

trying to understand why is it the bag. And 

if there are large differences, obviously, 

that indicates that there should be. But if 

there are little to no impacts on the energy 

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used, as long as you are implementing it the 

correct way, then it seems like having choices 

is not necessarily a bad thing. 

MR. TEICH: Right. Yes, and I 

think the gap is we just need to support that 

with data. And so, the round robin, from what 

you said a few minutes ago, it sounds like one 

is completed, has been completed, or is in 

process. 

MS. ARMSTRONG: We did a limited 

one, right, before? 

MR. TEICH: Okay. 

MS. ARMSTRONG: And I am not sure 

that you can draw 100 percent conclusion bags 

versus sheets. So, that being said, I think 

there is a common understanding that labs may 

have used different mechanisms. We didn't see 

a large variation in results, but we will see. 

MR. TEICH: Well, I would 

offer -- you know, maybe I am going way out of 

the box -- but I don't think we would be 

opposed to participating in a round robin to 

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confirm or gather data. 

MS. ARMSTRONG: Okay. Other 

manufacturers that agree to do that as well? 

I appreciate that offer. I will 

ask. 

MR. MANTHEI: This is Phil Manthei 

from Alliance Laundry Systems. 

I think it is just makes common 

sense. I mean, you have a cylinder, and 

trying to put a flat sheet into a cylinder 

makes no sense. 

MS. ARMSTRONG: All right. Moving 

along -- oh, anybody? 

MR. TEICH: I was just going to 

say, again, going along with what Phil said, 

it opens up much more areas for 

variability/interpretation. How do you wrap 

the flat sheet around it? That is where we 

saw the issues. 

MS. ARMSTRONG: Okay. Moving along 

to energy test cycle, or I might have them out 

of order on my agenda. 

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Page 187

 MS. CLEARY: Yes, I think we still 

had some other drum volume measurement issues. 

MS. ARMSTRONG: Okay. Keep going. 

MS. CLEARY: Yes. And I think, 

just to expand on the last point real quickly, 

it is that this could be down to like 

hundredths of a point in terms of the 

categories of the washers. So, that is what 

Phil, I think, was indicating. That is why we 

do see the potential here. 

MS. ARMSTRONG: I mean, just to 

clarify, the Department is not opposed to 

clarifying, where needed, but we will need 

some rationale. 

MS. CLEARY: Yes. Understood. 

I think that issue No. 3 on our 

sheet -- that is Jen at AHAM -- we probably 

don't need a lot of discussion on. It is 

something we just wanted to make sure to put 

on the record maybe, so that maybe labs are 

aware of this, that DOE procedure requires the 

weight of the water to be used to determine 

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the volume. NRCan may have a different 

procedure. We just think it is worthwhile to 

verify that all the labs are using the proper 

volume-measuring procedure, as required by 

DOE. 

MR. KVAIDHYANATHAN: Yes, this is 

Ravee, Samsung. 

The measurement of water volumes 

and weight, you know, the accuracy depends on 

the standard. So, what it really means is 

that, by using different approaches, the 

accuracy of measurement can be different. So, 

the weight measurement is done with more 

accuracy compared to the volume measurement, 

as per the standard. But the result will also 

be different if you use a different method in 

terms of accuracy. 

MS. ARMSTRONG: I don't know that 

you want me to say anything other than you 

have what our test procedure requires. I 

don't have it in front of you, but I assume 

that you have articulated it correctly. 

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Page 189

 MS. CLEARY: Yes, I think we see 

part of this --

MS. ARMSTRONG: Sure. That's fine. 

Fair enough. 

MS. CLEARY: -- open forum as 

putting it out there in the open, yes. Okay. 

The fourth issue that we have 

identified -- and this is also with regard to 

drum volume measurement -- deals with unique 

design features. So, this is sort of a broad 

category. We have identified one such 

situation could be the seal and the gasket in 

a horizontal-access machine, that labs could 

be interpreting this differently as how to 

measure the volume when there are different 

designs up in the drum. 

We would suggest specifically with 

regard to this gasket and this seal issue that 

the measurement of volume should not include 

the volume of the corrugations in the gasket, 

that bags should just be draped over the 

gasket, not extending into it. That would be 

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Page 190 

the specific language I think AHAM would 

suggest and shouldn't be seeing like the bag 

or the sheet being like stuffed into the 

gasket. 

There may also be other unique 

designs that either exist now for some 

manufacturers and not others or may be coming 

onto the marketplace that DOE should also be 

evaluating. We certainly recognize that it 

would be the manufacturer's, the individual 

manufacturer's own to come to DOE with those 

designs, but, overall, what we would be 

requesting today is that there should be a 

method to quickly and uniformly address these 

designs, so that all labs could be and would 

be testing in the same way. 

MS. ARMSTRONG: Okay. I mean, I 

would encourage you to come to DOE if you have 

a design for which you think the guidance does 

not specifically or clearly articulate how to 

do something before you do your certification 

testing and before any subsequent verification 

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Page 191 

testing may be done. That is going to be the 

easiest way to deal with this. 

And to Jen's point, we will think 

of ways that we can expedite a response with 

whatever regulatory mechanisms we have 

available to us. 

MR. MANTHEI: Do you mean that each 

manufacturer should come to you? 

MS. ARMSTRONG: So, to the extent 

you want to work with AHAM, because you all 

have a common design that needs to be 

addressed, that is fine. If each manufacturer 

has a different issue, you may also come to us 

individually. That is kind of at your 

discretion, depending on the potential designs 

that may need further clarification which you 

do not feel is adequately addressed by our 

test procedure or guidance. 

This is Ashley from DOE. 

MR. OSANN: This is Ed Osann. 

I have got a question about the 

AHAM position. In this case, seeking to 

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Page 192 

clarify that the volume of the corrugations in 

the gasket basically are not measured. Is 

this out of concern for the repeatability of 

the measurement or is this because -- why 

should this volume be excluded? 

MR. TEICH: I think it is 

repeatability of the measurements, but, then, 

more importantly, getting at the consumer 

facing issue, cloths are not meant to reside 

in that area. 

As you go through the wash process, 

we specifically try to keep cloths out of that 

area. So, how could it be included in a 

usable capacity. 

MR. OSANN: So, this goes back --

this is Ed Osann again -- so, this goes back 

to the notion that the drum volume is supposed 

to be the extent to which the --

MR. TEICH: The usable capacity. 

MR. OSANN: -- the volume that is 

used for washing clothes? 

MR. TEICH: Correct. 

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 This is Dan Teich at Whirlpool. 

I'm sorry. 

MS. FARBER: This Julia from UL. 

I may have some comments related to 

this issue, but not necessarily specific to 

the gaskets. So, I am wondering if you want 

us to wait on that until the end or if you 

want us to share those comments now. 

MS. ARMSTRONG: Please share them 

now. 

MS. FARBER: Okay. All right. So, 

we have some clarity questions about the 

capacity measurement of clothes washers. 

According to our engineers, the latest 

guidance is showing examples of where the 

capacity of clothes washers should be 

measured, and that has helped to consistently 

measuring the volume across many models. But 

the concern is for top-loading models, this 

capacity measurement does not represent the 

useful space of loading clothes by the 

consumer. And when the guidance came out, it 

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Page 194 

represents a much closer -- it was much closer 

to the usable space than previous 

interpretations. Now that that has been out 

for several months after the guidance, there 

are some models in the market that are getting 

further from the consumer useful space while 

still being within the guidelines of the 

latest guidance. 

So, it is our suggestion that, if 

you could at DOE, that guidance documents and 

schematics get updated periodically to ensure 

that the measured capacity reflects the usable 

space, per the intent of the standard. 

MS. ARMSTRONG: This is Ashley. 

So, I think, as a general practice, 

we do not have an issue updating guidance 

documents where they may necessitate revision. 

However, we are going to have to know the 

details about why and what needs to be 

considered for reopening. 

MS. FARBER: Thank you. 

MR. HOMBROEK: This is Phil 

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Page 195 

Hombroek from GE. 

A question, actually, to UL. Were 

you talking about the difference between the 

J-1 and J-2 documents? 

MS. FARBER: That is referenced in 

here, yes. 

And I have another question about 

the transition of declared capacity from J-1 

to J-2 and when that might be taking place. 

Sorry. This is Julia from UL. 

MS. KOHL: This is Betsy Kohl from 

DOE GC. 

The new J-2 is required for use on 

the compliance date, those new standards that 

were published in The Federal Register 

yesterday, I guess. 

PARTICIPANT: We can't hear you. 

MS. KOHL: Oh, sorry. 

Betsy Kohl, DOE GC. 

Use of J-2 is required on the 

compliance date of the new standards that were 

just published in the DFR a day or two ago, 

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Page 196 

assuming that we don't get adverse comments 

that would lead us to withdraw the rule. 

MR. HOMBROEK: This is Phil 

Hombroek from GE. 

You made reference to a new rule 

that came out in the last day or something? 

Okay. And you are backing out more of the 

standards in J-2 versus what is in the J-1? 

Is that what I understand? 

MR. TEICH: This is Dan Teich from 

Whirlpool. 

I hope you are referring to the 

direct final rule that came out --

MS. ARMSTRONG: We are. 

MR. TEICH: -- which was we saw a 

pre-version of that, I don't know, two weeks, 

three weeks ago. 

MS. ARMSTRONG: Yes. It is just a 

standard rule. It is not a test procedure 

rule. 

MR. HOMBROEK: Got it. I 

understand. 

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Page 197

 MS. ARMSTRONG: The compliance 

date, the test procedure is keyed to the 

amended standards. So, the J-2 is keyed to 

the amended standards. So, you don't actually 

have to use the J-2 procedure until the 

compliance date of the amended standards, 

which got published yesterday. That is clear. 

MR. KVAIDHYANATHAN: That is March 

7, 2015. 

MR. HOMBROEK: 2015? Okay. 

MS. ARMSTRONG: Okay. Have we 

dealt with volume? 

MS. CLEARY: No. 

(Laughter.) 

MS. ARMSTRONG: Oh, okay. Keep 

going with volume. 

MS. CLEARY: Jen Cleary. 

We have one more to address. The 

current volume measurement guidance, as well 

as Appendix J-2, the language does make it 

clear that the shipping bolts are to remain in 

place. But neither of those documents 

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Page 198 

specifies whether the shipping bolts should be 

supported. 

So, AHAM would suggest that DOE 

should expressly state both in the current 

guidance and in Appendix J-2, that the 

shipping bolts should be supported. The 

reasoning there is that this would prevent the 

drum from sagging when the water is added and 

will also keep the unit in as-shipped 

condition, which we understand to be the 

intent of both J-2 and the guidance. This 

will also prevent damage to the unit during 

the test. 

So, I don't know if the 

manufacturers have more they wanted to add to 

that. 

MR. HOMBROEK: It is Phil Hombroek 

from GE. 

Just to make sure you understand 

what we mean by being supported, what we mean 

is that the shipping bolts themselves during 

the test need to be held or fixed; otherwise, 

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the back of the unit sags down and creates the 

distortion that has been talked about that can 

add an impact on your volume and, also, can 

damage the unit, as we mentioned. 

And we know this varies between 

third-party labs as to whether it gets done or 

not. It does have an impact. 

Thank you. 

MS. ARMSTRONG: Okay. Anybody else 

on drum volume capacity? 

(No response.) 

Okay. 

MR. MORRIS: Thank you, Ashley. 

This is Wayne Morris from AHAM. 

The issue that we brought up in 

item No. 6 has to do with the energy test 

cycle. This is the concern that is expressed. 

I mean, I am not going to go ahead and read 

the entire thing. I think you get the picture 

on this. 

But our position is that the 

sanitization cycle and any other cycles here 

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Page 200 

should not contribute to the accuracy 

representation. We have suggested here that a 

consumer usage study needs to be done. If 

there is not data to show that the consumers 

use the sanitizing cycle or other cycles 

often, then the cycle should not be required 

in the test cycle. 

So, we would like the Department's 

comments on this situation, and welcome my 

colleagues as well. 

MS. ARMSTRONG: Are you 

volunteering to do a consumer usage study? 

MR. MORRIS: Well, we think that it 

needs to be done. 

This is Wayne Morris. Sorry. 

And we would certainly be glad to 

work with the Department on that. 

(Laughter.) 

MS. ARMSTRONG: The Department is 

always glad to work with you, too. 

MR. MORRIS: Great. 

(Laughter.) 

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Page 201

 Maybe this is one of those where 

one could supply labor and one could supply 

money. 

(Laughter.) 

It would probably have to be a 

negotiated rulemaking on that one. 

(Laughter.) 

MS. ARMSTRONG: Okay. 

MR. MORRIS: This is Wayne again. 

Do you have any questions about 

what we are suggesting there or why? I mean, 

I think that that is why we t’d this up today, 

is to see if you understand kind of what we 

are leading at. 

MS. ARMSTRONG: Yes, I mean, I 

think we get it, right? 

MR. MORRIS: If you want me to, I 

will go on then. The test cloth loading 

method varies. We have already talked a 

little bit about this with regard to the 

possibility of a setting or a situation that 

could occur with an unbalance. 

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Page 202

 But the loading of top machines, 

top-loading machines without an agitator is 

particularly troublesome, as we have found in 

some of our testing situations, the test 

procedure states in the load and the energy 

clause, by grasping them in the center and 

shaking them to hang loosely and then putting 

them into the clothes container. It doesn't 

define how or where to place that test cloth 

in the drum. 

And so, what we had suggested was 

that DOE could allow the use of a form where 

the manufacturer indicates the load pattern 

until a more precise loading can be developed 

for the test procedure. 

An alternative to this, also, if 

the Department is willing, we might be able to 

look at the possibility of a video, as has 

been suggested before, that we could develop, 

circulate comments. And then, if all the labs 

are in agreement, then we could use that as a 

loading pattern, if it is an industry-wide 

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situation. If this turns out to be an 

individual product situation, then this may be 

a loading pattern that needs to be indicated 

in some form. 

So, we would like the Department's 

thoughts on how best to proceed with this 

situation. I think we are willing to help 

with this. But I think that we need to have 

some indication from the Department which they 

would prefer before we set out in one 

direction or another. 

MS. ARMSTRONG: This is Ashley from 

the Department. 

I think, at the outset, we need to 

understand that there is a significant --

there is an impact on consumption and/or 

ratings with load pattern variance. We need 

to get to that first. 

MR. HOMBROEK: This is Phil from 

GE. 

Certainly, different machines 

operate differently and have different sensing 

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mechanisms by which they determine load size. 

And it our view that we need to inform the 

consumer on these specific types of machines, 

how to properly load the machine to get the 

best performance. And we do that in our useand-care manuals, and that is our facility, if 

you will, to communicate to both the consumer 

and whoever may be testing our units what the 

best and most appropriate means to load the 

machine. 

But it all comes down to how you 

load-sense, and different manufacturers do it 

differently. Sometimes it is a matter of 

agitating the machine. Sometimes it is a 

matter of spinning the machine, and some are 

very complicated and somewhat proprietary. 

So, at the end of the day, they do 

operate and we do feel an obligation to try to 

get to that by communicating to the consumer. 

But I will say that it will certainly have an 

impact on the DOE measurement if it is not 

done properly. 

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 MR. TEICH: This is Dan from 

Whirlpool. 

everything 

And I

Phil 

will ju

said. 

st fully agree with 

I think this was 

demonstrated as we did our verification lab 

visits. And that is truly why we got in a 

discussion to clarify and came up with this 

proposal. We all instruct in our 

instructions. And with the newer machines, 

relatively-newer machines, it is very, very 

important. It makes a big difference. 

MS. ARMSTRONG: Okay. So, to 

answer Wayne's question about how this should 

be solved, I think the Department needs to 

think about this and get back to you before we 

can tell you kind of our position on the best 

pathway forward. 

Thanks. 

MR. HOMBROEK: Let me just add one 

more thing. This is Phil Hombroek from GE 

again. 

About grasping the cloth versus 

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laying it flat in the machine, I just want to 

make it quick and brief. It does make a 

difference if you have a cloth that is held in 

place and tossed in the basket versus it going 

flat one on top of another all the way around 

the basket. 

Cloths that typically are laying 

flat on top one after another are going to get 

to that issue where we are going to have more 

potential for out-of-balance loads. Because 

if you can imagine the water going right on 

top of those flat sheets, all you are doing is 

creating one solid cake, and that is what we 

are trying to avoid. That is why it is 

important to us. 

Thank you. 

MR. MORRIS: And this is Wayne. 

I would add to that, that the issue 

also is that that is not the way the consumer 

loads a machine. They don't lay something out 

flat and then pack it into the machine in a 

flat method one on top of another. At least I 

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don't ever know of any consumer to do it, or 

if there is anybody on the telephone that 

wants to volunteer they do, that would be 

interesting to learn. But I think that most 

consumers don't behave in that way. So, this 

will be closer to approximating the way that 

the consumer actually does load a machine. 

Thank you. 

MS. ARMSTRONG: Any other comments? 

Questions? 

(No response.) 

Okay. Water pressure. 

MR. MORRIS: This is Wayne again. 

Thank you. 

Yes, obviously, this is very 

similar to the issue that we talked about 

earlier today in regard to the dishwasher. 

Our experience has been that labs have been 

seen interpreting how and where the water 

pressure is measured and controlled 

differently. And we are concerned that this, 

as we described earlier, is important because 

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it is an issue of that drop in pressure that 

happens when you first open the valve to the 

situation. 

So, again, is there a certain 

amount of time that the pressure can go below 

the limit. The lab seems to be applying 

different limits to this situation. So, we 

have made a suggestion that the pressure can 

be measured as the water is flowing. That is 

consistent with what we have said before and 

what we have talked about earlier. 

DOE made this change request in 

Appendix J-2, but we are going to be with J-1 

for three years. We think it is important 

that we have a clarification in that 

situation. Water pressure is expected to drop 

at the moment the valve opens, and we 

suggested the two-second limit for the 

transient pressure drop be added to both the 

J-1 and the J-2. And so, we are asking that 

the Department do that by form of guidance. 

MR. HOMBROEK: This is Phil 

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Hombroek from GE. 

I think we all kind of collectively 

agreed that two seconds was reasonable for our 

own labs' capabilities, and it is something 

that kind of drives consistency amongst all 

the groups. 

If we placed a higher tolerance on 

it, for example, that would require additional 

equipment, and so on, in order to prevent any 

reduction in pressure for less than a second. 

For example, that would cause a lot of lab 

restructuring. 

MS. ARMSTRONG: And just a 

question. Is this something you pretty much 

voluntarily maintain now? 

MR. MORRIS: We do. This is Wayne 

Morris. We do. Many of the manufacturers 

have volunteered that they do that as well. 

And this is also done with the laboratory that 

AHAM uses in its verification program. 

As Phil said, it is a capability 

situation. The labs are capable of measuring 

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it in that timeframe without going to 

extremely-expensive equipment. And we also 

think that the labs will see a constancy and 

very little tolerance changes, differences in 

their measurements if we do this on a flowing 

basis, which is, I think, what was intended 

all along and what seems to be intended in 

other test procedures. 

Thanks. 

MS. FARBER: This is Julia Farber 

from UL. 

We are measuring the water as 

flowing and we agree with the two-second 

recommendation. 

Thank you. 

MS. ARMSTRONG: Okay. Keep going, 

yes. Ambient conditions. 

MR. MORRIS: Wayne Morris again. 

Recording the ambient temperature 

and humidity is not currently required by the 

DOE test procedure. This may not be as 

critical as it was in the dishwasher 

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situation, where the air drying and that 

situation. But when you pack a large number 

of washing machines that all are using in some 

cases heated water as well as cold water into 

a room to do multiple test runs, all going on 

at the same time, we think that it is very 

important that we try to maintain the ambient 

conditions. 

And so, we do believe it is 

necessary that the labs are recording their 

ambient conditions. And so, we think that it 

is something that the Department can indicate 

in guidance that this should be done. 

We believe it is important for the 

manufacturers to have the access to those 

ambient temperatures in case there is any lab 

dispute that may arise. One of the procedures 

that the AHAM procedural guide allows for is 

for the manufacturer to challenge the 

laboratory. While that is used on the 

extremely rare occasion, it is important that 

when you backtrack to those circumstances, and 

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certainly if there is an enforcement action, 

it is sometimes necessary to go backwards into 

data. In some cases, you are going backwards 

a year; you are going backwards a significant 

period of time. 

Whereas, a lab may be doing things 

the same way today that they did, say, 30 days 

ago, they may be doing things differently 

today than they did two years ago. And so, as 

we get more and more data accumulating over a 

longer period of time, it is important to have 

these recordings. So, we are suggesting that 

this is something that the Department, it is 

good laboratory practice to not only structure 

this and measure this, but it is also 

important to record this, if we need to ever 

go backwards. 

MR. TEICH: This is Dan from 

Whirlpool. 

I guess I would just add that is a 

practice in our labs. So, that is one of the 

reasons, if we ever do need to challenge a 

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verification test, we would look for that 

data. 

MR. MORRIS: This is Wayne. 

And it is a practice that we use in 

our laboratory for our verification program. 

We think it is probably good laboratory 

practice for anyone. I find it hard to 

believe that anybody would not do it, but we 

also think it is important that, if the 

Department doesn't specify that, then it is 

one more variable that we can get to that 

could affect the results. 

Thanks. 

MS. ARMSTRONG: So, a question for 

you, and forgive my lack of knowledge in being 

able to quickly find this. Are the humidity 

conditions actually specified in the test 

procedure that are required to be maintained? 

So, why would you want them recorded? I mean, 

I am not saying at the outset that that 

wouldn't just be good information to have as a 

basis for what was going on during the test, 

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but what basis would you have to challenge 

anything if there is no requirement for them? 

MR. MORRIS: This is Wayne Morris. 

The only thing I would say is you 

are right, it isn't, but it is good laboratory 

practice in any situation. And almost any 

standard out there is going to require a 

temperature and a humidity min and max. So, 

it is not something that we are asking for 

that is extremely strange. But if the 

Department feels that the temperature is the 

only one they want to ask for being recorded 

because that is what is in the CFR and the 

test procedure, we could understand that. We 

were just asking because it is consistency. 

MS. ARMSTRONG: Oh, yes. This is 

Ashley from the Department. 

As a best practice thing, I am not 

advocating a position here for the Department. 

I am just more trying to understand where the 

request comes from on humidity. 

MR. MANTHEI: This is Phil Manthei 

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from Alliance Laundry Systems. 

It could impact, I suppose, very 

slightly when you do the RMC measurement; you 

are taking that load out and you have to go 

weigh it. Well, how far away walking with 

this load and it is evaporating more moisture 

and the humidity level in the air is going to 

have some impact on that. 

MS. ARMSTRONG: Okay. 

MR. MORRIS: Go ahead? 

MS. ARMSTRONG: Yes. 

MR. MORRIS: Okay. Thank you, 

Ashley. 

No. 10, I guess we are asking a 

question. Is the Department doing any testing 

per J-2? It would be useful to observe the 

standby portion of the test. 

Also, should manufacturers discover 

the ambiguities in the test procedure language 

with regard to low-power mode, what is the 

best process for addressing those with DOE? 

Is it possibly with industry-sought guidance? 

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We would just like to seek some feedback with 

this situation. I think that the J-2 now 

calls out the standby or low-power mode 

measurement. We just would have liked some 

information in regard to this. 

DOE. 

MS. ARMSTRONG: This is Ashley from 

We did do 

So, the J-2 rulemaking is complete. 

testing in support of that 

rulemaking during the rulemaking proceeding. 

That being said, obviously, if you 

come across in your testing ambiguities on how 

you think people are interpreting J-2 or if 

you read it and it is unclear on how you 

should test for J-2, I encourage you to submit 

a comment or submit a question. You can send 

it to me. You can submit it through our 

guidance database, which is the best way to do 

it. 

And obviously, we would issue 

guidance across the board for all, and a test 

procedure guidance, as our policy was stated 

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earlier, would be put out for comment. 

MR. MORRIS: This is Wayne Morris. 

Is the data that you did in regard 

to the standby portion or low-power mode 

portion available? 

MS. REICH: This is Judith Reich 

from Navigant. 

A summary of that data is available 

in the notices that accompanied the test 

procedure rulemaking. 

MR. HOMBROEK: This is Phil 

Hombroek from GE. 

I would like to ask, further, if 

you guys would be willing to offer which lab 

may have done the testing, so that we might be 

able to go see some of the testing and maybe 

set up some of our own units to do that, just 

to make sure that we are following along what 

was intended. 

MS. ARMSTRONG: We did it at our 

own lab. So, the answer is going to be no. 

But, that being said, like 

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something was mentioned in the hall. To the 

extent you guys all go to a third party, and 

you may want to invite the Department, I don't 

know that we could necessarily articulate, 

depending on the spot, but we would definitely 

be willing to be part of those discussions as 

to what is going on and how the test procedure 

is being done, if you all wanted to go to a 

lab to do it, similar to what you did prior to 

picking a lab for your verification. 

MR. HOMBROEK: I think that is an 

excellent idea. And this is Phil from GE. 

I would certainly like to suggest 

maybe a third party that we could all agree to 

go to and run some testing with the J-2 in an 

open forum where we could see the test run. 

MR. MORRIS: Well, Ashley, if there 

is anybody else, that one of my colleagues 

might have any additional items, I would 

certainly be willing. But I think that, 

overall, obviously, we want to thank the 

Department for today and for Judy and others 

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who have helped with the workshop. 

This is something that we have been 

asking for for a while. I know that you all 

have seen the need for it as well. But, as we 

get more and more laboratories involved and 

more manufacturers with their laboratories 

involved, as well as, then, in the case that 

we have verification laboratories and now we 

have enforcement actions and enforcement 

laboratories involved in this, the lab-to-lab 

variation is something that we would like to 

try to reduce as much as possible. And I 

think the Department would agree with us on 

that. 

The importance, also, cannot be 

overstated with the fact that, as we begin to 

squeeze the amount of energy out of these 

machines -- and it doesn't matter whether we 

are talking room air conditioners or 

dishwashers or dehumidifiers or whether it is 

clothes washers, we are talking about water 

factors now which are down in the tenths of 

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digits. We are talking about calculations of 

load volumes that in some cases is extremely 

minuscule between the one division of a 

section and another. And we have seen 

examples of that ourselves. 

As we begin to look at kilowatt 

hours per year, certainly in the low triple 

digits, the differences are beginning to be 

extremely important. We believe that, 

overall, this program is extremely well run, 

that the manufacturers have made a huge amount 

of investment to make sure that there is 

absolutely as much as possible consistency 

across all lines. 

We voluntarily participated in 

Department of Energy activities of measuring 

in our verification program. We help with 

reporting to DOE when there is an issue that 

may come up, though it is extremely rare. We 

have been as cooperative as we can with all of 

these situations. 

We appreciate the laboratories. 

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And the laboratories have been very, very 

cooperative with us in all of these 

situations. 

But I think that, as we begin to 

squeeze this amount of energy and water and 

other activities, the differences between a 

unit that may potentially be a non-compliant 

unit and one that is compliant is extremely 

low. And so, any reduction in the variability 

we can do is important, not just to us, but to 

the consumer. We want the consumer to have 

faith in the numbers that are shown on the 

machine and in databases and by the 

manufacturer. 

The other situation is also 

important. And that is that, as we begin to 

squeeze these numbers down less and less, the 

manufacturers have got to design machines that 

meet these. And they have got to be able to 

do design testing in new machines and know 

that that same test is going to be done 

multiple times, and it is going to result in 

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the same results two, three, four years down 

the road, when it is tested in a verification 

procedure. 

So, we have set requirements for 

picking units up as a certain percentage. It 

takes several years before you are going to 

get all the models. And that means that there 

is a span of time between the time that that 

was certification-tested to the time that it 

is verification-tested. And that period of 

time allows for differences. 

So, the more that we can do to 

reduce this by giving guidance, writing it 

down, putting it in procedures, is all going 

to go to the credibility of the program and 

building it into a situation that allows the 

consumer to have most accurate information. 

So, thank you, and we appreciate 

all of the effort that it takes to put these 

on, people that are on the phone lines as well 

that have been helpful in communicating. So, 

it is all a good situation, and we hope that 

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for the other products that we are looking at 

we can do something like this, and we can do 

it on an ongoing basis. 

Thank you. 

MS. ARMSTRONG: So, I will, just in 

closing, say we appreciate everyone coming 

today. We look forward to working together 

with a lot of the issues that we have 

identified today that we may not have 

solutions for right off the bat. But we 

appreciate your taking the time to come here. 

As you do encounter additional 

potential clarifications or issues, I do 

encourage you to engage the Department early, 

either through the guidance process or through 

an email to the product PM or myself. It 

really helps us both inform our rulemaking 

processes, but for those that we don't have 

ongoing, you know, to better understand what 

we may need to do to help clarify where 

ambiguities lie, where we can. 

So, with that, I hope everyone has 

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safe travels and enjoys their weekend. 

Thanks. 

(Whereupon, at 1:44 p.m., the 

meeting was adjourned.) 

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170:9 130:21 131:20 32:12 36:4 38:14 186:12,20 187:3 214:9,15 215:14

anomaly 167:22 applied 38:17 39:2,21 41:18 187:11 188:18 219:3

168:20 173:15 39:15 40:12,14 42:12,15 44:15 189:3 190:17 aspect 51:4 81:18

174:20 176:4,5 42:11 46:6 125:14 47:12 49:4 50:11 191:9 193:9 109:11

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118:9 119:16 108:22 113:17 155:17 171:17 working 18:16 125:16

121:20 122:1,6

133:13 135:8,13

119:12 137:20

144:18 148:20

176:1,14 179:4

181:15 184:10

23:21 24:1 61:13

103:21 104:16 Z

136:15,19 138:19 149:1 153:5 193:1 196:11 106:19 110:15 zero 63:4 148:7,8

139:1 140:13 199:14 200:15 205:2 212:19 130:3 165:2 223:7 150:1

141:14 145:1,9 201:9 206:17 Whirlpool's 111:14 Works 149:5 zone 75:13

146:4,7,9,22

147:20 148:7

149:5,6,8,20

150:3,5,14,16

164:3,13,22 167:8

167:8 168:4,18

170:20 172:10

174:16 187:22

188:8 198:8

206:11 207:12,19

208:9,16 210:12

211:4,4 219:21

221:5

WATSON 3:13

wattage 119:15

watts 51:12

way 7:21 10:11

16:11 19:8,12,16

24:8,13 30:21

38:4 48:7 51:5

54:4 63:14 72:10

73:15 78:1 79:22

83:9 84:18,20,20

87:6 105:4 108:1

114:1 115:4 117:8

117:16 123:22

124:4,5,11 125:13

125:14 126:14

142:22 144:2

149:10 154:21

155:3 161:10,10

161:21 165:3

171:7 176:21

207:13 209:16

210:18 213:3

214:3 217:2

Wayne's 205:13

ways 79:2 170:17

173:5 176:17

191:4

wear 55:17 63:1

65:5

wear-in 64:4

webinar 7:17,20

8:7,8 44:6 98:11

website 7:12 16:15

31:7,20 102:8

weekend 159:11

224:1

weeks 196:16,17

weigh 215:5

weight 17:21

187:22 188:9,13

welcome 6:12 7:17

54:11 88:9 134:8

152:19 156:9

159:4 200:9

went 83:21,21

158:12,12 167:10

weren't 46:2

WES 3:3

WESTPHALEN

3:12 65:12 66:1,5

66:8

Whirlpool 2:18,18

2:19 9:13 11:12

whowants 44:3

widen 152:6

WILBAND 3:9

WILLIAMS 3:7

willing 80:14

156:10 173:13

202:17 203:7

217:14 218:6,20

window 45:12 48:1

wire 82:4

wish 20:6 43:19

withdraw 196:2

witness 54:6

witnessed 15:1

133:12,21

witnessing 126:16

wonder 42:8

wondering 66:13

118:20 148:15

193:6

WOODCOCK 3:8

WOODFORD 3:2

word 145:7

wording 14:21 90:2

109:18 161:15

words 47:19 68:3

69:17 111:4

124:12 128:18,19

132:2

work 6:6 8:10

10:17,21 18:14

57:18 72:18 76:13

95:14 105:12,13

workshop 219:1

worth 128:19,20

worthwhile 114:8

188:2

wouldn't 34:21

35:14 47:18 65:5

79:9 82:1 86:5

168:1,1 184:13

213:21

Wow 20:14 144:17

wrap 186:17

write 115:12

writing 91:17

222:13

written 40:10

86:15 93:9,21

94:13 108:17

130:13 136:21

137:17 147:4

wrong 122:8

161:11

Wuesthoff 53:12

53:13,15 54:11

WUESTOFF 3:6

X

X 59:5,10 64:21

Y

year 16:4,5,9 28:14

30:1 69:4 184:5

212:4 220:7

years 30:11,20

67:10 165:15,15

1

1 1:6 87:15

1.1.5 109:6

1:33 159:2

1:44 224:3

10 215:14

10-minute 158:6

10:24 83:21

10:47 83:22

100 5:4 114:15

185:14

100-degree 60:9

1000 1:10

108 5:5

12:08 158:12

12:33 158:13

124 5:6

13 4:5,6

135 5:7

138 5:8

14 136:15 157:2

142 5:9

143 5:10

147 5:11

15 83:19

15-minute 83:8

158:7

152 5:12

156 5:13

158 5:8

16 51:6,18 66:19

141:9

160 5:14

Neal R. Gross & Co., Inc.

202-234-4433
Page 252 

161 5:15 430.23 37:4

180 5:16 44 4:17

1992 147:1,9 148:6 45 119:3

156:1

5

2

5 102:2 138:5

2 55:4 87:15,18 5,000 63:10

133:17 142:10 5,000-mile 63:7

180:6 50 168:11

2.6.3.2 89:3 55 4:19

20 66:14,22 67:19

6 68:2,5 70:3 119:2 6 4:2 199:16

60456 161:12

141:6 158:8,9

200 5:17 177:11

2009 146:14 147:9 63 4:20
 

148:6,10 149:4
 

7 155:8 156:1 7 197:9 2010 5:2 85:4,19 70 151:9 154:5 2012 1:6

72 63:2,4,9,14 2015 197:9,10 73 4:21 202 5:18

75 151:2,7,10 208 5:19

152:18,19,21 211 5:20

153:18 154:10 216 5:21

22 4:8,9

8 24 55:20 56:2 62:21 8 125:2 63:14,15,16,17 8E-089 1:10 64:5 66:12,13 80 151:9 154:5 69:9 83 4:22 25 158:8 85 5:1,2 148:7 2500 69:4,5 150:1 26 4:10

29 4:11

9

9 4:4

3 9:00 1:11

3 187:16 9:05 6:2 3-dimensional 78:5 93 5:3 30 34:10,15 212:7 97.6 41:15 30-day 32:20

31 4:13

36 4:14

4

4 138:5

40 69:2,2 70:17

40-degree 60:10

41 4:15

43 4:16

Neal R. Gross & Co., Inc.

202-234-4433
 

253

C E R T I F I C A T E
 

This is to certify that the foregoing transcript 


In the matter of: Room A/Cs, Dishwashers and

Residential Clothes Washers

Before: US DOE

Date: 06-01-12

Place: Washington, DC

was duly recorded and accurately transcribed under 


my direction; further, that said transcript is a 


true and accurate record of the proceedings. 


-----------------------

Court Reporter 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com