May 22, 2013 

Via E-Mail 

Ms. Ashley Armstrong

U.S. Department of Energy 

Office of the Building Technologies Program, Mailstop EE-2J 

1000 Independence Avenue, SW

Washington, DC 20585-0121 

EERE_ACES@ee.doe.gov 

Re: AHAM Request for Guidance on Several Refrigerator/Freezer Test Procedure Issues

The Association of Home Appliance Manufacturers (AHAM) respectfully submits the following

requests for guidance on several questions regarding the refrigerator/freezer test procedures, as 

specified below. 

AHAM represents manufacturers of major, portable and floor care home appliances, and 

suppliers to the industry. AHAM’s more than 150 members employ tens of thousands of people 

in the U.S. and produce more than 95% of the household appliances shipped for sale within the 

U.S. The factory shipment value of these products is more than $30 billion annually. The home 

appliance industry, through its products and innovation, is essential to U.S. consumer lifestyle, 

health, safety and convenience. Through its technology, employees and productivity, the 

industry contributes significantly to U.S. jobs and economic security. Home appliances also are 

a success story in terms of energy efficiency and environmental protection. New appliances 

often represent the most effective choice a consumer can make to reduce home energy use and 

costs. 

I. What Surface Is Used to Set the Rear Clearance of the Unit During Testing When 

the Back of the Unit Is Not All One Plane?

DOE’s recent amendments to the refrigerator test procedure recognized ambiguity regarding 

Appendix A1’s rear clearance requirements by clarifying the set-up requirements for rear 

clearance. Specifically, DOE added language to the test procedure in Appendix A indicating that 

the “clearance shall not be greater than 2 inches (51 mm) from the plane of the cabinet’s back 

panel to the vertical surface. If permanent rear spacers extend further than this distance, the 

appliance shall be located with the spacers in contact with the vertical surface.” See 10 C.F.R. 

430, Appendix A, § 2.8. 
p 2

Although this language does clarify the requirements as compared to Appendix A1, it does still 

leave ambiguity regarding what surface is to be used to set the rear clearance when the back of 

the unit is not all on one plane. Thus, AHAM asks DOE to clarify that, in that situation, testers 

should refer to the Committee Draft for Vote (CDV) version of Part 1 of IEC 62552.2 Household 

refrigerating appliances – Characteristics and test methods.

1

 Annex B, section B.2.3.1 is 

consistent with Appendix A, § 2.8, but also provides more detail regarding the surface to be used 

to set the rear clearance. For example, it indicates that the rear plane of the appliance is the 

largest flat surface at the rear of the cabinet shell excluding any local features (e.g., protrusions 

associated with brackets or the compressor). It also provides a number of diagrams that are 

helpful in determining how to set up the unit under test (see Figure B1). AHAM understands 

that DOE may not be able to simply reference IEC 62552.2 in guidance, but we request that 

DOE issue guidance that exactly harmonizes with that draft standard. Not only does section 

B.2.3.1 match the intent of Appendix A, § 2.8, but harmonization with international standards is 

the best way to provide consistency and clarity to regulated parties and reduce burden on 

manufacturers. 

II. Is the Volume of All Air Ducts Deducted From the Determination of Volume?

10 C.F.R. 430, Appendix A, section 5.3 requires electric refrigerator and electric refrigeratorfreezer total refrigerated volume to be measured in accordance with AHAM/ANSI HRF-1-2008. 

That standard indicates that, among other things, the “volume of air ducts required for proper 

cooling and operation of the unit” “shall be considered as being in place and their volumes 

deducted.” Does DOE interpret “the volume of air ducts required for proper cooling and 

operation of the unit” to include only the air ducts that feed the fresh food and freezer 

compartments or all air ducts in the unit? 

III. How Are Product Classes Determined Without a Defrost Cycle Type?

Appendix A, section 1.9 states: 

“Defrost cycle type” means a distinct sequence of control whose function is to remove 

frost and/or ice from a refrigerated surface. There may be variations in the defrost control 

sequence such as the number of defrost heaters energized. Each such variation 

establishes a separate distinct defrost cycle type. However, defrost achieved regularly 

during the compressor off-cycles by warming of the evaporator without active heat 

addition is not a defrost cycle type. (emphasis added)

The last sentence, in italics above, is confusing. It seems to imply that off-cycle defrosts are not 

automatic defrost units; however, the only alternative is for off-cycle defrosts to be considered

manual defrost units and that certainly cannot be the case since the customer would not interact 

with the defrost in such a product. The ambiguity in the sentence could also indicate that if a 

product does not use a heater, then there is not a defrost cycle type. If that is the case, then, 

because product classes for refrigerator/freezers are based, in part, on defrost type, it would be 

impossible to determine what product class the product is in and the energy use of the product. 

 

1 We understand that the CDV was circulated for vote on May 10, 2013, and that voting will close on August 16, 

2013. Given that the standard is in the CDV stage, we do not expect substantive changes. 
p 3

Accordingly, due to the extensive confusion that sentence creates, AHAM respectfully requests

that DOE clarify the intent behind the italicized language, including how product class is to be 

determined when a product does not use a heater. 

IV. Compartment Temperature Measurements

DOE made the following amendments from Appendix A1 to Appendix A for section 5.1.2 

(redlines indicate changes to Appendix A1): 

Compartment Temperature. The compartment temperature for each test period shall be an 

average of the measured temperatures taken in a compartment during the test period as 

defined in section 4.one or more complete compressor cycles. One compressor cycle is 

one complete motor “on” and one complete “off” period. For long-time automatic defrost 

models, compartment temperatures shall be those measured in the first part of the test 

period specified in section 4.2.1. For models with variable defrost controls, compartment 

temperatures shall be those measured in the first part of the test period specified in 

section 4.2.2. 

The amended language indicates that the averages of the compartment temperatures are to be 

taken during the test period defined in Section 4. This test period is from defrost to defrost and 

includes defrost recovery. AHAM would like to know what the reasons were behind this 

change, especially considering the language in Appendix A1, which specifically indicates that 

defrost recovery shall not be included. Our understanding is that it was not DOE’s intent to 

include defrost recovery, and we thus request that DOE clarify its intent so that regulated parties 

understand the compartment temperature requirements.

V. The Stabilization Period Duration is Unclear.

In the current test procedure, Appendix A1, the steady state condition is described, in section 2.9, 

to be measured over a stabilization period constrained by a two hour minimum: 

2.9 Steady State Condition. Steady state conditions exist if the temperature 

measurements in all measured compartments taken at four minute intervals or less during 

a stabilization period are not changing at a rate greater than 0.042 °F. (0.023 °C.) per 

hour as determined by the applicable condition of A or B. 

A. The average of the measurements during a two hour period if no cycling occurs or 

during a number of complete repetitive compressor cycles through a period of no less 

than two hours is compared to the average over an equivalent time period with three 

hours elapsed between the two measurement periods.

B. If A above cannot be used, the average of the measurements during a number of 

complete repetitive compressor cycles through a period of no less than two hours and 

including the last complete cycle prior to a defrost period, or if no cycling occurs, the 

average of the measurements during the last two hours prior to a defrost period; are 
p 4

compared to the same averaging period prior to the following defrost period. (emphasis 

added) 

The language above does not indicate a maximum constraint for the stabilization period. AHAM 

requests that DOE issue guidance clarifying whether no maximum constraint is intended or if the 

maximum constraint for the stabilization period is the first cycle that ends beyond the two hour 

minimum (i.e., a cycle could start before two hours but end after two hours and that would be 

considered the first cycle that ends beyond the two hour minimum). The stabilization period for 

the latter would be determined by the number of completed cycles necessary to satisfy the two

hour minimum.

AHAM appreciates the opportunity to seek guidance clarifying these many questions on the 

refrigerator/freezer test procedures, and would be glad to further discuss these issues should you 

so request. 

Respectfully Submitted,

Jennifer Cleary

Director, Regulatory Affairs

cc: Lucas Adin, DOE