Federal Register - September 1, 2021
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Source: Federal Register
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Federal Register / Vol. 86, No. 167 / Wednesday, September 1, 2021 / Proposed Rules
testing.72 In particular, DOE observed that the material properties of the energy test cloth had a significant effect on the RMC measurement,73 which as discussed was added to Appendix J1
2001 to measure the effectiveness of the final spin cycle in removing moisture from the wash load. As described in the test cloth report, the final specifications for the energy test cloth were developed to be representative of a consumer load:
A 50-percent cotton/50-percent polyester blended material was specified to approximate the typical mix of cotton, cotton/polyester blend, and synthetic articles that are machinewashed by consumers. In developing the test cloth specifications, DOE also considered:
b Manufacturability: A 50/50 cottonpolyester momie weave was specified because at the time, such cloth was produced in high volume, had been produced to a consistent specification for many years, and was expected to be produced on this basis for the foreseeable future. 66 FR 3314, 3331.
b Consistency in test cloth production: The cloth material properties were specified in detail, including fiber content, thread count, and fabric weight; as well as requirements to verify that water repellent finishes are not applied to the cloth. Id.
b Consistency of the RMC
measurement among different lots: A
procedure was developed to generate correction factors for each new lot i.e., batch of test cloth to normalize test results and ensure consistent RMC
measurements regardless of which lot is used for testing. Id.
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1. Test Cloth Specification In the May 2020 RFI, DOE requested comments on manufacturers and testing laboratories experience with the current test cloth specifications and whether DOE should consider any changes to the energy test cloth specifications to reduce burden and improve testing results. 85 FR 31065, 31071.
AHAM commented that it would strongly oppose changing from the uniform test cloth to a more varied load.
72 Development of a Standardized Energy Test Cloth for Measuring Remaining Moisture Content in a Residential Clothes Washer. U.S. Department of Energy: Buildings, Research and Standards. May 2000. Available online at www.regulations.gov/
document/EERE-2006-STD-0064-0277.
73 The RMC measurement is an important aspect of DOEs clothes washer test procedure because the RMC value determines the drying energy, which is the largest contributor to IMEF. Based on the Technical Support Documents from the March 2012
Final Rule, drying energy represents 65 percent of the total energy for a 2015 baseline-efficiency toploading standard RCW, and 72 percent for a 2015
baseline-efficiency front-loading standard RCW.
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AHAM stated that the clothes washer test procedure requires the use of a uniform test cloth to produce repeatable and reproducible results. AHAM, No. 5
at p. 3 According to AHAM, the introduction of a real-world load that includes items with different weights, sizes, and materials could introduce significant variation in the test procedure. AHAM stated that sufficient data have not been provided that would demonstrate acceptable repeatability and reproducibility using a real-world test load. Id.
GEA recommended that DOE not change the current test cloth specifications, noting that significant work has gone into addressing the myriad complexities with test cloth variation. GEA, No. 13 at p. 2
DOE is not proposing any changes to the test cloth specification.
2. Consolidation to Appendix J3
Appendix J3 specifies a qualification procedure that must be conducted on all new lots of energy test cloth prior to the use of such test cloths in any clothes washer test procedure. This qualification procedure provides a set of correction factors that correlate the measured RMC values of the new test cloth lot with a set of standard RMC
values established as the historical reference point. These correction factors are applied to the RMC test results in section 3.8.2.6 of Appendix J2 to ensure the repeatability and reproducibility of test results performed using different lots of test cloth. The measured RMC of each clothes washer has a significant impact on the final IMEF value.
DOE is proposing several structural changes to Appendix J3 to consolidate all of the test cloth specifications and procedures some of which are currently located in Appendix J2 that must be evaluated on each new lot of test cloth.
Consolidating into a single test procedure will improve the overall logical flow of both test procedures and clarify that the test cloth procedures need not be conducted for each clothes washer under test. As described further, the proposed changes would remove from Appendix J2 specifications and procedures that are not intended to be completed for every clothes washer test.
The proposed edits would also formally codify additional qualification procedures that are currently conducted for every new lot of test cloth.
a. Test Cloth Requirements in Appendix J2
Section 2.7 of Appendix J2 Test cloths contains specifications and procedures regarding the test cloth.
Sections 2.7.1 and 2.7.2 specify the
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unfinished and finished dimensions, maximum lifetime, and marking requirements for energy test cloth and energy stuffer cloths, respectively.
These sections also specify that mixed lots of material must not be used for testing. Section 2.7.3 specifies a procedure for preconditioning new test cloth, which requires performing a series of five wash cycles on all new unused test cloths before the cloth can be used for clothes washer tests. Section 2.7.4 provides the material specifications fabric type, fabric weight, thread count, and fiber content for the energy test cloths and energy stuffer cloths, as well as three industry test methods that must be performed to confirm the absence of any waterrepellent finishes and to measure the cloth shrinkage after preconditioning.
Section 2.7.5 references Appendix J3 for performing the standard extractor procedure to measure the moisture absorption and retention characteristic of each new lot of cloth.
Several of these provisions within section 2.7 of Appendix J2 are not intended to be conducted as part of each individual clothes washer test performed under Appendix J2. Based on discussions with the AHAM Test Cloth Task Force, DOE is aware that some of the test cloth provisions in section 2.7
of Appendix J2 are performed by a third-party laboratory on each new lot of test cloth, avoiding the need for manufacturers and test laboratories to perform the same procedures for each individual clothes washer test. 85 FR
31065, 31071.
In the May 2020 RFI, DOE requested comments on whether to consolidate into Appendix J3 provisions from section 2.7 of Appendix J2 that relate only to the testing of the test cloth and are not required to be performed for each individual Appendix J2 clothes washer test. Id. DOE also sought comment on whether to remove these provisions entirely. Id.
AHAM supported the consolidation of section 2.7 of Appendix J2 provisions into Appendix J3, stating that doing so would mitigate testing burden. AHAM, No. 5 at p. 9
NEEA supported reorganization of the test procedure to put all test cloth qualification and lot correction information into the separate Appendix J3 test procedure, as this would add clarity and improve ease of use. NEEA, No. 12 at p. 25
In this NOPR, DOE is proposing to move most of the specifications from section 2.7 of Appendix J2 to Appendix J3. Section 2.7 of Appendix J2 would retain the following specifications, which are relevant to the conduct of
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