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#2GG

U.S. DEPARTMENT OF ENERGY 

+ + + + + 

DISHWASHER TEST PROCEDURE 

 PROPOSED RULE 

+ + + + + 

 PUBLIC WORKSHOP 

+ + + + + 

Tuesday, November 2, 1999 

+ + + + + 

The workshop met in Room 1E-245, Forrestal 

Building, 1000 Independence Avenue, S.W., Washington, 

D.C., at 9:00 a.m., Edward Pollock presiding. 

PRESENT: 

EDWARD POLLOCK, DOE 

LOU KERESTESY, Facilitator 

NATASCHA CASTRO, NIST 

BARBARA TWIGG, DOE 

RANDY COOPER, Maytag 

ROBERT DuPONT, Product Vision and Reality 

TOM ECKMAN, Northwest Power Planning 

 Council 

MARK EDWARDS, BSH Home Appliances 

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CHRISTINE EGAN, ACEEE 

ERNST GRUNEWALD, Whirlpool 

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PRESENT (Continued): 

KYRAN HOFF, General Electric 

TOM JOHNSON, Maytag 

ROBERT JUDD, Whirlpool 

CHRIS KAESER, BSH Home Appliances 

TED KLECZKO, Miele 

EUGENE MARGOLIS, DOE 

JAMES MILLS, FTC 

WAYNE MORRIS, AHAM 

STEVE PETERSON, Whirlpool 

DENNIS POINTER, Frigidaire 

GLENN SCHLEEDE, Energy Market and 

 Policy Analysis, Inc. 

CHARLES STEPHENS, Oregon Department of 

 Energy 

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 C-O-N-T-E-N-T-S 

PAGE

Welcome, Edward Pollock, Jr. ......................4 

Introduction of Proceedings, Barbara Twigg ........5 

Introductions and Agenda Review, Lou Kerestesy ...11 

Presentation and Discussion of Issues: 

Average Yearly Number of Cycles ............18 

Repeatability of Testing ...................32 

Definition for Compact and Standard Models..61 

Test Procedure for Soil Sensing Models ...........67 

Discussion of Weighting .........................204 

Closing Remarks ................................233 

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 P-R-O-C-E-E-D-I-N-G-S 

 (9:08 a.m.) 

MR. POLLOCK: Shall we get started? 

Good morning. My name is Ed Pollock. I 

am Director of the Office of Research and Standards, 

which has responsibility for developing the test 

procedures and standards for the appliances and for 

other products. 

I want to welcome all of you here this 

morning and thank you for all coming. It was what, 

about two years ago I remember standing around a 

couple of dishwashers out at NIST with Natascha as we 

went through some of the early test procedure steps to 

try to determine what is the most appropriate way to 

test these dishwashers would be. 

So it has been a fairly intensive amount 

of effort on the part of a number of you, and we 

appreciate the time that you have put in developing 

this test procedure. We look forward to moving now to 

discussing the final issues and getting this rule 

finalized and out there so that it can be used in 

certifying the efficiency of the different dishwashers 

that are on the market. 

And with that I'm going to turn it over to 

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Barbara. 

MS. TWIGG: Good morning. I'm Barbara 

Twigg. I am the team leader for the dishwasher 

project here at the Department of Energy. 

And you have already been introduced to Ed 

Pollock, the Director of our office. This is Natascha 

Castro, who is our engineer consultant at the National 

Institute of Standards and Technology, and Eugene 

Margolis from the Office of General Counsel here at 

the Department of Energy, and Mark Friedrichs is also 

on the team for our Policy Office, but I don't see him 

here yet. 

Please bear with me while I read some 

fairly standardized and a little bit boring remarks, 

but we need to enter this into the record. 

So on behalf of the department, I would 

like to thank you all for taking to participate in 

this public workshop. We've chosen the format of a 

public workshop for today's public hearing on our 

proposed rulemaking in order to facilitate the 

exchange of ideas and information in a more informal 

manner hopefully. 

This workshop is a forum for discussing 

the changes we proposed to the dishwasher test 

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procedure published in the notice of proposed 

rulemaking in the Federal Register on September 28th, 

1999. The notice included an announcement of today's 

workshop. 

In addition to that notice, the department 

sent a letter on October 11th, 1999, to organizations 

who might have an interest in this rulemaking. Anyone 

attending this workshop or submitting written comments 

will be added to our list for future mailings. 

Materials related to this rulemaking will also be 

posted on our Web site at http, and I'll enter that 

into the record, but it's listed in the Federal 

Register notice that you have picked up today. 

Today the department is seeking comments 

on all facets of the proposed test procedure, 

including the new procedure and formulas for testing 

dishwashers using soil sensing technology, revised 

definitions for compact and standard models, some 

changes to the inputs for calculating the estimated 

annual operating cost, some new specifications to 

improve testing repeatability, and any other pertinent 

issues that you wish to bring to DOE's attention. 

The comments received here today, along 

with those submitted during the written comment 

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period, will assist the department in developing the 

final rule for dishwasher test procedures. 

I am the presiding officer for the 

workshop. Lou Kerestesy will facilitate and set the 

guidelines for conducting the workshop. 

In approximately two weeks a complete copy 

of the transcript will be available for inspection and 

copying at DOE's Freedom of Information Reading Room, 

located in Room 1E-190, which is right down the hall 

from here. 

Anyone wishing to purchase a copy of the 

transcript may make arrangements with our court 

reporter up front. 

To provide the department with as much 

pertinent information and as many views as can be 

reasonably attained, and to enable interested persons 

to express their views, the workshop will be conducted 

in accordance with the following procedures. 

We will begin with introductions and 

review the agenda. We invite you to add issues you 

think are important but not already covered. 

Following the agenda review, we will move 

to the discussion topics. Natascha will make a brief 

statement about the proposed changes, and I will 

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summarize any written comments we have received to 

date. 

Then we will open the floor to discussion. 

 We will move through each topic identified by the 

department the same way and see what makes sense for 

any topics you might add to the agenda. 

We should have ample time to raise and 

discuss all important issues, but we would ask, 

however, that all participants refrain from making 

overly lengthy remarks so that everyone gets the floor 

time they need. 

A facilitator will enforce this ground 

rule and will also limit debate when speakers' points 

have been made and are clear. 

Questions are welcome throughout these 

presentations unless you are advised otherwise. It 

may be necessary, however, to cut off debate on some 

topics to remain on schedule, although there may be 

time at the of the workshop for additional discussion 

of significant issues. 

I encourage everyone present to 

participate as much as possible so that we can get a 

full spectrum of opinion on these issues. 

The workshop is scheduled to end at four 

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o'clock today unless, of course, we finish early, 

which is likely I would think. Topics which have not 

been completely discussed by that time can be 

addressed in additional written comments, which are 

due by December 13th, 1999. 

All written comments and data submissions 

will be available for public inspection at DOE's 

Freedom of Information Room. The phone number there: 

 (202) 586-6020. 

Please send your comments to Brenda 

Edwards-Jones here at the department, referring to 

Docket No. EE-RM-TP-99-500 when you respond. We would 

like to have ten copies of your comments and support 

data, along with an electronic copy of the comments or 

data using Word Perfect or Microsoft Excel. No fax 

comments will be accepted. 

Any person submitting information which he 

or she believes to be confidential and exempt by law 

from public disclosure should submit one complete 

signed copy, plus ten copies and a copy on a disk from 

which information claimed to be confidential has been 

deleted. In accordance with the procedures 

established in 10 CFR, Part 1004.11, the Department of 

Energy will make its own determination as to whether 

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the information shall be exempt from public 

disclosure. 

Again, we appreciate the time and effort 

you've taken in preparing for this workshop, and we 

are pleased to receive your comments and opinions. 

Our purpose today is to listen to your views. 

This rulemaking stands as a good example 

of the need for test procedures to respond to changes 

in technology. When a new type of product enters the 

market, in this case dishwashers with soil sensing 

technology, we may need to update certain aspects of 

test procedures in order to continue to measure energy 

consumption accurately for all models. 

The new formulas for testing soil sensing 

machines provide the core of our proposal. In 

addition, we are proposing changes that would improve 

the accuracy and repeatability of some of the steps of 

the current test procedure, such as installation, 

conditioning, cycle requirements, for example. 

We also propose to bring a consistent 

federal definition to compact and standard size 

machines and to update the number of cycles per year 

to reflect current use patterns. 

Today, however, we are not planning to 

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address the issue of standby power consumption in 

dishwashers, although the department recognizes the 

importance of this issue. We plan to develop 

consistent policy for all covered appliances on a 

program-wide basis and will not include standby power 

as part of an individual test procedure rulemaking at 

this time. 

As you can see from the agenda, we plan to 

start with the smaller issues and progress to the new 

procedure for testing the soil sensing machines, 

leaving plenty of time this afternoon for full 

overflow discussion as we grapple with such hard to 

pin down topics as how well does American rinse its 

dishes. 

The pretreatment percentage is an 

important component of measuring the energy and water 

consumption of soil sensing dishwashers, and it needs 

to be quantified as accurately as possible. 

We also need to understand the connection 

between pretreatment and the number and type of wash 

cycles. 

I would now like to introduce our 

facilitator, Lou Kerestesy, who will review the 

agenda, provide some housekeeping details, and 

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describe how we're going to conduct the meeting. 

Lou. 

MR. KERESTESY: Thank you, Barbara. 

Good morning. My name is Lou Kerestesy. 

I'll be the facilitator for the day. 

I'm going to just jump right into a few 

things. Yeah, let's do some introductions, and then 

we've got a couple of things to cover before we get to 

the work. 

Wayne, why don't we start with you? Let's 

go around and introduce yourself, name and 

affiliation. 

MR. MORRIS: I'm Wayne Morris with the 

Association of Home Appliance Manufacturers. 

MR. COOPER: Randy Cooper with Maytag 

Appliances. 

MR. KERESTESY: Yeah, just shout it out. 

MR. JOHNSON: Tom Johnson with Maytag. 

MR. KERESTESY: Thanks. 

MR. POINTER: Dennis Pointer with 

Frigidaire. 

MR. JUDD: Bob Judd with Whirlpool 

Corporation, and I have with me Steve Peterson, Ernie 

Grunewald and Wayne Klug. 

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MR. KERESTESY: Thank you. 

MR. KLECZKO: Ted Kleczko, Miele, 

Incorporated. 

MR. STEPHENS: Charlie Stephens, Oregon 

Office of Energy. 

MS. EGAN: Christine Egan, American 

Council for Energy Efficient Economy. 

MR. EDWARDS: Mark Edwards, BSH Home 

Appliances. 

MR. GAZER: Chris Gazer, BSH Home 

Appliances. 

MR. KERESTESY: Thank you. 

Did Gene and Beverly here -- 

MR. MARGOLIS: Eugene Margolis, counsel 

for the program. 

MS. CASTRO: Natascha Castro, National 

Institute of Standards and Technology. 

MR. KERESTESY: Now we'll go in the back 

here. 

MR. ECKMAN: Tom Eckman, Northwest Power 

Planning Council. 

MR. DuPONT: Ron DuPont, representing 

Natural Resources Canada. 

MR. MILLS: James Mills, Federal Trade 

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Commission. 

MR. SCHLEEDE: Glenn Schleede, citizen, 

consumer, and taxpayer. 

MS. HOFF: Kyran Hoff, G.E. Appliances. 

(Inaudible introductions.) 

MR. KERESTESY: Thank you very much. 

And we also have a recorder today keeping 

everything micked and recorded for the record, and 

your name is? 

THE REPORTER: John. 

MR. KERESTESY: John. Thank you, John. 

A couple of quick housekeeping details. 

You probably have already found where the bathrooms 

and coffee is. Bathrooms are down the hall to the 

left. Either way? I found them down to the left, and 

there are some down to the right. 

And coffee shop or the snack bar where we 

can get some coffee and some things is one floor below 

this room. So if you can get the elevator and make 

your way around the corner, that will orient you to 

where that shop is and we'll talk about what lunch 

opportunities are at that time. 

When you speak, please do -- if you're at 

the table, be sure you pull a mic in front of you, and 

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if you're not at the table, we want to get you to a 

mic to make a comment so it's recorded. 

I'll just take a minute to go over the 

morning part of the agenda. You have a package with 

you, and this is pretty clean. So there's not a lot 

to this. 

We're going to start with a brief 

presentation on each topic, a brief presentation by 

Natascha just to give some context for the discussion 

of that issue. She's got some Power Point slides, 

which are also printed for you; go over a few points, 

and then if there have been any written comments 

submitted relevant to that subject, Barbara will 

summarize those so that everybody knows what has been 

submitted. 

And then we will open it up to discussion. 

 You understand the purpose of these workshops is to 

exchange information, identify some issues, have some 

discussion about the issues. We want to be sure that 

everybody has had a chance to make their points, have 

some time to make the points that you think are 

important. 

Some people have some slides with them or 

some overheads that we're going to use. We're not 

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trying to do two things. There are two things we're 

not trying to do. One, we're not trying to reach 

agreement today on any of these particular points. 

The purpose of the workshop is information exchange 

and the identification and discussion of some issues. 

That doesn't mean we're going to reach 

agreement or consensus on the topics that we discuss. 

 That's not the point of the event. 

And, two, there comes a point that there's 

a line that I'm going to watch for that I want to give 

you fair notice of now. When you've made your point 

and maybe you've made it twice, and maybe I let you 

make it two and a half times, but we're not looking to 

persuade each other in this day today. 

Especially the members of the department 

are here to hear information to take into 

consideration for the rulemaking. When your point has 

been made to the listeners, I'm going to cut you off, 

and we're going to move on. Fair enough? Fair 

enough, for everybody's sake so that everybody has 

some air time. 

Any questions before we start? 

I think that we -- yes, sir. 

MR. MORRIS: Wayne Morris. 

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I'd just like to ask if Barbara or 

Natascha could discuss at some point in time the 

procedure or the timetable as we move forward, what 

the next steps would be, and particularly with respect 

to implementation vis-a-vis the FTC. Since we've got 

James here, maybe he can talk to us a little bit about 

how this would correspond to the phase-in cycle for 

actually labeling the product. 

MR. KERESTESY: Do you want to cover that 

now or make a few notes about it and we'll cover it 

later? 

MS. TWIGG: Let's do that later. 

MR. KERESTESY: Okay. We'll do that 

later. Thanks, Wayne. We will do that. 

MS. TWIGG: It sort of depends on what we 

discover here in terms of where we're going and if we 

have new wrinkles 

MR. KERESTESY: Okay. We actually started 

a few minutes late, and we're actually now ahead of 

schedule by a few minutes, which is nice. 

We'll go to the 9:30 slot on the agenda, 

presentation and discussion of issues, and Natascha 

will. We're going to go through those one by one. So 

Natascha will show some slides on the average yearly 

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number of cycles. If there are any written comments 

submitted, Barbara will read those, and then we'll 

have some discussion about that issue. 

I'm not sure who among you have -- I mean, 

if you've got comments, we're just going to have you 

raise your hand and we'll go in order and get 

everybody's comments. I know some of you have some 

material to show, and I'm not sure who that is. So 

let me know if you've got some slides or something 

that you want to put up. 

PARTICIPANT: Are there other agenda items 

besides the one that Wayne brought up? 

MR. KERESTESY: Good question. Thank you. 

Is there any way in which you want to add 

to the agenda? Any topics that aren't on there that 

you want to add? 

PARTICIPANT: The NRC position on this. 

MR. KERESTESY: NRC position on these 

issues. Where would that most logically come? 

PARTICIPANT: I think it's at the end. 

MR. KERESTESY: Okay. Anything else to 

add to the agenda? 

(No response.) 

MR. KERESTESY: All right. So we have 

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added NRC position and the timetable of the events to 

follow this workshop. Very good. 

MS. CASTRO: The first topic that I'd like 

to cover is the updating the average yearly number of 

cycles, and this number was last updated in 1983, and 

we've since had changes in consumer use of 

dishwashers, and we'd like to update that to reflect 

current consumer use. 

Data was solicited for more recent survey 

years, and some data came forward from the Soap and 

Detergent Association. The average that came forward 

out of that data was 264 cycles per year, and that was 

an average of data representing survey years 1986 to 

1996. 

And here in the chart, you'll see that 

there has been a downward trend. We're currently 

using an average use value of 322 cycles per year. 

An additional, more recent survey from 

Oregon reported 280 cycles per year. That also showed 

some variation depending on the household size, but 

currently we're looking at a new value of 264 cycles 

per year, which is that SDA average. 

And I'd like to open up the floor for 

discussion. I don't believe we have any comments. 

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MR. KERESTESY: Any comments on that? 

MS. TWIGG: No. 

MR. SCHLEEDE: My name is Glenn Schleede, 

citizen, consumer, and taxpayer. 

I've got about four questions that I can 

just lay them out, and then you can respond however 

you wish. 

The first question, on the public 

availability of the data from SDA. Are the data 

publicly available, and are data available that will 

permit judging the validity, reliability, and 

representativeness of those data? 

That's two questions. The third question 

is I notice in the data that there's a distinct 

downward trend in the numbers, going from 286 to 244 

or 14 and a half percent, something like that, over a 

few years. Question: does SDA have any explanation 

for that? Is it trends from eating out or preprepared food or what? 

And a question for DOE related to that: 

why pick the average of those numbers when there seems 

to be such a distinct downward trend? 

As far as the Oregon survey, since those 

people have such low subsidized electric rates out 

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there, I can see why they would use their dishwashers 

more than people with higher rates. So I guess I 

wouldn't give that a whole lot of credibility. 

Fourth question is dispersion around these 

averages. Averages are useful in an economy where 

everyone wears size seven hats, but we have fairly 

wide differences in practices in this economy, and the 

question: is there date available on the dispersion 

around these averages so that one can see how much 

people would benefit or how much they would lose by 

forced to use an average weight for a number of cycles 

if a standard is based on that? 

That's the end of my questions. 

MR. KERESTESY: Thank you very much. 

I think we've been copying those down. 

Data availability; explanation of cycles; the 

rationale for picking the average; and the range or 

dispersion around the average. 

Do you want to start going through those 

and then we'll have some more discussion or do you 

want to get -- do you just want to list some topics? 

There are other hands. 

Why don't we put some topics up and then 

we'll -- Robert and then Wayne. 

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PARTICIPANT: Go ahead. 

MR. MORRIS: Okay. Wayne Morris. 

We would like to make a comment about 

this, not a question. So I don't know whether you 

find it appropriate at this moment or you want to -- 

MR. KERESTESY: That's fine. Yeah, that's 

fine. 

MR. MORRIS: AHAM agrees with the number 

that the department has chosen, 264 cycles. We think 

it is indicative of the trends that we're seeing and 

in other data that is available of the use of 

dishwashers and, for that matter, other types of 

kitchen appliances. 

It is data that has been made available 

from the Soap and Detergent Association, graciously 

from them, to AHAM and thus to Department of Energy. 

Beyond the data that is available, I don't believe 

they had indicated they would be willing to provide 

additional data or break that data down. 

We do not have data as such to support the 

number. The number that the department chose is 

slightly more number of cycles than what AHAM had 

suggested, but we are willing to accept this. 

The information that we have had through 

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customer surveys is that dishwashers are in larger 

capacity than they have been previously. Families do 

eat out more often than they do or did previously. 

There is more use of disposable containers for food 

packaging that are not placed in dishwashers, and in 

fact, we find that families are of slightly smaller 

size, as well, as dishwashers are beginning to be used 

more often in one and two-person families than they 

were traditionally, where they were found more often 

in large family homes or dwellings. 

So we think it is indicative of the 

overall situation. We do not have data to support 

whether this trend is going to continue or not 

continue. It is merely what is happening at the 

present time. 

Thank you. 

MR. KERESTESY: Thank you. 

Let me get some other questions for 

discussion. Charlie. 

MR. STEPHENS: Charlie Stephens. 

Natascha, is there fairly strong 

correlation in the data between family size and 

cycles? 

MS. CASTRO: I don't have information on 

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the family size from the SDA data. 

MR. STEPHENS: Okay. So you really 

can't -- 

MS. CASTRO: It was a national survey. I 

don't have -- 

MR. STEPHENS: And it didn't have family 

size in it? 

MS. CASTRO: No. It might have been 

asked. I haven't seen that data. The only data that 

was made available was the number of cycles per year. 

 The question was asked on average how many cycles or 

how many loads are washed per week, and it was 

extrapolated for the year. 

MR. STEPHENS: Okay. Is there any way to 

find out or get that data? Because I think when it 

comes time to talk about standards for dishwashers 

that data is going to be important. 

MR. KERESTESY: Other topics to get out? 

We had several that were mentioned, and I want to 

complete the list and then get to those. 

Christine. 

MS. EGAN: My question is whether or not 

the 280 number is included in the average. 

MS. CASTRO: It is not. 

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MR. KERESTESY: Do you want to start the 

topical list? You've touched on a couple of things, 

but do you want to just go down that list now, those 

four questions? 

MS. CASTRO: Okay. 

MR. KERESTESY: And address those and 

we'll have some discussion about those. 

MS. CASTRO: All right. With regard to 

data availability, the information that I got just for 

various survey years what the number of loads were 

week -- the average number of loads per week washed 

for the families that were surveyed. 

I believe additional information was taken 

that hasn't been made available yet that I will 

request information regarding the family size. 

The explanation of cycles, I have heard 

the same reason for the number, the decrease in the 

number of cycles: more people eating out, but I've 

also heard that more recently that that trend might 

pick up, and that's why originally I looked at a trend 

line, and it projected a number even lower. 

But recently there's more interest in 

people starting to look at home. There's more use, 

and so that's one of the reasons we decided to go with 

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an average. It's a bit more conservative. 

And I'd like to add that a reason that our 

average is higher than the AHAM data or the SDA data 

that came through AHAM was that I eliminated some 

intermediate points. I'll just point out that there 

was some additional data available for a '90-'91 

survey and '92-'93 survey, and since that was 

imbalanced, I did not take a look at those, and that's 

why we came out with the average of 264. 

And the last question regarding dispersion 

around the averages, as I said, I only have a single 

point, a single data point for each survey year. If I 

have more information available, I'll make that 

available through Barbara Twigg. Okay? 

MR. KERESTESY: Yes, sir. 

MR. SCHLEEDE: Glenn Schleede again. 

If I could ask for further clarification, 

one is a question of availability of this data. Will 

it be available to the public? 

And second, with respect to the data, what 

do we have on the way the survey was conducted to know 

whether it is, in fact, representative, valid, and 

reliable? 

Lots of people can product lots of data, 

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and it isn't necessarily any good unless you can tell 

whether it is, in fact, valid statistical data. 

You mentioned that there is information 

indicating that people are cooking at home more and so 

on. What basis is there in that? Are there data 

available to demonstrate that, statistical data, or 

what do you have that would justify that point and to 

suggest that the trend will change from what it 

apparently has been over the last seven or eight 

years? 

MS. CASTRO: Okay. I believe the data 

should be available. I have a few copies of it here, 

and if DOE agrees, I can just make that available 

today. 

Let me see. With regard to data available 

showing an increased cooking at home, I don't have 

data available. That came out of discussions trying 

to come up with possible reasons for this more recent 

upswing and explanations for the decreasing average 

dishwasher use. So I'm not aware of any survey that 

has those results available at this point. 

MR. SCHLEEDE: Glenn Schleede again. 

Where is the most recent upswing? I don't 

see that in the data. 

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MS. CASTRO: The '95-'96 survey year. 

MR. SCHLEEDE: Oh, okay. I see that. I 

confused that with the Oregon data. Okay. 

How about data on dispersion around the 

averages? 

MS. CASTRO: I do not have that data at 

this point. I think it will be a lot clearer. For 

those who are interested, I can make the SDA data 

available, and you'll see it's just single data points 

for each of those survey years. 

MS. TWIGG: There isn't anyone here from 

SDA related company, is there? Because we had invited 

them. I was hoping someone would come. 

MR. MORRIS: This is Wayne. 

May I make a comment in regard to this? 

Glenn, I know that your questions in regard to looking 

for additional data are something that everybody would 

like to have. We don't, and we're not going to get it 

because Soap and Detergent Association was asked for 

additional data, and they don't have it from the 

manufacturers that presented it to them, and they're 

not going to make it available. 

Data has been used very successfully for 

many, many years in not only dishwashers, but also in 

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clothes washers. The information from the Soap and 

Detergent Association on clothes washer cycles 

triangulated very well with the data that was 

presented in other usage surveys and was used for the 

setting of the cycles in the clothes washer rulemaking 

that was done previous and, indeed, was done in the 

test procedure work that was done about three years 

ago. 

The manufacturers of dishwasher detergent 

have, if you will, a vested interest in making sure 

that that data is absolutely as accurate as they can 

do because they use it for inventory tracking, and to 

them it is extremely important to know exactly how 

much dishwasher detergent is going to be used. 

So to our knowledge, there would be no 

reason why the number would be either overstated or 

understated on their part to present such data, and I 

think that that's why AHAM has suggested that it is a 

good use of material or data that is available. 

It is limited. It does not have all of 

the traditional data resources that we would normally 

like. That is not going to be made available because 

the companies consider that to be proprietary in 

nature. 

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I would agree with Charlie's comment that 

if the department does go forward with any rulemaking 

activities or wishes to do this in the future, that 

the department may wish to look at other ways of 

capturing the data. 

We would support anything that is a good, 

solid data set. This is the only thing we have right 

now, and it's the best we can come up with. 

MR. KERESTESY: Yes, sir. 

MR. ECKMAN: Tom Eckman, Northwest Power 

Plant Council. 

It would be helpful at least if we could 

get from the detergent manufacturers a description of 

the survey technique or process by which they collect 

the data so that we know sample size and things like 

that. 

The questions that were asked, unless it's 

basically an inventory tracking process where they 

fundamentally said, "We sold so much soap. This means 

that there are so many dishwashers out there and so 

many cycles a year," but if it was simply survey data, 

that would be useful to know the process by which the 

data was collected. 

And you know, if there are associated 

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things like household income so that we can calibrate 

it with the Oregon survey, that would also be helpful. 

MR. KERESTESY: And that was part of your 

point about methodology. 

Christine, did you have your hand up to 

get in? 

MS. EGAN: I did. 

MR. KERESTESY: Okay. Other questions or 

comments about this topic, cycles, about the data? 

MR. JUDD: We applaud the DOE proposal to 

revise the average annual use of dishwashers to 264 

cycles per year. We agree with DOE that revising the 

annual use of dishwashers to a number of cycles as 

representative of actual consumer use is not only 

appropriate, but necessary to maintain the dishwasher 

test procedures consistent with statutory requirements 

that are included in 42 U.S. Code 6293 that basically 

says "test procedure prescribed or amended shall be 

reasonably designed to use test results which measure 

energy efficiency, energy use or estimated annual 

operating costs during representative average use 

cycle or period of use," and so on. 

So I think this is a very appropriate step 

and something that DOE should proceed with. 

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MS. TWIGG: Could you add your name? Did 

you say your name before? 

MR. JUDD: Bob Judd, Whirlpool. Excuse 

me. 

MR. KERESTESY: Okay. I'm like an 

auctioneer. Going once, going twice. Any last 

comments on this topic? Charles? 

MR. STEPHENS: Yeah, just one last plug 

for trying to figure out what's behind the data. I 

think you'll find we've just been doing some plotting 

here and you'll find that the Oregon data actually 

fits rather nicely with the V that you've got there in 

the data. If you take one more year out and look at 

280, it's right on that trend line from 244 to 260 to 

280. 

And the average falls somewhere between 

260 and 270 at the moment, but I wouldn't necessarily 

suggest that there's a definite downward trend. 

Before I made that forecast, I'd want to know why it's 

doing what it's doing or if there's some other factors 

that one could correlate that you can use to forecast 

into the future or not. 

I mean maybe you can't, but I would like 

to know that. So I think before you go ahead and 

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settle on a number, I think I'd want to know, for 

instance, is the family size -- I mean, our data 

suggests that cycles per year is strongly correlated 

with family size, and there is a national average 

family size. I don't know whether the survey data has 

that same family size and, therefore, you could 

correlate that with any trends you see in national 

average family size or whatever. 

But I would want to know that data before 

I settled on a number. 

MS. CASTRO: Okay. There's one thing I 

wanted to add. This is just some notes from the 

survey. It says, "The data below comes from our study 

contacting nationally representative panelists from 

the standpoint of geography, family size, age of 

homemaker, gender, income, and employment status. The 

data are obtained through an independent, outside 

research organization. This survey is run annually 

and has a base size of 1,500 to 1,800 respondents." 

I will try to contact SDA to see if we can 

get that data available. If anything does come 

forward, I'll take a look at family size and see if 

there's any correction that needs to be made. 

MR. KERESTESY: Anything else you want to 

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add before we move on? 

Good. Thank you. 

Second topic. Repeatability of testing. 

MS. CASTRO: Okay. This second issue 

encompasses a number of changes we made to improve the 

test clarity and the repeatability of the test 

procedure. 

I did some studies a few years back to 

take a look at the effect of the ambient conditions to 

see its effect on energy consumption. First off, DOE 

proposes to reduce the range of ambient temperature 

that's acceptable. 

Currently it's 70 to 85 degrees 

Fahrenheit, and it's proposed to be reduced to 75 plus 

or minus five degrees Fahrenheit. 

The results of the study that I did showed 

that the average total energy consumption was 17.6 

percent lower for a test conducted at an ambient 

condition of 85 degrees compared to an ambient test of 

75 degrees Fahrenheit. 

The second change is to include more 

detailed installation requirements to try and 

standardize it across the various testing 

laboratories. It was taken from the UL standard for 

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dishwasher. 

And the third topic is to add a 

conditioning cycle as part of the test method to 

better approximate household conditions, and that 

would be to prime the lines to make sure that there is 

water in the sump area of the pump, which is more 

typical. It's what we expect for a typical household 

condition. 

And then finally, this isn't really a 

change to any of the instrumentation tolerances, 

except we're consolidating all of the specifications 

for the different instrumentation. We're basing 

tolerances on nominal values so that all of the 

manufacturers have a target, are going for the same 

target value, and to introduce new specifications for 

temperature measurement devices. 

So those are the four items we're looking 

at to improve test clarity and repeatability. 

MR. KERESTESY: Thanks, Natascha. 

Let's just list some issues for 

discussion, and then we'll have comments and question 

and answer. Just issues to put on the table for 

discussion about test repeatability. 

Wayne. 

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MR. MORRIS: Wayne Morris at AHAM. 

If we could just talk briefly about the 

conditioning cycle situation. 

MR. KERESTESY: Yes, sir. 

MR. ECKMAN: The plus or minus tolerances 

on temperature testing. 

MR. KERESTESY: Thank you. Temp. 

tolerances. 

Anything else? 

MR. JUDD: We have a comment or suggestion 

on the truncated drying cycle. 

MR. KERESTESY: Truncated -- conditioning 

cycle, temp. tolerances, the truncated cycle. Any 

others? We can add to this as we go, but I just 

thought it would be good to put on the table what some 

of the subjects were for discussion. 

So anybody want to add one before I turn 

to Wayne? 

Wayne, why don't you pose your question or 

comment about the conditioning cycle? 

MR. MORRIS: This is Wayne Morris. 

All four of these areas are ones that AHAM 

suggested to the department to tighten up the test 

procedure and also to deal with some uniformity of 

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testing and allow the manufacturers a little more 

flexibility in the way that they're doing this testing 

versus other testing that they need to do. 

In terms of the temperature situation, we 

agree with the department's resetting of the tolerance 

range. It's in keeping with what AHAM had suggested. 

This assists manufacturers who have now 

been able in laboratories to achieve greater tolerance 

restrictions in the testing. Going to tighter 

tolerances of this would be extremely difficult in 

laboratory environments to maintain throughout a cycle 

because the dishwasher, of course, does heat the 

environment as it's being tested. 

The second area in regard to the 

installation requirements, just to point out for 

clarification it's a reference actually to the UL and 

CSA, which are harmonized standards, which allow the 

manufacturer to do the same testing in both the U.S. 

and Canada in the same way. 

In terms of the conditioning cycle, 

there's only one small difficulty with the way the 

description is made in the test procedure as proposed, 

and that is that we think it needs to be clarified 

that the entire cycle does not need to be run in order 

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to do this. So, indeed, you would not have to run two 

dishwasher cycles. 

We do believe it's important to have water 

in the pump to represent the way that a consumer 

actually finds the dishwasher when they run their 

cycle on a typical evening, but we believe that the 

manufacturer should be allowed to find some 

methodology to do that. 

It may involve simply filling, rinsing, 

and draining the dishwasher quickly prior to running 

the actual energy cycle, but it does not need to run 

an entire wash cycle through an hour or whatever in 

order to prime the pump, and we just think it needs to 

be clarified in there that any methodology that would 

allow water to be entered into the pump area would be 

acceptable. 

In terms of -- and Bob brought up the 

truncated. I'll let him open it up, but I think we're 

in concert with what Bob would want to present. So 

I'll let him speak to the truncated normal. 

MR. KERESTESY: You all done then? 

Go ahead, Bob, and then we'll go back. 

MR. JUDD: Bob Judd for Whirlpool. 

To add to Wayne's comment on the preEE-RM-TP-99-500 COMMENT 02GG
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conditioning cycle, I think a good way to write that 

would be to pre-condition the machine using any cycle 

that fills, circulates, and drains water. For 

Whirlpool, that's a rinse and hold cycle. Other 

manufacturers may call it something else, but we would 

see that as a minimum requirement because that would 

fill the water lines, fill the sump, run the pump, 

circulate water through the dishwasher and drain it. 

The advantage of that kind of a cycle is 

that it wouldn't add heat because if it's anything 

that has heat in it, then you've got to let the 

dishwasher cool to come back to ambient to run the 

test, and it's strictly an issue of how much time it 

takes to get these tests done. 

So I think if you come with a test 

procedure that says any cycle that does those three 

things, it should be preconditioned. 

To the truncated dry cycle for that, we 

support clarifying how tests are performed to 

determine the energy use of dishwashers having a 

truncated cycle. However, we oppose any change in the 

test procedure that would require additional testing. 

Three points under that. Today Whirlpool 

obtains truncated cycle normal energy consumption 

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during a full normal cycle by recording the energy 

consumption at the end of the final rinse. In other 

words, we record the energy used at that point, let 

the machine run through the dry cycle, record it again 

for a full cycle. 

So with one test cycle, we get two data 

points. We get the truncated dry cycle. We get the 

full dry cycle with running one test. 

The energy consumed by the dishwasher 

during the truncated cycle while the timer is running 

out is inconsequential. For our machine it's .002 

kilowatt hours, whether it's an electronic or an 

electromechanical timer or machine. That's in 

comparison to two kilowatt hours for the full cycle. 

So it's that kind. You know, it's .002 kilowatt hours 

compared to two kilowatt hours for a whole cycle. 

That small amount of energy used, if you 

correlate that back to 264 cycles a year at eight 

cents or eight cents per kilowatt hour, you're talking 

about four cents of energy a year for all 264 cycles 

for the energy used by the timer during that truncated 

dry cycle. So that does not warrant running two full 

tests because it doubles the test and time that it 

takes to go through the light because not only do you 

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have to run the test again. You have to let the 

dishwasher cool down. 

So it's the time for the cycle; it's the 

cool-down time to get back to ambient to start and run 

it again; and it adds no value. And our guess is that 

most machines are going to consume a very small amount 

of energy during that period, and it's not worth 

running two full tests. 

So we would propose that the test 

procedure provide that if the truncated dry cycle uses 

some very minuscule amount of energy, that you can 

combine those steps. We don't have exact wording, but 

I think the concept that is merits clarification. 

MR. KERESTESY: Did you capture that? 

MS. CASTRO: Yes. 

MR. KERESTESY: Do you want to respond on 

any of these issues or ask any questions? 

MS. CASTRO: Not at this point. 

MR. KERESTESY: All right. I'll see if 

there's other comments on this topic before I go to 

tolerances. 

So you don't have anything. Barbara, do 

you have anything? 

MS. TWIGG: No. I think it's an 

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interesting point. You know, our role here today is 

to hear all of this, and then we'll figure out what to 

do with them after we finish the meeting, but that 

certainly seems like a good point. 

MR. KERESTESY: Some more comments on this 

general truncated cycle topic? Charlie. 

MR. STEPHENS: Charlie Stephens. 

Wayne touched on an interesting topic 

there when he was going over all the changes AHAM had 

recommended, and that is the NRC requirements for the 

inter-guide label I've noticed myself in some of the 

dishwashers we've been qualifying for our tax credit 

program lately that the numbers on there on the interguide and the energy guide are not the same. 

To what extent are we changing this test 

procedure or recommending changes here that make this 

consistent with the Canadian test procedures for CSA? 

MS. TWIGG: Well, we invited the Canadians 

to come today, but -- 

PARTICIPANTS: We are here. 

MS. TWIGG: Oh, we did get one. Oh, 

great. 

MR. DuPONT: Hi. I'm Ron DuPont 

representing Natural Resources Canada and also 

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observing for CSA. 

Our role here just today is to observe, 

and they have the intention to take this information 

and try to make the standards consistent and 

harmonized. So I don't have any input to the meeting, 

but I have been asked to give a full report back on 

all of the factors necessary. 

MS. TWIGG: Great. Well, thank you for 

coming. 

MR. STEPHENS: I guess I still would like 

to hear from DOE or from Wayne as to what extent are 

we going to end up with a test procedure here that's 

consistent with what CSA requires. 

MR. KERESTESY: Do you want to respond to 

anything or let Wayne? 

MR. MORRIS: This is Wayne Morris. 

I would like to respond for the 

manufacturers, I guess, that it is absolutely our 

intent that the test procedures be in as much concert 

as is entirely possible, and indeed, when AHAM started 

out this process of suggesting changes to the 

department about the test procedure on dishwashers, we 

encouraged the department as they have done to keep 

NR-CAN and CSA informed at every step, and we have had 

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assurances from NR-CAN that they would take everything 

under advisement. I can't speak for them to say that 

they're going to do it, but that they have assured us 

that they would take everything under advisement. 

Their intent is, as Ron said, to make sure 

that the test procedure is the same. Currently there 

are some slight differences, and we would like to work 

those out and have the labels read as much the same as 

is possible to do. 

We think that this will go somewhat to 

that situation, although the reason for these were not 

because the CSA standard does this and the U.S. does 

not. That wasn't the purposes of doing these 

recommendations originally. 

They were, in fact, to tighten the 

tolerances, to allow for better testing of the units, 

more uniformity, that type of thing. We will seek to 

do the same thing with the CSA standard as well. 

So that is the intent at least. That has 

been all along. 

MR. STEPHENS: So we're not using the 

current procedures in Canada at all as a guide for 

what we're doing here? 

MR. MORRIS: I can't speak to that. Does 

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anyone from -- 

MR. EDWARDS: I think the procedures are 

very much the same. 

MR. KERESTESY: Your name, please. 

MR. EDWARDS: Mike Edwards, BSH. 

I think the procedures are very much the 

same, except for the metric conversions. That's my 

understanding, and I would even like to -- we haven't 

discussed this with the other manufacturers, but I 

don't see any reason we couldn't narrow it down to one 

energy label on the dishwasher, the same label for 

both. 

MR. KERESTESY: Yes, sir, please. 

MR. GRUNEWALD: Ernst Grunewald, 

Whirlpool. 

I am also on the Canadian Energy Committee 

for the CSA, and prior to I believe it was 1992, '93, 

we had a different standard, a fivefold (phonetic) 

different and the temperature was slightly different. 

 We always had problems. The standards were 

harmonized. The test procedures are identical. 

So if there are differences, it may be 

something in the declaration, but as far as the test 

procedure is concerned, I mean, we are certified by 

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CSA at Whirlpool with exactly the same test. That is 

the very important thing, and Mr. Judd will address 

that a little bit later. 

We're very concerned that we keep dates 

together because it doubles the testing. I can 

guarantee you that, but if there is a difference that 

you see in the number, somebody put another number of 

cycles per year on or what have you because the intent 

of CSA was to harmonize exactly to the DOE. 

CSA is in possession of the proposed 

rulemaking. I sent my committee chair a copy, and he 

said that he was taking a look at it, and I think 

you're saying the same thing. 

So, you know, you should pursue why there 

seems to be a difference in that number. 

MR. STEPHENS: Yeah, I'm not seeing a 

difference in every case, but I'm more concerned that 

we're proposing changes here, and I want to make sure 

that CSA is also proposing the same changes. So -- 

MR. KERESTESY: It sounds like -- 

PARTICIPANT: Violent agreement. 

MR. KERESTESY: In violent agreement? Is 

that what you said? 

(Laughter.) 

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MR. KERESTESY: It sounds like there is 

not a definitive answer to the question, but certainly 

the point has been noted, and it's something that can 

be examined further as the rulemaking proceeds. 

MR. MORRIS: Lou, we kind of got 

sidetracked on that one, but I wanted to raise a 

question for Natascha or Barbara. 

The second that you have changed in your 

proposed changing to the truncated normal cycle, was 

there a reason for this? I don't understand why the 

change was proposed. There doesn't seem to be an 

explanation of why it was necessary. 

MS. CASTRO: Using the word "preset? 

MR. MORRIS: Yes. 

MS. CASTRO: That doesn't actually affect 

the way it was conducted, just to clarify that this is 

something that's done. The whole cycle needs to be 

set before the test has begun so that all of the 

buttons are pressed prior to administration of the 

cycle. 

MR. MORRIS: So this is Wayne again. 

So for clarification, it wasn't the 

department's intent by changing that word to require 

manufacturers to run two tests in a five or six-hour 

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hold-down period in between. Is that what you're 

telling me? You were trying to do it for 

clarification purposes but not necessarily to require 

manufacturers to run two tests? 

MS. TWIGG: I think the prime thing there 

was clarity of definitions somehow. 

MR. MORRIS: Okay. Well, I think that if 

that's the reason, then I would suggest that we can 

look at perhaps modifying a word slightly because as 

Bob brought out, the point that we're finding is that 

by changing a word here, you could require 

manufacturers, depending on how they interpret it, and 

we would hope everybody else would do it the same way, 

is that you would require a manufacturer to run an 

entire truncated cycle, stop, allow a machine for five 

or so hours to cool down, then turn around and run a 

full test again or vice versa, but you'd have to run 

two full tests. 

In an audit sequence, in a production line 

when you're trying to run hundreds of machines, you 

know, an extra day of testing on individual machines 

that would yield essentially no additional valuable 

information seems to be, you know, unwieldy. 

So if that's really what was done, we'd 

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just like to work together on the wording. 

MS. CASTRO: Yes. It was my understanding 

that when I studied the test procedure initially, I 

believe that the manufacturers did, in fact, run two 

test cycles. I did not realize that you just measured 

the energy at the end for the truncated portion. 

Sure, I do see now how that does change 

it. 

MR. JUDD: That's why we reacted. 

MS. CASTRO: Yes. Okay. 

MR. KERESTESY: Okay? That's clear? 

Good. I like that. 

I think we've covered the cycle issues 

pretty clearly, pretty thoroughly. We still have a 

question about tolerances. Do you want to address 

that again? 

MR. ECKMAN: Yeah. It looks from the 

analysis that was done that given the range in 

efficiency that you get by testing at different 

ambient temperatures, there's a ten degree range that 

shows up to be an almost 18 percent difference in 

efficiency, and basically you're providing a ten 

degree range with those tolerances. 

From 75 plus or minus five, there's still 

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a ten degree range. So you can get an 18 percent 

difference by testing at low temperatures or at the 

high temperature, depending on where the ambient start 

was. 

My question is whether or not it's better 

to set a start temperature given that the environment 

is going to heat up as the cycles go through or 

whether you want a mean temperature for the entire 

test. What's more important? 

MR. KERESTESY: Did you understand that 

question? 

MR. ECKMAN: Is that clear? 

MS. CASTRO: Yes. 

MR. ECKMAN: Do you want an ambient start 

temperature given that the room is going to heat up or 

the test chamber is going to heat up while you do the 

test, or do you want a mean temperature during the 

entire test? Which is more critical to getting 

consistent results? 

MR. EDWARDS: Mike Edwards, BSH. 

I think if you only established a start 

temperature of the room, the thermal mass of the room 

could be different and, therefore, your results would 

be different. 

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MR. ECKMAN: So you want a mean 

temperature during the test. And that mean 

temperature during the test is ten degrees 

potentially, which is basically what you pointed out 

here provides a differential of 18 percent in 

efficiency. That's a fair tolerance. 

MR. EDWARDS: I can even offer some 

comments to that. To control the room temperature to 

a greater extent, the only way that I can think of as 

I've gone through setting up the laboratory is to go 

into environmental chambers, and they have moving air, 

and then that has a negative effect on the length of 

time the dishwasher would run. 

So to tighten the tolerances up any more, 

it would be very difficult and very costly. 

MS. CASTRO: Yes. I'd like to add just 

that one of the reasons that DOE just looked at a five 

degree reduction is test burden for the manufacturers. 

 We also took a look at the IEC standard and looked at 

their high end temperature. 

The warmer it is, the more the machine is 

affected by it. So the upper end of the proposed 

temperature range is comparable to that of the IEC. 

MR. KERESTESY: Let's see. We had Randy 

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and then, Ted, did you or someone behind you? And 

then Charlie. Okay. 

Randy. 

MR. COOPER: This is Randy Cooper, Maytag. 

Natascha, could you clarify, I guess, how 

this 17.6 percent was generated? Was it based on 

mini-machines, broad I guess machine analysis, or how 

that was determined? Because I'm not sure that's 

typical of all machines. 

MS. CASTRO: Yes. This was actually just 

conducted on two machines, and the exact number was 

not critical. It just showed that machines are 

affected by the ambient conditions and that we saw 

reducing the allowable ambient temperature range as 

one means to improve repeatability. 

So this number just shows that the 

machines are affected by the ambient temperature and 

that it can significantly affect the energy 

consumption. 

MR. COOPER: This is Randy again. 

So is that 17.6 then based on one machine 

run at 85 and the other one run at 75 or is that based 

on -- 

MS. CASTRO: No. 

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MR. COOPER: -- one at 85 and then the 

other one at 75? 

MS. CASTRO: It is the same machine run at 

both conditions. 

MR. GRUNEWALD: This is Ernie Grunewald. 

I have a question. 

MR. KERESTESY: Is it a follow-up to this? 

MR. GRUNEWALD: Yes, sir. When you did 

that test, did you have them in the enclosure that 

you're proposing to use, the UL enclosure? 

MS. CASTRO: No, not exactly, no. 

MR. GRUNEWALD: That makes an extremely 

significant difference because the temperature sensing 

of the devices of our machines are external. 

MS. CASTRO: Yes. 

MR. GRUNEWALD: And to Mike's air flow, to 

Randy's question how did you run it, if there is air 

flow there or the ambient affects the thermostats, 

then you get false readings. You know, I will wager a 

cup of coffee from the DOE for the fact that if these 

were done in an enclosure, our experience is you will 

not see that kind of difference. 

MS. CASTRO: It was tested in an 

enclosure. It was not tested under the UL standard. 

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It was tested following installation requirements 

suggested by the manufacturers. So it did have an 

enclosure. It did have sides, but the new proposed 

language for the installation requires that it have 

the tightest possible enclosure, and there was a small 

gap. 

So it was just following the 

manufacturer's installation instructions and not free 

to open air. 

MR. KERESTESY: But was it that would be 

consistent: 

MR. GRUNEWALD: That is consistent with 

our experience. Even a half inch gap all the way 

around -- this is Ernst Grunewald again. 

It is consistent with what Natascha found. 

 Any time you allow air flow to come around the 

machine, especially in the sub area under the door 

line, you can fool the thermostats into reading a 

lower temperature and causing it to be cranked up. 

So I would say my estimate would be with 

the UL enclosure that that difference would not be 

that significant, and that the plus or minus five is 

as tight as we ever want to go because if you're 

looking at a laboratory and there's 700 square feet, 

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other machines running, only in a factory setting, 

there is no way you're going to go less than five, and 

it's going to create from a nightmare of having to 

include an environmental chamber. 

So I'd say five is tight, and you know, 

when you take a look at ISO standards and all of the 

international standards, plus or minus two degrees 

Centigrade, which is just about plus or minus five, 

it's very common. 

Thank you. 

MR. KERESTESY: Randy, okay, and then 

Charlie and, Chris, did you want to? Okay. 

Charlie? 

MR. STEPHENS: Charlie Stephens. 

I still have to wonder how much we're 

going to improve repeatability given the range. I 

mean it sounds like Natascha was testing in an 

enclosure that's currently used by the manufacturers 

even though it may not be exactly what's being 

recommended in these changes, and it still gives a 

fairly hefty range of outcomes. 

I guess I'm not sure how much we're going 

to improve repeatability, I mean, given that you can 

test at either end of that range and get that much of 

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a difference. I mean even if it's a 15 percent or 

even ten percent, that's a fairly big number. 

MR. COOPER: Charlie, this is Randy Cooper 

from Maytag. 

I guess based on our experience, I guess 

we have never seen 17.6 variation on that with the 

units we have from the standpoint of it's a set cycle. 

 The ambient is not going to have that large of an 

impact, and I guess we really question where this 

number came from, and I guess this is the first time 

we have seen this number. 

Like I said, I would like further 

investigation if you feel deeply about it. 

MR. KERESTESY: Bob. Oh, go ahead. 

MR. STEPHENS: Yeah, I mean, like I say 

even if it's not 17 percent, even if it's half of 

that, you're still talking a big number. So I guess 

I'd be concerned about what you see. 

I mean, okay, you don't see 17.6 percent. 

 What do you see over a ten degree range? I mean, 

we've been talking about fooling the thermostat here. 

 So it's obvious that it can happen, and if an air gap 

of half an inch around the machine makes a big 

difference, then I guess I've got to wonder if these 

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machines aren't a little overly sensitive to ambient 

temperature, but eight percent is a big number. 

I mean that's a big number of kilowatt 

hours. That's 50 kilowatt hours on a typical machine. 

MR. KERESTESY: Did you want to break in, 

Bob? 

MR. JUDD: Bob Judd from Whirlpool. 

The discussion has been that we're running 

these in lab settings, and one, we're not smart enough 

to be able to make the room be 70 or 80. We're trying 

to hold it within that plus or minus five degree 

range, and I think we're saying we're agreeing with 

Randy that we're not seeing that kind of variability 

because if we were, we'd have a hard time getting our 

test results to cluster, and I think we don't see that 

kind of a change. 

I don't think it's half, but we haven't 

run it. So to the extent I don't know that we can 

hold a test room to one or two degrees though over 

time. It's going to be what it is,a nd I think plus 

or minus five is about there. 

MR. MORRIS: this is Wayne Morris. 

I've just got a quick question and comment 

in terms of this to Charlie. Understand that it is to 

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the manufacturer's benefit to have that tolerance as 

tight as is humanly possible so that their 

repeatability is extremely good because if it is not 

good, then they have to run quite an additional survey 

of units in order to prove what the mean and standard 

deviation is of the energy values. 

So I mean, if it's really to the benefit 

of the manufacturers to keep the tolerance down and 

also to have that variability as small as is possible, 

that's really what we're trying to do with a lot of 

these changes that we suggested, is to get that 

variability down. It benefits you, and it benefits 

us. 

So I think that, you know, certainly 

anything that I've ever seen in terms of manufacturing 

would never suggest, you know, probably anything more 

than a three or four percent range of temperature over 

that ten degree difference. 

And in fact, it's really not ten degrees 

because in fact, the way it was previously described, 

a manufacturer would normally hold the media value 

somewhere in the 77 degree range and try and keep that 

tolerance narrow so that they could then improve the 

variability. 

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So we're going really from 77 degrees, the 

media point of 70 to 85, to really 75. We're really 

not changing that as much as we're changing and we're 

reducing the tolerance. It's a function of what we 

can actually do in the settings where the units are 

tested, and it's also to try and get the greatest 

reputability that we can because it's to our benefit 

as well as everybody's. 

MR. EDWARDS: Mike Edwards, BSH again. 

I think to Wayne's point, is this not 

captured in -- we have to record the higher of the 

two, the average or the confidence level, and if we 

were able to control the room temperature precisely, I 

think the energy figures would possibly even improve. 

And one other point. In Natascha's study, 

would you not have been subjected to the same thing? 

I mean, your air conditioner or your heat system would 

heat up and cool down, and you're saying that you ran 

at precisely 85 and precisely 75? I think you would 

have probably had some of the same variation in your 

test. 

MS. CASTRO: Yes. It was an environmental 

chamber, but it's a large environmental chamber, and 

the area immediately around the machine would heat up. 

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MR. EDWARDS: Environmental chambers 

circulate air though to maintain the air temperature. 

 So that throws a whole different thing in. You can't 

run with that. 

MS. CASTRO: Right. This is not how -- 

the way I ran the test is not how the manufacturers 

are expected to run the test, and that's why we're 

looking at that ten degree, but we felt that 15 

degrees did allow a large variation. 

MR. EDWARDS: We can't test environmental 

chambers. It doesn't work at all. 

MR. JUDD: My suggestion is if you did run 

that in an environmental chamber -- this is Bob Judd 

at Whirlpool -- that accounts for that big swing, 

Charlie, and not the variability of the dishwasher 

because you're circulating air through that, and it's 

trying to cool down the room that the dishwasher is 

trying to heat up. So you've got a fight going on, 

and I think that that's an absolutely irrelevant test. 

 I think we'd have to go back and check it in a real 

lab setting. 

And we're as sure as we can be we're not 

going to see anything close to 17 percent variation. 

MR. STEPHENS: Are the changes to the 

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enclosure requirements going to make this better or 

worse? 

MR. JUDD: WE believe it makes it very 

much better because it's tight around the dishwasher. 

MR. GRUNEWALD: Might I add? This is 

Ernst Grunewald again. 

We had an audit at one time, outside 

audit, and the numbers were totally off, and obviously 

it's a panic going on. How could that be? Well, when 

you take a look at 430 today, it just says follow 

manufacturer's instructions for the installation, 

which is very loose because the manufacturer will say 

put it under a counter. 

As a matter of fact, it was interpreted as 

just put it under a counter, and there was no 

enclosure, and the results at that time were like ten 

percent difference. So we knew there was something 

wrong. 

Once the enclosure was used, less than one 

percent, and so that is probably the single most 

important proposal that the DOE is making today, the 

value for repeatability and reproducibility lab to 

lab. That is key to us. 

So the answer to your question is, yes, it 

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is a very significant change, and it harmonizes, if 

you will, in CSA's enclosures. 

MR. MORRIS: This is Wayne. 

I'd like to add to that. Not only that, 

but it also seeks to reproduce the actual household 

environment because the unit is not in a household 

just stuck with a countertop on top of it and nothing 

around the sides. In fact, in the household, it does 

have cabinets, usually on both sides of the 

dishwasher, and they are in close proximity just the 

way that this enclosure that is being supported would 

do. 

So it's not an environmental chamber. 

Neither is a household, and so consequently what we're 

trying to do is reproduce the setting as close as 

possible and get repeatability, which we think that 

the plywood situation is valid in terms of its 

approximation of a household environment, and it also 

allows greater reproducibility of the data. 

MR. STEPHENS: Yeah, I took my dishwasher 

out on Sunday, and I really wish I had had some of 

those tolerances we're talking about. 

(Laughter.) 

MR. KERESTESY: Sounds like we've covered 

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this one pretty thoroughly. Anyone want to add any 

final comment on this topic? 

All set, and you were going to kick this 

off. Any loose ends? 

Okay. We are close to on schedule, and we 

have one topic on the agenda before the scheduled 

break. Is definitions a big or little issue to go 

through 

PARTICIPANT: Little. 

MR. KERESTESY: Little? Let's do it and 

then we'll take the break. 

MS. CASTRO: Okay. This third issue is 

the definition of compact versus standard dishwashers. 

 Currently the class distinctions are made using work 

based definitions, and I've made a chart here 

displaying a few cases that show paradoxical labeling. 

In the first model, we have Model A. It's 

an under counter dishwasher, 18 in width, eight place 

setting capacity, and is currently designated as a 

compact. This is kind of a standard for the under 

counter compacts. 

The second is an under sink model. It's 

24 inch width, eight place setting capacity, and it's 

labeled as a standard. 

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And then the third is an under counter 

dishwasher. It's a 24 inch width and six eight place 

setting capacity. That's an estimate, and it's 

currently labeled as a standard. 

So we see that if we're looking at Models 

A and C, in the first case an eight place setting 

capacity dishwasher is labeled as a compact, and in C 

a six place setting is labeled as a standard. 

And we felt that in order to establish 

more meaningful definitions for compact versus 

standard, we needed to look at measures that are more 

useful to consumers when they making purchasing 

decisions, to hold the dishwashers to standards that 

are appropriate for their intended class, and to have 

uniformity in federal definitions for making class 

distinctions. 

AHAM had proposed a capacity based 

definition, which is the determinant used by industry 

and the FTC for labeling. The proposed definition 

that came out of this is the compact dishwasher 

capacity, less than eight place settings plus six 

serving pieces as specified in Section 6 of AHAM 

Standard DW-1, and standard dishwasher capacity equal 

to or greater than eight place settings plus six 

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serving pieces as specified in Section 6 of AHAM 

Standard DW-1. 

And in the chart that you see below, I've 

added a column showing what the proposed class 

designations would be. The Model A that was 

originally a compact with an eight place setting 

capacity would not be designated as a standard. 

The second model, a standard, would remain 

as such because of its eight place setting capacity. 

And the under counter, with an estimated 

six place setting capacity that was previously 

designated as a standard would change to a compact. 

I would just like to add that that model C 

is currently using the FTC definition for labeling and 

would not be affected, would still be able to meet the 

minimum energy standard that is required for compacts, 

which is .62. 

MR. KERESTESY: Thanks, Natascha. 

Any questions? Any issues to discuss? 

Charlie. 

MR. STEPHENS: Charlie Stephens. 

Just one curious question. Why is the 

word "estimated" attached to six at the bottom in 

Model C there? 

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MS. CASTRO: I contacted the manufacturer 

and asked them what the place setting capacity is, and 

they did not have an answer for me, the people that I 

contacted, which I guess is their consumer help or 

sales division. 

I have seen the models, and I spoke to one 

representative, and he confirmed that six was a good 

estimate. It also depends on the loading. If they 

don't have a published definition of what a place 

setting capacity is, then it's just an estimate based 

on how the unit is loaded. 

So that is how I arrived at the six place 

setting capacity. 

MR. JUDD: Yes, sir. 

MR. DuPONT: Ron DuPont. 

It's just a curious question. Was there 

any consideration for more classifications in the case 

of coming dishwashers that may have far more than 

eight place settings? Like is this part of the 

legislation where we're going to have to attack for 

future models? 

Like is two classifications enough or 

should there be more classifications? And it's only a 

curious question. 

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MS. CASTRO: Yeah. I wasn't aware of any 

dishwashers or manufacturers that are looking at 

dishwashers larger than 12 place setting capacity, 

which is what the current standard is. Perhaps some 

of the manufacturers, if they're aware of any, might 

mention it, but for residential, 12 has been found to 

be the upper end, the maximum. 

MR. KERESTESY: Yes, sir. 

MR. MILLS: James Mills, FTC. 

We currently, as you correctly state, 

Natascha, require the place setting criterion in order 

to determine whether a product is going to be labeled 

standard or compact. So in your first example they 

would be labeled in accordance with that, and they 

would be labeled as you come out in your second 

example because place setting is what we use as the 

criterion, and we reference the Department of Energy's 

Part 430, which in turn references AHAM's standard for 

that. 

So we have a standard that the industry is 

required to use to determine whether the product is 

going to be designated for labeling purposes as a 

standard or a compact. 

So I'm kind of wondering also, as Charlie 

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was, what's up with the person who had to estimate it? 

 Somewhere in there they've got to make that 

determination for labeling purposes, and I would think 

that based on the size, they could probably get more 

place settings in accordance with the AHAM standard 

than six in there. 

I don't know that any better than you do, 

even less because I didn't talk to them, but I just 

want to point out that where you're heading is where 

we are, and we have AHAM standard that's referenced 

through your reference of it, and we should be in 

perfect harmony. 

MR. KERESTESY: Well, on that note, having 

come full circles to the last standard, why don't we 

take a 15 minute break and we'll come back and pick up 

the next topic? 

(Whereupon, the foregoing matter went off 

the record at 10:26 a.m. and went back on 

the record at 10:49 a.m.) 

MR. KERESTESY: We are passing out some 

papers from the last session. Copies of the data that 

Natascha referred to. 

We've got a few empty seats here, which 

I'd like to invite people to come up and take. Anyone 

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who is sitting back there can come up to the table, 

and just put your name and affiliation on the table 

tent so I can see who you are and others can. 

And one other very, very important piece 

of housekeeping information. If anyone came in with 

equipment like laptops, in particular -- your mic is 

breaking up? Is that any better? I'll lower it and 

see if that helps. 

We have a very important housekeeping 

matter to bring to your attention. Is that better? 

Losing power? 

If any of you came in with laptops, please 

be sure to see Brenda Edwards-Jones in the back and 

get a property pass. Naturally the guards are going 

to be not concerned about what you bring in with 

laptops, but if you leave with a laptop, they don't 

know it's yours, and if you're running out and you've 

got to catch a plane, you don't want to have to be 

delayed at the door for half an hour while someone 

sorts out whose laptop this is. 

So get a property pass from Brenda, fill 

it out, and she'll help you take care of that, and 

then you won't have any trouble getting past the 

guards, and I assume it probably just has mostly to do 

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with laptops. 

Okay. I would like to follow the same 

procedure we've been following. I asked a couple of 

you at break, and I got some feedback that the 

discussion seems like it's working well. So let's do 

this. Let's have Natascha present a couple of slides 

on what the proposal is about. 

We have written comments that Barbara will 

summarize on this one, and then I want to list the 

issues. We have some guests who want to make a 

presentation. We'll do that, and then we'll have the 

discussion. 

And anyone who wants to come up here, 

please come on up and join us at the table. 

MS. CASTRO: Okay. On the fourth issue, 

soil sensing technology, I think everyone here is 

aware that there are the soil sensing dishwashers that 

default to shortened cycles in the absence of soils, 

and therefore, it can't be tested adequately with the 

current DOE test procedure. 

Also, in addition, there are manufacturers 

that are labeling their dishwashers with lower energy 

factors than their test results measure because they 

realize that it's not representative of consumers' 

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use. 

Initially when we were looking at various 

testing options, we discussed performance tests, field 

studies, and control override sequence. Much of this 

discussion was held with various stakeholders, and we 

found that performance tests were the most realistic 

when combined with the energy test. That's in the 

manner that the IEC is testing. 

In that case, defining a normal soil load 

would be difficult, and it would also have 

repeatability issues. There's also a high test 

burden. These are difficult tests to conduct, and the 

machines could then no longer be sold as new once the 

soils had been introduced. 

The second testing option we looked at was 

connected field studies to get real world data 

regarding the typical cycle times. We're aware of 

some of the manufacturers that already collect such 

data for smaller regions of the United States, but 

it's difficult to establish a sample population. 

And then the third testing option that we 

looked at was one proposed by AHAM, which was to use a 

control override sequence provided by the 

manufacturers to simulate normal operation, and once 

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the appropriate cycle is determined, it is highly 

repeatable. 

From the AHAM proposal, the manufacturers 

would then test with the current DOE test procedure 

and conduct first the test in the normal cycle labeled 

as Emin, and again in their truncated normal cycle, 

Emin for truncated. 

The dishwasher would then be forced to 

undergo a maximum set to normal response, once again 

tested under both normal and truncated normal 

conditions, and that would give us Emax. 

The total energy for the machine would 

then be a combination of Emin and Emax, where each is 

prorated by the fraction of persons pretreating the 

loads. 

DOE took this suggestion into 

consideration and made some modifications. First, to 

add a class stating that if a maximum sensor response 

cannot be forced, then the manufacturers would have to 

introduce soils according to the AHAM DW-1, and that 

would be to obtain the maximum energy consumption. 

The equation also had to be applied to 

water and energy consumption separately, and then 

finally we evaluated the recommendation to use 

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pretreatment values based on the Soap and Detergent 

Association data. 

MR. KERESTESY: Okay. Thank you, 

Natascha. 

Barbara, do you have a set of comments or 

one comment to summarize, a comment from one commenter 

to summarize? 

MS. TWIGG: We only received one comment 

for this workshop, and it came in very much at the end 

of the day last night from the National Resources 

Defense Council, and it really speaks more as we're 

going to get into the percentages of prerinsing than 

to this technique. So I think I'll hold that comment. 

MR. KERESTESY: Okay, okay. All right. 

At this point let me get issues listed again, and then 

we're going to have a little bit more information to 

provide for the discussion. 

So headline some issues for me, please. 

Just go ahead and toss them out, and I'll write them 

down 

MR. MORRIS: Lou, we have kind of a 

presentation to make about this. So at some point 

whenever it's appropriate, we would like to do that. 

MR. KERESTESY: I'll get these issues 

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listed, and then we'll do that. 

Ed. 

MR. POLLOCK: I know we separated these 

two as the technique or method that we'd use and then 

the issue of what the percentages would be that would 

be used in this equation. It may be right now I'd 

just point out is there anyone here who has comments 

or issues with this particular approach to be used in 

the determination of the conservation and energy 

efficient models this way. If not, then we can move 

on to the real meat of the discussion, which is what 

numbers do we put in this equation. 

MR. KERESTESY: Charlie and then Wayne. 

MR. STEPHENS: Yeah, Charlie Stephens. 

I guess I have a very fundamental question 

which is, you know, why are we proposing to change the 

current test procedure at all. What's wrong now that 

this will fix? 

MR. KERESTESY: What's wrong now that this 

will fix? Thank you. 

Wayne, did you want to respond to that? 

MR. MORRIS: To answer Ed's question -- 

this is Wayne Morris -- yes, we have comments on both 

the technique and -- 

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MR. KERESTESY: So we want to cover that. 

MR. POLLOCK: Are both of them covered in 

your presentation? 

MR. MORRIS: Yes. 

MR. KERESTESY: Okay, okay. Which means 

we'll open this up a little bit. If anyone has issues 

related to both topics, I will list them now. We'll 

go over them in this section. 

MR. JUDD: And I think we have, as Wayne 

suggested -- this is Bob Judd -- we do have comments 

on the methodology and on the ratio, and we have an 

additional alternate procedure that we want to 

propose. 

MR. KERESTESY: Okay. 

MR. JUDD: So to the extent that's an 

additional topic. 

MR. KERESTESY: Go ahead. 

MR. POLLOCK: Is it then sort of the sense 

of the group that we should combine these two issues 

and move forward with these presentations at this 

time? 

MR. KERESTESY: That's what I'm hearing. 

Okay. A lot of nodding heads. 

I've been informed that once you've said 

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your name, you don't have to repeat it. They'll know 

who you are, and they'll be able to put your name with 

the comments subsequently. So except for people who 

haven't spoke up yet, use your name when you speak, 

and then we're okay after that. 

So let's open this up then to just some 

issues that are related to both these subjects. We're 

going to combine them for the purposes of the 

discussion. What we're on now that this proposal will 

fix is the only one I have up here. Just give me some 

topics, headings. 

MR. STEPHENS: Yeah, I think I'm a little 

confused about where we are here. 

MR. KERESTESY: Okay, okay. 

MR. STEPHENS: This is one big issue, I 

think, overall, but I guess I do have one more thing I 

could throw in. I don't know if it fits here or not, 

but I'm trying to figure out whether we know -- who 

knows how these machines respond to soil, given that 

it's my understanding there's quite a number of 

different ways that these machines work? You know, 

some of them take a truncated cycle and then lengthen 

it. Other ones take a full cycle and shorten it. 

There's different ways to sense whether the dishes are 

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dirty or not. 

I know Fisher and Pikel (phonetic), for 

instance, has one type of system and other people in 

this room have others. 

So given that there's so many different 

technologies out there that aim to shorten the cycle 

and truncate the energy and water use, I guess I'd 

like to know who knows anything about how these 

machines respond to dirty dishes. 

MR. KERESTESY: Okay. 

MR. STEPHENS: Regardless of how dearth 

they are, you know. 

MR. KERESTESY: Good. Thank you. 

MR. STEPHENS: Has anybody measured that? 

MR. KERESTESY: I've got that. 

Did you want to? 

MS. CASTRO: I'd like to present the data 

that I have at this point and then perhaps if 

manufacturers or various organizations have additional 

data to present we could just use that as a starting 

point. 

MS. EGAN: One last question, if I could. 

 Do you want me to give a specific question to what's 

been presented so far now or wait until we've 

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presented the rest? 

MR. KERESTESY: Say again? 

MS. EGAN: Do you want me to give a 

specific -- I have a question on what was presented so 

far, and I'm saying do you want me to wait until she's 

all done or do you want me to give it now. I'm just a 

little confused as to how we're -- 

MR. KERESTESY: Okay. 

MS. EGAN: I can do it all at once at the 

end if that's -- 

MS. TWIGG: Why don't we let Natascha 

finish her presentation. 

MS. EGAN: Okay. 

MS. TWIGG: And then we'll package it all 

together with the percentages. 

MR. KERESTESY: Okay. 

MS. CASTRO: Okay. The first point is 

just the fact that pretreated dishes with low soil 

levels have been found to trigger minimum normal 

responses from sensor models for shortened cycles. 

The data that we have from the STA was based on 1995 

data and stated that 79 percent of the population 

pretreats their dishes, and that was defined as using 

water to rinse, scrub, or soap the dishes, and 21 

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percent of those surveyed did nothing or merely 

scraped their dishes. 

These results came with a caution that 

they're based on consumer perception and 

interpretation, not an objective test measure of loads 

washed and have the associated inherent uncertainties 

of consumer questionnaires. 

This data could give na indication of the 

use and patterns of use, but should probably not be 

used in an energy standard setting framework, and that 

was an excerpt from the SDA letter to AHAM in July of 

'98. 

We looked for additional data to find 

information on consumer practices, and one additional 

survey showed that in 1989, the survey population 

showed 73 percent pretreating and 27 percent not 

pretreating loads. 

We also have the Oregon Energy Office CEE 

alliance dishwasher survey, which was fielded in the 

Pacific Northwest. This survey was used to provide 

detailed data on consumer dishwasher practices, but 

it's not nationally conclusive, and the results of 

that survey can be interpreted as either 83 percent 

pretreated or 63 percent pretreated. 

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And additionally manufacturers' consumer 

research data. There is some data that has been 

collected by manufacturers to show the cycle response 

for various levels of pretreatment, combined with 

pretreatment practices, and that data is not 

available, but manufacturers are conducting their own 

consumer research. 

Pending better data DOE was initially 

proposing a 70 percent pretreatment percentage and 30 

percent non-pretreatment as a compromise value based 

on the available qualitative data. 

Okay, and this final chart just shows for 

various percentages of pretreatment what the effect is 

on the energy factor. All models for standard 

dishwashers have to require -- have to meet the 

minimum energy standard of .46 cycles per kilowatt 

hour, and here along the top P represents the 

percentage of pretreated dishes, and one minus P is 

the percentage of non-pretreated dishes. 

So in this first column the 8020 was 

originally proposed by AHAM. The Models A, B, C, D, 

E, and F are all soil sensing models. Data presented 

by AHAM for various different models. 

The 7921 represents the 1995 data 

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presented by SDA. 

Seventy-three, twenty-six is the average 

for the Oregon energy data. 

Seventy, thirty was the proposed 

compromise value. Here you begin to see that some of 

the soil sensing dishwashers begin to become 

borderline or do not meet the minimum energy standard 

as the percentage of pretreated dishes decreases. 

Sixty-three, thirty-seven is the lower end 

of the Oregon survey data. 

And 6040 was one of the initial proposals 

by environmentalist group. 

So I think I'd just like to leave this up 

while we begin the discussion on various methods. 

MR. KERESTESY: Thank you, Natascha. 

Christine, do you want to put your issue, 

raise your question or issue now? 

MS. EGAN: Yes. On what was presented 

originally, I guess I'd like to just hear a little bit 

more about the difficulties of establishing 

representative sample. 

MR. KERESTESY: Okay. 

MS. EGAN: And why, and I'll leave that 

for now and wait until we get into these percentages 

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discussions. 

MR. KERESTESY: Thank you. 

Well, why don't we have -- do you want to 

start? 

PARTICIPANT: Do you want to address 

Christine's question? 

MR. KERESTESY: Will it come out in the 

discussion? 

MS. EGAN: I'm sorry? 

MR. KERESTESY: No, it won't come out in 

the discussion? Do you want to -- 

MS. EGAN: It's probably the easiest point 

to tackle it if you want to start with it. 

MR. KERESTESY: Who could speak to that? 

Thanks, Wayne. 

Who could speak to that? The question is 

will someone explain the difficulties establishing 

representative samples. 

MS. EGAN: With real world field tests, I 

guess. 

MR. KERESTESY: Who could speak to that? 

MS. CASTRO: I'll just state that from the 

field tests that were available, manufacturers -- it 

was my understanding that they just tested a small 

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population perhaps close to their research base and 

did not do national surveys. 

All the SDA data did not study the typical 

cycle time. So it seemed that it was not an issue 

that was covered by the detergent manufacturers or any 

other organization at this point. So the surveys were 

not available. 

WE had discussed the possibility of using 

I believe it was Good Housekeeping to introduce some 

questions into that survey, but we began by looking at 

various control override options. That seemed to be 

initially the best route. 

MS. EGAN: Okay. 

MR. KERESTESY: Can any of the 

manufacturers -- Wayne. 

MR. MORRIS: This is Wayne Morris with 

AHAM. 

This is a very difficult thing to answer. 

 I think in terms of can you go out and get a survey 

of how many people pretreat, the answer is of course 

you can. It's a matter of time and money, and 

certainly that's something that the department has 

more of than we do, and we applaud them on their 

efforts to gather lots of data on rulemakings and 

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other things. 

But in any case, the biggest challenge 

that you are faced with in terms of doing that is the 

definition of what is meant by pretreatment. To one 

household, I pretreat my dishes and they're, quote, 

somewhat clean is a big difference between another 

household. 

And until, I guess, you were doing this 

with "knock on the door and show them" pictures of 

dishes at different levels of cleanliness and then ask 

them how many, or to put some kind of I guess it would 

either be filter on the drain of the dishwasher and 

capture the load of material that comes off every 

cycle, I'm not sure how you can ever know what one 

person calls somewhat clean or somewhat dirty and 

another person does. 

And so even if you can get the value of 

how many people pretreat and you do as Oregon tried to 

do in breaking it down into different categories, 

there's no assurance that, in fact, the level that one 

person judges is the same. 

The other compounding difficulty is that 

not the same person in a household loads every dish, 

nor do they treat it the same way in the household, 

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nor do they do the same from one load to the next 

necessarily, although trends are probably the case, 

that they would stay with the same attitude toward 

their dishwasher. 

It is a very complex issue, and when we 

tried to break it down in our proposal to a simpler 

way of looking at it, and we've even found great 

difficulties with the methodology that we have 

suggested originally, and that's what we'll talk about 

in a little while. 

I don't know if that helps, but if helps 

to put parameters around what the difficulties are is 

what I was trying to do. 

MS. EGAN: I think the question is then 

the definition of real world data is actually not what 

I had understood it to be. In other words, real world 

data, I think you'll get agreement around the table 

that consumer behavior surveys have their flaws, and 

I'm sure we'll go into detail about that. 

So real world data on typical cycle times 

was not meant to indicate what actually is happening 

in dishwashers. It wasn't a metering, for example. 

MS. CASTRO: Metering was actually what I 

had initially -- what I thought would be the best way 

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to collect the data, to actually have field studies 

measuring what the cycle times were. So it wouldn't 

actually involve what the soil loads were. It would 

just measure how long were these dishwashers running 

and how often. 

MS. EGAN: And so what I've heard so far 

is that that data is not available, but I'm still 

questioning what is the aspect of difficulty in 

gathering a national sample of that data. I 

understand that it's not available, but I'm 

questioning the level of difficulty. Why is that 

difficult? 

MS. CASTRO: Instrumenting all of the 

various dishwashers and knowing which ones to 

instrument. 

MR. MORRIS: If I could, Christine, again 

answer this by saying not all of the technologies -- 

Charlie even mentioned this -- not all of the 

technologies are the same, and so metering doesn't 

give you anything unless you were to meter every 

aspect of that dishwasher. 

You would have to meter the times of all 

of the different parts of the cycles, the application 

of heat, the amount of water, and when the water is 

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applied because that's a big issue, the aspect of the 

drain and the cleaning of the filter and all of that 

situation, and you would have to know essentially I 

guess you would say the cycle opportunities that are 

available to that particular style or class of 

technology. 

If every one of these dishwashers by every 

manufacturer operated the exact same way, in other 

words, that when it triggers some response off of 

absolutely clear dishes that it did it by the number 

of fills or they all did it by the length of fills or 

they all did it by the -- that would be great. 

Unfortunately they're not, and that's just the nature 

of creativity in the engineering world to come up with 

lots of different ways of skinning this cat. 

MR. KERESTESY: Charlie. 

MR. STEPHENS: Yeah. I would add to this 

that I didn't find the dish problem to be as big an 

issue as how dishwashers respond to the dishes. When 

we sat out to go after some of this data ourselves, we 

were of the impression that we didn't have time to do 

Phase 2. 

Phase 2 was to go out and sub-meter the 

water and energy consumption of the dishwashers in 

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those households so that you could correlate water and 

energy consumption with what people said they did to 

their dishes. 

I mean, I ultimately don't necessarily 

care what they do to their dishes as long as I can 

correlate energy and water use to what they did to 

their dishes and what they said they did to their 

dishes, even if it's not particular accurate. 

If all we're going to know in the future 

is how people treated their dishes or pretreated their 

dishes based on some survey results, then I'd like to 

know how the dishwashers respond, and so far I've yet 

to see any data as to how the various technologies 

respond to identical loads of dishes, assuming you 

could create such a thing, and you can't. 

But the fact is it is possible to go out 

and sub-meter water consumption of a dishwasher at the 

street for three months. It's possible to go out and 

sub-meter the energy consumption of the things and 

correlate these things, but to my knowledge, no one 

has done that on a national basis or on a 

representative sample basis, and I'm at a loss as to 

how you can even begin to recommend changes for 

credits for the extremes of the operation of these 

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things without that kind of data in hand. 

I would suggest that if the problem -- my 

first question about, you know, what problem is it 

we're trying to solve here. Maybe I'm wrong, but I'm 

presuming that people don't feel that the current test 

procedure accurately reflects what this dishwasher 

will use in the field. 

Well, I would suggest that in the absence 

of any data on how these machines respond to any given 

level of dirtiness on the dishes, you still don't know 

what these dishwashers use in the field when you're 

finished, and so I guess I'm having trouble finding 

any rationale for changing something that isn't going 

to improve what we know. 

You know, if we don't know what 

dishwashers in the sensor type use to begin with, then 

we don't know any more when we're finished. 

MR. KERESTESY: I'm glad we started with 

the easy part. 

(Laughter.) 

MR. KERESTESY: Well, you posed a 

question, and we have some explanation by way of an 

answer, and back to the point that you just finished 

with, Charlie. 

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MR. JUDD: My comment at this point would 

be, I think, some of what we're going to talk about 

will either help or carry on that discussion and 

rather than try to bring that to a resolution at this 

point, I would suggest that we probably go through the 

stuff, and we'll have more information on which to 

have a further discussion. 

MR. KERESTESY: Are you all set? 

MS. TWIGG: Yeah. 

MR. KERESTESY: I mean there's many entry 

points into this one. Do you want to start? 

MS. TWIGG: I think it would be the 

appropriate time for me to just summarize the one 

comment that we did get which fits in with what 

Christine and Charlie are saying from the National 

Resources Defense Council. 

Basically they're supporting what the 

Oregon Office of Energy has previously submitted to 

the department, and sometimes they phrase it a little 

differently, and they, too, feel like why are we 

rushing into changing things when we don't have the 

data to kind of support these changes. It's better to 

offer too little credit for this new feature than too 

much, and they raise the question of what's going to 

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happen to things like the Energy Star Program if 

they're counting on energy savings through them, and 

they're not really sure they're going to get it. They 

don't want to undercut the credibility with consumers 

if they're basing things on energy savings that aren't 

really accurate here. 

And they promote actually the most 

conservative formula, percentages to put in the 

formula of any. They said they would just give them 

credit for one-third of the time going to the shortest 

cycle and essentially reverse what we have. Instead 

of 70-30, they'd go like 30-70. 

MR. KERESTESY: Thanks for reminding me 

that you had the comments, the submission to 

summarize. 

We have a presentation to make which I 

think will add additional information to these items 

and context for discussion. Do you want to start 

that? 

MR. MORRIS: Sure. 

MR. KERESTESY: Is it the overhead that 

you showed me? Oh, you have slides. Okay, okay. I 

wasn't sure which. 

MR. MORRIS: We'd just like to present a 

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little bit of information as background in terms of 

this and to support some of the information that we've 

already sort of opened the discussions of. 

I want to begin by at least saying that 

I'm not necessarily trying to present an absolute 

uniform AHAM opinion about all of this, but rather to 

try and set the context in regard to some of the 

discussion and to hopefully try and arrive at, if we 

can perhaps at least, some uniformity or some 

agreement on some things. 

Our assumptions on this may be somewhat 

different than NRDC's, but nevertheless that's not 

unique. We all agree that the objective is to 

encourage energy efficiency. I hope that that is a 

common assumption. At least it certainly is from our 

standpoint, and we would hope that it is from others 

as well. 

We want to discourage sink washing or 

prewashing as much as possible. That's really one of 

the main reasons that AHAM presented this opportunity 

to begin with, was that we want to try and encourage 

people to understand that for the most part 

dishwashers, especially dishwashers that are produced 

in the latter years, today, and indeed in many of the 

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more full featured types of models do not need to have 

prerinsing, prewashing. 

And manufacturers have tried at various 

times with advertising campaigns to encourage this, 

and I will tell you it's a slow, slow learning 

process. However, with the advent of soil sensor 

machines, we are starting to at least see gradually 

that consumers, indeed, begin to understand that 

situation. 

The difficulty comes with some of the 

other things. We want to test a sensor based machine 

in a realistic manner. I think that's a common 

assumption as well. We want to try and do it the way 

that it is actually being used in the household. 

And we want a test procedure which is 

reproducible because the lack of that doesn't do any 

of us any good. 

We believe that the Northwest Energy 

Alliance data, along with CEE, has data supporting the 

fact that more consumers prewash dishes than 

previously believed, and we believe that manufacturers 

have additional data to show that an adaptive response 

is evoked less often than previously understood and 

assumed. 

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Let me explain something here because I 

think that there's a great misconception out there 

about the censor based machines. 

The misconception is that dishwashers have 

sort of an absolute lowest response to clean dishes 

and that then they incrementally at very small 

increments then move that power and usage of water or 

heat or time or whatever upward according to that, and 

that just isn't the case. 

Sensor based dishwashers have got to do 

one thing absolutely from the very beginning on every 

dish that they encounter. They've got to get it 

clean. The purpose of having the dishwasher for the 

manufacturers is to clean dishes, not to satisfy 

energy. It's great that we can encourage energy 

usage, and it's great that we can label energy, and we 

hope that we can encourage more people to be energy 

efficient, but that's not the reason the manufacturers 

do this. It's to clean the dishes. 

And, therefore, in a baked on setting or 

in a setting where there are light soils that are 

applied very difficultly to the dishwasher, even 

though the dishwasher may see that as being a light 

amount of soil, it's got to clean that, and it's got 

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to clean that because it's got to use the proper 

amount of energy, the proper amount of water, the 

proper amount of heat, and the proper length of cycle 

in order to do that. 

And so it isn't some incremental 

situation. It is usually a massive jump from zero 

dirt, if you want to think of it that way, absolute 

clean dishes, to the very first response is a large 

response by the dishwasher, to get all of those dishes 

very clean. 

And so that's why we believe that looking 

at this in terms of a ratio is a way to look at it in 

a more fair manner. Now, this, I hope, is an adequate 

representation of what we saw in the chart that came 

from the Northwest Energy Alliance data. That is a 

representation of what all of the different types of 

soil levels are, from very clean all the way up to 

very dirty. 

And we focus actually on this last row 

because, in fact, those are the ones that trigger the 

largest response by the dishwasher, the very dirty, 

and in terms of that, we'd certainly love to know what 

a consumer sees as very dirty, but in fact, if we -- 

and I know everybody can read this a different way -- 

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but we've got to look at this as being that the first 

three rows of this combined really tell us what 

consumers are doing to do some pretreatment of that 

dish to go into the dishwasher, and that essentially 

this last one is probably where they are doing 

virtually no pretreatment of dishes, which then looks 

at what is that formula that we can look at. 

We've looked at this situation and believe 

that the department's suggestion of a 70-30 

dramatically overstates the maximum response of soil 

sensing dishwashers in a household environment. 

Certain technologies are severely punished by this 

ratio, and if such a ratio were used, we believe that 

the energy standard level of .46 must be reduced and 

the standard opened for notice and comment. 

This is a dramatic departure from where we 

are today, and while I understand some of the data 

that Natascha presented in terms of how dishwashers 

respond to the testing, I would say in large part we 

don't agree with the data that was presented and don't 

find that it represents how it was tested in an actual 

manufacturer's environment. 

The other side of that is that it does not 

take into account some other technologies which have 

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recently been added to the marketplace. 

The other thing about the data that 

Natascha presented in the chart form is that there are 

several of those data points that are dangerously 

close to the .46. We would consider that probably 

.47, .48 are in areas that have got to be repeatable 

data and have got to be taken into account with this. 

We believe that the assumption that's put 

into the NOPR that because most soil sensing models 

appear to be fully compliant rather than marginally 

compliant, they don't expect a significant number of 

machines to fail; we're unfortunately in disagreement 

with that. We think that there are quite a number of 

dishwashers that may not make that situation. 

There are some technologies that under 70-

30 will be well above the .46. It is design 

restrictive of certain types of technologies. Testing 

with soil loads is extremely expensive and results in 

unsalable machines, and without knowing the exact 

ratio of consumers, this is all based on an estimate 

situation. 

But we do think that it has to come to a 

realistic numbering system. 

We believe that one of the alternatives is 

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to use a 95-5 ratio of those who pretreat dishes to 

those who do no pretreatment, and we think that's 

borne out by the data from the Northwest Energy 

Alliance. 

We believe that any option below that does 

present some difficulties with the definition of 

"maximum" in terms of maximum response. It penalizes 

certain technologies and introduces additional 

variables, and it necessitates lengthy alternatives in 

testing and, indeed, would probably cause the standard 

to need to be opened up for further review. 

So, again, we're not trying here 

necessarily to look at this in terms of where all of 

the data exists, but rather, we wanted to try and 

frame this out and help you to understand that based 

on newer information, this ratio that was presented of 

70-30 is absolutely not supportable. 

Thank you. 

MR. KERESTESY: Why don't we get some 

questions for -- go ahead and get back by the mic -- 

and get some questions for you on this, on these 

slides. 

MS. EGAN: An easy one. Can I get a copy 

of the presentation to bring back to the ranch? 

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MR. MORRIS: Sure. 

MR. KERESTESY: Charlie. 

MR. STEPHENS: Yeah. I have a little 

question there. Wayne seemed to have diverged there 

in his presentation. In the early part of the 

presentation he said something about the primary, you 

know, purpose of the dishwasher is to get the dishes 

clean, and these things are going to have sort of a 

stairstepped kind of response to any dirt that -- I 

use the term "dirt" loosely obviously -- that's 

present in whatever technology sensors are being used, 

whether it be a differential pressure or turbidity or 

whatever. 

And yet he seems to want to dwell on the 

very dirty untreated portion of the data that we 

gathered. 

I just wanted to point out two other 

things. We gathered from the data that at least two 

levels of the pretreatment or no pretreatment in our 

data would probably come into play in affecting the 

way a sensor machine operated, if not three. 

And I also want to point out that there 

was a fairly dramatic and consistent difference in the 

amount of pretreatment that people with sensor 

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equipped machines did compared to people without 

sensor machines. For some reason the people with 

sensor equipped machines -- and I don't know the 

reason for this -- didn't pretreat their dishes nearly 

as much as the people who had non-sensor machines. 

Maybe they knew they had the sensor machines or they 

put some faith in it that they didn't in the other 

models. I don't know. 

But the point is I don't understand the 

justification for dwelling on only the completely 

untreated dishes a triggering a full cycle response 

from these machines in the manner that a 95-5 ratio 

would imply. We don't believe that our data should be 

interpreted that way. 

But I would still maintain that there's a 

huge gap between knowing how people pretreat their 

dishes and knowing how the machines respond to that, 

and I have yet to see any data on that yet. 

I would like to do that. I would like 

somebody to do it. Maybe we'll have to do it again, 

but somebody needs to document that before I would see 

any rationale for changing this. 

MR. KERESTESY: Any response? 

MR. MORRIS: Well, there are a couple of 

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points that you raised, Charlie, that I think I'm not 

sure I can give you that information only because I 

think that a lot of that information is proprietary to 

individual technologies and manufacturers, and I 

certainly wouldn't be one to ask the manufacturers to 

divulge that information in a public setting that, 

after all, is exactly what they have. 

I would also like to remind both the 

department and others that the purpose of having this, 

I believe, is to present a consumer at the time of 

purchase of a dishwasher with what their expected 

energy outcome is going to be. So whether or not 

after they've become familiar with the dishwasher they 

pretreat less is irrelevant. It has to do more with 

what their behavior is the day that they buy the 

dishwasher because that is, indeed, what they're 

looking at when they compare Model A with Model B on 

the showroom floor. They're looking at that energy 

guide label, and we're trying to give them the basis 

of comparison of the information at the time that they 

purchased that dishwasher. 

And the best way to do that is really to 

look at an overall history of people's response to 

pretreatment, not with people who are entirely very 

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sensitized to this. 

The Oregon study is a very interesting 

study, and I think it bears out some very interesting 

information, but after all, it is take of only people 

who have not only purchased an energy efficient model, 

but also have applied for a tax credit. So they're 

already sensitized highly. 

Then they're being telephoned and asked 

about their habits of energy efficiency and the way 

they pretreat dishes. 

I mean, essentially almost the minute you 

do that, you're dealing with a subset of the 

population. I mean, you can't get away from that. 

That's going to happen almost any time you do that, 

but it isn't, and I don't think it was meant to be, a 

national survey of what the habits of people are. 

So we think that even if it looks at and 

says that five percent of people do nothing to the 

pretreatment, that's of those people who have very 

highly energy efficient, opt of the line, extremely 

well performing dishwashers, whereas the general 

population don't have those dishwashers and may, in 

fact, have to pretreat significantly more. 

So we think that that data bears out 

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exactly what we're suggesting, is that for the 

population at large, the population probably is 

significantly greater than 80 percent, and we're 

suggesting it's probably closer to 95 percent do some 

type of pretreatment of their dishes. 

MR. STEPHENS: Charlie Stephens again. 

That still doesn't tell me what their 

dishwashers do. I mean, you know, even if I could 

correlate their pretreatment or discover somehow what 

level of pretreatment results in a truncated response, 

let's say, by a sensor equipped dishwasher, I still 

don't know what the results of that are. 

I understand the proprietary nature of the 

data, Wayne, but that doesn't help me. I need to see 

some data that gives me some faith not only that these 

dishwashers respond in an energy and water saving way 

at some level of pretreatment, but also that every 

machine or every technology deserves some similar 

level of credit. 

I have lots more questions that actually 

go into this, too. I don't know how reliable this 

technology is. 

MR. KERESTESY: Charlie, before you go 

there, Tom had also put your hand up on the last 

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point. Let's see if he's got a comment or question on 

the subject that we're on before we move off of it. 

MR. JOHNSON: Okay. Tom Johnson from 

Maytag. 

And it goes back a little bit to the first 

statement that you had made in regard to why change 

the standard as opposed to leaving it where it is 

right now, and I guess just a comment on that. 

You know, when we're designing the 

dishwasher, as Wayne said, it's to satisfy our 

customers to have clean dishes when everything is 

done. However, to do that, we design a very robust 

cycle that will really clean a lot of soil, and that's 

to make sure that everybody is going to be happy with 

the performance of their dishwasher. 

But what we know is most people do prewash 

their dishes. They don't have that amount of food 

soil in their dishwasher, and another thing we know is 

most people choose a normal cycle no matter what the 

dishes are like that go in there. 

And so what's happening is the people who 

prewash are really consuming more energy than what 

would be necessary to clean that load. With the 

adaptive control what we can do is sense that and 

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cause the cycle to be truncated so that it uses less 

energy to adapt for that. 

However, due to the current standard and 

the way you can label, what would happen is that we 

could label our product to show, you know, it being 

very energy efficient. However, for those folks who 

don't pretreat, they wouldn't achieve that level. 

So what we feel is, you know, as a 

manufacturer, if we put that very energy efficient 

label on there, it shouldn't be completely 

representative of the full population. So what we've 

actually doing, you know, we have chosen to change the 

rating from what we could actually get from the DOE 

standard to try to make it more reflect what we think 

that the general population would see in energy use. 

And we have done some testing. You know, 

it was not national based. It was just in order to 

determine what we thought would be the right 

performance level for the dishwasher, and we've come 

up with a ratio that we apply, and that's how we put 

out energy label on there. 

So this what we're talking about now would 

help put the energy standard, the testing method more 

in alignment with what consumers would truly see. By 

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not doing this, the energy label would, in a sense, 

understate what the true energy use would be. 

Therefore, that's the reason for proposing changes at 

this time. 

MR. KERESTESY: Thank you, Tom. 

Are there any other -- do you want to? 

MR. STEPHENS: I mean, I understand the 

rationale, but again, I still keep coming back to the 

same thing. No one has showed me any data that gives 

me any faith whatsoever. 

I mean, bear in mind in the background 

here this is not -- I don't put a lot of faith in 

consumer reports. I mean, you know, they have their 

problems, but the fact is that's the only reporting 

I've seen that's been written up in any systematic 

way, and they weren't very encouraging about the level 

of performance of sensor equipped dishwashers in 

trying to truncate the dishwashing cycle and saving 

energy and water. 

I mean, I remember distinctly that one 

model they tested took two full complete cycles with 

absolutely clear dishes before it finally recognized 

that the dishes were clean and cut back. This is 

after a dirty load. 

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And, you know, you read about those thing 

and you say, "Wait a minute here, you know. Maybe 

something's wrong with the machine. Maybe this 

technology works peculiarly compared to others, but 

it's not consistent with what I expected these 

machines to do based on what people are telling me." 

I still can't connect dirty dishes -- pick 

any level of dirt. I don't even care what level of 

dirt you pick in the survey data. Pick any one and 

tell me what the machine will do. Tell me how much 

energy and water it'll use because in the long run 

that's what's going to give you your accurate 

reflection. 

I mean, I don't know how reliable these 

technologies are, what happens when they break. I 

mean if the thing stops functioning, does the consumer 

know it? Do they think that they now have to fix the 

machine? If the thing is still washing the dishes 

pretty well and it costs $150 to fix it, will they fix 

it? 

You know, what's it doing? I think that 

if the machine is like some where it starts with a 

short cycle and adds if the dishes continue to come 

out dirty, well, and then it breaks and it just does a 

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short cycle, I figure the consumers may eventually 

discover that the dishes aren't getting quite as clean 

as they should, and maybe something is wrong. 

But what about the machine that starts 

with a full cycle and cuts back and it just defaults 

to the full cycle when it breaks? Will the consumer 

know it's broken? Will the consumer fix it? 

I mean, there's an awful lot of credit 

that we're being throw at these machines, and I'm not 

sure. Until I see data, I'm not sure that any credit 

at all is all that warranted. 

MR. KERESTESY: Bob. 

MR. JUDD: I think we might answer some of 

that, but we may raise as many questions as we answer, 

but let's take a run through it. 

MR. KERESTESY: Are there slide or the -- 

okay. 

MR. JUDD: Can you see that from the back? 

 Actually that's probably not going to be clear back 

there. 

We'd like to run through kind of picking 

up where Wayne and the comments left off. We do 

support the 95-5 ratio of pretreatment to no 

pretreatment, as Wayne suggested. 

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The rationale for that basically goes 

along the line that we like the idea of a fixed ratio. 

 It's a simple test to run the numbers. That's 

laudable. We think using both minimum and maximum 

energy consumption for the product does capture 

additional energy use for soil sensing dishwashers, 

and that's laudable. 

We think the 95-5 ratio is reasonable 

based on Whirlpool field test data. That's not a full 

answer, Charlie, to your question, but we have a 

sample of dishwashers in two locations. One's a 

factory location, and one is in Benton Harbor where 

our offices are. 

We have had units out for two to 30 

months. The bulk of them have been in the range of 

two years, some a little longer. A recent set of 

models have been out for a fairly short period of 

time, where we did put counters on the soil sensors. 

So we counted the number of times that the soil sensor 

mechanism did do an adaptive response above the 

minimum. 

MR. STEPHENS: A quick question. How does 

that technology work? What's its mode of operation? 

I just need to know what you're counting. 

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MR. PETERSON: Steve Peterson. 

We are looking at pressure differentials 

in the soil accumulation chamber, and when the 

dishwasher senses a certain soil level, we have a 

switch that responds to that, and this field test data 

he's talking about, we have a counter present, and so 

we can see how many times the dishwasher has seen a 

soil level that will cause additional energy to be 

added to the product. 

MR. JUDD: So the default is -- 

MR. PETERSON: The default is minimum, and 

then if you get this switch to activate, then we add 

energy from the minimum. 

MR. JUDD: So as we looked at that and we 

looked at the NEEA data, we see a very good 

correlation with five percent being a situation that 

would be a trip because we're running one and a half 

percent on average of machines tripped beyond the 

minimum amount. 

I think as Tom Johnson said, like Maytag, 

we design that normal cycle very robust. The primary 

concern is making sure that we wash dishes in a 

minimum response. If there's a very heavy soil load, 

we'll go above it, but we think our response of one 

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and a half percent on average of trips into a more 

than minimum response is pretty consistent with the 

data that you gathered in Oregon where you're seeing 

three or five percent, whatever the number is. 

We think that would correlate in. It's 

not perfect, but it does bring some actual monitoring. 

 It's not impressions. It's not what I think I did. 

It's counting what the machine did, and in some cases 

over 30 months. It's fairly long running. It's 26 

machines. It's two cities, but we think it's enough 

spread that it does have some validity, and I think it 

anchors the information that you have. 

The last comment on there I think we've 

talked about already, which is we're supporting making 

sure this tracks with NR-Canada. 

However, saying all of that, we don't 

believe that a -- well, number one, minimum-maximum 

ratio is easy to run the tests on. We would agree 

with that, but we don't think it produces 

representative energy performance results for all soil 

sensing dishwashers. 

We agree that the consumer pretreatment is 

an important factor to be considered, but it's clearly 

not the only factor, and we think that the design of 

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the soil sensing control system must be accounted for 

in the response of different dishwashers to soil 

loads, whatever the level, is different, and we think 

it needs to be accommodated. 

I'd like to digress for a minute. We did 

some limited testing to compare -- I'm going to 

apologize for the lightness of the lines. We didn't 

realize it until we got down here that we should have 

made those lines heavier in Power Point, but this is 

four different manufacturers' dishwashers. We ran 

them at zero soil load, a four place AHAM DW-1 soil 

load, and an eight place DW-1 soil load to simulate in 

a rough way substantial pretreating, some pretreating 

and virtually no pretreating. 

I don't think four and eight are the magic 

numbers. It was a way to differentiate the amount of 

soil in the dishwasher, and what we see from this is 

that at zero load, we're fairly well clustered. 

However, when you start going to four and eight, there 

is a substantially different response of different 

soil sensing systems to a soil load, and we think 

merely looking at the two ends with some sort of a 

fixed ratio is not going to be representative of what 

real machines do in a real world. 

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Because as you've amply pointed out, 

Charlie, getting reliable consumer use data that we 

can base any kind of a fixed calculation on, I think, 

is going to be very difficult because it would take a 

massive survey to get statistically significant data 

on that, and it's going to be very subjective, I 

think, if you say what do you do to your dishes 

because, you know, some soil, a lot of soil, what have 

you, is going to be something that is going to be very 

hard to get information on. 

I think we can get information on what 

machines actually do. 

Point four is what we mentioned before. I 

think NAECA requires us to come up with the test 

procedure which is representative of real world 

conditions. I think that's key. 

Accordingly, we're recommending that DOE 

provide an additional, not a substitute, alternate 

procedure to that that they're proposing that would 

allow more nearly real world conditions. 

The rationale again is that consumers very 

rarely wash very clean or very dirty dishes. That 

leaves most of the time dishwashers are run in the 

broad middle range and some information about the 

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broad middle range is going to be very important. 

I don't know if all of you have seen a DW1 test load. We brought that along today just -- 

that happens to be eight place setting, and to make it 

a little easier to see, we did a close-up of just the 

plate. There's only one more way to go. 

(Laughter.) 

MR. JUDD: I think the number that we 

talked about, the total soil, to put that into 

perspective, for an eight place setting according to 

DW-1, that's what, 250 grams of soil load? I mean 

that's a lot of stuff, and it's hard to pick up in a 

photograph, but the yellow stuff is egg dried on. The 

brown is meat. The orange is mashed potatoes, and the 

other is raspberry juice. It isn't just like you'd 

take it off the table. That stuff has been dried for 

two hours. It's a rigorous test. 

It wasn't designed for energy. It was 

designed for performance, and that's the way it would 

set up. What can the dishwasher do to take off the 

soil? But that's a substantial soil load. 

As DOE alluded to, we don't think that we 

want to -- we would agree wholeheartedly, but we do 

not want to go to soil based testing for energy 

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consumption. We don't want to go there. It's 

expensive. It's difficult. Its repeatability and 

reproducibility would be a problem. 

There was an illusion earlier that it 

produced not salable units. When we run audit tests 

at the manufacturing plant, if we run soiled loads 

through those machines, those are machines that we 

can't sell, and so it's impossible from an ongoing 

compliance standpoint to run soil loads of whatever 

size and duration. 

We have a proposal for a starting point 

for discussion. It's not a polished procedure, but I 

think it's an approach that might be an alternate for 

us to proceed with. That would be that we run, in 

effect, a two-step process. 

The first would be to determine the 

adaptive response of a dishwasher to soil loads. The 

minimum would be the same as the minimum today. It 

would be zero soil load. The maximum would be a 

maximum, whatever that is. There are some issues with 

that. 

And the medium would be running the 

dishwasher with an agreed upon medium soil load to 

determine what the adaptive response is. If it's a 

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machine that does various fills, if the minimum is two 

and the maximum is five, find out what an agreed 

minimum or medium soil load is, find out what the 

adaptive response of that -- of whatever the 

dishwasher is to that load. Then use for the energy 

consumption calculation simulating the machine, 

setting the machine so that it runs the minimum, the 

maximum, and the medium soil load test, and then you 

would go to a three step calculation whereas the DOE 

has proposed two. 

The next bit will be to talk about the mix 

between minimum, medium, and max. We have, again, a 

starting point for discussion for that, but we think 

that goes a long way to answer some of the questions, 

Charlie that you've been raising. 

We kept saying over there did we prime you 

to ask the questions, and we really didn't. We 

haven't talked about this ahead of time at all, but I 

think those are the questions that we've been 

struggling with internally over the last weeks trying 

to put this presentation together, and while a fixed 

ratio, whatever it is, has simplicity going for it, we 

have serious concerns about the representativeness of 

that, and we think at a minimum we need an alternate 

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approach that will begin to look at the adaptive 

response of how machines operate over the world. 

As to the ratio to be picked, again, we 

don't have a firm recommendation. We have a starting 

point, and the starting point would be the NEEA/CEE 

data that came from Oregon. I think that to us 

represents what we think happens in the real world, 25 

percent minimum, a broad 70 percent with some soil, 

and a small percentage, five percent with very dirty. 

 We think that's a reasonable starting point. 

It has the benefit of matching our data, 

which says a very low percentage do we trip and get 

into other than a minimum cycle, and again, I think 

some work needs to be done to set those ratios. 

That's a starting point. I think it's probably not 

sufficient data to do that, but there has got to be a 

way to come up with a profile that runs through a 

broad range of typical, of typical use. 

Individually, and I think within the 

subcommittee, they have spent a lot of time debating 

this without good agreement yet, but I think a comment 

that kind of at the end of the day yesterday that one 

of us raised that I want to quote is, you know, these 

are soil sensing dishwashers, and somehow I think that 

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we're going to have to account for how the dishwashers 

respond to different soil levels, how the dishwasher 

responds to different soil levels if we're going to do 

anything better than just pick a simple number, which 

isn't representative. 

I think a fixed ratio, anything in the 

range of 50-50, 30-70, 80-20, is going to treat 

different dishwashers unfairly. We'll come back to 

that on the impact thing. I've got some more to talk 

about when we get to impact. 

MR. KERESTESY: Okay. 

MR. JUDD: I think given the hour perhaps 

if there are questions about what we've raised, I can 

try to answer those now and we can come back and have 

more discussion after lunch. 

MR. KERESTESY: And, in fact, what I'd 

also like to do, can we make copies of this? 

MR. JUDD: Yes. 

MR. KERESTESY: So why don't we have some 

questions now? We'll break for lunch and get this 

material copied over lunch, and then it'll be in front 

of you when we come back. 

MR. STEPHENS: I had one question just to 

understand that. So the proposal you make would use 

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this technique, this test procedure to establish a 

ratio for a particular technology. 

MR. JUDD: Right. In other words, the 

thought behind it is we would identify somehow what 

kind of a medium soil load is. It's not going to be 

DW-1, eight place settings for sure. 

MR. STEPHENS: Yeah, I understand. 

MR. JUDD: And that's an issue because I 

don't think we've thought about that individually or 

as an industry other than for ultimate cleaning 

performance, but we would define some sort of a 

typical -- and it may be a range of typical -- soil 

loads and determine what the adaptive response of that 

is. 

The endpoints are relatively easy. The 

minimum is very easy. The maximum, when we get back 

to the details this afternoon, I think there are some 

questions that we have regarding how you would do the 

maximum test because, again, there's a difference in 

the real world what machines would do and what they're 

theoretically capable of doing is maybe different, and 

what kind of soil load it would take to get to a 

maximum response is an issue that has to be resolved. 

MR. STEPHENS: So then you would just 

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establish the weight and then use that weighted 

average later. 

MR. JUDD: Right, to come up with some 

sort of a weight, and then the compliance testing, 

certification testing, audit testing is pretty 

straightforward because you set the machine to run 

minimum, maximum, and the medium point. It takes an 

additional run, but you're not using soil in either 

the certification or audit testing. So you don't run 

the issue of production units that are run for audit 

being nonsalable. You're running them three cycles 

instead of two, but that to me is not unduly 

burdensome. 

MR. KERESTESY: Randy. 

MR. COOPER: This is Randy. I guess I'd 

like to make a comment. 

What Whirlpool has proposed here is really 

based on the fact that their sensor technology is 

different than what other manufacturers are using. So 

they feel they need a certain test to work with their 

technology. 

I guess without getting into too many 

proprietary things, Maytag itself goes through a very 

rigorous test of testing points in between middle soil 

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and heavy soil, and again comes back to a ratio 

because that would come through on four points because 

they would propose on three points. 

Generally what that all gets down to is 

it's math, and you can change your ratios, whatever it 

is, to get to the point so that as best it's labeled 

for the dishwasher based on the uses the consumer 

would see. 

MR. STEPHENS: Randy, are you saying you 

kind of already do something like this as it is? 

MR. COOPER: We do, but I guess we weren't 

in full concurrence with what is produced by 

Whirlpool. 

MR. STEPHENS: Because? 

MR. COOPER: Mainly based on the soil 

levels that they chose and what they were trying to 

highlight I'll say based on soil levels. 

I guess the main point would be that 

there's different technologies here, and I guess that 

just needs to go into further discussion on what would 

be the best way for a test protocol to not create a 

competitive advantage or disadvantage. 

MR. STEPHENS: Yeah, I think consumer 

reports and Whirlpool's testing has shown that there 

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is a difference in the response of different 

technologies. So I think that's always the case in 

adaptive controls. I mean we're seeing the same thing 

in clothes washers. 

So I don't know. I guess I'm not troubled 

by that, but it does -- 

MR. COOPER: Well, and I think it gets 

down to the philosophy of do you start with the 

maximum cycle and go from there or do you start with 

the minimum cycle and build off of that, and the 

question is do you use the censors to meet the energy 

standard or do you use the censors to improve your 

energy standard. 

MR. KERESTESY: Any other questions or 

comments? Everyone needs some -- 

MS. EGAN: I have one quick clarification 

question, and maybe I'm off, but if I understood 

correctly from both of the presentations, it seems 

that an underlying assumption -- I just want to be 

clear on that -- is that only the five percent number, 

only the very dirty number triggers a maximum cycle. 

Is that a true statement? 

MR. JUDD: Yes, that's consistent with 

both presentations. 

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MS. EGAN: So that the somewhat dirty 

triggers something else. It's not the maximum. 

MR. JUDD: That would be -- 

MS. EGAN: The 95-5 would imply that it 

triggers the minimum, which we can debate, but the 

position of the -- it seems that there's consensus in 

the industry that only the five percent triggers 

maximum. Is that true? 

MR. JUDD: That would be true from our 

viewpoint. 

MS. EGAN: I guess that was Wayne in the 

presentation. That was what I understood from how you 

were interpreting that last line of the CEE data, and 

I just wanted to make sure that I understand that 

correctly. 

MR. JOHNSON: Yeah, this is Tom. 

I think that starts to get into some of 

the specifics, you know, of the technology, and you 

know, it may be very appropriate for the data that was 

obtained in the Whirlpool study, but wouldn't 

necessarily be completely representative of all sensor 

technology. 

MS. EGAN: Okay. 

MR. MORRIS: This is Wayne. Can I respond 

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to that, too? 

Since you were mentioning my presentation, 

that wasn't my intention to say that about all types 

of technology or all types of dishwashers. It was 

merely to point out that certain types do that, and 

that the test procedure that the department has come 

up with may not be reflective of the wide diversity of 

situations that take effect, nor some manufacturers 

may not feel that the Whirlpool presentation is 

representative of the way that their machines, indeed, 

behave. 

And I think that's why Whirlpool presented 

this as an alternative, that if the manufacturer feels 

that their technology is not appropriately tested 

under the way that the department has set it up, then 

a manufacturer could choose to do it a different way, 

and that they would say that their particular 

technology -- I think I'm careful in saying this -- 

they feel that their technology would best lend itself 

to perhaps seeing a three data point type spread and 

to look at a ratio for that situation. 

Whereas other manufacturers may feel that 

the way that their technology is set up, that the two 

points, the min. and the max. and a fixed ratio 

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between them works perfectly fine, as long as we can 

get to what that ratio is. 

We have, I think, severe disagreement that 

for the non-workable type technologies -- I'll say it 

that way. That's the wrong way to characterize it -- 

but for the other technologies, that a 70-30 is 

absolutely very design restrictive, and it is very, 

very punishing to those manufacturers to try and give 

an adequate representation of how the dishwasher 

behaves in an actual real world environment. 

This is suggesting that as high as 30 

percent of people do essentially nothing to their 

dishes, and that just isn't the case, and I'm not, 

again, trying to suggest that only the max. response 

is judged by those situations. That's not the case. 

I don't know that I can give you exact data. 

We, you know, gather that, and that's very 

proprietary as to how they would judge this. All of 

the manufacturers have looked at how their dishwashers 

behave and feel that the 80-20 that we originally 

proposed was an adequate way of testing theirs. It 

gave representation. 

Whirlpool feels that their particular 

technology is not served by that two line split 

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situation or two fixed ratio points and have proposed 

an alternate, and that's really probably about all we 

can draw from this. 

MR. STEPHENS: I can respond to Wayne. 

The thing is though a 70-30 split is a 

concoction. It's an invention. In most cases I 

presume these dishwashers have more than two 

responses. I mean it's not just either maximum or 

minimum. It's just that that's what we propose to 

measure so far. I mean that's what the current 

proposal looks like, not Whirlpool's necessarily, but 

we're just looking at minimum and maximum. 

But the fact is that 70-30 may be the 

appropriate weight if there's some response in the 

middle that's triggered 80 percent of the time. I 

mean maybe the correct ratio is 70-30, trying to get 

at what the real annual energy use will be because 

there's some response between minimum and maximum. 

Now, I don't know whether that's 

punishing, but the fact of the matter is there's a 

whole range of energy use in dishwashers out there 

right now. Some dishwashers use more energy and water 

than others, and you know, it's punishing, I suppose, 

in some regard to the ones that use more to some 

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consumers, but that's the way it is. 

That's kind of what we're trying to get at 

here, and if we're going to be giving credit to a 

technology that's designed to save energy, then I 

guess I want to be somewhat certain that it is saving 

energy, and if it's not, I'm not in favor of giving it 

any credit or more credit than it's due. It's that 

simple, I guess. 

MR. KERESTESY: I saw a couple of heads 

nodding. Do you want to add anything onto his 

comments? And then I want to see if anybody else has 

comments, and then we'll break. 

MR. COOPER: I guess I would just go back 

to that chart. Based on our internal testing, we do 

sample customers. We have them, again, proprietary -- 

we have them take Polaroids of what they're loading in 

the dishwasher and try to recreate that. 

We then take a look at that, looking at 

the ratios of what cycle is selected, and I'll say 

roll that up into a big number, which again a ratio 

can reflect that and, I guess, in our estimation at 

80-20 is representative of what our customer base has 

shown us that that's acceptable, and again, that's why 

we continue to label it that. 

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And again, that does take into account 

many responses in between. 

MR. STEPHENS: Randy, are you saying that 

the 80-20 represents to dish load or represents the 

actual metered energy and water use of the dishwashers 

given those loads? Are you metering the energy and 

water use of your dishwashers when they face those 

loads? 

MR. COOPER: Since we have a certain 

preset number of conditions it can go to, we monitor 

how many times it goes to that condition, say, no 

soil, heavy, whatever that would be. We monitor that. 

 We know what that cycle will product energy-wise, and 

we can therefore ratio that up to what's required. 

MR. STEPHENS: and you're saying that an 

80 minimum and 20 maximum approximates what you get 

when you actually take into account all of the weights 

in between? 

MR. COOPER: Again, that's based on our 

test data, yes. 

MR. PETERSON: I'd like to add a comment 

to that. That can be representative with certain 

systems, but it's not represented with all, and in the 

case of some technologies out there, Whirlpool's and 

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others', putting a weight on this maximum and saying 

that's going to account for the medium responses is 

not an accurate reflection of the dishwasher, and 

that's why we presented the midpoint proposal, because 

it would more accurately represent all systems as 

opposed to just some systems. 

MR. KERESTESY: Everyone is looking at me 

like, okay, let's go get some lunch. Anybody who -- I 

take it that some of you who have spoken only once or 

twice or not at all are choosing not to. I want you 

to tell me if you don't feel like you can get in. 

I think there's been good discussion. I 

think there's been a lot of good issues and 

corrections put out, and I just want to be sure 

everybody has got a chance to ask questions or make 

comments, and I trust that you do because I don't 

think that anyone who has spoken has dominated. 

There['s just been some good exchange going here, and 

I think it's been helpful. I'm hearing that it's been 

helpful. 

But please, for those of you who have been 

quiet for the morning, I'd invite you to ask some 

questions or make some comments, and now that we're 

really into the meat of the subject, maybe you will. 

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We should break for -- speaking of meat -- 

we should break for lunch, and Barbara might want to 

tell us what some options are. 

MS. TWIGG: Let me make one comment first. 

 Are there any other people who are going to make 

presentations using slide? Because perhaps we could 

get copies made over lunchtime if you could give them 

to Brenda or Sandy up at the front. We could try to 

get them copied so we'd all have them for the 

afternoon. 

MR. KERESTESY: Okay. 

MS. TWIGG: So we'd love to get the copies 

done. 

I don't know. Is it raining outside? Has 

the rain come yet? 

MR. KERESTESY: I don't know. Okay. 

(Whereupon, at 12:10 p.m., the meeting was 

recessed for lunch, to reconvene at 1:24 p.m., the 

same day.) 

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A-F-T-E-R-N-O-O-N S-E-S-S-I-O-N 

 (1:24 p.m.) 

MR. KERESTESY: Let's reconvene and pick 

back up where we left off. 

Let's pick back up with the Whirlpool 

presentation, and Bob's going to finish a point that 

needs to be made clearer, and then we can have some 

discussion about that if we should. 

And then we would like to move to a 

discussion of how to shape up our proposal that could 

reconcile some of these differences that we're hearing 

about, and Natascha has got a statement to make that 

might kick that off. 

But first, Bob, if you'll finish up with 

what you were saying. 

MR. JUDD: Super. Just so we're clear, I 

think an issue that I didn't focus on, I think it's 

alluded to in my slides and in the written materials, 

but to make sure that we get it surfaced is what is 

maximum, whether it's a fixed ratio or even in a three 

point curve that we were suggesting for an adaptive 

response. 

And it may be more specific to one 

manufacturer or another. I think it depends a bit on 

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the design and operation of the soil sensing system, 

but to make an example, in our system, it takes a lot 

of soil load to evoke a maximum, a machine's maximum 

response. An eight place setting AHAM DW-1 load does 

not; a ten or 12 AHAM place setting soil load does not 

evoke a maximum response for our machine. To get 

there we had to go to the CU test. 

That isn't feasible for running the 

maximum number if you even went to a soil load because 

then you've got too much thermal mass in the 

dishwasher to be comparable because the procedure 

today says eight place settings. So you have a common 

thermal mass in the machine for running the test. 

So we have had considerable internal 

discussion within AHAM about is maximum maximum at 

some soil load or is maximum the theoretical maximum. 

 Probably it has to be the theoretical maximum, but I 

think it's something that DOE does need to address, is 

frame of this test procedure and get to something that 

everybody understands what it is because I think until 

yesterday or until the last week or so probably we 

have not had a common understanding in the industry 

what maximum meant, and that's partly behind the -- at 

one point we were really close supporting the 80-20 

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fixed ratio, and we were running an assumption of what 

a maximum response was at eight place settings, which 

is not theoretical maximum. 

And, you know, we have one answer on an 

80-20 ratio if it's what the machine really does under 

the eight place setting load of soiled dishes. It's 

another if it's a theoretical machine maximum, in 

which case, you know, as we'll get to later, we 

probably don't meet the standard if we're talking 

theoretical machine maximum, and I think there's a 

whole range of issues from a consumer's standpoint on 

that. 

So I think it's an issue that needs to be 

resolved. We don't have an answer, but I think it 

needs to be thought through. 

MR. STEPHENS: A question on that, Bob. I 

mean, is that something that you could sort of take 

care of if you were careful about it by picking a 

weight for that number carefully? 

MR. JUDD: I mean that gets back to our 

five percent or less for really heavy soils because we 

think for us you're way out on the use curve. For us, 

you're way out on the use curve to get to that kind of 

heavy soil load, and at five percent or so, we can 

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live with that, which is why we're supporting the 95-5 

ratio and we're supporting the kind of ratio we bid 

for a starting point, which is not inconsistent with 

your Oregon data, which shows, you know, three to five 

percent is very dirty. 

MR. STEPHENS: That's for non-sensor -- 

MR. JUDD: Well, whether it's three or 

five or two, it doesn't matter. The numbers are all 

low. One's three and one's five. 

MR. STEPHENS: Actually I think the -- 

PARTICIPANT: Well, in terms of 

pretreatment. 

MR. STEPHENS: Pretreatment? 

MR. JUDD: Yeah. I mean, it correlates. 

I mean I think it's in the ballpark. With a very low 

number, you know, it isn't so critical, but if you get 

to 20 or 30 percent for that for a machine that's very 

robust, it takes a lot of soil to get to the maximum 

response. Assigning a very high number to that is a 

serious problem. 

So I think it's what is maximum response 

and how do you evoke it. If you set up the test 

procedures to say if you can't set the machine to do 

that, you test it with the soil load. Then I think 

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you have a direct conflict because you can't -- I 

don't think you can run the test at more than eight 

place settings and not create fruit salad because you 

have some points at eight place settings, some at 

more. So how do you do it? 

I think it creates an issue that needs to 

be thought through and find a solution for. 

MS. CASTRO: The intent was to obtain a 

maximum normal cycle, not the machine's absolute 

maximum. Depending on the different technologies that 

might not be a good enough definition. 

MR. JUDD: Right. That's out point. 

MS. CASTRO: Okay. 

MR. JUDD: In the normal cycle. I mean we 

read that in the normal cycle what's the maximum 

response. 

MS. CASTRO: Right. 

MR. JUDD: The theoretical maximum 

response, and that's well beyond, well out on the 

curve of what anybody probably ever puts in the 

dishwasher. 

MR. EDWARDS: It was our understanding 

that you would want to run the machine one time and 

trigger the minimum water usage in a normal cycle and 

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one time and trigger the maximum possible water usage 

in that cycle, the normal cycle. 

MS. CASTRO: Yes. 

MR. EDWARDS: Is that correct? 

MS. CASTRO: Correct. 

MR. JUDD: And then not disagreeing with 

that, seeing that if you tried to do that with our 

machine without setting it but running a soil load, 

you'd never get it, and that's the issue. 

MR. KERESTESY: I thought your metaphor of 

getting fruit salad in this discussion was a good 

metaphor. 

MR. JUDD: Thank you. 

MS. CASTRO: But just one follow-up 

question. For the Whirlpool, for the machines that 

are available now, can the manufacturers obtain a 

maximum normal following this definition, putting 

aside the eight place setting AHAM load? 

MR. PETERSON: Yeah, we can simulate a 

maximum normal, but Bob's point is that maximum normal 

doesn't come into play even with the eight place 

setting. So we would question whether that's a 

practical maximum norm because if only 1.5 percent of 

our consumers are seeing even a single response, the 

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percent that would see a response beyond that is 

extremely, extremely small. 

So that was the concern, that the 

machine's theoretical maximum, the way our machine is 

designed, it goes way beyond even the type of loads 

that we're discussing today. 

MS. CASTRO: So the 1.5 percent was not -- 

MR. PETERSON: That's not maximum. That's 

more of the minimum. That's the initial response to 

the product. 

MR. EDWARDS: I think earlier Charlie had 

alluded to the fact that he was questioning how 

machine technology was written. If you have a normal 

cycle and then the water usage is reduced or you have 

a normal cycle and water is added to clean, I believe 

that's the conversation we're having, and I guess my 

fear is that if we go this route that other 

manufacturers may change their philosophies, and we 

would actually add water usage because we would -- as 

if we're writing now to have a normal cycle and then 

reduce water usage if the dishes are clean. We may 

switch and go the other route where we could -- in a 

cleanability test, you could run forever until you get 

perfectly clean dishes and you always score perfect. 

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MR. STEPHENS: Is that the cycle you'd 

label normal? 

MR. EDWARDS: That would be internal 

decisions that would have to be made, but that's the 

concern 

MR. STEPHENS: Well, I would guess you 

wouldn't label that cycle a normal cycle. 

MR. EDWARDS: Well -- 

MR. STEPHENS: I mean that would severely 

disadvantage you in the grand scheme of things, 

running forever. 

MR. EDWARDS: It depends on how this 

procedure is written, right? I mean you would get a 

good energy rating and an excellent cleaning result. 

MR. STEPHENS: You might get an excellent 

cleaning result, but I doubt you'd get a good energy 

rating. 

MR. EDWARDS: It depends on the outcome of 

this meeting. 

MR. PETERSON: I think Mike has a valid 

point. He's right. We could theoretically 

manufacture a good -- just add energy beyond what the 

max. was defined, the procedure. I guess that's one 

of the other reasons we come back to a three point 

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type approach, where a max. really could be a max. if 

we get the bulk of the energy weighting where the bulk 

of the usage is. So then you don't have to worry so 

much about that small percent on the top of the curve. 

But Mike is right. He's got a valid 

point. 

MR. KERESTESY: Did you have a comment to 

make? 

MS. HOFF: Yes. Kyran Hoff at G.E. 

I'd just like to say that the proposal is 

Whirlpool's proposal, and it works well for their 

machine. It doesn't work well necessarily for other 

manufacturers' machines. 

And I think it opens the discussion. If 

Whirlpool can propose this, why can't I as G.E. 

propose something that works well for my own machine? 

 And I think it opens the floor to that debate. How 

many alternatives can there be? 

MR. KERESTESY: Is that a segue to the 

point that you wanted to make? 

MS. CASTRO: Yes. Well, I just wanted to 

clarify that the 70-30 -- we were taking the maximum 

in two points, but we're using that -- we wanted to 

use that as the method to obtain an average normal, 

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find out what the energy consumption on average is for 

what is considered the normal cycle. 

At this point we'd like to solicit other 

proposals to try and find out what the best 

alternative would be. If one manufacturer uses four 

points to raise -- four points to calculate that 

average normal and one uses three points, that's one 

option, but we might need to come up with some 

procedure where all of the manufacturers are doing the 

same testing to obtain those weighting factors. 

So that if one manufacturer is surveying 

or testing, doing field tests of three machines or if 

we have these 26 machines, we need to make sure that 

all of the manufacturers have some sort of minimum or 

standard for obtaining that data, if that's what we're 

going to use as a basis for comparison. 

MS. HOFF: Right, and that's the basis for 

my concern, is that if you do show alternatives, it 

gives manufacturers the opportunity to test using 

different methods, and they're going to probably label 

the one that gives them the lowest rating. 

MR. KERESTESY: Gene and Charles. 

MR. MARGOLIS: Eugene Margolis, DOE's 

Office of General Counsel. 

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What we are doing here is changing the 

definitions of the terms, and by changing the 

definitions of those terms, I'd like to know how many 

machines would come under that so that when we look at 

the standard, once you change the test procedure, you 

then look at the minimal complying machines that meet 

the standard and see if under the new standard that 

standard might be reduced, and if it's reduced, that's 

the new standard. 

And we have only come up with about one 

machine that might have a problem. I am just 

wondering from this discussion, I mean, are there many 

more machines that could have an impact on the 

standard, and are we allowed to change the definition 

of the machines? 

And if in your December comments you could 

answer that, it would be very helpful to us. 

MR. KERESTESY: Bob and, Charlie, you had 

your hand up, too. Do you want to address this? 

MR. JUDD: Yes, please. I don't know if 

you want to do that now. I mean, it's one of your 

bullet points for this discussion. We do have a 

comment on that point. 

MR. KERESTESY: It's the same as this. 

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MR. JUDD: I think it's a consequence of 

that, but we're prepared to discuss both the impact on 

the compact change and what would be if a 70-30 fixed 

ratio were adopted. It's in our written comments, and 

I'll cover it when Louis wants to get to it. 

MR. KERESTESY: Charlie? 

MR. STEPHENS: Yeah, I just wanted to 

respond to the G.E. comment that I regard the 

Whirlpool proposal not for its specifics, but for its 

concept. It moves us in the right direction, as far 

as I'm concerned, which is, you know, right now quite 

frankly without that, we're working on a wild ass 

guess to the nearest tenth of a kilowatt hour for what 

these things use, and I haven't seen any other 

proposals that have been put on the table that are 

anything more than a guess. A different guess than 

what we're guessing now, but a guess nonetheless. 

And I'm all in favor of moving away from 

guessing at this and nailing something down even if 

what we come up with is imperfect, and I'm certainly 

willing to entertain any proposals from any other 

manufacturers if they think that this one 

disadvantages them somehow, in some way. I'd like to 

hear about those other concepts. 

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MS. HOFF: You do understand that the 

Whirlpool proposal is still a guess. 

MR. STEPHENS: It's based on some actual 

testing of a machine with other than clean dishes. 

MS. HOFF: Right, but they don't know how 

those dishes were soiled. 

MR. STEPHENS: I think the DW-1 procedure 

is fairly specific. 

MS. HOFF: Right, but they're arbitrarily 

picking the number of place settings that they're 

testing. Who says that four place settings is the 

median response a consumer would get? 

MR. STEPHENS: Would you suggest a 

different number? 

MS. HOFF: I don't know what it would be. 

 I'm saying it's a guess. 

MR. STEPHENS: Well, I mean, I'm 

suggesting that that's better for a sensor equipped 

machine that's supposed to detect soil than clean 

dishes. I mean we're running these things now with 

nothing but clean dishes. Are you suggesting that 

that's better than soiling the dishes in a soil sensor 

equipped machine? 

MS. HOFF: No, that's not what I'm 

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suggesting at all. I'm simply debating their proposal 

is based on guesses. They have some data as far as 

the response that was triggered. You know, one and a 

half percent of the time it was more than a minimum 

response, but the number of place settings, the four 

and the eight, are not based on data. 

We don't know that an average consumer is 

going to see a four place setting type of load. 

MR. JUDD: We would agree with you a lot, 

Kyran, at that point because we haven't done enough 

work to begin to define what a median response is, and 

that's why our proposal doesn't have soil loads in it, 

because I don't know what the right answer is. I know 

zero isn't the right answer, and I know maximum isn't 

the right answer, and I think that's something that if 

that approach is to be followed as an alternate or 

whatever, that some more work needs to be done at a 

series of reproducible soil loads. 

And at present the only tool we have is 

AHAM DW-1. It's not perfect, but I think one of the 

things we want to do after this meeting is go back and 

run a whole series of two, four, six, eight, you know, 

place settings or maybe even hit every one. I don't 

know, and look at -- because I don't think we know 

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exactly what our curve looks like. We know the 

general shape of it by the midpoint. We certainly 

don't know what competitive machines do. 

But I think that's a way to get at a 

reproducible to determine a median point of some sort, 

and I think DOE and people like Oregon and Northwest 

and ACEEE -- we all may have some input into that as 

to what's a kind of a medium soil setting. 

And I think if everybody runs the test, we 

may find that it's not so hard. My sense is that 

middle range is probably pretty broad, and it may not 

be so critical for anybody, whether it's two or three 

or four, whatever the number is. There may be a way 

to get at it, but I think we don't know until we all 

try it. 

And that's certainly not saying that zero, 

four and eight are the right answers. We did 

something to have a basis to make a point, to 

demonstrate the point that different soil sensor 

designs and technology respond differently, and that's 

all that's intended to demonstrate, not that those are 

right numbers. 

MR. KERESTESY: Randy had a comment and 

Wayne, I believe, and then Ron. Thank you. 

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MR. COOPER: I guess I had two points, and 

I guess it first goes back to Charlie's statement that 

nobody else had really any other proposals. I guess 

that goes back to five years ago when Maytag first 

came out with our sensor machine. We did do exactly 

what Whirlpool has done, and again, we took four 

points, took the ratio of those and came up with what 

we labeled the machine. 

Three years later as AHAM, we started just 

throwing out proposals again. Not everybody had 

sensor machines at the time, didn't know what we were 

looking at, and 80-20 came out on the table. 

We went back and looked at our numbers 

that we were labeling our machine at. Eighty-twenty 

was the exact same number that we were labeling at 

based on our previous data. 

So, again, we felt very comfortable and 

have probably driven the 80-20 a little more based on 

our experience, and again, that's with our machine. 

Now, I think you take a look at what 

Whirlpool has, they're proposing a three point system 

to do some testing. Now, three points, four points, 

as said, still the same number of points. 

Now, what could be done is I'll say 

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through a task force we'll go back and look at some 

soil levels and determine those points, what's a 

minimum response, normal response, maximum response, 

and then still take that and extrapolate that out into 

a two point system and determine the ratio -- I'll say 

an adequate ratio -- based on, say, either three 

points or four points to go through. 

And we run a broad range of manufacturers' 

machines and say this is what's obtainable, and then 

from there you can say, "Well, based on that, the 

ratio should be 72-28," which would then get us back 

to a two point system, a very simple test for us to 

run, a max./min., but something that would be, say, 

almost agreed upon between what's obtainable, as well 

as what the consumer may see. 

MR. JUDD: Randy, I understand your point, 

and if your control behaves linearly over varying soil 

loads, it makes a lot of sense, and our view is that 

some machines, including ours, do not behave linearly, 

and you k now, two points don't describe that, don't 

describe a curve for the way our machine behaves. 

We don't think any two points will. I 

think we feel that it's going to take more than two 

points to do that. We could be wrong, but our belief 

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today is that with a nonlinear behaving control, we 

need to have more points. 

I can see if a control behaved linearly, 

your argument makes a lot of sense, and I wouldn't 

disagree, but theoretically it could work for machines 

that have pretty linear controls. 

MR. KERESTESY: Response? 

MR. COOPER: And I would just say based 

on, again, a standard is supposed to level the playing 

field. Whether a response is linear or not linear, 

the rules should be the same for both machines, and 

that's what I said. 

If we take this wide distribution of 

machines, do the testing, pick a ratio that I'll say 

works for both, then you have your max./min. response. 

 You're not playing favorites to linear/nonlinear. 

But I guess from a simplistic standpoint 

that should be the direction. 

MR. KERESTESY: We had Wayne, Ron, Tom, 

and then -- Wayne, you can go. Just keep it in the 

order that hands went up. 

MR. MORRIS: Just to clarify it so that 

nobody goes away with any misconceptions, AHAM DW-1 

was never designed for energy testing purposes, and I 

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know that no one is suggesting that it was, but I 

think that we have to be very careful here to 

understand what DW-1 was designed to do. 

It is a test that the manufacturers feel 

they can run in their laboratories in a controlled 

environment with technicians that are well trained and 

can do this. 

Setting this up for outside laboratories 

who are not as well trained to do on an infrequent 

basis is going to result in all kinds of disagreements 

because even as we've found, while we can do some 

round robin testing to get some numbers, the last time 

we did round robin tests of machines on the DW-1, 

there was a significant difference between different 

laboratories. 

It is a test that is not meant to be 

totally reproducible from one laboratory and one 

environment to another. So we've got to be careful 

about introducing this. 

The other thing that we need to caution 

about DW-1 is that it was designed in its very heavy 

soil loading for a purpose, and the purpose is to 

stress a U.S. type built platform machine with a 

certain type of filter to determine whether or not 

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that machine can perform well in a redeposition test. 

 To clarify, what that means is when you throw a slug 

of junk into the dishwasher, you know, on these 

dishes, and it's going to come off fairly early in the 

cycle; it's going to hit that filter. It's going to 

stress it heavily, and you're going to find out 

whether you're going to have your oatmeal flakes on 

the top rack imbedded in the tops of the cups and 

saucers on the top rack. That's what it's designed to 

do. 

It's not designed, it was never designed 

to be an approximation of what you're going to find 

out there in the, quote, real world, although we try 

and keep it that way. It's an over stress test, and 

in fact, some members of AHAM's community think that 

the food soil load is way beyond what we should be 

testing and have suggested that on several occasions, 

and we've certainly considered that. 

But we've got to be real careful if we're 

going to start to pull this back in that you will 

probably find that, you know, or you may find that a 

one place setting AHAM DW-1 load is probably 

representative of in some cases the worst that you're 

going to find out there in the consumer's real world, 

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even when they're not pretreating their dishes. 

So let's be real careful in not thinking 

that eight place settings out here is going to be the 

worst and four is going to be the middle, and zero is 

going to be -- and no one is suggesting that, but I 

just don't want anybody walking away starting to think 

in that regard. 

This test is a heavy slug test of sediment 

material to try and over stress a filter mechanism. 

It's not for energy purposes, and it was never 

designed with that in mind, and indeed, as we're 

rewriting DW-1 and in the process right now, we're 

increasing in some cases not only the soil load, but 

the difficulty in removing it only because dishwashers 

have now caught up to that. So we want to try and get 

to that. 

I just don't want anybody walking away 

thinking differently on the use of DW-1. 

MR. KERESTESY: Thank you, Wayne. 

Ron. We've got a line-up here I want to 

try to get back to. 

MR. DuPONT: Okay. Actually my point has 

already been made further down in the meantime. 

MR. KERESTESY: Okay, okay. Thanks. 

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Tom. 

MR. JOHNSON: I just wanted to respond to 

two comments. The one about the multiple points being 

necessary to simulate the sensor response, any sensor 

actually could be -- you could represent that by 

taking its minimum response and its maximum response 

and then just picking a percentage, and no matter how 

the sensor responds in between that, you can still 

very, very closely represent that with that simple 

representation. 

So it doesn't necessarily drive to the 

point that you have to have intermediate points. In 

reality you can establish that no matter what the 

curve is just with a min./max. and a percent. 

The other thing, talking about data to 

substantiate the proposals, when we originally 

developed the first sensor based control, the testing 

that was done was actual field testing and actual 

consumer use habits as opposed to laboratory food 

soils, and the machines were monitored to see the 

response, you know, to what customers really do. 

And that's where it turned out that by 

taking the min. and a max. and the 80-20 ratio 

actually represented what was truly in the field for 

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this sample. 

I think the interesting thing is we've 

tended to back into this prewashing and no prewashing, 

and the reason is these numbers start to correlate, 

and you can kind of see that, okay, that makes sense 

that if you prewash, most people do, and that's the 80 

percent. Those who don't is 20, but that's not how we 

originally got there. 

It was the field data, and it just tended 

to correlate with this, and you can start to see a 

relationship. 

MR. KERESTESY: Thank you. 

Tom Eckman. 

MR. ECKMAN: Just to go back to a little 

context here, it seems to me that as Charlie pointed 

out earlier that the whole purpose of revising the 

test procedure is to address the ability of control 

strategies to respond to different levels of soil in 

the dish load, and if those control strategies have 

different logic, then they can either be represented 

linearly or nonlinearly depending upon their logic. 

In some cases, yes, you can come up with 

two numbers to multiply together to get the third 

that's the equivalent to all of those if you know what 

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the intermediate response is. So, yeah, it's true. 

You know, you can do 80-20 or you can take three 

points and multiply them together to get the sum of 

whatever that is so long as you know what the 

intermediate point is, and you can always go back to 

two. 

The problem is it seems to me that each 

control strategy has its own set of weight, and that's 

pretty hard to embody in a test procedure unless you 

basically mathematically have to derive those weights 

through the test procedure and use them in the machine 

for that particular machine. 

You can't just say it's 70-30, 80-20 

because it's idiosyncratic to the control logic you 

actually have for the sensors, and so one way or 

another you're going to have to define a test 

procedure that either computes what those control 

points are or defines those a priori. 

I don't think that picking 70-30 or 80-20, 

either one, does justice to the variance in the 

control strategies that might be out there, at least 

the two I've heard about today. One is linear. One 

tends to be not linear. Then you're not representing 

them the same way. 

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So you've really got to be dealing with 

whatever the intermediate points are. It turns out in 

the linear case it doesn't matter. It does for the 

nominal year case. 

The second point, if the intent is to 

exercise some set of test procedures or put together 

some test procedures that represent what the consumer 

will, indeed, see, then you do want to represent this 

midpoint because no matter what data we look at, the 

midpoint is the bulk of the operating regime, and so 

you really need to be careful about where you define 

that to be. 

You don't care really much about the n-ths 

(phonetic) because they're not weighted very heavily. 

 If five percent or ten percent is the top end, normal 

max., it doesn't matter very much what that actually 

turns out to be if 60 or 70 percent is what the 

midpoint is, and so you're really interested in what 

operational behavior the control strategy has in that 

midpoint, and so it's really important to get a good 

fix on that and less important to know whether they 

scrape, clean, and wash their dishes before they put 

them in the dishwasher or not. 

It's how it responds to a middle level of 

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loading, whatever that is, and you know, I think it's 

important that that be soiled dishes because that's 

what the sensor is supposed to respond to, is soiled 

dishes. 

MR. KERESTESY: Thanks, Tom. 

I think Charlie was trying to get in, and 

then maybe Steve or Bob. Yeah. 

MR. STEPHENS: Just one quick one. I 

think a case in point is Whirlpool's statements about 

their particular model where the DW-1 load doesn't 

particularly stress their machine. It seems to elicit 

one step's worth of response with lots more response 

available should the dishes have been much more dirty 

than that. 

So, you know, I think the DW-1 test load 

is not an inappropriate thing to use, given that most 

people know somewhat how to produce it. If you had a 

continuous curve, if the machine could respond in 

hundredths of a gallon and hundredths of a kilowatt 

hour to every tiny nuance in soil level, then we might 

have a little bit of a problem here trying to get 

reproducible results. 

But if most machines respond in steps, and 

the number of steps don't exceed the number of fingers 

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on one hand here, then I'm not sure that we really 

have all that big a problem as long as we get some 

response out of the thing with a dirty load and we do 

find what that midpoint is. 

If it's not a straight line, and I sense 

that based on what I'm hearing here it may not be a 

straight line, then I need to know if it steps up 

quickly and levels off or if it hangs in there low an 

then jumps. 

I mean, I don't know what it's going to do 

for any given technology, and I think we have to keep 

in mind here that we're talking about a test procedure 

that we'd like to work for all of these designs going 

ten years out from now forward. 

So, you know, there's other designs that 

aren't yet in the marketplace that may be even 

different than what we're looking at today, and it 

would be nice if the test procedure could cover those 

as well. 

But I think it is important to get the 

weights right, but once you've established the 

weights, I think it's important that the testing be 

very simple, and that it not involve after that 

dirtying the dishes and the dishwasher and everything 

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else. I can certainly appreciate that desire on the 

part of the manufacturers. 

So I think it's a matter of for each 

platform of establishing what these weights should be, 

and then from then on we just make some assumptions 

about what step the machine reaches for that weight. 

MR. KERESTESY: Thanks, Charlie. 

I'll go ahead and get Steve. 

MR. PETERSON: Yeah, I'd like to build up 

on the last three statements because I think they all 

really have some significant meat into them, starting 

with a statement down here, followed up by Tom and 

Charlie, and I think we're really getting to the 

essence of the situation here. 

I start out with Tom's statement about 

representing a particular adaptive systems response 

with two endpoints. That's absolutely possible. He 

is absolutely right. 

The difficulty is, and Tom's own record in 

the Maytag system across the continuum is represented 

well by an 80-20 fixed and maximum ratio. Whirlpool 

system, on the other hand, is accurately represented 

more by a 98-5 and a 1.5, and Tom hit that square on 

the head, that if you want to use two endpoints, you 

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have to have two different endpoints for each adaptive 

control system that responds differently. 

So the median point, let me go -- well, 

the concept of a median point or median points really 

eliminates that problem if you had enough -- Charlie 

said if you had a continuum. If we had, let's say, 12 

test points, you could get a very, very perfect 

response for every manufacturer's control system, no 

matter what their control system was. 

But now we've got to come back to the real 

of practicality. We can't run 12 systems, but another 

point that Tom made that is very important and one of 

the key central themes of our proposal is the bulk of 

the consumers are not eight place settings, and 

they're not zero place settings. So it's really 

critically important to get some midpoint. 

I also agree with Karen that we've not 

really fully represented whether it should be four, 

two. I mean I think that can be some follow-up work. 

 We would agree with G.E.'s position that, yeah, that 

would have to be determined, but certainly that is the 

critical point. 

And then given three points, yes, we don't 

have a continuous curve, but at least we've clearly 

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defined whether it's a linear system or it has a knee 

in the curve or is there some difference. So I think 

those are some key points. 

I'd like to also follow up on Wayne's 

comment about the AHAM load. I agree with his 

cautions, especially as we look at the defining test 

points. I think everyone needs to recognize, and I 

think Wayne made the point, that the load was designed 

primarily to test performance. It's over stressed. 

Therefore, when we look at even this max. level, maybe 

eight is even too high. So I think it's a good case 

in point that that has to be calibrated. 

There has to be calibration from the AHAM 

test load which is done to really stress the machine 

to a consumer's dirty test load, which is probably 

nowhere near as dirty, and so that's also another I'd 

say "to do" list item that would have to be reconciled 

as to what those representative points might be. 

But, again, I think there's been some 

really good discussion. I just wanted to follow up 

with some agreement there. 

MR. KERESTESY: Thank you, Steve. 

Ed. 

MR. POLLOCK: I'm just going to step back, 

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and I'm not a dishwasher engineer. So you guys have a 

lot more information about the way these things work, 

but it is my basic understanding that basically what 

you're doing is you're running a different number of 

cycles of water. You extend the run time perhaps for 

different cycles and different patterns depending on 

these sensors, but there are pretty much, my 

understanding, discrete steps because of the 

fundamental number of changes of water that you put 

into the system. 

And those perhaps I was thinking could be 

calibrated to a way instead of doing actual dirty 

dishes that we would introduce some material food 

particles not on a plate, but in a way that's very 

tightly controlled at some point in the cycle in the 

test to trigger these responses. 

I don't know. I mean I'm just trying to 

think other approaches we might go that would give us 

a little tighter control in a test methodology where 

we're measuring the energy efficiency and the 

triggering there of the cycles, as opposed to 

performance on washing dishes, which is a different 

purpose here. 

I'm only offering this as an idea. Maybe 

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we can come up with some other approach that would 

allow us to have a better laboratory control for a 

test. 

MR. EDWARDS: If the purpose of the DOE 

procedure is to limit the energy usage of dishwashers, 

I think the three point approach almost encourages the 

other manufacturers to write wash cycles that could 

use much more energy than they currently do. 

So aren't we getting away from the 

purpose? 

MR. PETERSON: Can you explain that? 

MR. EDWARDS: If we go to this three point 

system, if we're to do this, and right now many 

manufacturers write their wash cycles with a normal 

cycle and in the event that clean dishes are 

introduced, it reduces the water consumption. Some 

manufacturers write the wash cycles so that it can 

continually add water. 

I don't know what the limit would be in 

order to get the best washability results. So we 

would go away from this philosophy of having a normal 

cycle that reduces water consumption, and you would 

start writing your wash programs when soil tests are 

in that you could add water. You could keep adding 

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water. 

And I think it gets away from the limit 

that we're trying to put on energy usage. 

MR. ECKMAN: I still don't understand 

that. If you continue to add water, you continue to 

add energy in water. That seems to be counter to 

getting good test results on the standard. 

MR. EDWARDS: Well, the point of it is 

that the energy consumption, it acts as a limit for 

us. It has kind of leveled the playing field. It 

says all manufacturers need to meet this energy 

consumption. 

This three point system that Whirlpool is 

proposing allows us to use much more energy in a heavy 

wash cycle like AHAM than we have been able to in the 

past. 

Is that -- 

MR. STEPHENS: I don't understand why. 

It's still .46. You can't go past .46. 

MR. EDWARDS: Right now if we run an 

energy test, we are limited by that .46. When you say 

that only five percent of the product out there would 

-- let's see how I can explain this. 

Again, the test procedure and the energy 

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limits. We have worked with those, and I think it 

does level the playing field. It prevents 

manufacturers from continually adding energy and 

adding water usage and exceeding this .46 limit. 

MR. ECKMAN: If the three points still 

can't exceed .46 when they're weighted together -- 

MR. EDWARDS: That's correct. That's 

correct. 

MR. ECKMAN: -- then I don't know how you 

play that -- 

MR. EDWARDS: But it's going to change the 

philosophy that certain manufacturers are using, and 

we will write programs that use more energy. 

MR. KERESTESY: Okay. Ed? 

MR. POLLOCK: I think what I hear you 

saying is that in the max. load because you're only 

going to count it for five percent, you could go 

higher, and so therefore if you had somebody who 

always ran it in max. load, it would not be more than 

the machine that is not a smart machine. Is that what 

you were trying to state? 

MR. EDWARDS: Yes. 

MR. POLLOCK: Yeah, and I guess that's one 

of the concerns that we might have with any of these 

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where you have a balance and a mix with the smart 

machines, not just the max. load issue, but the issue 

of once you define those points and you have a smart 

machine, you can tweak the point a little bit to get 

you to just the bottom of that point. 

How do we define the test procedure in 

such a way that people in their designs and their 

intelligent machines don't tweak it to gain the test 

methodology that we're using? 

MR. KERESTESY: Kyran, Charlie. 

MS. HOFF: I would agree with both what Ed 

and Mike have brought up. I think the issue Mike is 

addressing is you're weighting that maximum response 

very low, and then it depends on where you set the 

maximum response. 

If you set it at eight place settings, 

that may or may not be the true theoretical maximum 

for that machine. You could run it at 12 place 

settings and get a higher response, and nowhere in the 

formula is that accounted for. 

So I think what Mike was getting after was 

a manufacturer could say, "Okay. Eight place 

settings. I'm going to let that trigger my medium 

response, and then I'm going to have something higher 

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than that so that when I run an AHAM test at 12 place 

settings or when CU does their testing," which is a 

much heavier load than even what AHAM is, "I would get 

even a higher response." And then nowhere in your 

procedure would that be accounted for. 

So I think that's what he's saying, is 

that it could lead manufacturers to redesign their 

algorithm such that portions of it aren't included in 

the DOE equation, but yet it gives them the option of 

going above and beyond so they can get excellent wash 

performance when heavy soiled loads are placed. 

MR. KERESTESY: Thank you. 

Charlie. 

MR. STEPHENS: Yeah, I think I understand 

that, but I would suggest that if you think about how 

the test would be done with the midpoint, take two 

scenarios. You've got a machine that's programmed to 

only use more energy and water if you get beyond a 

certain point as you suggest, with a 12 place setting 

or a Consumer Union load. Most of the time if you do 

a midpoint, one of two things is going to happen. 

Either your machine at that midpoint is doing a really 

good job, like Whirlpool implies their machine is 

doing, and it truncates the cycle in that midpoint at 

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a very low energy and water use with I don't know how 

many place settings, four, six, eight. You know, I 

don't much care what we settle on as long as we think 

it's fairly representative of where most consumers 

are. 

If that weight is 60 percent or 70 percent 

and it's a low number and it's reasonably 

representative of what we think consumers are going to 

do with their dishes, then I'm not sure where we're 

gaining the system. 

Now, if your machine doesn't do so well, 

and it's still got a fairly heavy soil load as it 

moves on through, well, then you need that more energy 

and water, and if it does, it'll move it up the scale 

in that midpoint. It will keep washing until it hits, 

you know, on that eight place setting or six place 

setting or four, whatever it is. If it has to go 

another step or two, well, then the energy use is 

going to go up and it's still constrained by .46, and 

it's going to get a big weight, and you're not going 

to do so well. You're not going to come out with as 

good an energy factor if your machine doesn't respond 

until several steps later than somebody else's when 

you go to measure that intermediate point with a 

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consistently dirty, midpoint dirty load. 

I guess I'm not concerned if the excessive 

energy use is out there so far that you can only trip 

it with a Consumers Union load, you know. I mean, 

I've got a lot of people sitting around the table here 

saying that consumers don't dirty their dishes that 

much, that it's a tiny fraction out there, and if 

that's indeed true, then I guess I have to wonder why 

I'm concerned about that. 

MR. KERESTESY: Steve and then Mike. 

MR. PETERSON: Yeah. Now, actually it 

becomes a follow-up to Charlie's statement. What Mike 

and Kyran said is true. Many manufacturers could -- 

they can today -- can put more energy into 12 AHAM, 12 

place CU, whatever they want to do. Fine. I mean, 

that's okay. 

I think Charlie hit the nail on the head. 

 We've been sitting around here all day saying 

consumers don't even do eight AHAM place settings, and 

the DOE energy test procedure is intended to measure 

what the consumers are doing in the field. So why are 

we worried about 12 place settings? So what if we put 

four kilowatt hours into a place setting load and one 

person in these United States runs that two times a 

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year? Has the United States lost a lot of energy? 

Heck no, but the vast bulk of the 

consumers that are going to be out there, someone that 

has two, three, or four place settings, if these 

machines aren't very energy efficient there, that's 

where the penalty would be paid and rightly so, by the 

machines that are efficient whether consumers are 

using them. 

We're trying to measure energy where the 

average and the weighted, heavily weighted use, and 

the practices in the United States is relevant. So 

I'm not worried about 12 place settings. 

And I would invite any of our competitors 

to put a lot of energy in there if that's what they so 

choose. It's certainly not going to be wasted in the 

real life field conditions. 

MR. KERESTESY: Mike. 

MR. EDWARDS: If we were to set this 

midpoint, if you will, at six percent, I'm not so sure 

-- I haven't tried it -- that we can't write a wash 

cycle that gives the minimum water usage its six place 

settings. I mean, I think there's a possibility 

there. So then you would have a minimum water usage, 

another minimum water usage, and this maximum water 

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usage at one and a half percent. 

MR. JUDD: My answer to that would be if 

that does a good job of washing dishes, that's a good 

deal. It's good for consumers, and it's great for 

energy. There's nothing wrong with that. That's what 

this is all about. 

MR. KERESTESY: Kyran, and before I get 

back there, Christine I think had one. 

MS. HOFF: I had a response just to 

something Charlie said regarding the three point 

system and that if you had a midpoint, you know, it's 

a wash. Really it's not. It depends on what soil 

load do we set that point to be, and what are the 

percentages because you still get it under the same 

issue that you have with the two point system. 

Not all manufacturers have an 80-20 type 

ratio. If you've done a field test, you probably 

wouldn't find that G.E. and Maytag, Frigidaire and 

Whirlpool all trigger something above a minimum 

response in the same percentage the same fraction of 

time. So its' still the same question. 

No matter if it's a two point system or a 

three point system, what are the percentages and what 

is the load you define for each of those? Because 

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it's going to be different for everybody. 

MR. EDWARDS: And how do we come up with 

one thing that works for everyone that's fair for all 

of us. 

MR. KERESTESY: Christine, did you want to 

and then Tom Eckman? 

MS. EGAN: Yeah. I think that the feeling 

I'm getting from the discussion that's taking place 

here is that the devil is in the details of what we 

decide. What is the maximum? What is this medium 

point? What is the minimum point? 

And I'd like to hear. I mean, is the 

maximum that we're giving a five percent weight to, 

for example, if that's the number we agree to, is that 

a theoretical thing that never happens, or is that 

actually the maximum of the normal cycle? 

Because it seems to me what we really want 

to represent isn't some -- I mean, I guess I'm a 

little confused why manufacturers are making 

dishwashers to clean at levels that never occur in 

reality anyway, but that aside, just being curious as 

to why all of this over performance is being packed 

in, shouldn't the test procedure reflect the reality 

of the min., median, and max., not a five percent 

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weight to something that never transpires in reality? 

MR. JUDD: Well, you've got to restate the 

issue that we opened this afternoon with. I think 

that's a serious issue. 

I think no matter how you do it, it's 

still not a big percentage of the time. I think there 

are good arguments from simplicity's standpoint, and 

to partly answer the issue that Mike has raised, to 

disincentivize a manufacturer from writing an 

indefinite number of cycles, that it would just keep 

running forever in a very heavy soil load, that you 

would -- there is a good argument to be made for the 

theoretical maximum capability of the machine. Hold 

the percentage low, but it says what is the most it 

can use, what's the least it can use, you know, what 

does it use in the normal circumstances. 

Set the weights, and then you have the two 

ends objectively set, and that I think removes a 

substantial part of the incentive to just let it run 

forever, quote, unquote, keep the number low, and then 

really worry about the middle range. 

And Kyran is right. It's not simple. If 

we had a simple answer, we'd have figured it out 

because we've had some people that are pretty capable, 

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not me, but the engineers that are here with me and 

behind you guys, working on this, and it's not. It's 

not, "Oh, yeah, that's the answer." 

But I think if we're going to 

realistically look at, as we've said two or three 

times to different people, soil sensors that are 

intended to do something and running them where 

they're not doing what they're doing, it's very hard 

to characterize different systems fairly and 

competitively. 

Somehow we have to do it, and there's 

going to be some winners and losers in the short term, 

and you're right. Whatever we measure is going to 

drive how machines perform in the future. So I think 

we have to be careful about that because it's being 

careful what you measure because that's what you get. 

So it's not a simple task you've started 

down, but I think we have to go at it somehow. 

MR. KERESTESY: Wayne, did you want to add 

to that? 

MR. MORRIS: There are a couple of points. 

 I wanted to go back to a question that Ed raised 

about can we come up with some sort of alternative, 

simple test kind of situation that you can do. 

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Unfortunately, no. We discussed that 

heavily at AHAM meetings to look and see if there was 

some alternative material. I mean for some 

technologies, for some food soil sensor technologies, 

you could probably put a teaspoon of coffee grounds 

in, and you could trigger responses. 

And so that's beautiful. Oh, let's just 

use coffee grounds. Unfortunately, you know, you can 

then say, "Well, do I use half a teaspoon then to 

represent the medium response?" 

Well, maybe, maybe not, but then you get 

into more problems with the fact that certain 

technologies don't respond to just the opacity of a 

food soil like coffee grounds, and so you may need 

something else. It may be density. It may be the 

pressure drop on a filter situation. It may be having 

to do with the mixing quality of the food material and 

how often it goes back through. 

We looked at so many of these, and we've 

considered them all, and unfortunately, no, there 

isn't one simple, little, you know, like drop marbles 

in and figure out whether it's going to reflect what 

the consumer does. 

So we'd like to look at that in terms of 

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if that's what the department really wants to pursue. 

 That's something that we'd have to go back and do a 

lot of work on, and I'm not sure that it bears that 

kind of huge amount of research effort, but if the 

department feels that that's an appropriate way to go, 

just let us know. You know, we sure would rather not 

spend the resources on that, but you know, if it needs 

to be. 

Let me see if I can set down where I think 

that we might be able to suggest some opportunities 

here, and I'm being presumptuous of thinking that I 

can help the department come to grips with this 

problem because I'm not sure that we have collectively 

even among AHAM uniformity in how to do this. 

But if the department wishes to have the 

manufacturers go back and look at the situation again, 

you know, we could look at it in terms of trying to 

come up with alternative setting levels or whatever 

you want to call them, soil setting levels, but I 

think it is extremely important to have some kind of 

information from the department early on that if we're 

going to look at, let's say, a three tier kind of 

approach, we need to fix the percentage sort of before 

we go out and look at the numbers of what the 

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min./max./medium response is going to be. Otherwise 

there are so many variables here that depending on 

different technologies, I could pick different 

percentages in different min./max./medium responses, 

and then I could give you different answers as to 

whether machines that are out there today meet the 

level or not. 

And, see, you might have sort of a 

multivariate kind of situation going on. I'm not sure 

you're going to ever get to an answer. So it might be 

helpful if the department is considering as an 

alternate coming up with a three tiered kind of 

approach or four or whatever your number is. 

You know, tell us at these percentages we 

want you to tell us what the response situation is and 

help us to define that, but I think we might be trying 

to set ourselves up too much if we're going to just 

take this thing from ground up. 

I'm suggesting that as an opportunity for 

discussion anyway as a way out of this box because 

right now we're kind of coming to you and saying it 

works for some, it doesn't work for others, and, gee, 

help us figure out which is right. 

And I don't know that we've done much but 

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confused things today. 

MR. POLLOCK: Thank you, Wayne. 

I wasn't proposing that we spend a lot of 

time developing it. It was a question of I heard you 

give this long speech about how the AHAM performance 

test was not intended to be an energy efficiency 

measurement and, therefore, we shouldn't put a lot of 

weight in it. So I was just asking the question. 

Are there other ways? Obviously you guys 

have a lot more knowledge about these systems, the way 

they work, and why they work the way they do, and the 

reason for having the workshop is for you to educate 

us. 

I do think it's something that we need to 

work on together to come to some resolution on this. 

We, DOE, are not in a position to dictate this. With 

all of these different control strategies, there's a 

lot of variables that we need to consider, and I'm not 

quite sure how the best way to get to the bottom of 

this is. 

I would be interested in recommendations. 

 I think we're going to end up being a situation which 

we talked briefly at lunchtime that we're going to 

have to compile some data. We're going to have to 

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take a look at that, and we're going to have to come 

back with a proposal hopefully with your help and then 

solicit comment on this again because I just don't 

think from what I've heard today that we have enough 

information at this point in time to lay out something 

that's really going to be viable. 

We talked a little bit this morning about 

submitting confidential data. It seems to me that the 

way we may need to go is for us to understand better 

how each of your proposed machines operate, which I 

understand is confidential. 

We would have Natascha evaluate that, look 

at some different patterns, and try to determine some 

approach which would, along the lines that have been 

discussed today, allow us to come up with something 

that we would propose to you and let you try it out 

and come back and tell us what you think happens. 

If you've got other ideas on how we go, 

but just at this point in time, given that the 

technology is evolving so quickly and the strategies 

are changing from what we originally understood when 

the test procedure was put together, I think we need 

to do some more work on this. 

MS. EGAN: The only thing in that I don't 

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hear a real easy way for those of us at this end of 

the table here to kind of get a sense for the numbers 

and the percentages and the data, and so that concerns 

me a little bit. 

How are we going to evaluate the different 

data points and sets? I mean that sounds a little bit 

like we have to kind of just go, "Okay. We trust that 

these are the right data points." 

So I mean, I guess conceptually from our 

perspective the original proposal that was put out we 

felt was too generous, frankly. Seventy-thirty, you 

know, we weren't happy with that, and the reason for 

that is essentially the discussion I've heard, which 

is that these extremes basically aren't the bulk of 

what's going on. There's this wide area in the 

middle, and nobody really knows what's going on 

because we haven't actually measured it. 

So anything that gets us to basing this on 

something other than consumers reporting their sense 

of dirt, which my definition of dirt is different from 

your definition of dirt, and self-reported surveys are 

always, always inflated; you could get into also the 

social desirability of cleanliness likely leads to 

people are overestimating how clean, you know, their 

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dishes are going -- I mean the inflation factor of 

this you can't ignore. 

So anything that gets toward defining 

what's the reality of that middle point we would be 

supportive of and weighing that based on actual data 

rather than, you know, perception. That would be 

where we would come down, but it's got to be somewhat 

transparent. 

MR. KERESTESY: Ed and then Charlie and 

Tom. 

MR. POLLOCK: I agree with you. I think 

there are actually two parts to this. One is coming 

up with a test methodology which measures the 

equipment performance. There is still this issue out 

here that we started off with today, which is how many 

people prerinse and what's the actual dirtiness of the 

dishes put in there, which is the field data that 

you're talking about, and somehow that has to be 

integrated into this because it's not just a question 

of the triggering but how often does that triggering 

happen in the product. 

And we haven't got a real answer for that 

yet either. We've sort of ignored it this afternoon, 

but that does have to be addressed at some point in 

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time. 

MR. KERESTESY: Charlie, Tom. 

MR. STEPHENS: I'd just like to go to one 

higher level here. What we've got here in the 

Whirlpool presentation, we noted that NAECA presumed 

that we will have a test procedure that as best as 

possible estimates what actual energy use will be in 

this product in the field on average, and you folks 

have brought us sensor equipped machines. Thank you 

very much. 

Now, I presume, and maybe I'm presuming 

too much, that the reason you did this was so that 

some of these products increasingly perhaps would use 

exactly the amount of water and energy required to get 

the dishes perfectly clean and no more than that. 

Now, that's a concept that our entire 

economy should be pursuing, you know. Just enough to 

do the job and no more, and in the meantime we have a 

standard that sort of keeps people from saying, "Yeah, 

if I throw 20 gallons at it I'll get it," you know. 

Yeah, you will with 20 gallons, but that's 

why we have a standard. You can't throw 20 gallons at 

it. Maybe you can throw eight and a half or nine 

gallons at it and still meet the standard. 

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So there are limits, but we've got a 

machine, the technology here that's different, but it 

still is meant to do the same thing, to meter the 

energy and water use to just the amount that's needed 

to do the job and no more than that, and I think it is 

incumbent upon DOE to come up with a test procedure 

for these machines that actually estimates what these 

things will use, not a guess, not just, you know, pick 

some numbers based on one half of the equation, which 

is how people treat their dishes, but the other half. 

 What do the machines do when people treat their 

dishes that way? 

And so I would just like to see DOE pursue 

this to the extent that we can get some data, and I 

think if the manufacturers are willing to go try a DW1 test load, four place settings, six place settings, 

two and a half place settings, whatever, and see what 

kind of a curve you get given your technology, and 

come back and say, "Our best performance is with six 

place settings," or, "we like six place settings as 

representative of the middle," you might find that 

most manufacturers land on the same number. 

I don't know, but I think until somebody 

goes out and actually tries it, I don't think we're 

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going to know the answer to that question. So I'd 

love to see the manufacturer sort of postulate where 

they would land for their technology. 

MR. JUDD: We're stealing each other 

lines. I was going to suggest that as a first step 

that maybe we'd do something like have the 

manufacturers submit data to DOE at one to eight DW-1 

place settings, and look at that and let Natascha look 

at it, and that you could even roll that up and do A, 

B, C, D, E machines or whatever and just see what 

happens. 

And you know, you're right. We might find 

that 2.5 is a break point for everybody. I don't 

know. Until we get that, you know, then maybe we can 

increment into it. If we kind of figure out what the 

shape of the curve is, then we could have something 

ont unlike this where, given those numbers, then you'd 

go at different weighting, and we could perhaps, you 

know, back into a way to get something that everyone 

maybe isn't thrilled with but can stand as a starting 

point, and maybe we'll figure out that you guys are 

right. Two points will do it. 

But I don't know. I mean I think that's 

the concern everybody has, is they kind of know how 

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they behave, but you don't see the mix, and there's, 

you know, a concern that some other approach might 

make you not meet the standard or give, you know, 

Brand X a big competitive advantage, and so no one is 

kind of willing to move, and somehow we've got to 

break out of there. 

MR. KERESTESY: Well, Tom has been trying 

to break in, but let me ask a question, Tom, based on 

this because you made a suggestion and a number of 

heads nodded. 

Is this something that maybe you should 

talk about a little bit more or talk about later about 

exactly what to do and how to do it or can you fold it 

into a nest step? 

The data seem to be -- the need for data, 

that seemed to address the need for data, Bob, and I 

just want to keep moving on and not lose this. Did we 

just agree to something that would be helpful? 

MR. POLLOCK: I guess this is something 

that the AHAM and the manufacturers would have to be 

agreed upon to come back to us, but it certainly seems 

to me to be the first thing we need to do. We need to 

understand how these machines function under different 

loads, and then after that, we can begin to take a 

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look at it and talk about how do we design a test that 

fairly measures that performance for the different 

design strategies. 

MR. KERESTESY: Tom has been trying to 

break in, Randy, and then I'll come back to you. 

MR. ECKMAN: Yeah, I support what Robert 

has to propose there. I think it would be exceedingly 

valuable to get some sort of aggregation mask 

(phonetic) through NIST or whatever so that we could 

see how various control strategies respond at various 

loading levels, and I think it would be also useful to 

get some that don't have control strategies associated 

with them to take a look at what they do in response 

to those same loadings. 

You know, what's the typical cycle program 

that's going on for those, and seeing how different 

kilo-hour per cycle we're seeing? 

And I suspect it wouldn't hurt to have a 

washability number out of them. 

MR. JUDD: No. 

MR. ECKMAN: Whatever that cleanliness is. 

(Laughter and simultaneous conversation.) 

MR. MORRIS: This is Wayne. 

There are very few things today that I 

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think I can agree on from the manufacturer's 

perspective 100 percent, and you will not get a 

washability number out of any of the -- 

(Laughter.) 

MR. ECKMAN: Just trying to make sure that 

this is normalized. You know, there's input, and then 

there's consumer satisfaction, and there's an output. 

 Hopefully you guys are going to be conscientious 

about that. 

MR. JUDD: The marketplace is responsible 

for that. 

MR. POLLOCK: That is traditionally with 

DOE. We assume the marketplace takes care of the 

performance. 

MR. ECKMAN: That's fine, and I know 

they're really tuned into that. 

MR. POLLOCK: Well, it was good to know 

where that line was. 

(Laughter.) 

MR. ECKMAN: We know where consensus ends. 

MR. POLLOCK: That's right. 

Randy was trying to get in, too. 

MR. MORRIS: I don't understand -- this is 

Wayne -- I don't understand, Tom, then what would be 

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the value of producing the energy results for a 

machine that doesn't have sensor technology. 

MR. ECKMAN: Just to see where the 

baseline is for others, I think. 

MR. MORRIS: Baseline of what? Of energy? 

MR. ECKMAN: No. You've got so much water 

and energy going into the noncontrolled -- the ones 

without control logic, and I'd just like to see that 

against those with control logic to see, you know, is 

the control logic basically buying us a shorter cycle, 

kilowatt hours, or is it not. 

MR. MORRIS: I still don't understand what 

it is we would be reporting on the machine that 

doesn't have a sensor. 

MR. ECKMAN: Well, if you plot this, 

you're going to see a straight line across there 

because it has a single cycle length regardless of 

loading. 

Those numbers, they exist. We have a test 

for that. 

MR. MORRIS: It's called where's .46. I 

think that's the answer to that for machines. 

MR. POLLOCK: Don't some of them have a 

thermostat adjustment on them so that as you change 

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the load, you're going to change the power use a 

little bit? 

MR. ECKMAN: Would the thermal mass 

change? 

MR. POLLOCK: I don't know how much value 

it is, but it does seem there would be a slight 

variation. 

MR. JUDD: But what we were suggesting in 

the one to eight is that there would always be eight 

place settings in the dishwasher. It's one soil, two 

soil, three soil. Otherwise you can't tell what's 

soil and the difference in -- 

MR. POLLOCK: Okay, all right. Understood 

because I had not stressed before we need to make sure 

we define this test so that everybody does the same 

thing. 

MR. JUDD: But I think you'd have to hold 

the thermal mass the same, and it's how many of the 

eight you soil might be the variable. 

MR. POLLOCK: Right. 

MR. KERESTESY: Okay. Randy, you've been 

trying to get in for a few minutes and then Charlie 

and Christine. 

MR. COOPER: I guess this was to add. 

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Before Bob had mentioned it, and we had sketched out a 

very similar plan as a proposal. One thing that we 

would recommend is that we look at things less than 

one piece or one place setting soil-wise and a quarter 

or half because we've got pictures that show 90 

percent of the consumers aren't putting anything even 

close to what's on that one. So we need those 

breakdowns as well. 

MR. POLLOCK: What I'd ask, because it 

sounds like you've discussed this already, if you're 

pretty well firmed up on this, that you submit a 

proposal to us that we'd have Natascha evaluate and 

then get back to you for comment, and then we'll 

finalize the process that we're going to use for this 

test, make sure that we've defined all of the 

parameters that need to be measured and controlled so 

that we're doing it uniformly and that we make sure 

that we've got good data when we go forward with it. 

MR. KERESTESY: Charlie. 

MR. STEPHENS: I just had one question or 

recommendation here about following up with CSA and 

making sure they have the same level of interest or if 

they have any additional input to this before we get 

completed. In other words, before we get all of the 

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way down the track it would be nice to have them weigh 

in if they have some comment. 

MR. POLLOCK: Thank you, Charlie. 

Make sure that Natascha also coordinates 

with them as she works on developing this and 

coordinating it. 

MR. KERESTESY: Christine, did you have 

something? 

MS. EGAN: Yes. I think I'm not a 

dishwasher engineer so I've been trying all day to 

really hang in with these discussions, and I'm feeling 

the need for a recap of what we are proposing here and 

what we all think it's going to accomplish to make 

sure we're on the same page, which is that this 

aggregation that we're talking about doing is going to 

get at the formula that we use. 

In other words, is it min./max.? Is it 

min./medium/max.? It's going to give us a sense of 

what that formula would best be to represent the 

varying designs of soil sensing technology. 

Are we using this to determine the weight 

that this speaks to? 

MR. JUDD: No. 

MS. EGAN: That's mine. Okay. I just 

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wanted consensus. 

MR. JUDD: It's kind of what medium is. 

MS. EGAN: We're going to come up with an 

idea of what medium is, what max is, and we will then, 

based on further discussion, determine how we weight 

that. 

MR. JUDD: Because you've got to fix 

something first before you can let the other one vary 

and have a meaningful discussion. 

MS. EGAN: That's where I thought we were. 

 I just wanted to make sure. 

MR. KERESTESY: The purpose of all the 

data points was to -- 

MR. JUDD: To see if we can get a starting 

point that no one is going to go nuts on. 

PARTICIPANT: And minimize the number of 

them. 

MR. JUDD: Right, and how many how many 

iterations, yeah. We can't do but one. 

MR. KERESTESY: Well, it seems like we've 

got -- does that make sense to you and there's 

agreement on proceeding with that? 

Yeah, is there anything to wrap up on 

that? Because I want to get back to this to see if 

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there's any other issues you might have had some 

comments on, on size, definition. So I think we're 

winding down on this one. 

Mike, is there -- 

MR. EDWARDS: One other point. I think 

Maytag has asked that we go the minimum, a half a 

place setting or whatever, and Whirlpool has mentioned 

the middle. Shouldn't we also give the maximum? 

MR. PETERSON: We were suggesting one 

through eight. 

MR. EDWARDS: I'm saying the very maximum 

output of the machine given -- 

MR. JUDD: Oh, maximum maximum. That may 

not be a bad idea. We can determine that while we're 

at it, find out what the theoretical maximum is of the 

machine and get that written down. Yeah, good 

suggestion. 

MS. CASTRO: How would that be obtained 

then if you are limiting the -- 

MR. JUDD: However we do it artificially. 

 You would have to trigger it. You couldn't do it 

with -- 

MR. PETERSON: We know what to do with the 

algorithm to make it use the most energy it can 

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possibly use. 

MR. JUDD: A way to say that would be you 

go up to an eight place setting, DW-1. If that isn't 

the maximum response with that load, you'd 

artificially set it to run a theoretical maximum 

response on top. So you'd have two points there. If 

the eight place DW-1 load is not evoking the maximum 

response, you do another one forcing it. 

MR. POLLOCK: With eight place settings. 

MR. JUDD: Then you go eight place 

settings clean. So that way it would give us that 

answer. 

MR. KERESTESY: So on these points of a 

quarter, half, or up to the max., there's agreement 

that the AHAM and the manufacturers are going to put 

together a proposal to -- 

MR. JUDD: A proposal that they'd have; 

that we'd each give thoughts to Natascha and let her 

come back and prescribe the round robin. 

MR. KERESTESY: I thought I heard 

something different that said if you were firmed up on 

this, which -- okay. 

MR. JUDD: That was Wayne. 

MR. KERESTESY: Yeah, okay. 

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MR. JUDD: Excuse me. 

MR. POLLOCK: Yeah, either way is fine. I 

don't want to take too long to do it. If it would be 

quicker to submit it to Natascha and let her compile 

it or work with Wayne to compile it, whatever you're 

comfortable with. 

MR. KERESTESY: Okay. 

MR. JUDD: Just to let you know what we're 

doing. If Wayne compiles it, we'll -- 

MR. MORRIS: This is Wayne. 

I think what i had understood was that the 

department wanted a proposal from the manufacturers 

for a test plan, and I think probably the best way of 

doing that is to have each of the manufacturers think 

about the elements that would be involved in that. 

We'll get together, not necessarily face 

to face, but we'll get together, and we'll try and 

resolve how the test plan will be developed, and we 

all propose one test plan to the department of how we 

would do it. 

The department will then make the 

determination of whether that needs to be modified or 

ask questions or whatever they need to do, give it 

back to us, and then we'll go about setting out to 

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gather the data. 

MR. KERESTESY: Actually one other step in 

there which I should confirm with Ed. I think what 

he proposed was then that would be noticed. That 

would be proposed for comment formally; is that right? 

I think so. 

MR. POLLOCK: That's going to slow it 

down. 

MS. TWIGG: Well, we're going to have an 

informal exchange first. 

MR. KERESTESY: Right, right. 

MR. MORRIS: Excuse me. I think the 

department could certainly send that out to the 

participants who have signed up for this workshop and 

have shown interest doing it. There's no interest why 

it can't be E-mailed or whatever to Charlie and 

Christine and Tom and all the others that are 

interested in this, and they can certainly supply 

comments back to the department. 

But I'd rather not go to the Federal 

Register level. 

MR. KERESTESY: Yeah. 

MR. POLLOCK: We can put where needed. 

We'll put it up on our Web page to share the 

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information. 

MR. KERESTESY: Okay. All right. Just a 

time check here. Two, forty-five. We're going to try 

to end at four. 

Well, we had timetable of events set at 

the end, which adds cover to some during the -- yeah, 

NRC position was requested. 

MR. POLLOCK: I think we discussed that. 

MR. KERESTESY: I'm sort of back up to 

where we still are. Any other issues which I don't 

know if you'll have. We have some loose ends to tie 

up right now that are in that one to three o'clock 

time period. 

Ron. 

MR. DuPONT: I'm just a little bit -- I'd 

just like clarification on the issue on truncated from 

earlier this morning. Have we decided to change that 

or not change it? Remember there was a disagreement 

on its meaning. 

MR. KERESTESY: Well, there wasn't a 

decision, was there? 

MR. DuPONT: No. 

MR. JUDD: We raised the issue and were 

hoping you all will address it. 

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MR. PETERSON: And I don't think the 

disagreement was on meaning. It was on definition of 

the test method. I think everybody knows the meaning. 

 It's just the technicality on how you actually write 

down the numbers when you run the test. 

MR. MORRIS: And the words that are used 

in the test procedure. 

MR. PETERSON: The words that have been 

selected now drive ambiguity or drives you to two 

complete tests, which we do not do today, and we were 

not proposing to add. 

MR. MORRIS: And I don't think the 

department ever intended to. So I think they want -- 

MR. KERESTESY: I think that was what -- 

MR. JUDD: I they were assuming I think 

was the issue. They were assuming we were running to 

today, which most or all of us don't. 

MR. DuPONT: So does that mean the wording 

won't be changed? 

MS. CASTRO: I believe so. Well -- 

MR. PETERSON: I would suggest either not 

changing or looking at the wording and clarifying it 

so that it's clear that you can -- obviously there's 

ambiguity because the department interpreted something 

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different than what we're doing. So I think there 

probably needs to be a wording change to make it -- 

MR. KERESTESY: I think the department 

understood the point, and I think -- I'm not trying 

to put words in your mouth. I'm trying to remember 

what was said this afternoon. 

I think there was an intention to clarify 

the wording consistent with the discussion; is that 

correct, or tell me if I -- 

MS. TWIGG: Yes. 

MR. KERESTESY: That's my recollection. 

Okay. 

Thanks, Ron, because that was a loose end, 

and let's do some loose ends now. 

There's five bullets under that one to 

three o'clock time period. We've been talking about 

probably all of them, I think, at some point here. 

I know that Whirlpool has -- 

MR. JUDD: The last two I think we 

haven't. We probably tippy-toed around. Maybe the 

answer won't be surprising, but we probably ought to 

say it just so you have the information in your 

database and the record. 

MR. KERESTESY: Actually what I want to do 

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is get -- I know that you have something to say on 

those two points. Can I get a show of hands of -- I'm 

just trying to get a sense of what we have left to do 

-- someone who's got something they want to bring up 

about any of those five bullets or other issues? 

PARTICIPANT: I have one. 

MR. KERESTESY: But I just want to get a 

sense first and then -- so are we really that close? 

Do you guys have any other questions or issues you 

wanted to put back to the group before we left? 

MS. EGAN: You're saying we have only the 

last two items on this list to discuss? 

MR. KERESTESY: Well, going by this, and 

then there was those -- 

MS. EGAN: I just want to make sure I'm on 

the right part of the agenda. It's any dishwashers 

adversely, any dishwashers adversely. It's those two 

bullets that we have remaining to discuss. So if 

there are any other -- do I have one? I have one 

titled "Preliminary." So that could be the problem. 

MR. KERESTESY: Oh, yeah, yeah. There's 

the final. 

MR. JUDD: It's still the same two 

bullets, worded differently. 

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MR. KERESTESY: Worded differently. the 

wording threw me. Okay. So they've got comments to 

make on that, and I'm just seeing if anybody else has 

comments to make on those five bullets or other 

issues. 

MS. EGAN: The only thing that I would say 

is that we have to be explicit about the fact that 

we've deferred much of the percentages conversation, 

the weighting conversation. We're all in agreement 

that we're deferring that to tackle that other. 

PARTICIPANTS: Right. 

MS. EGAN: Okay. When there is one other 

-- two others on the list. 

MR. KERESTESY: Okay. A couple other 

things. 

MR. STEPHENS: Yeah, I just had one about 

the definition of normal cycle. There's at least one 

series of products out there that I think have tended 

to stretch that definition a little far, and I'm 

wondering if the definition couldn't be tightened up a 

little more to more accurately reflect what consumers 

actually use. 

It's possible, for instance, to define the 

normal cycle as a cycle in which no water is heated by 

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the dishwasher, and in fact, there's at least one 

manufacturer that does that. 

MR. KERESTESY: And what's the other 

issue, Charlie? 

MS. EGAN: The energy factors are better 

than what you get soil sensing with clean dishes. 

MR. KERESTESY: You said you had two? 

MR. STEPHENS: No, the other one I'd like 

to wait until the very end. I have a question for 

DOE. 

MR. KERESTESY: Okay, okay, okay. What 

makes more sense? You guys tell me. Shall we talk 

about this for a minute? 

MR. STEPHENS: That means everybody 

familiar with what I'm talking about. 

MR. KERESTESY: Some yeses and some noes. 

MR. GRUNEWALD; You know, the law 

basically states that the normal cycle is what a 

manufacturer recommends for everyday dishes, and I 

think the fact that you found a machine that 

apparently had been run without heat would be in 

conflict with what the definition is of a water 

heating dishwasher because the definition of a water 

heating dishwasher, and that was instituted in 1982 or 

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'83, was that in at least two rinses at one time and 

then later on in one rinse, the water would be heated 

to just about 120. 

So if you have a water heating dishwasher 

which you recommend that they use 120 degree water, in 

my opinion you have to use a normal cycle that would 

meet the decision of a water heating dishwasher, which 

would require that at least one of those fills be to 

120 plus. 

MR. STEPHENS: They are making the 

assumption that based on the DOE test procedure -- 

what's the temperature of the inlet water of the DOE 

test procedure? 

MR. GRUNEWALD: One, twenty, 50 or 140. 

One, forty, no load, nothing, just water. One, twenty 

is because in 1979, 1980 the water heating dishwasher 

was introduced. That's when the load came into being, 

because of the heat load. 

And then the European machines came to the 

country and 50 degree F. was added. So 50 and 120 are 

both water heating dishwashers. 

Definition, the current definition is that 

that means that in one rinse per wash, that water be 

heated to above 120 because when you fill the machine 

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with 120 degree water, you do not have 120 in the 

machine obviously and start down at 95, and maybe your 

last fill may be 120. 

The DOE is saying, hey, one of those 

rinses be heated. Otherwise you don't have a water 

heating dishwasher. 

Then they have defined the normal cycle as 

what the manufacturer recommends. So to me the 

logical interpretation would be that if you intend to 

use the normal cycle, that must include one of the 

heated rinses. I think that would be -- 

MR. STEPHENS: As far as I know. Can you 

imagine another way to get to an energy factor of .93? 

MR. GRUNEWALD: No, but I'm saying that 

may not be in compliance with the act though. 

MR. STEPHENS: Well, except they went to 

get a determination of whether it would be, and they 

were apparently told that it was, and that's why it's 

labeled the way it is today. 

So I guess I'm wondering if that's the 

kind of interpretation we can get, and I think we've 

got a whole set of machines out there that are 

somewhat misleading in their current labeling because 

of that. 

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And I think if the interpretation of the 

rule is such that you can do that and label it that 

way, then perhaps the definition we have today is a 

little too loose. 

MR. MORRIS: This is Wayne. 

I'd like to respond if I could to that, 

and I'd like to ask the department to be very cautious 

about, you know, how we handle this situation. I 

mean, while I understand what Charlie is saying, let's 

be careful not to jump off the deep end because we may 

have one machine out there. Let's ask the department 

to go out and look at this situation and whether or 

not an interpretation, indeed, has been given on that 

situation, and maybe they could deal with that on an 

enforcement type of situation as they choose to do so. 

But if there are not a whole, quote, whole 

bunch of dishwashers out there that are doing this 

kind of thing, then let's not throw the baby out with 

the bath water here. If the definition is held firm 

and is interpreted fairly among all the manufacturers 

or at least 99 plus percent of the models that are out 

there, let's be careful and not going and writing new 

definitions or we're going to end up with the same 

kind of thing that we did with the truncated and all 

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the other things that we've tried to do, is in terms 

of trying to get better, we in come cases make it 

worse. 

MR. STEPHENS: Well, yeah, I understand 

that, but I'm not looking backward. I'm looking 

forward. 

MR. POLLOCK: Charlie, I think what Wayne 

has just said is true. It really sound to me like we 

do have a definition that defines normal in terms of 

the number of heat cycles, and we need to take a look 

at this particular product and see if it meets the 

definition. 

If it does not, then I think it is an 

enforcement issue, and we'll need to revisit that, if 

we have visited it before. I don't know. I'm not 

familiar with a determination that was handed down to 

this particular manufacturer, but if you would give us 

information on that, I will take a look at that again. 

MR. KERESTESY: Do some fact finding. 

Okay. Good, good. 

All right. Bob, do you -- you had some 

written comments which are now actually in front of 

everybody, right? It's part of that package? 

MR. JUDD: The first piece of it is. The 

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first piece is very quick. 

Any dishwashers adversely affected by 

changing definitions of compact and standard models, 

we're not aware of any. 

However, the second piece of that is 

dishwashers adversely affected by the new test 

procedure as was proposed, 70-30 that's in the notice 

of proposed rulemaking. 

For all the stuff we've talked about, we 

don't think that's the right way to go, but I think 

the important point is that today no Whirlpool 

Corporation produced soil sensing dishwasher would 

meet the dishwasher energy consumption standard at a 

fixed ratio of 70-30 min./max. no matter how you 

determine the max. number. 

We think that's not an insubstantial 

number. That's in round numbers 500,000 dishwashers a 

year. It's 25 percent more or less. Ten percent of 

the total dishwasher market was about five million 

units. That's a substantial number of dishwashers. 

That's just ours. 

I don't know what the impact would be on 

other manufacturers. So I think, you know, absolutely 

as you look at your notice of proposed rulemaking, it 

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is not an insubstantial impact on the current 

production of dishwashers. 

There's some discussion in the notice of 

proposed rulemaking about grandfathering existing 

models. That's not an answer for us because we don't 

anticipate, you know, eliminating the current control 

structure in the near future, and in our mind 

grandfathering covers units that are in production at 

the time the rule goes into effect, would not affect 

new model numbers coming down the pike after that, and 

so if the final rule turns out to be 70-30 fixed 

ratio, no matter how you do it, we think the 

consequences that you must go through the process to 

reset the standard based on the impact of the current 

production. 

And I think, you know, from all of the 

discussion today, I think we were kind of people 

feeling that's not the answer, but I think we need to 

keep that issue kind of in front of us, that as 

proposed it has a substantial impact. 

MR. POLLOCK: That's the reason for asking 

the question that you alluded to earlier this 

afternoon. We need to know what the consequences of a 

change will be from all of the manufacturers, and 

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certainly with the numbers of that extent, we need to 

consider how we would deal with that, and you're 

right. We would have to do something with the 

amendment of the standards because having that many 

grandfathered just doesn't make sense. 

MR. STEPHENS: Can I ask a clarifying 

question? When you say 70-30, you've talking 70 

minimum and 30 maximum, right? 

MR. JUDD: Right, correct. But, again, it 

goes back to we think like in the real world one and a 

half percent of the time on average we trip beyond a 

minimum. So anything that puts that much weight on 

the maximum, whether it's a normal max. at eight place 

settings or a theoretical max. is way more energy than 

we ever use in the real world. 

And so that's what a high weighting 

absolutely does to a machine that doesn't use much 

energy over from zero quite a ways up the line, and 

it's a different philosophy, and I don't think the 

intent of DOE is to legislate out one design approach 

over another. 

I think the marketplace ought to do that. 

 We need to have a test that frames up and let's the 

marketplace decide which is the best strategy, but 

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it's got to measure fairly to that. 

MR. KERESTESY: Thanks, Rob. 

Where are we? 

MR. POLLOCK: I don't know if any other 

manufacturers have comments on this particular issue. 

 As we go through this, since we're going to be 

changing the definition of the test cycle, and those 

numbers will have to come back and revisit this 

question when we come up with the new design. 

My preference is not to be in a position 

where we have to adjust the standard, but certainly 

having large numbers of product out there that are 

grandfathered and also restricting, if it's 

appropriate, a design which really does save energy is 

not our intent either. 

So we'll need your help in identifying 

where we are with this and make sure we do the fix 

that makes the most sense and does result in energy 

savings using this type of control strategy. 

MR. JUDD: That's why we're here, to help 

you do that. 

MR. KERESTESY: Other issues? Tom. 

Mr. ECKMAN: This occurred to me going 

back to the round robin test procedure or however it's 

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defined. You guys are going to undertake at least 

some normalization across there. 

To the extent that you have in various 

samples surveys or otherwise that you've taken with 

machines out there, do you collect kilowatt hour per 

consumer per consumer information? Do you meter this 

stuff? 

This is just an open question for the 

manufacturers. You know, Maytag and Whirlpool both 

have 20-some or some number of machines out there that 

you've been monitoring so that you know that one and a 

half times it kicks into beyond the minimum run. 

Do you have kilowatt hour per home or 

whatever in any of those? 

MR. KERESTESY: Wayne? 

MR. MORRIS: I believe I remember asking 

this question at one of the AHAM meetings, and the 

answer that I got back was in some cases yes and in 

some cases no. 

In many cases what the manufacturers were 

looking for was the response to how many times did the 

dishwasher exceed the minimum response, and indeed, 

then what levels or what numbers of responses that 

particular dishwasher gave in terms of its time or its 

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length of cycle or its number of cycles or whatever. 

And we're not metering it to gather actual kilowatt 

hours. 

Other manufacturers in a few cases might 

have done that, but in a broad sort of brush approach, 

the answer is no. All manufacturers didn't just meter 

dishwashers in the field to do that. 

I guess, you know, in retrospect, 

hindsight being what it is, we probably all would have 

loved to have had that data, but it wasn't done, and 

so in some cases might have been. 

MR. JUDD: I think an issue with metering, 

it would have been interesting, but it would have been 

very hard to correlate back to lab test conditions 

because you wouldn't necessarily have an AHAM eight 

place setting loaded, and the thermal loads would be 

different. 

You know, from my personal experience, we 

have a fair range of dish load in a dishwasher, and I 

think, you know, if you're not controlling all of the 

variables that we talked about earlier in the day 

about putting it in the box and doing all of that 

stuff in 120 degree water and all of that stuff, the 

kilowatt hours are interesting, but they don't 

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correlate to anything. 

So it's an interesting point. I 

understand it, but I think outside of test condition, 

it's very hard. 

MR. KERESTESY: Charlie. 

MR. STEPHENS: Yeah, I'm not sure that's 

true necessarily. The refrigerator-freezer test 

conditions don't even begin to resemble how consumers 

use their refrigerators, but oddly enough it comes out 

pretty close to what real consumption is when they do 

because it's designed that way. 

So if you go out and meter it, I don't 

know. We might come up with numbers that are pretty 

good and pretty close, which I'd like to do. So let's 

see if we can't do that. 

MR. KERESTESY: Well, let me ask this 

question since Christine raised the issue of the 

weighting a couple of time, and with all of you here 

maybe to pick your brains about that a little bit, do 

you have enough steam in you to maybe brainstorm a 

little bit about strategy, about options, about method 

or approaches to the weighting? 

It might be good if we could spend a few 

minutes talking about that. It would be a benefit, I 

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think, to DOE and Natascha when they get to that step, 

and we might not have the benefit of everybody being 

together. 

Anybody have a thought on that that they'd 

like to offer to start some discussion about 

weighting? 

MR. JUDD: The first thought that crosses 

my mind, I think, because we have two sets of 

variables going on, it's been very hard to get 

started, and I think until we have some idea of what 

medium is, any discussion about weighting is going to 

be really hard to get any kind of closure on. 

I think we have to fix one set or the 

other of the variables first to have that discussion, 

and I think people have to look at what they think 

their products do against some sort of a straw process 

for that. 

And then the weighting discussion can go 

on, but I think at this point it's so theoretical that 

we're just going to be tilting at stuff and say, well, 

you have -- you can't run that many variables and have 

a meaning discussion, I guess. 

MR. POLLOCK: I guess one of the things 

I'm hearing here, and it concerns me a little bit, is 

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one way to get to the weighting is to come up with our 

definition of what the medium or what the number of 

points we're going to use, then look at how the 

machines actually perform right now and decide on a 

percentage so that we make sure they pass the 

standard. 

The other, which I suspect that people 

down at this end of the room will want is what happens 

in normal operation in the field, and what are the 

real numbers that we should put in there. 

And I don't know how we reconcile those 

two positions, but at some point we're going to have 

to do that. 

MR. GRUNEWALD: I think the key there -- 

this is Grunewald -- the key there is Charles has 

started, that we certainly need more survey data 

because that's the only frame of reference you have to 

how your customers are using that. 

So I'm not volunteering anything because I 

don't know, you know, how our marketing folks would 

think about it, but part of the task that we could 

possibly look at is to start at least -- it would be a 

limited survey, but if you have ten manufacturers or 

eight limited surveys and there is some correlation 

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there and to, yeah, I have it, to use the same 

wording, I mean, settling down on certain types of 

terms and maybe even send a Polaroid out like Randy is 

talking about, then get that idea, I agree with you. 

I don't think we want to set those numbers 

because it needs to pass or not. That would be false. 

 But to get that data and maybe those folks could help 

the manufacturers there because they have the access 

to the public 

MR. POLLOCK: Yeah. That is part of where 

I was going. I don't have the detergent data right 

now, but any additional data that we can get from some 

of the field testing that manufacturers have done, if 

you'd be willing to provide that in some sort of blind 

data form to us so that we would have access to that 

to expand our database, and certainly anything that 

anybody else is aware of that's out there that we 

might use. 

We're limited on what we can do without 

going through a very complicated process to do a 

survey. If need be we can do that, but it requires 

Federal Register notices, approval from OMB, et 

cetera, before we can do that type of survey. So I'd 

rather if we can get your help to get that data so 

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that we can use rather than have to do it ourselves, 

that it would be very helpful. 

MR. KERESTESY: Christine and then Tom. 

MS. EGAN: I'm going to let Tom go first. 

MR. KERESTESY: Tom and then Christine. 

MR. ECKMAN: The reason I raised that 

awful question of has anybody metered this stuff is 

that rather than sort of picking a mid-range number 

out of the hat in terms of loading, that if we had 

some idea of the kilowatt hours a year used and some 

idea of the number of cycles per year used on average 

with some idea of what the dispersion around that 

might be, then it isn't necessarily to go out and 

survey to find out how dirty dishes are and how often 

the soiled dishes are used. 

If we can basically calibrate saying, 

"Look. The used 550 kilowatt hours a year with 265 

cycles," where in the test procedures that we're 

looking at here at zero through eight place settings 

do we see a number that's roughly equivalent to that 

at the federal standard level at the .6 cycles per 

kilowatt hours? 

And then you have some idea. Well, that 

seems to be the average, and you can say that's 

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probably the loading that we ought to be testing 

around as the median case because you can say 

empirically that's tied to total use, if you have the 

sub-metered data where you can actually bring those 

two together, but I'm not sure we do. 

MR. MORRIS: But with Bob's point, you 

would have to control the run environment identical to 

what you're doing with that. 

MR. ECKMAN: No, I'm just basically saying 

if the average consumer right now with an EF .46 

machine out there post '94 uses 500 kilowatt hours or 

550 kilowatt hours, somehow or another those are 

complying machine, and whatever they're doing, that's 

the norm of what's going out. 

You just pick a test level that gets you 

that equivalent at .46. So it just jumps over the 

other question of whether you scrape plates or not. 

It ties the two together. 

MR. MORRIS: It just unfortunately I don't 

think is that simple because as Mike pointed out, you 

don't know how it's behaving. You're going to have to 

match that unit up somewhere somehow. You've going to 

have to find out where its baseline actually is. 

You're going to have to know the model, serial number, 

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when it was produced, and you're going to have to know 

the manufacturer's name on all of that. 

And then you're going to have to try and 

tie that back to what that manufacturer tested that in 

a laboratory environment. 

All of that, I don't know that you can do 

that in the physical realities. I mean if all things 

were unlimited in time and money to throw at this 

thing, sure, but that just isn't reality. 

MR. STEPHENS: Whoa, whoa, whoa. We've 

already been doing some of this stuff. You actually 

don't have to do all of that. I can tie to a 

manufacturer's model number. I can get right down to 

a model number. I can find several thousand of those 

by model number, and I've got AWWA's offer of helping 

us sub-meter the water use at the street. I can 

control for what cycle people are using or get them to 

use a particular cycle, the normal cycle, whatever the 

cycle is we're interested in, and then I can meter 

energy and water use. 

MR. MORRIS: But at the end of the day 

what do you know now? 

MR. STEPHENS: I know that on average 

1,500 households or more use so many -- divided up 

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into manufacturers' model numbers, let's just pick 

some off-the-wall numbers. Let's assume that I've got 

one model number that tests at an energy factor of 

.52, and it, therefore, uses so many kilowatt hours a 

year in accordance with the test procedure now. 

I mean that it -- I don't know what that 

translates to. If I use .56, it's 575 kilowatt hours. 

 I know that number. 

So now I go out and I measure it, and it 

turns out they use 554 on average. So that means the 

test procedure for that model is overshooting what 

real use is, and if my weighting scheme comes up with 

520, then it's too low. If my weighting scheme comes 

up with 580, it's too high. 

MR. MORRIS: But, Charlie, you don't know 

whether that machine was run in partial cycles. 

MR. STEPHENS: Yes, I do. I control for 

that. 

MR. MORRIS: You don't. You don't know 

whether the machine was run at a time when the thing 

had fewer that eight place setting load. 

MR. STEPHENS: Doesn't matter. It's 

measuring how actual households -- how much energy per 

year an actual household will use using that 

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particular model of dishwasher, which is what the test 

procedure is supposed to -- 

MR. MORRIS: You don't know medium load or 

high load or a low load. You don't know any of that. 

MR. STEPHENS: It doesn't matter. 

MR. MORRIS: Yeah, it does. 

MR. STEPHENS: No. According to NAECA the 

test procedure is supposed to as accurately as 

possible reflect actual use in the field regardless. 

I mean, you can design the test procedure however you 

want. It's like the refrigerator test procedure. 

Nobody controls. 

Do you know how the refrigerator test is 

done? You do, right? Does that resemble how 

consumers use their refrigerators? 

Well, I can tell you that the annual 

energy use of a refrigerator actually does come really 

close to the tested values for those refrigerators, 

even though the way consumers use them doesn't really 

resemble at all the way the test is conducted. 

The same case with dishwashers. The test 

procedure doesn't necessarily have to resemble how 

consumers actually use it as long as you feel that 

most of the time the answer you get is reflective of 

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actual use, if that's the goal under NAECA, and 

according to the presentation this morning, it is. 

MR. MORRIS: You went around in circular 

logic there. 

MR. STEPHENS: No. We do this all the 

time. It's if I went out and sub-metered a 

refrigerator and I got a bunch of answers for how many 

kilowatt hours a refrigerator uses, if I compare that 

to the tested value, it's really good. It's really 

close, even though the way that those two numbers were 

derived were totally different, in the lab and in the 

house. 

It doesn't matter. I conclude from that 

that the test procedure, however it's written is 

fairly reflective of how actual energy consumption is 

in the field, which is what we're asking for here. 

Now, I don't guarantee you that that's the 

result we're going to get, but I can at least derive 

some comfort that I know how many kilowatt hours 

various models of dishwashers use compared to how many 

kilowatt hours they're purported to use in accordance 

with the test procedure, and I only care about the 

former. 

MR. MORRIS: Well, thank you very much for 

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what you care about. Unfortunately we're trying to 

get to a test procedure here that we can run in a 

laboratory and it can approximate as close as possible 

what it does in the real world. That is what we're 

after. 

It's not one of these things where 

haphazardly we happen to arrive at that. We're trying 

to actually design that. 

I think that metering data is not going to 

tell us anything, and we're going to sit here for 

hours and hour pouring over data and argue about 

whether or not it's full loads or partial loads or 

whether it was heavily soiled or lightly soiled, and 

at the end of the day, that metered data isn't going 

to tell us anything. 

Whereas if we can go back and take a look 

at the survey situation of how people actually 

pretreat dishes, that is going to tell us something, 

and we've got that data. We don't need to go any 

farther. 

So I think that we need to arrive at the 

situation or we've already talked about doing. Find 

out what the minimum, medium/maximum type of situation 

and responses are, the way it responds individually 

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under those situations, and then let's sit down and 

let's, using the data that we presently have, 

approximate the weighting factors as we can and try 

and get to a test procedure that's workable for the 

manufacturers. 

I just unfortunately don't think that 

metering data, unless we are so absolutely careful in 

that house that we've got a camera on those people all 

24 hours a day, we're not going to really know much of 

anything at the end of the time. Sorry. 

MR. KERESTESY: I think I'll interject 

myself in this one. 

Tom, do you want to say something, and 

then I want to see if anyone else has any comment on 

this point? 

MR. ECKMAN: Yeah, we'll see. 

MR. KERESTESY: Okay, okay. Anybody else 

want to add anything on this discussion of metering? 

Steve? 

MR. PETERSON: Yeah, I think while the 

metering concept theoretically has merit, I would 

agree with Wayne. The practicality of getting down to 

enough single variables to bring back the test 

procedures, well, I think some additional survey work 

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is warranted, taking what we've got and then doing 

some additional survey work. 

I think the point is trying to get to what 

are those consumers doing for that practical load, 

that load they use a lot, and then that's really going 

to help us get to the test procedure. This just has 

too many technical procedures. 

MR. KERESTESY: Is there -- go ahead. 

Sorry. Ed and then Christine. 

MR. POLLOCK: I think that there's 

actually a middle position here in that from DOE's 

point of view I'd like to take a look at all data 

that's available. Certainly if there is metering 

data, it would be interesting to see what that 

represented, especially if we can identify it by model 

number of dishwasher, and especially other survey 

data. 

I mean the bigger database we have, the 

more different perspectives we have on this. 

Hopefully the better understanding we'll have of what 

the results are. I don't want to force it into either 

or at this point in time. Let's look at all of the 

resources we have and see if we can interpret that to 

make sense out of it, to use it to do a better test. 

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MR. KERESTESY: Christie. 

MS. EGAN: We've talked a little bit. 

There's been some discussion of the weaknesses of this 

metering data, and I'm going to put on my consumer 

researcher hat for a second and talk about there are 

definite weaknesses to using this qualitative survey 

data to try to get data on people's habitual behavior. 

You can look a survey data from all kinds 

of habitual behavior. People are really bad at 

representing the habitual behavior within percentages 

that are accurate. 

If you look, if you actually go into 

people's home and ask them, "Pick out the disk that's 

somewhat clean. Pick out the dish that's somewhat 

dirty," and you really start getting -- this stuff is 

based on perception. It's based on behaviors that 

they don't think about in this. 

They don't put their dish in the 

dishwasher thinking, "I think this is a somewhat dirty 

dish. Rather, this one's a somewhat clean dish." 

These are not systems and paradigms that people 

operate within. So you're asking them to put numbers 

to things they don't do. 

This is a highly -- they're going to tend 

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to inflate as a result is my argument because 

basically you're asking them how often do you do 

something. Oh, it's something I should be doing. So 

I do it a fair amount. Clean is good, so I do -- 

you're going to get inflation in this data. 

So you really need to handle that. This 

is probably pushing the limits of what qualitative 

data can do, and so we need to -- I'm the biggest 

advocate of qualitative research, but you really need 

to look at this in a very real, rational way, and I 

think that the metering data -- the DOE is taking the 

right approach on this. A metering data would provide 

a nice counterpoint. 

There's no easy way to get at this 

problem, and asking people how dirty is dirty is 

certainly not a solution because you'd get 32 

definitions around the table of dirt. 

The last thing that I just wanted to say 

on this was to raise the issue that my understanding 

of the concept of these soil sensing dishes is that 

you're supposed to be putting these things in dirty, 

but these are being sold as pieces of equipment that 

minimize the burden on the household. 

And I guess I have a fair amount of faith 

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in the ability of the manufacturing community to 

market consumer benefits like that and would think 

that then the trend would be that we're going to see a 

decrease in the number of people who are prewashing, 

and so that would not in this room, again relooking at 

these numbers, you know, every couple of years, to 

take that long trend vision of -- I understand the 

whole point here is for you guys to get less people to 

prewash. That's what's being sold. 

So if you're successful, then these 

numbers of prewashing today, which seem to range 

anywhere from 60 to 80 are going to be moving down. 

So that makes me a little uncomfortable with being -- 

let me just say it makes 95-5 look a little bit 

entertaining. 

MR. MORRIS: This is Wayne. 

I'd like to just simply remind everybody 

though that is very true, Christine, and I don't have 

anything to disagree with what you said, other than 

that what we're trying to do here is to allow a 

consumer at the point of purchasing the dishwasher 

based on the habits that they come into this with, to 

choose from Model A from Model B, and that's not based 

on how they're going to change their behavior after 

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they have used the machine. That's not what we're 

after here. 

We're after giving them the raw comparison 

at the time that they choose Model A from Model B, and 

they're not going to instantly make the decision based 

on 20 years or 30 years of history with dishwashers of 

saying, "Tomorrow since I bought a soil sensing 

dishwasher I'm going to radically change my behavior," 

because the date that we -- 

MS. EGAN: But it's not an either/or. 

MR. MORRIS: -- even see from the Oregon 

study says they don't because there's not a huge 

difference between those people who are even after 

they have used the soil sensing dishwasher for a 

while, have radically changed their habits of putting 

in heavily dirty or somewhat dirty or whatever dishes. 

MS. EGAN: The only point that I would say 

is I understand and agree with what you're saying, but 

what I'm saying is this product is banking on the 

concept that you are going to convince the consumer in 

2001 to prewash less than the consumer that buys 

today. 

If you create value for this product, that 

people's prewashing habits are going to decrease. 

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Maybe the first person learns not at the point of 

sale, but after using it, but they then tell their 

neighbor, Mrs. Jones, "Hey, this thing's great. You 

don't have to prewash with the thing," and Mrs. Jones 

a year later goes out and buys her dishwasher based on 

point of sale lower prewash habits. 

And so what I'm saying is that's what this 

whole idea is predicated on, is that prewashing is 

going to go down. That's the benefit, the consumer 

value of this product. 

MR. KERESTESY: Yes, Tom and then Bob. 

MR. JOHNSON: Just to follow up on what 

you said, that it's predicated on driving habits to 

less prewashing, there's another aspect of this, and 

it is to give those who prewash a benefit. In other 

words, where they do prewash, they don't have to use 

as much energy as they might do in a dishwasher 

without a sensor. 

So that's the addition benefit, is I do 

prewash and the machine will adapt, and it will 

actually cause me to use less energy. 

MS. EGAN: And I'm all for -- I understand 

that these things, used appropriate, it will actually 

use less energy and water than if the person is 

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spending, you know, five minutes of running water at 

the prewash, and I'm all for that. I just want to 

make sure that this test procedure accurately 

reflects, you know, what's going to be happening with 

how these products are used for something other than 

this static moment. 

MR. KERESTESY: Bob. 

MR. JUDD: Even the risk that I'm not an 

engineer, it seems to me that if you count cycles and 

somehow track what cycles are run and how often the 

sensor actuates over a period of time, you would get 

the information better than tracking watts and water 

because with a machine you know that you should be 

able to in the lab figure out how many kilowatts it's 

using and how much water it's using once you know what 

cycle to select it with, whether it's a rinse all, 

whether it's normal, whether it's pots and pans. 

Whatever cycle, you can filter out the cycles that you 

don't want to look at, and you would have real -- you 

know, over a period of time you'd have real life what 

cycles consumers are choosing and how often the sensor 

actuates to do more than a minimum wash, whatever that 

is. 

And within a brand you could track that 

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data. If you ran some points, you wouldn't have to 

have thousands. My sense is you'd have to run some 

test sites around, but run it for more than a week. I 

think you -- I mean we're looking at data we've run 

for a year and more than a year, and I think to really 

get at where people kind of settle out is to really 

get at that. You can't do it in 30 or 60 days, I 

don't think. 

That's a start. I don't know how fast the 

data would flatten out. 

MR. STEPHENS: I can speak to that a 

little bit. I think I'd probably get an estimate of 

annual consumption in 90 days without too much 

trouble. I can also, if it's possible to do it, I 

don't know that the answer will be clear, but I can 

take the householders for which I have survey data as 

to how they treated their dishes or not, and I can 

correlate that with their energy use and find out if 

there is any correlation with their energy use. 

And I don't know what I'm hearing. I mean 

if I go out and get this information on a model by 

model basis, am I hearing correctly that people aren't 

interested in having that information? 

MR. JOHNSON: Actually I think what you've 

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mentioned, it sounds like a very interesting proposal. 

 I mean it's something that sounds like you've got the 

ability to gather some data that's fairly extensive, 

and I think there is value in doing that. 

In other words, what I'm hearing is you 

can actually -- you'll know how the dishwasher is 

used. You can monitor the amount of water and the 

amount of electricity that it's consuming and, 

therefore, in a sense come up with an energy number 

for that. 

In order to do that for sensor based 

machines though, since we have never established a 

correlation factor between the current DOE energy test 

procedure and what's actually in the field, I would 

think that we should include those in the sample to 

first establish that correlation on a non-sensor based 

machine, and then go ahead and do it on the sensor 

based machine also. 

But, you know, I for one would be very 

interested in that data, and I think there could be 

some great value in that to see if it does truly 

track. 

MR. STEPHENS: It might. I don't know. 

MR. KERESTESY: Randy. 

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MR. COOPER: Are these machines the only, 

I guess, that were bought for the tax credit? 

MR. STEPHENS: They don't have to be. I 

actually can get data through several dealers that we 

work with for any machines that I want. I have 

several dealers that sell most all of the brands, and 

I can pretty much have them help me get a sample of 

anybody's dishwashers that are the ones of interest 

and track them into homes, do the survey, meter their 

energy and water use, and then see if there is a 

correlation between what they tell me in the survey 

and what I see in the energy and water consumption. 

I mean we've been sub-metering electricity 

for a long time, and AWWA has got a way of submetering water now at the street for any fixture in 

the house or all of them, whatever. So we -- 

MR. COOPER: The key I had was that you 

would have to cover all brands. 

MR. STEPHENS: Yeah, we would have to 

cover all the brands of interest, and if we want to do 

some non-sensor models to see, you know, what the 

correlation is, we can do that, too. 

Some of the ones that get a tax credit, 

for instance, are non-sensor models. 

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MR. JOHNSON: And I think some of the 

benefit of doing the baseline of non-sensor machines 

is it takes some of the variability out that comes 

into the field, such as in the test procedure we say 

120 degree water. Do homes truly have that? Some 

have a higher temperature. Some of them have the 120, 

but by the time the water gets to the dishwasher it's 

not 120, and dishwashers will compensate for that. 

But, again, if we take a non-sensor based 

machine and establish that baseline, then we can do a 

comparison to the sensor based. 

MR. STEPHENS: Yeah, and in fact, we could 

probably do that at the same time. We can get water 

temperature in the household. Our average water 

temperature out where we are is about 131 rather than 

120. So we could also collect that information in the 

process of getting it so we could statistically adjust 

what we're seeing to compensate for the fact that it 

isn't 120. 

MR. KERESTESY: Steve. 

MR. PETERSON: Yeah. To add to this 

proposal or, I guess, the question to have, I'd like 

that information especially if the machines that you 

put in the study could be sensor and cycle countered 

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as well, and then I think we could eliminate any 

potential noise out of the study. 

So if we had cycle counters and sensor 

counters I would be happy with that. 

MR. STEPHENS: Yeah, but I don't know how 

to do that. I mean I know how to measure water 

consumption of any fixture or device in the house at 

the street, and I know how to sub-meter electricity 

and get a thermocouple on the water supply, on the hot 

water supply, but I don't know how to count trips of 

censors in individual manufacturers' machines. 

MR. PETERSON: I think the manufacturers 

could provide you with that information. 

MR. STEPHENS: Do you want to provide that 

information? 

MR. PETERSON: Sure. 

MR. JUDD: I mean, I think it would make 

it easier for us to look at each other's data if we 

had some of it measured both ways, and it would make 

it easier for everybody to understand the correlation 

or lack thereof. 

MR. STEPHENS: Well, let's talk about that 

after we wrap this up. 

MR. JUDD: And see how we can do that. We 

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ought to explore it. 

MR. STEPHENS: And see what we can do. 

I'll have to go back and talk about money and size and 

scope and all of that. 

MR. JUDD: Yeah, it wouldn't have to maybe 

be all of it. If would be up to you just to verify 

the correlation or lack thereof that would say either 

we've done enough, it works; we haven't done enough, 

we can't tell if it works; or there's no correlation 

and it doesn't make any sense. 

We could probably get 80 percent of the 

answer with a very few sites. 

MR. STEPHENS: Yeah, I can't tell you what 

the answer is going to be. 

MR. JUDD: But I think, again, it would be 

sharing and kind of helping everybody to think, "Well, 

yeah, I know how. It goes my way, but I don't know if 

I trust it the other ways because they've been trying 

to trick me." 

I don't think it's quite that way, but I 

think that's kind of the underlying concern, that 

somehow there's a win for me if I do it this way, and 

everyone's afraid to let go of their way of doing it. 

MR. KERESTESY: Yeah, Barbara was going to 

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break in. 

MS. TWIGG: I guess I just continue to 

have one point of confusion, and in a way I feel 

almost more confused by the end of today than I did 

when I started. Just in terms of, I mean, one of our 

fundamental inquiries when we started here was really 

understanding how the machines work, what the cycles 

mean, what they do in response to the dirty dishes. 

Like when you all come in now today and 

the piece of data we heard for the first time today, 

which is maybe as Whirlpool was saying only one and a 

half percent of the times would the maximum cycle be 

triggered or something, and to get to that takes an 

incredible dirty load of dishes. 

And then I'm thinking, well, is that so 

unrealistic and basically then your standard cycle is 

set to accommodate fairly modestly dirty dishes. 

And the point that Christine was saying 

keeps rolling around in my mind, too, that if you're 

marketing these machines as you don't have to 

prerinse, let's save energy because you don't have to 

prerinse, and the trend is gradually going to go that 

way, then where is your cycle actually set if your 

assumption, as you say, you want a robust cycle? It's 

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going to clean the various dishes and various degree 

of dirtiness. 

We really do need some different points of 

access to data to kind of clarify, you know, what 

these cycles are doing, what they mean, and what kind 

of dishes they're expecting, and they can accommodate 

in terms of dirtiness. 

MR. PETERSON: Let me make one comment to 

that. One of the other reasons that we think it's 

important to get a test procedure that really covers a 

broader range than we think the max./min. might do is 

that sensor technology is not static. In fact, it's 

probably one of the most dynamic fields in dishwasher 

development. 

We have second generation technology and 

development that could totally change the way 

Whirlpool dishwashers operate. So we think it's 

important to get a test procedure that fairly 

represents any sensor technology because I can tell 

you five years from now ours is not going to be what 

it is today. It's going to be something different, 

and that's true probably of every manufacturer sitting 

around this table. 

So, you know, I don't think we can -- you 

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know, the procedure has to be more representative of 

that outside world and how any particular system 

operates today. It's important for today, but it's 

kind of inconsequential to the long term, and any time 

we put a standard in place, it needs to be robust for 

the long term, and that technology is changing 

rapidly. 

And, you know, there are things that are 

going to be coming that will change the dynamics of 

this so that the test procedure really has to 

represent the consumer usage so that the machines are 

always being measured against consumer usage. 

MR. JUDD: I think another thing to keep 

in mind that's not going to make your job any easier, 

Barbara, but energy performance of soil sensors is one 

of the parameters that manufacturers look at, but it's 

not the only parameter, and energy consumption, while, 

one, we need to meet the minimum or maximum, whichever 

way you want to say, number is to be qualified to 

sell; also to look at what is the step up for Energy 

Star or the rebate programs. 

But also there are other consumer demand 

issues to keep in mind, which is ultimate cleaning 

performance, other parameters. So it's a tradeoff of 

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1323 RHODE ISLAND AVE., N.W. 

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 

various things, and I think, you know, if you were 

looking purely at energy, you would probably design an 

adaptive response control system different than if 

you're looking at a range of parameters for what you 

perceive you as a manufacturer want to -- how you want 

to address consumer demand as you perceive it. 

And I would guess that probably all of us 

look at it a little differently, and we have a 

different philosophy, which is why those curves look 

different and probably always will, and that's 

probably good. 

MR. KERESTESY: I think it's Kyran and 

then I'll wrap this up and ask John to address NRC -- 

answer the NRC question that was raised earlier and 

then maybe close with some comments from you. 

Kyran. 

MS. HOFF: I just had a comment about the 

survey or the metering that you were talking about 

doing. Wouldn't you also have to know what the 

consumer was putting into the product or at least have 

a degree of confidence that across the brands you have 

a large enough sample size for each brand to know that 

it should be pretty much the same? 

Yeah, you're going to have a mix of 

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NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 

consumers that pretreat and those that don't? 

MR. STEPHENS: Yeah, I think you do have 

to have enough of a sample size with each model 

number. So I think obviously you don't want to spend 

so much money and time that you end up with 5,000 

sample households. You'd actually like to do some 

fewer than that, but you also need -- that might 

suggest that we minimize the number of models so that 

we get a good sample for each model that takes into 

account that kind of variation. 

So, yeah, we do need a good sample for 

each model to wash out the consumer variances. 

MR. KERESTESY: I think earlier in the day 

Wayne raised a point about what the NRC position was. 

 Is that the right way to say it? 

MR. MORRIS: Coordination, I think. 

MR. DuPONT: Okay. NRC and CSA both 

operate very much as DOE does, and in subjects like 

this, they look for input from the manufacturers. 

What I'm here to do is to bring back to them as much 

of this input as I can so that they don't have to 

separately go to all of the manufacturers. It's their 

intention to look at anything that's decided here and 

try to harmonize the standard and keep them the same. 

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NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 

 Whether or not in the end they actually do this will 

be dependent on their own committees and their own 

internal operation, but their basic intention is to 

try to make all of these the same totally. 

Does that answer the question? 

MR. KERESTESY: Thank you. Thank you. 

Thank you. Barbara, do you want to wrap this up with 

some closing remarks and maybe some comment about next 

steps? 

MS. TWIGG: Well, it's been a great 

discussion today, and we've certainly learned a lot 

more than we knew before and know some directions in 

which we're going to head. 

I guess it sounds as if one of the major 

next steps is now in the camp of the manufacturers, 

and I guess I'm curious as to what sort of time frame 

you might be thinking about in terms of how you could 

sort of collect the data that you're talking about 

doing. 

MR. MORRIS: We'll get back to you. 

MS. TWIGG: Yeah. 

MR. KERESTESY: Natascha, do you have any? 

MS. CASTRO: Just to jump back to the 

issue of the ambient temperature, we had discussed 

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NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 

that it seemed that everyone was in agreement about 

the benefits of restricting the range that we operate 

under, that we test under, and that we see an 

improvement with a five degree reduction. 

Was there any other comment about that? 

No? Okay. 

I just wanted to make sure that people 

were satisfied with that. Those were the only. 

MR. KERESTESY: Okay. 

MR. POLLOCK: I just wanted to remind 

people that we at the current time do have a written 

comment period, which right now closes on Monday, 

December 13th. 

Certainly we are interested in your 

comments on any of the issues we have discussed today 

where you can add additional detail. We have the 

transcript from today. So it's not necessary to 

repeat what was discussed here today, and if there are 

other ideas for collecting data, other sources of 

data, data that you already have that you are willing 

to share with us, we certainly would appreciate that 

being supplied to us. 

Again, I just want to emphasize that if it 

is proprietary data that you do not want to be made 

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NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 

public, there are two ways that that could be 

provided. One would be through AHAM, where they would 

blind it in some way. 

Secondly, it would be to provide it to us 

in two forms. One, the copy would include the full 

statement with the confidential data, and then 

additional copies provided with that being removed 

from it, anything that's confidential, which would go 

into the public record so that we can treat it in a 

way that protects that confidentiality. 

As I indicated earlier, I believe because 

of where we are on this issue of the test cycle and 

the data as far as the prerinse, we will need to open 

the comment period after we've decided the direction 

that we're going to go. So that will extend the 

rulemaking schedule to some extent. 

What we will do is that data which we 

have, as we compile it, as we get information that we 

can share publicly, we will continue to post that on 

our Web site, to solicit written comment. Hopefully 

we can resolve these issues through that process 

without having the expense and the complication of 

having another workshop. 

However, if we do find that we are bound 

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NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 

up here and that we need a face-to-face, we will 

schedule a workshop. It's not my intent at this point 

though to propose that. And I guess just to close out 

then, if there are no other comments, I just want to 

thank you all. 

Charlie? 

MR. STEPHENS: Yeah, I have one. Just in 

case you thought you'd get away without this one, 

you've expressed your intention not to deal with 

standby energy consumption. Do you -- can you tell me 

when you're going to address that and with what staff 

and whether or not you intend to do that before you 

publish the final rule for the water heater 

rulemaking? 

MR. POLLOCK: I'm not quite sure why it's 

important for the water heater rule. 

MR. STEPHENS: Well, because their standby 

energy consumption is counted right now. 

MR. POLLOCK: Yes, it is, and that's been 

there. That's a little different than some of these 

where it's in control. 

But what we're doing, Charlie, and for 

those of the rest of you, on my research side, not the 

standards side, we are doing some research right now 

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NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 

to get a better idea of the extent of this use and the 

ways it could be addressed. 

At some point in time we are going to have 

to go back, especially now that we're finding more and 

more of the machines have standby power. The reason 

we have been concerned about the dishwasher to date is 

that usually when the door latch is open, there isn't 

standby power. Understand that that is now being 

added. 

So we are studying it right now. At some 

point in time it will have to be added into test 

procedures if it's significant, and I'm not going to 

define significant at this point, although we'll note 

that the court said anything that's measurable is 

significant in the Arrington trial. 

So that's something I don't have exact 

dates on schedule, but it's something that we will be 

working on during this next year and moving forward on 

coming up with some proposal on the way we deal with 

it. 

MR. STEPHENS: So in the next year is the 

answer to when? 

MR. POLLOCK: As I said, I don't have a 

particular schedule. I'm just now getting my hands 

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NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 

around that other part of my office because I have not 

been working with the research side. I have the 

project there, and I'm just starting to get a sense of 

what they can do and how quickly they move, and until 

I have a better understanding and get on top of 

directing that work, I'm sort of shaky about making 

any time commitments. 

MR. KERESTESY: Let me just add my thanks. 

I hope it was a good discussion for you. 

I think there were a lot of ideas brought out, and 

we're ending 20 minutes earlier. That's a wrap. Oh, 

and did you get your forms for the property pass? 

PARTICIPANTS: Yes. 

MR. KERESTESY: Very good. 

(Whereupon, at 3:39 p.m., the meeting was 

concluded.) 

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