apartment of Energy

Washington, DC 20585

DEC18 1992

Mr. Mike Thompson

Director, Government Relations

Whirlpool Corporation

Mail Drop 3004

2000 M-63

Benton Harbor, MI 49022

Dear Mr. Thompson:

This is in response to your letter of October 19, 1992, requesting

interpretation of the DOE clothes washer test procedure regarding the

wash/rinse temperature requirement in section 3.2.2.2; minimum wash time

requirement in section 2.10; and volume measurement for clothes washers

in section 3.1.1 as published in the Federal Register on

September 28, 1977, (42 FR 49808) and incorporated into the Code of

Federal Regulations at 10 CFR Part 430, Subpart B, Appendix J.

The Department has reviewed your interpretation request concerning its

clothes washer test procedure and feels that clarification is warranted.

The first question relates to section 3.2.2.2, which requires the

setting of the wash/rinse temperature selector of an automatic clothes

washer to the hottest setting (i.e., hot/warm) after activating the

normal cycle requirement in section 3.2.1. DOE does not agree with

Whirlpool's interpretation of having the option to define the normal

cycle as excluding the hottest setting and thereby test clothes washers

only at cooler temperature settings (i.e., hot/cold, warm/warm,

warm/cold and cold/cold). DOE does not consider temperature setting to

be a selection feature within the normal cycle. The Department believes

that cycle selection controls features such as agitation speed, spin

speed, number of rinses and fills. The requirement in section 3.2.2.2

to "set the wash/rinse temperature selector" clearly indicates this

control as an independent feature from the normal cycle selector. DOE

believes that Whirlpool must set their temperature switch to the hottest

setting available (i.e., hot/warm) after the normal cycle is selected as

required in section 3.2.2.2. This is followed by testing at the other

wash/rinse temperature selectors available that use hot water (i.e.,

hot/cold, warm/warm, and warm/cold) as required in section 3.2:2.6 in

order to test and certify clothes washers in accordance to the DOE test

procedure (Appendix J to Subpart B of Part 430).

The second question relates to section 2.10, which provides the setting

of the wash time. Section 2.10 states that the wash time be set for

"approximately 10 minutes, but that the actual wash time (period of

agitation) shall be no less than 9.75 minutes. Where controls are

provided for agitation and spin speed, set them for the normal cycle."

DOE does not agree with Whirlpool's interpretation of having the option

to test and certify an 8 minute wash time clothes washer machine. The

 EE-RM-93-701 COMMENT 0A

Mr. Mike Thompson 

Department of Energy 

Washington, DC 20585 

DEC 181992 

Director, Government Relations 

Whirlpool Corporation Mail Drop 3004 

2000 M-63 

Benton Harbor, MI 49022 

Dear Mr. Thompson: 

This is in response to your letter of October 19, 1992, requesting interpretation of the DOE clothes washer test procedure regarding the 

wash/rinse temperature requirement in section 3.2.2.2; minimum wash time 

requirement in section 2.10; and volume measurement for clothes washers 

in section 3.1.1 as published in the Federal Register on 

September 28, 1977, (42 FR 49808) and incorporated into the Code of 

Federal Regulations at 10 CFR Part 430, Subpart B, Appendix J. 

The Department has reviewed your interpretation request concerning its 

clothes washer test procedure and feels that clarification is warranted. 

The first question relates to section 3.2.2.2, which requires the 

setting of the wash/rinse temperature selector of an automatic clothes 

washer to the hottest setting (i.e., hot/warm) after activating the 

normal cycle requirement in section 3.2.1. DOE does not agree with 

Whirlpool's interpretation of having the option to define the normal 

cycle as excluding the hottest setting and thereby test clothes washers 

only at cooler temperature settings (i.e., hot/cold, warm/warm, 

warm/cold and cold/cold). DOE does not consider temperature setting to 

be a selection feature within the normal cycle. The Department believes 

that cycle selection controls features such as agitation speed, spin speed, number of rinses and fills. The requirement in section 3.2.2.2 

to "set the wash/rinse temperature selector" clearly indicates this 

control as an independent feature from the normal cycle selector. DOE 

believes that Whirlpool must set their temperature switch to the hottest 

setting available (i.e., hot/warm) after the normal cycle is selected as 

required in section 3.2.2.2. This is followed by testing at the other 

wash/rinse temperature selectors available that use hot water (i.e., 

hot/cold, warm/warm, and warm/cold) as required in section 3.~:2.6 in 

order to test and certify clothes washers in accordance to the DOE test 

procedure (Appendix J to Subpart B of Part 430). 

Tbe second question relates to section 2.10, which provides the setting of the wash time. Section 2.10 states that the wash time be set for 

"approximately 10 minutes, but that the actual wash time (period of 

agitation) shall be no less than 9.75 minutes. Where controls are 

provided for agitation and spin speed, set them for the normal cycle." DOE does not agree with Whirlpool's interpretation of having the option 

to test and certify an 8 minute wash time clothes washer machine. The 
Department considers "wash time" to be a separate selection feature from

the normal cycle. The phrase "set them for the normal cycle" refers to

agitation and spin speed control selectors only, not wash time. Based

on the consideration of the above, the Department believes that

Whirlpool's interpretation is inconsistent with the mandatory wash time

requirements of section 2.10. DOE believes that any machine tested and

certified using the Clothes Washer Test Method (Appendix J to Subpart B

of Part 430) must adhere to the minimum actual wash time requirements of

at least 9.75 minutes.

The Department realizes that some machines could incorporate certain

features that might prevent testing in accordance with its clothes

washer test procedure. For example, a wash time of 8 minutes could be

built into the normal cycle selector rather than be a separate feature

controlled by the consumer. This would prevent testing and a petition

for a waiver from the DOE Clothes Washer Test Procedure would be needed

as described in Part 430.27.

The third question relates to section 3.1.1, which provides the

measurement requirements of the clothes washer volume. Section 3.1.1

specifies that the volume is to be measured by lining the clothes

container, with the agitator in place, with 2 mil plastic film or some

other method to prevent the water from entering the outer tub container.

DOE does not agree with Whirlpool's proposed interpretation to include

the volume under the agitator. First, section 3.1 of Appendix J states

that the clothes container capacity measurement is to be for "the entire

volume which a dry clothes load could occupy within the clothes

container". The Department does not consider "volume in the agitator"

as usable space for clothes washing. Next, the requirement in section

3.1.1 that "the agitator shall be in place" is to exclude the volume of

the agitator. Finally, Whirlpool's proposed interpretation would result

in different energy factors for clothes washers which were identical

other than one having a hollow agitator and the other having a solid

agitator when in fact the usefulness and performance of the two machines

would be virtually identical. DOE does not believe that this outcome

would be in the public's best interest. Based on the consideration of

the above, the Department believes that the Whirlpool interpretation is

inconsistent with the requirements of section 3.1.1 of Appendix J to

Subpart B of Part 430. DOE believes that any method used to measure

clothes container capacity should prevent water from entering both the

outer tub container and the agitator if it is hollow.

If you should have any additional questions, contact Bill Hui-of my

staff at (202) 586-9127.

Michael J. McCabe , Director

Office of Codes and Standards

Office of Building Technologies

Conservation and Renewable Energy

 EE-RM-93-701 COMMENT 0A

Department considers "wash time" to be a separate selection feature from 

the normal cycle. The phrase "set them for the normal cycle" refers to 

agitation and spin speed control selectors only, not wash time. Based 

on the consideration of the above, the Department believes that 

Whirlpool's interpretation is inconsistent with the mandatory wash time 

requirements of section 2.10. DOE believes that any machine tested and 

certified using the Clothes Washer Test Method (Appendix J to Subpart B 

of Part 430) must adhere to the minimum actual wash time requirements of 

at least 9.75 minutes. 

The Department realizes that some machines could incorporate certain 

features that might prevent testing in accordance with its clothes 

washer test procedure. For example, a wash time of 8 minutes could be 

built into the normal cycle selector rather than be a separate feature 

controlled by the consumer. This would prevent testing and a petition for a waiver from the DOE Clothes Washer Test Procedure would be needed 

as described in Part 430.27. 

The third question relates to section 3.1.1, which provides the 

measurement requirements of the clothes washer volume. Section 3.1.1 

specifies that the volume is to be measured by lining the clothes 

container, with the agitator in place, with 2 mil plastic film or some 

other method to prevent the water from entering the outer tub container. 

DOE does not agree with Whirlpool's proposed interpretation to include . the volume under the agitator. First, section 3.1 of Appendix J states 

that the clothes container capacity measurement is to be for "the entire 

volume which a dry clothes load could occupy within the clothes 

container". The Department does not consider "volume in the agitator" 

as usable space for clothes washing. Next, the requirement in section 

3.1.1 that "the agitator shall be in place" is to exclude the volume of 

the agitator. Finally, Whirlpool's proposed interpretation would result 

in different energy factors for clothes washers which were identical 

other than one having a hollow agitator and the other having a solid 

agitator when in fact the usefulness and performance of the two machines 

would be virtually identical. DOE does not believe that this outcome 

would be in the public's best interest. Based on the consideration of 

the above, the Department believes that the Whirlpool interpretation is 

inconsistent with the requirements of section 3.1.1 of Appendix J to 

Subpart B of Part 430. DOE believes that any method used to measure 

clothes container capacity should prevent water from entering both the 

outer tub container and the agitator if it is hollow. 

If you should have any additional questions, contact Bill Hui.of my staff at (202) 586-9127. 

;;~r0~ Michael J. McCabe, Director 

Office of Codes and Standards 

Office of Building Technologies Conservation and Renewable Energy 
CONCURRENCES

Mr. Mike Thompson

Director, Government Relations

Whirlpool Corporation

Mail Drop 3004

2000 M-63

Benton Harbor, MI 49022

Dear Mr. Thompson:

This is in response to your letter of October 19, 1992, requesting

interpretation of the DOE clothes washer test procedure regarding the

wash/rinse temperature requirement in section 3.2.2.2; minimum wash time

requirement in section 2.10; and volume measurement for clothes washers in

section 3.1.1 as published in the Federal Register on September 28, 1977, (42

FR 49808) and incorporated into the Code of Federal Regulations at 10 CFR

Part 430, Subpart B, Appendix J.

The Department has reviewed your interpretation request concerning its

clothes washer test procedure and feels that clarification is warranted.

The first question relates to section 3.2.2.2, which requires the setting of

the wash/rinse temperature selector of an automatic clothes washer to the

hottest setting (i.e., hot/warm) after activating the normal cycle

requirement in section 3.2.1. DOE does not agree with Whirlpool's

interpretation of having the option to define the normal cycle as excluding

the hottest setting and thereby test clothes washers only at cooler

temperature settings (i.e., hot/cold, warm/warm, warm/cold and cold/cold).

DOE does not consider temperature setting to be a selection feature within

the normal cycle. The Department believes that cycle selection controls

features such as agitation speed, spin speed, number of rinses and fills.

The requirement in section 3.2.2.2 to "set the wash/rinse temperature

selector" clearly indicates this control as an independent feature from the

normal cycle selector. DOE believes that Whirlpool must set their

temperature switch to the hottest setting available (i.e., hot/warm) after

the normal cycle is selected as required in section 3.2.2.2. This is

followed by testing at the other wash/rinse temperature selectors available

that use hot water (i.e., hot/cold, warm/warm, and warm/cold) as required in

section 3.2.2.6 in order to test and certify clothes washers in accordance to

the DOE test procedure (Appendix J to Subpart B of Part 430).

The second question relates to section 2.10, which provides the setting of

the wash time. Section 2.10 states that the wash time be set for

"approximately 10 minutes, but that the actual wash time (period of

agitation) shall be no less than 9.75 minutes. Where controls are provided

for agitation and spin speed, set them for the normal cycle." DOE does not

agree with Whirlpool's interpretation of having the option to test and

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C:\WPDATA\RCORSPD\WPOOL:CE-431:HUI:ra:6-9127:12/18/92:

 EE-RM-93-701 COMMENT 0A

Mr. Mike Thompson 

Director, Government Relations 

Whirlpool Corporation 

Mail Drop 3004 

2000 M-63 

Benton Harbor, MI 49022 

Dear Mr. Thompson: 

This is in response to your letter of October 19, 1992, requesting 

interpretation of the DOE clothes washer test procedure regarding the 

wash/rinse temperature requirement in section 3.2.2.2; minimum wash time 

requirement in section 2.10; and volume measurement for clothes washers in 

section 3.1.1 as published in the Federal Register on September 28, 1977, (42 

FR 49808) and incorporated into the Code of Federal Regulations at 10 CFR 

Part 430, Subpart B, Appendix J. 

The Department has reviewed your interpretation request concerning its 

clothes washer test procedure and feels that clarification is warranted. 

The first question relates to section 3.2.2.2, which requires the setting of 

the wash/rinse temperature selector of an automatic clothes washer to the 

hottest setting (i.e., hot/warm) after activating the normal cycle 

requirement in section 3.2.1. DOE does not agree with Whirlpool's 

interpretation of having the option to define the normal cycle as excluding 

the hottest setting and thereby test clothes washers only at cooler 

temperature settings (i.e., hot/cold, warm/warm, warm/cold and cold/cold). 

DOE does not consider temperature setting to be a selection feature within 

the normal cycle. The Department believes that cycle selection controls 

features such as agitation speed, spin speed, number of rinses and fills. 

The requirement in section 3.2.2.2 to "set the wash/rinse temperature 

selector" clearly indicates this control as an independent feature from the 

normal cycle selector. DOE believes that Whirlpool must set their 

temperature switch to the hottest setting available (i.e., hot/warm) after 

the normal cycle is selected as required in section 3.2.2.2. This is 

followed by testing at the other wash/rinse temperature selectors available 

that use hot water (i.e., hot/cold, warm/warm, and warm/cold) as required in 

section 3.2.2.6 in order to test and certify clothes washers in accordance to 

the DOE test procedure (Appendix J to Subpart B of Part 430). 

The second question relates to section 2.10, which provides the setting of 

the wash time. Section 2.10 states that the wash time be set for 

"approximately 10 minutes, but that the actual wash time (period of 

agitation) shall be no less than 9.75 minutes. Where controls are provided 

for agitation and spin speed, set them for the normal cycle." DOE does not 

agree with Whirlpool's interpretation of having the option to test and 

C: \WPDATA\RCORSPD\WPOOL:CE-431:HUI:ra:6-9127: 12/18/92: 

CONCURRENCES 

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