### 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 Mr. Mike Thompson 

### DepartmentofEnergy Washington, DC20585 

## DEC

# 181992

Director, Government Relations Whirlpool Corporation Mail Drop 3004 2000 M-63 Benton Harbor, MI 49022

DearMr. Thompson: This is in response toyour letterofOctober 19, 1992, requesting interpretation ofthe DOE clotheswasher testprocedure regarding the wash/rinse temperature requirement in section 3.2.2.2; minimumwash 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 clotheswasher test procedure and feels thatclarification iswarranted. The first question relates to section 3.2.2.2, which requires the setting ofthe wash/rinse temperature selectorofan 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 ofhaving the option to define the normal cycle as excluding the hottest setting and thereby testclotheswashers only at coolertemperature settings (i.e., hot/cold, warm/warm, warm/cold and cold/cold). DOE does not consider temperature settingto be a selection feature within the normal cycle. The Department believes that cycle selection controls features such as agitation speed, spin speed, number ofrinses and fills. The requirement in section 3.2.2.2 to "setthe wash/rinse temperature selector" clearly indicates this control as an independent feature from the normal cycle selector. DOE believes thatWhirlpool must settheirtemperature switch to the hottest setting available (i.e., hot/warm) afterthe normal cycle is selected as required in section 3.2.2.2. This is followed by testing atthe 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 certifyclotheswashers in accordance to the DOE test procedure (Appendix J to Subpart BofPart 430). Tbe second question relates to section 2.10, which provides the setting ofthe 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, setthem for the normal cycle." DOE does not agree with Whirlpool's interpretation ofhaving the option to test and certifyan 8minute wash time clotheswashermachine. TheDepartment 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 Department considers "wash time" to be aseparate selection feature from the normal cycle. The phrase "setthem for the normal cycle" refers to agitation and spin speed control selectors only, notwash time. Based on the consideration ofthe above, the Department believes that Whirlpool's interpretation is inconsistentwith themandatory wash time requirements ofsection 2.10. DOE believes that any machine tested and certified using the Clothes Washer Test Method (Appendix J to Subpart B ofPart 430) must adhere tothe minimum actual wash time requirements of at least 9.75 minutes. The Department realizes that some machines could incorporate certain features thatmight prevent testing in accordance with its clothes washer test procedure. For example, awash time of8minutes could be built into the normal cycle selectorratherthan be a separate feature controlled by the consumer. This would prevent testing and apetition for awaiver from the DOE Clothes WasherTest Procedure would be needed as described in Part 430.27. The third question relates to section 3.1.1, which provides the measurement requirements ofthe clotheswasher volume. Section 3.1.1 specifies that the volume is to be measured by lining the clothes container, with the agitator in place, with 2mil plastic film or some othermethod 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 ofAppendix J states

that the clothes containercapacitymeasurement is to be for "the entire volume which adry clothes load could occupy within the clothes container". The Department does not consider "volume in the agitator" as usable space for clotheswashing. 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 interpretationwould result in different energy factors for clotheswashers which were identical other than one having ahollow agitator and the other having a solid agitatorwhen in fact the usefulness and performance ofthe 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 thatthe Whirlpool interpretation is inconsistentwith the requirements of section 3.1.1 ofAppendix J to Subpart BofPart 430. DOE believes that any method used tomeasure clothes containercapacity should preventwater from entering both the outer tub containerand the agitator ifit is hollow. Ifyou should have any additional questions, contact Bill Hui.ofmy staffat (202) 586-9127.

# ;;~r0~ Michael 

### J. McCabe, Director Office ofCodes and Standards Office ofBuilding Technologies Conservation and Renewable EnergyCONCURRENCES

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 RTG. SYMBOL CE-431 INITIALS/SIG HUI /C DATE 6^ 12/18/92
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C:\WPDATA\RCORSPD\WPOOL:CE-431:HUI:ra:6-9127:12/18/92: 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 ofOctober 19, 1992, requesting interpretation ofthe 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 ofan 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 ofrinses 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 otherwash/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 Bof 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 ofhaving the option to test and

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