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

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

EE-RM-TP-99-500 COMMENT 02DD
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 minimum standards 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-setting s Des! nation

A Undercounter 18 8 compact

B Undersink 24 8 standard

C Undercounter 24 6 estimated standard

EE-RM-TP-99-500 COMMENT 02DD
Undercounter

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 .)

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

EE-RM-TP-99-500 COMMENT 02DD
ISSUE 4: ARAMProposal and Modifications

Test according to the existing DOE test procedure,

Emin is the average of a) normal and b) truncated normal

m Test under a forced maximum sensor 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 maximum response can not be

forced, then a soil load shall be introduced according to Dw-1 to

obtain the maximum energy consumption

" Applied the equation to water and energy consumption separately

" Evaluated the recommendation to base pretreatment values on the

Soap & Detergent Association Data.

EE-RM-TP-99-500 COMMENT 02DD
ISSUE S: Effect of Pre-treatment on the Energy

Factor

All models are required to meet the minimum energy standard of

0 .46 cycles/kWh

Based on available pretreatment data, 70/30 is proposed

*Highlighted values are at or below the minimum energy 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

EE-RM-TP-99-500 COMMENT 02DD
ISSUE S : Pretreatment values used to weight Emin

and Emax

Pre-treated dishes with low soil levels in the water will most likely

trigger a minimum normal response from sensor 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)

EE-RM-TP-99-500 COMMENT 02DD
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.

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