## SUE 1 : Representative Average Use Cycles

Last updated in 1983, the average use values must reflect current consumer dishwasher use Data was solicited for more recent survey years " Soap & Detergent Assoc. (SDA)- average 264 cycles/year (1986-1996) " Oregon survey results support 280 cycles/year

e v y U 290 280 270 260 250 240 ~... . 230 +___. . . . -286 Average Consumer Dishwasher Use

-275.6 265

.2

"85/86' "87/88' "89/90' "91/92' "93/94' "95/96'

Survey Year

254 .8 244

.4 260

## ISSUE 2: Test Clarity & Repeatability

DOE proposes the ambient temp range, 74 to 85 °F be reduced to 75±5 °F " Average total energy consumption was 17.6 %lower for ambient at 85 °F than for ambient at 75 °F 

### Detailed installation requirements are added to support uniformity among testing laboratories A conditioning cycle is introduced as part of the test method to better approximate household conditions A separate "Instrumentation" section formulated " to consolidate measurement specifications " to base tolerances on nominal values " to introduce new

specifications for temperature measurement devices

## ISSUE 3: Compact vs. Standard

Current class distinctions are made using width-based definitions which results 

## in paradoxical labeling 

### for some models

Factors in establishing dishwasher classes

" measures useful to consumers when making purchasing decisions " that all dishwashers are held to appropriate minimumstandards for their intended class " uniformity in federal definitions for making class distinctions 

### ARAM proposed capacity-based definitions, the determinant used by industry and the FTC 

### for labeling Width Capacity Current Class Model Type inches (place-settings Des! nation A Undercounter 18 8 compact B Undersink 24 8 standard C Undercounter 24 6 estimated standardUndercounter

Undersink Undercounter Proposed Class Designation 

### ISSUE 3: Proposed DOE Definitions 

### DOE Proposed definitions : i Compact Dishwasher (capacity less than eight place settings plus six serving pieces as specified in section 6 of ARAM Standard DW1 .) ii Standard Dishwasher (capacity equal to or greater than eight place settings plus 

### six serving pieces as specified in section 6 of AHAM Standard DW-1 .)

## ISSUE 4: Soil-Sensing Technology

Soil-sensing dishwashers " default to a shortened cycle when tested w/o soils (e.g .,DOE test) " labeled by manufacturers with lower energy factors than measured because results are not representative of consumer use. 

### Testing options to get reliable energy data " Performance tests

- most realistic when combined w/ energy test ; however, defining a `normal' soil load would be difficult with repeatability issues

- high test burden, machines could no longer be sold as `new' " Field studies for real world data regarding typical cycle times

- some manufacturers already collect data

- difficult to establish a sample representative of population " Control override sequence provided by manufacturers to simulate normal operation

- highly repeatable once appropriate cycle is determined

## ISSUE 4: ARAM Proposal and Modifications Test according to the existing DOE test procedure, Emin is the average of a) normal and b) truncated normal 

### mTest under a forced maximumsensor normal response Emax is the average of c) normal and d) truncated normal



### E= (Emin x P) + (Emax x (1-P) where, P = fraction of persons not pre-treating loads .DOE made modifications " Added a clause stating that if a maximumresponse can not be forced, then a soil load shall be introduced according to Dw-1 to obtain the maximumenergy consumption " Applied the equation to water and energy consumption separately " Evaluated the recommendation to base pretreatment values on the Soap & Detergent Association Data.

## ISSUE S: Effect of Pre-treatment on the Energy

Factor All models are required to meet the minimumenergy standard of 0.46 cycles/kWh Based on available pretreatment data, 70/30 is proposed

*Highlighted values are at or below the minimumenergy standard P 80 79 73 70 63 60 50 

### 1-P 20 21 26 30 37 40 50 

### Model Energy Factor [cycles/kWh] A 0.49 0.49 0.49 0.48 0.47 0.47 0.46 B 0.47 0.47 0.47 0.47 0.46 0 .46 0 .45 

### C 0.54 0.54 0.53 0.52 0.51 0.50 0.48 

### D 0.48 0.47 0.47 0 .47 0.46 0

.46 0 .45 

### E 0.47 0.46 0 .46 0 .45 0 .44 0 .44 0 .43 

### F 0.49 0.49 0.48 0.48 0.47 0 .47 0 .46

## ISSUE S: Pretreatment values used to weight Emin

and Emax Pre-treated dishes with 

## lowsoil levels in the water will most likely trigger a minimumnormal response fromsensor models SDA report, based on 1995 data, states that 79 %pre-treat their dishes (using water to rinse scrub or soak the dishes) and 21 % of those surveyed do nothing or merely scrape their plates . SDA cautions: results are based on consumer perception and interpretation, not on objective test measures of loads washed and have "the associated inherent uncertainties of consumer questionnaires ." data could give an "indication of the use and patterns of use, " but "should probably not be used in an energy standards setting framework." (SDA letter to ARAM, July 13, 1998)

## ISSUE S: Other Survevs and Venues

A search for additional data yielded 

### information on consumer practices in 1989, showing 73%pre-treated and 27%not pre-treated loads. Oregon Energy Office-CEE/Alliance Dishwasher Survey

- fielded in the Pacific Northwest, this survey may provide detailed data on consumer dishwashing practices; however, the study is not nationally conclusive

- Results can be interpreted as either 83%pre-treated or 63%pre-treated Manufacturer's Consumer Research Data

- data on the cycle response for various levels of pretreatment combined with pretreatment practices could be used to establish a `sensor normal' 

### Pending better data, DOE proposes a 70%pre-treatment percentage as a compromise value based on the available qualitative data.