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Federal Register / Vol. 86, No. 243 / Wednesday, December 22, 2021 / Proposed Rules
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mitigate burden, DOEs proposal additionally specifies that non-soilsensing dishwashers are required to test the medium and light soil loads only if the next-greater soil load requires the use of the most energy-intensive cycle.
To estimate the testing burden associated with this proposal, DOE
estimates that most non-soil-sensing dishwashers would only be tested at the heavy soil load. Therefore, DOE
estimates the total testing duration for non-soil sensing dishwashers under the proposed appendix C1 to be 9.5 hours 2.5 hours to soil the load + 1 hour to score the load and calculate cleaning index.
Based on data from the Bureau of Labor Statistics BLSs Occupational Employment and Wage Statistics, the mean hourly wage for electrical and electronic engineering technologist and technician is $29.27.35 Additionally, DOE used data from BLSs Employer Costs for Employee Compensation to estimate the percent that wages comprise the total compensation for an employee. DOE estimates that wages make up 70.4 percent of the total compensation for private industry employees.36 Therefore, DOE estimated that the total hourly compensation including all fringe benefits of a technician performing these tests is approximately $41.58.37 Using these labor rates and time estimates, DOE
estimated that it would cost dishwasher manufacturers approximately $1,165 to conduct a single test on a soil-sensing dishwasher unit and approximately $395 to conduct a single test on a nonsoil-sensing dishwasher unit.38
DOE requires at least two units to be tested for each basic model prior to certifying a rating with DOE. Therefore, DOE estimates that manufacturers would incur testing costs of approximately $2,330 per soil-sensing dishwasher basic model and approximately $790 per non-soilsensing dishwasher basic model. The 35 DOE used the mean hourly wage of the 17
3027 Mechanical Engineering Technologists and Technicians from the most recent BLS
Occupational Employment and Wage Statistics May 2020 to estimate the hourly wage rate of a technician assumed to perform this testing. See www.bls.gov/oes/current/oes173027.htm. Last accessed on July 26, 2021.
36 DOE used the March 2021 Employer Costs for Employee Compensation to estimate that for Private Industry Workers, Wages and Salaries are 70.4 percent of the total employee compensation. See www.bls.gov/news.release/
archives/ecec_06172021.pdf. Last accessed on July 26, 2021.
37 $29.27 0.704 = $41.58.
38 Soil-sensing dishwasher: $41.58 28 hours =
$1,164.24 rounded to $1,165 Non-soil-sensing dishwasher: $41.58 9.5 hours = $395.01 rounded to $395.

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incremental increase in testing costs under the proposed updates to appendix C1 compared to the current appendix C1
would be approximately $250 per soilsensing dishwasher basic model and approximately $290 per non-soilsensing dishwasher basic model.
DOE requests comment on its initial determination as to the impacts from the proposed amendments to appendix C1
related to the rated energy and water use of currently certified dishwashers. DOE
also requests comment on the potential impact to manufacturers from the updates proposed to appendix C1.
Finally, DOE requests comment on its estimated costs for testing soil-sensing and non-soil-sensing dishwashers according to the proposed appendix C1.
In addition to the proposed amendments to appendix C1, DOE is also proposing a new appendix C2. As proposed, use of appendix C2 would be required in conjunction with the compliance date of future amendments to the energy conservation standards for dishwashers, should such amendments be adopted. The proposed change to the annual number of cycles and low-power mode hours, both of which are used for the calculation of energy consumption, would change certain inputs to the calculation, but would not impact the burden as compared to conducting the calculation under the current test procedure.
Another proposed update in the proposed appendix C2 would require the use of a new detergent type and method to calculate the detergent dosage. Based on testing that DOE
conducted in support of the October 2020 Final Rule, DOE estimates that the updated detergent dosage methodology would reduce testing time by about 1
hour because the new methodology estimates detergent dosage based on the number of place settings as opposed to the prewash and main wash fill water volumes as required under the current and proposed appendix C1 test procedure. Determination of the prewash and main wash fill water volumes requires about 1 hour to identify the prewash and main wash phases of a test cycle, isolating the water consumed during these specific portions of the cycle, and then calculating the quantity of detergent required.
Based on these estimates DOE
anticipates the total duration to test soilsensing dishwashers according to the newly proposed appendix C2 would be 27 hours. Similarly, DOEs estimate of the total duration to test non-soilsensing dishwashers according to proposed appendix C1 would be 9.5
hours. Therefore, the total duration to test non-soil-sensing dishwashers
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according to the newly proposed appendix C2 would be 8.5 hours. Using the same labor rates as those used to estimate the testing costs for the updates proposed to appendix C1, DOE
estimated that it would cost dishwasher manufacturers approximately $2,246 per soil-sensing dishwasher basic model and approximately $705 per non-soilsensing dishwasher basic model.39
These costs would be for testing pursuant to newly proposed appendix C2, and as proposed, testing pursuant to new appendix C2 would only be required at such time as compliance is required with amended energy conservation standards for dishwashers, should such amendments be adopted.
DOE will address the expected costs to industry if and when DOE establishes energy conservation standards for dishwashers.
DOE requests comment on the potential impact to manufacturers from the updates proposed to the newly proposed appendix C2. Specifically, DOE requests comment on the per basic model test costs associated with testing soil-sensing and non-soil-sensing dishwashers.
2. Harmonization With Industry Standards DOEs established practice is to adopt industry test standards as DOE test procedures for covered products and equipment, unless such methodology would be unduly burdensome to conduct or would not produce test results that reflect the energy efficiency, energy use, water use as specified in EPCA or estimated operating costs of that equipment during a representative average use cycle. Section 8c of 10
CFR part 430 subpart C appendix A. In cases where the industry standard does not meet EPCA statutory criteria for test procedures, DOE will make modifications through the rulemaking process to these standards as the DOE
test procedure.
The current test procedure for dishwashers at appendix C1 references ANSI/AHAM DW12010 in definitions and for testing conditions, and IEC
62301 Ed. 2.0 for test conditions, equipment, and standby mode power consumption measurement. The industry standards DOE proposes to reference via amendments described in this notice are discussed in further detail in Section III.B and Section IV.M
of this document. DOE requests comments on the benefits and burdens 39 27 hours testing time per soil-sensing unit
$41.58 per hour 2 units per basic model =
$2,245.32 rounded to $2,245 and 8.5 hours test time per non-soil-sensing unit $41.58 per hour
2 units per basic model = $706.86 rounded to $705

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