CHAPTER 4. SCREENING ANALYSIS

TABLE OF CONTENTS

4.1 INTRODUCTION ........................................................................................................... 4-1

4.2 DISCUSSION OF TECHNOLOGY OPTIONS.............................................................. 4-1

4.2.1 Screened-Out Technology Options.................................................................................. 4-1

4.2.1.1 Ozonated laundering ...................................................................................... 4-3

4.2.1.2 Plastic particle cleaning ................................................................................. 4-3

4.2.2 Remaining Design Options.............................................................................................. 4-4

LIST OF TABLES

Table 4.2.1 Retained Design Options for Commercial Clothes Washers............................... 4-4

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CHAPTER 4. SCREENING ANALYSIS

4.1 INTRODUCTION

This chapter discusses the screening analysis conducted by the U.S. Department of 

Energy (DOE) of the technology options identified in the market and technology assessment for 

commercial clothes washers (CCW) (chapter 3 of this technical support document (TSD)). In the 

market and technology assessment, DOE presented an initial list of technology options that can 

be used to reduce energy consumption of CCWs. The goal of the screening analysis is to identify 

any technologies that will be eliminated from further consideration in the rulemaking analyses.

The candidate technology options are assessed based on DOE analysis as well as inputs 

from stakeholders including manufacturers, trade organizations, and energy efficiency advocates. 

Technology options that are judged to be viable approaches for improving energy efficiency are 

retained as inputs to the subsequent engineering analysis, and are designated as design options. 

Technology options that are not incorporated in commercial clothes washer equipment or in 

working prototypes or that fail to meet certain criteria regarding practicability to manufacture, 

install and service, impacts on equipment utility or availability, or health or safety will be 

eliminated from consideration in accordance with Energy Conservation Program for Consumer 

Products: Procedures for Consideration of New or Revised Energy Conservation Standards for 

Consumer Products. 61 FR 36974 (July 15, 1996). The rationale for either screening out or 

retaining each technology option is detailed in the following sections.

4.2 DISCUSSION OF TECHNOLOGY OPTIONS

For commercial clothes washers, the screening criteria specified in section 4.1 were 

applied to the technology options to either retain or eliminate each technology from the 

engineering analysis. DOE derived the list of technology options as a subset of options 

considered in the previous CCW energy conservations standards rulemaking. DOE has included 

temperature-differentiated pricing controls as an additional technology option based on 

comments received in response to the framework document for this rulemaking.

4.2.1 Screened-Out Technology Options

The following section describes the technology options that were screened out prior to 

the engineering analysis, along with the rationale for elimination.

The technologies identified in the market and technology assessment were evaluated 

pursuant to the criteria set out in the Energy Policy and Conservation Act (EPCA), Pub. L. 94-

163, 42 U.S.C. 6291 et seq. (42 U.S.C. 6311-6317) EPCA provides criteria for prescribing new 

or amended standards, which will achieve the maximum improvement in energy efficiency that 

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the Secretary of Energy determines is technologically feasible. (42 U.S.C. 6295(o)(2)(A) and 

6316(a)) It also establishes guidelines for determining whether a standard is economically 

justified. (42 U.S.C. 6295(o)(2)(B) and 6316(a)) Pursuant to the EPCA requirements for 

determining whether a standard is technologically feasible and economically justified, appendix 

A to subpart C of Title 10 Code of Federal Regulations part 430 (10 CFR part 430), Procedures, 

Interpretations and Policies for Consideration of New or Revised Energy Conservation 

Standards for Consumer Products (the Process Rule), sets forth procedures to guide DOE in the 

consideration and promulgation of new or revised product energy conservation standards under 

EPCA. These procedures elaborate on the statutory criteria provided in 42 U.S.C. 6295 and in 

part eliminate problematic technologies early in the process of revising an energy conservation

standard. Under the guidelines, at the outset of a rulemaking, DOE eliminates from consideration 

technologies that present unacceptable problems with respect to the following four factors: 

(1) Technological feasibility. If it is determined that a technology has not been 

incorporated in commercially available products or in working prototypes, then that technology 

will not be considered further.

(2) Practicability to manufacture, install, and service. If it is determined that mass 

production of a technology in commercially available products and reliable installation and 

servicing of the technology could not be achieved on the scale necessary to serve the relevant 

market at the time of the effective date of the standard, then that technology will not be 

considered further.

(3) Impacts on product utility or product availability. If a technology is determined to 

have significant adverse impact on the utility of the equipment to significant subgroups of 

consumers, or results in the unavailability of any covered equipment type with performance 

characteristics (including reliability), features, size, capacities, and volumes that are substantially 

the same as equipment generally available in the United States at the time, it will not be 

considered further.

(4) Impacts on Health or Safety. If it is determined that a technology will have 

significant adverse impacts on health or safety, it will not be considered further.

Based on these factors, DOE screened out ozonated laundering and polymer bead 

cleaning for the reasons that follow.

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4.2.1.1 Ozonated laundering

DOE has concluded that ozonated laundering presents unacceptable problems with the 

following EPCA screening criteria:

(1) Technological feasibility. Although ozone laundering systems are commercially 

available as add-on systems for large-scale commercial or institutional multi-load clothes 

washers, DOE is unaware of any instances of this technology being incorporated into any 

commercially available products or prototypes for the type of commercial clothes washers 

covered by DOE standards, which include primarily single-load soft-mounted clothes washers 

intended for use in coin-operated laundries and multi-family housing settings.

(2) Practicability to manufacture, install, and service. DOE believes that it would not 

be practicable to manufacture, install and service this technology on the scale necessary to serve 

the U.S. commercial clothes washer market at the time of the effective date of an amended 

standard.

(4) Impacts on Health or Safety. Because this technology has not been implemented in 

coin-operated laundries our multi-family housing settings, DOE is unable to assess whether 

ozone laundry technology would have any adverse impacts on end-user health or safety.

4.2.1.2 Plastic particle cleaning

DOE has concluded that plastic particle cleaning presents unacceptable problems with the 

following EPCA screening criteria:

(1) Technological feasibility. Although plastic particle cleaning systems are 

commercially available for large-scale commercial or institutional multi-load clothes washers, 

DOE is unaware of any instances of this technology being incorporated into any commercially 

available products or working prototypes for the type of commercial clothes washers covered by 

DOE standards, which include primarily single-load soft-mounted clothes washers intended for 

use in coin-operated laundries and multi-family housing settings.

(2) Practicability to manufacture, install, and service. Plastic particle cleaning is still 

in the research stage for single-load residential-style clothes washers, so DOE believes that it 

would not be practicable to manufacture, install and service this technology on the scale 

necessary to serve the relevant market at the time of the effective date of an amended standard.

In addition, the requirements for the potential purchase, handling, reusing, recycling, and/or 

disposal of the plastic particles are unknown.

(3) Impacts on product utility or product availability. DOE is unable to assess the 

potential impact of plastic particle cleaning on product utility. DOE notes that as currently 

implemented, plastic particle cleaning systems are operated by trained staff in large-scale 

commercial or institutional laundry settings. Because of the significantly different operating 

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protocol compared to commercial clothes washers currently on the market, DOE does not believe 

that such technology could be used by untrained users, which would include most users of coinoperated laundries and multi-family housing laundry equipment. DOE is also unable to evaluate 

impacts on cleaning performance compared to current commercial clothes washer products on 

the market.

4.2.2 Remaining Design Options

Table 4.2.1 lists the technology options for commercial clothes washers that were 

retained by DOE and subsequently designated as design options.

Table 4.2.1 Retained Design Options for Commercial Clothes Washers

1. Adaptive water fill

2. Advanced agitation concepts for top-loading machines 

3. Capacity increase

4. Direct-drive motor 

5. Higher spin speeds to reduce remaining moisture content 

6. Motor efficiency improvements

7. Spray rinse or similar water-reducing rinse technology 

8. Temperature-differentiated pricing controls

9. Thermostatically controlled mixing valves 

10. Water recirculation loop

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REFERENCES

(None)

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