EE-RM-TP-99-500 COMMENT 30DD

ubUc Hearing to Discuss 

Notice of ... roposed Rulemaking 

on 

Dishwasher Tes,t Procedure 

October 22, 2002 

u.s. Department of Energy, Washington, DC 

Barbara Twigg, Dishwasher Project Mgr. 

(202) 586 .. 8714 

b b t ' ." r .'.,'. lt@'d " ...... ," v ar,a,a~"wigg .' ee,~oe.go " 
EE-RM-TP-99-500 COMMENT 30DD

~~---~----

Purpose of Hearing: To receive comments 

on the changes and additions proposed 

for the dishwasher test procedure. 

- Testing soil-sensing models with soiled 

dishware 

- Reduced average-use cycles per year 

- New Definitions 

- Voltage Requirements 

- Standb ener measurement and re ortin 

Building Technologies 2 
EE-RM-TP-99-500 COMMENT 30DD

--~- ----

Dishwasher Rulemakin His 

Notice of Proposed Rulemaking: 

September 28, 1999 - Proposed a test procedure 

for soil-sensing models with a weighted and 

averaged method, still using clean dishes. 

Final Rule - December 18,2001: 

Included test specifications, new compactstandard definitions, reduced average use cycles to 

264 - But deferred soil-sensing method for more 

research. 

Building Technologies 3 
EE-RM-TP-99-500 COMMENT 30DD

Dishwasher Rulemakin His 

Correction Notice - May 1, 2002: 

Corrected equations in 12/18/01 final rule 

for determining the water energy 

consumption per cycle using gas-heated or 

oil-heated water. 

Notice of Proposed Rulemaking: 

September 2, 2002 - Test method using 

soiled dish ware, incorporating standby 

power in estimated annual energy cost. 

Building Technologies 4 
EE-RM-TP-99-500 COMMENT 30DD

--------------.~~~~--~~~~-

Comments and Website 

Comments Due: November 18,2002 

Send to: dishwashertp@ee.doe.gov 

docket number: EE-RM/TP-99-500 

(DOE prefers Word Perfect 5.1,6.1, or 8; Word or pdf files 

acceptable) 

http://www.eren.doe.gov/buildings/codesstandards/index.htm 

(stakeholder information) 

Building Technologies 5 
EE-RM-TP-99-500 COMMENT 30DD

TEST PROCEDURE CHANGES 

Natascha Castro 

National Institute of Standards & Technology 

(natascha.castro @nist.gov) 

u.s. DOE Public Hearing on 

Dishwasher Test Procedure 

October 22, 2001 

Building Technologies 6 
EE-RM-TP-99-500 COMMENT 30DD

Major Changes in this Rulemaking 

1. New soil-based method to test soil-sensing machines 

2. Updated annual dishwasher use based on new survey data 

3. New terms used in the dishwasher test procedure are defined 

4. Voltage requirements are modified 

5. New standby power measurement and reporting 

Building Technologies 7 
EE-RM-TP-99-500 COMMENT 30DD

1. Soil-sensing Dishwasher Test Method 

• Soil-based testing 

• Potential to be the most realistic test method 

• Used in international standards (IEC 60436) 

• Relevant to all current sensor technologies 

• Complexities to soil-based testing 

1lI AHAM-DW-I-1992 with 1999 addendum selected because it is 

representative of common US soils and is already in use 

Building Technologies 8 
EE-RM-TP-99-500 COMMENT 30DD

1. Soil-sensing Dishwasher Test Method 

• Run tests of the Sensor Heavy, Sensor Medium, and Sensor Light Cycles. 

• Measure energy consumption values at the end of each test and record as the 

energy consumption for the Sensor Heavy, Sensor Medium, and Sensor Light 

Cycle. 

1 =----~~~--~~------------~----------------------

) +(O.33xEnergy .)+(O.05xEnergy ) 

EF 

So;tnsing ··(···O.62xEnergy 

.•. . Sensor Sensor Sensor 

Light Medium Heavy 

Note: frequency of cycle use values determined by TIAX. 

• For DW's wi an air dry option, interrupt the tests to measure energy 

consumption values immediately before the heated dry and record for the 

Truncated Sensor Heavy, Truncated Sensor Medium, and Truncated Sensor 

Light Cycle. 

Building Technologies 9 
EE-RM-TP-99-500 COMMENT 30DD

~---~---

2. A verage Use Cycles 

• Data used in 2001 rulemaking was 'best available' but had 

gaps; new survey findings used to obtain a 'Nationally 

Representative" value . 

• New findings support a lower average use value. 

• TIAX analysis shows range is more accurately 200-233 cycles/year 

• DOE proposes 215 cycles/year as the Representative Average Use Value 

• This value used in calculation of Estimated Annual Operating Cost 

• This value does not impact the Energy Factor 

Building Technologies 10 
EE-RM-TP-99-500 COMMENT 30DD

--~----------------

3. Proposed DOE Definitions 

• Proposed definitions: 

I. "Soil-sensing dishwasher" means a dishwasher that has the ability to 

adjust automatically any energy consuming aspect of a wash cycle 

based on the soil load of the dishes. 

II. "Non soil-sensing dishwasher" means a dishwasher that does not have 

the ability to adjust automatically any energy consuming aspects of a 

wash cycle based on the soil load of the dishes. 

III. "Standby mode "means the power consumption condition when the 

dishwasher is connected to the main electricity supply and the door lock 

is unlatched. 

Building Technologies 11 
EE-RM-TP-99-500 COMMENT 30DD

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3. Proposed DOE Definitions 

The following cycles are defined as "the set of operations in a soil-sensing 

dishwasher that constitutes the response for completely washing a load of 

dishes" as listed in the table below. 

Sensor 

Sensor light 3 

IV. Truncated Sensor Light Cycle 

V. Truncated Sensor Medium Cycle 

VI. Truncated Sensor Heavy Cycle 

. 1, so led with half the 

AHAM DW -1 soil load 3 

Same cycle, except eliminating 

the heated-dry portion of the cycle 

Building Technologies 12 

4 

4 
EE-RM-TP-99-500 COMMENT 30DD

4. Voltage Requirements 

• Electrical energy supply. 

• "Dishwashers that operate with an electrical supply of 120 volts. 

Maintain the electrical supply to the dishwasher at 120 volts + 2% and 

within one percent of the nameplate frequency as specified by the 

manufacturer. " 

Increases voltage requirements from 115 + 2% to 120V + 2% 

• Installation instructions call for 120 V. 

• Potential impact 3-5% increase for models labeled for 120V use and 

tested at 115. 

Building Technologies 13 
EE-RM-TP-99-500 COMMENT 30DD

-~~---------

5. Standby Power 

• Measurement instrumentation (timer, watt/watt-hour meter) 

• Measurement method 

• Connect the dishwasher to a watt/watt-hr meter 

• Ensure operation in stand-by mode 

• Stabilize for a minimum of 5 minutes 

• Read energy consumption a minimum of 5 minutes 

• Record time & watt-hours consumed. 

• Determine Annual Standby power use 

• Calculate the average standby power, Sm' expressed in watts by dividing the 

measured energy consumption by the duration of the measurement. 

• Calculate the stand-by hours per year, Hs 

• S = Sm X ((Hs)/lOOO) 

• Impact 

• S added to Annual Energy Use 

• S included in Estimated Annual Operating Cost (EAOC) 

• S not included in calculation of Energy Factor 

Building Technologies 14 
EE-RM-TP-99-500 COMMENT 30DD

Dishwasher Survey Review and Findings 

John Bowman 

Powered by 

Innovation since 1886 

u.s. Department of Energy - Building Technologies Program 

Public Hearing on Proposed Revisions to Dishwasher Test Procedure 

October 22, 2002 
EE-RM-TP-99-500 COMMENT 30DD

Overview 

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I Suggofling Data Reguirements I 

I '" "'ii> ~ ~" ;fu", '\ ::% ~ &'th:~:"'il§ &m", 

Data Sourses ? 

I #mh1r, h" dr*ti!'% "m 1@% ,%" , N" -" maw' 

I Mousellalas'SoiletliDisl1l1are 

~"tm" ,,~- ill A<S;.~'i;" _ *"'~~~\~ ~ ,,"iii ,,'" _ W iii ,,1' 0;:,"%'" %'*@itt0)Ml'!t0@#%'\"&'%:.'t:::.-''' tm ~~'\i'wm·~'%" ~ iii' "" § 

Ireguensy af Use 

u "$it~,, m"" "'~ "~'K''(\''''" ~Ji '* "")' 0 " ",'i ~ 1':t'ii~ Wi"*,,,* illi~ __ ~"<;:%k'fb"lJb"%::,~1 x" $ m:: Mt®; " 

i Summary of liRaings , 

16 
EE-RM-TP-99-500 COMMENT 30DD

Dishwasher Survey Review Executive Summary 

This review of available data on households' dishwasher usage habits 

shows broad support to define: 

• Households' pretreatment methods, 

• Distribution of households by the level of soil in a dishwasher load, 

• Quantitative amounts of soil on the dish ware, and 

• Frequency of households' use of a dishwasher. 

17 
EE-RM-TP-99-500 COMMENT 30DD

Dishwasher Survey Review Executive Summary 

The review suggests two key findings: 

• A separate path in the test procedure for soil-sensing dishwashers can 

be created to measure energy consumption using a weighted, threepoint test method with different amounts of soiled dishware. 

• The number of average-use cycles per year can be reduced to 215 

cycles per year. 

18 
EE-RM-TP-99-500 COMMENT 30DD

Dishwasher Survey Review Support Data Requirements 

To address needed revisions in the dishwasher test procedure that 

would consider testing soil-sensing dishwashers and updating the 

frequency of dishwasher use, this review set out to address several 

questions: 

• How soiled are the dishes in the dishwashers of U.S. households? 

- Quantity of soil? 

- Types of soil? 

• How loaded are the dishwashers in U.S. households? 

- Quantity of dishware? 

- Type of dishware? 

• How to reflect that soiling in a modified energy consumption test method? 

• How often do U.S. households use a dishwasher? 

19 
EE-RM-TP-99-500 COMMENT 30DD

Dishwasher Survey Review Data Sources 

The review and its findings draw from a number of sources: 

1) Review of existing industry and DOE dishwasher test standards; 

2) Review and analysis of survey information from eight individual sources 

including dishwasher and detergent manufacturers, energy and 

consumer interest groups, independent researchers, and government 

agencies; and 

3) Discussions with key personnel in industry, DOE, NIST, consumers 

groups, and TIAX. 

20 
EE-RM-TP-99-500 COMMENT 30DD

Dishwasher Survey Review Data Sources 

A requirement of this review is to maintain the confidentiality of the 

industry survey sources. To this end no industry source is identified. 

Only general information on the data source is provided. 

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HoUseheJIdS .• ' ~. ?\:Iftfornlaiion 

...... S~x)!~ . Nationally Representative 

Quality of 

. Infof,nation 

High 

High 

. SUrvR'1\~F. Regional Moderate fV\'.;.'., •. ·l.~·, 

... : ... ~~"~Y~V;:i: Nationally Representative Moderate 

S'~· . . ... N f II Rtf Mdt 

~7.C~~,r-+--N-:-t-::-~-:-II~-R-:~-:-:-::-~-t-:l-::-:--+-------+--------+----o-H-i:-~-e------i 

21 
EE-RM-TP-99-500 COMMENT 30DD

Dishwasher Survey Review Households' Soiled Dishware 

How soiled are the dishes in the dishwashers of U.S. households? 

• Quantity of soil? 

- Drawn from data on: 

- Pretreatment methods and the resultant soil levels on dishware, 

- Qualitative ranking of soil level, and 

- Assessment of quantitative amounts of soil associated with the 

qualitative ranking of soil level. 

• Type of soil? 

- Drawn from data in existing industry standards 

22 
EE-RM-TP-99-500 COMMENT 30DD

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... 

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tn 

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"C 

15 

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CI) 

tn 

:::J 

0 

J: 

c4 

::::» 

-~-------------------------------

Dishwasher Survey Review Households' Soiled Dishware Pretreatment Methods 

Over 700/0 of U.S. households pretreat dishes with water before loading 

into the dishwasher (surveys A, C, E, F, G and H). 

80.0% ,..---------------------------------------, 

70.0% 

60.0% 

50.0% 

40.0% 

30.0% 

20.0% 

10.0% 

Over 70% of consumers pretreat dishes 

with water before loading into 

dishwasher. 

r--------------~-------------'\ 

0.0% 4---

Pre-rinse with Pre-wash, including Pre-soak the dish Scrape food without Removed large 

water some scrubbing water scraps 

Pretreatment Method 

Do nothing 

23 
EE-RM-TP-99-500 COMMENT 30DD

In 

lI. 

CI) 

.c 

In 

~ .c 

In 

is 

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"i -

In 

"tJ 

15 

.c 

CI) 

In 

:::J 

0 

l: 

c4 

::::) 

Dishwasher Survey Review Households' Soiled Dishware Qualitative Levels of Soil 

Surveys A and C (cumulatively representing over 9,000 U.S. 

households) show that U.S. households' dishwasher use distributes in 

three levels of soil- Light, Medium and Heavy. 70%~----~----~------------------------------------~--~----------. 

62% 

60% -

50% 

40% 

330/0 

30% 

20% 

10% 

50/0 

0% 

Light Medium Heavy 

Soil Level 24 
EE-RM-TP-99-500 COMMENT 30DD

Dishwasher Survey Review Households' Soiled Dishware Types of Soil 

The industry-recognized, 'worst-case' cleaning performance test, 

ANSI/AHAM Standard DW-1, precisely defines: 1) food soils that are 

representative of the types of soils on the dishware of U.S. 

households; 2) amounts of those food soils; and 3) procedures to 

apply the food soils and to prepare the dishware for testing. 

25 
EE-RM-TP-99-500 COMMENT 30DD

Dishwasher Survey Review Households' Soiled Dishware Quantitative Amounts of Soil 

Given the breadth and depth of survey C, it serves as the basis here. 

Survey C suggests the following amounts of soil as representative of 

each of the soil levels: 

1 AHAM DW-1 specifies a mass of 31.3 grams of food soils applied to each place setting. 

2 Note that this is one-half of the 31.3 grams of the food soils normally applied to one place setting in DW-1. 

26 
EE-RM-TP-99-500 COMMENT 30DD

Dishwasher Survey Review Households' Soiled Dishware Amount & Type of Dishware 

How loaded are the dishwashers in U.S. households? 

• Quantity of dishware? 

- Vast majority of households (>80%) run dishwashers at full capacity. 

- In conjunction with average operation of about once every other day, 

implies that some portion, -1/2, of the dishware load with varying 

levels of soil is air-drying for about a day. 

- ANSII AHAM Standard DW-1 is being revised to consider longer airdrying of soiled dishware. 

• Type of dishware? 

- As might be expected, a wide variety of dishware is used in U.S. 

households. 

- One nationally representative survey indicates that for >50% of 

households plastic dishware makes up 25% or more of the load. 

- Any impact is likely to be of secondary importance to implementing a 

soil-based test method for soil-sensing dishwashers. 

27 
EE-RM-TP-99-500 COMMENT 30DD

Dishwasher Survey Review Suggested Test Method for Soil-Sensing Dishwashers 

The review suggests that a 3-point test using different amounts of 

soiled dishware would more accurately reflect the energy consumption 

of soil-sensing dishwashers. 

Heavy 4 4 8 

lVIedium 2 6 8 

Ught 1 wi Y2 soil2 7 8 

1 AHAM OW-1 specifies a mass of 31.3 grams of food soils applied to each place setting. 

2 Note that this is one-half of the 31.3 grams of the food soils normally applied to one 

place setting in OW -1 . 

The energy factor would then be an average of the 3 tests weighted by 

the distribution of U.S. households in the three soil level categories: 

EFSoil-sensing= 1/((.62 X EnergYLight)+(.33 X EnergYMediurrJ+(.05 X EnergYHeavy)) 

28 
EE-RM-TP-99-500 COMMENT 30DD

Dishwasher Survey Review Frequency of Use 

How often do U.S. households use a dishwasher? - A· lot less 

according to EIA's 1997 RECS and several other surveys. 

60.0% -,------------------------------------, 

"-

CD 

.c 

til 

50.0% 

~ 40.0% 

.c 

til 

is 

co 

.c 

·i - 30.0% 

til 

"0 .c 

:g 

:::s 

o :J: 20.0% 

~ ::l 

10.0% 

0.0%+----

Less Than 4 Times 

EIA's 1997 RECS 

Median: Half of the responses are at less than 

4 times per week, or 208 cycles per year. 

Average: Can range from 207 to 282 cycles 

per year depending on definition of the 

categories. 

4to6Times At. Least Once Each Day 

29 
EE-RM-TP-99-500 COMMENT 30DD

Dishwasher Survey Review Frequency of Use 

Review of five nationally representative surveys showed a wide range of 

average-use cycles/year that was narrowed to the suggested range of 200 

to 233 average-use cycles per year. 215 average-use cycles splits the 

range. 

i~~erage of;" 

~X"'b'D" 2 

~:J~;1:'~'ttltql! of Avt~t~d_tJ: e~('tYear for a Dishwasher , . " ~;,;, '''' "<", ;, ,Y, :" 

'b\l.;;oWt~a.~Ayef •• eJ:OItt 

Values· Values1 

162 181 201 

153 191 230 

155 189 224 

225 225 226 

207 245 282 

180 206 233 

1 Consistent definitions for the broad and/or unbounded categories presented in the surveys. 

2 Note that this range centers near the median of the 1997 RECS data. A weighted average of the 

'Average' Category Values yielded 200 average-use cycles/year and was taken as the bottom of the 

suggested range. 

30 
EE-RM-TP-99-500 COMMENT 30DD

Dishwasher Survey Review Summary of Findings 

The findings of this review suggest that: 

• Creating a separate path in the test method for soil-sensing dishwashers 

and adopting the weighted three-point test method previously outlined will 

more accurately reflect the energy consumption of soil-sensing 

dishwashers, and 

• Reducing the average-use cycles per year for dishwashers to 215 cycles 

per year will more closely represent average household dishwasher 

usage. 

31