EE-RM-TP-99-500 COMMENT 02FF

washington 

agpliance manufacturers dEl U II I 1M 

Ms. Barbara Twigg 

Energy Conservation Specialist 

U.S. Department of Energy 

Forrestal Building 

1000 Independence Ave. SW 

Room 11-018 

Washington, DC 20585 

Dear Ms. Twigg: 

III.. 1III/IIIIIIIIII11IIII_lllIIII_lIlOll. 1III111J1 I fI I ill j J I aau £. n n _ 

govemment relations offfce 

70 I pennsylvania avenue, nw A. suite 900 A. washington, de 20004 

tel 202 • 434.7484. fax 202. 434.7400 & e-mail ahamdc@aham.org 

July 22, 1998 

As part of the submittal AHAM made to DOE regarding Dishwasher Test Procedure, we 

promised to supply information regarding the number of cycles of use per year. I am enclosing a copy of 

information from the Soap & Detergent Association on this subject. We trust this will assist the 

Department in its revisions. 

fwern 

cc: 

If you have any questions, please contact me. 

! 

AHAM Dishwashet Manufacturers 

#131872.1 (0493) 

Sincerely, 

Wayne E. Morris 

Technical Director-Regulatory Affairs 
EE-RM-TP-99-500 COMMENT 02FF

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SOAI The Soap (md Detergent AssOCiation 

July 13, 1993 

Mr. Wayne Morris 

AllAM 

701 Pennsylvania Avenue, N.W. 

Suite 900 

Wasbington, DC 20004 

Dear Mr. Morris: 

This is to follow up on your request from the Association ofRame Appliance Manufaeturers (AllAM) 

for infonnation on the number of dishwasher cycles used, and pre-rinsinglpre.washing practices. 

The Soap and Detergent Association has approached its members who produce automatic dishwashing 

detergent to see if this type of data exists. One company has responded with the following information. 

Relative to the number of automatic dishwashing toads done: \( .X 

Dishwabm.: Vsers-Past Z ~ 8~£16 ~7181 82l2f2 2!ll21 21~ 9219J 93/24 22£26 

Avg. Loads, 5.5 5.3 5.1 4.8 4.9' 4,8 4.1 5,0 

aU ADW owning households 

Relative to pre-treating, based on a 1995 consumer questionnaire study, this company reports that the 

percentage of people who pretreated was 79%, Pre.trcating is defined as using water to rinse. scrub, or 

soak. The remaining 21% did nothing or scraped off the plates without using water. As machine and 

product manufacturers advertise more Unproved cleaning p~ this may decrease in the future. 

The company responding cautioned that the information is based on interviews with consum~ and 

therefore is the individual consumer' $ perception of the number of loads tun. how many loads are 

pretreated. etc, The consumer's perception may not represent the real number of loads washed when 

measured in another objective measure of loads washed. Because this is based on consumer perCeption 

and consumer'interpretation and bas the associated inherent uncertainties of consumer questionnaires. 

this data should probably not be used in an energy standards setting framework. The data. can give an 

indication of the use and patterns of use and may be useful to the DOE testing procedure. 

The members of the Soap and Detergent Association presents this infonnation based on this specific 

request. subject to the comments above. We cannot guarantee that such data will be available in the 

future or, if available, on what time schedule. 

475 Pork Avenue South, New York. N.Y. 10016. (212) 725-1262. Fax (212) 213-0685