Federal Register - September 1, 2021
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Source: Federal Register
Federal Register / Vol. 86, No. 167 / Wednesday, September 1, 2021 / Proposed Rules
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individual clothes washer tests: The maximum lifetime specification, marking requirements, and the requirement that mixed lots of material must not be used for testing. All other specifications from section 2.7 of Appendix J2 would be moved to Appendix J3. DOE would add a general statement in section 2.7 of Appendix J2
that the test cloth material and dimensions must conform to the specifications in Appendix J3. These proposed changes are also reflected in the proposed new Appendix J.
DOE requests comment on its proposal to consolidate into Appendix J3 the test cloth specifications and procedures from section 2.7 of Appendix J2 that are not intended to be conducted as part of each individual clothes washer test performed under Appendix J2.
b. Test Cloth Requirements in Appendix J3
Industry has developed a process in which the qualification procedure described above is performed by a thirdparty laboratory, and the results are reviewed and approved by the AHAM
Test Cloth Task Force, after which the new lot of test cloth is made available for purchase by manufacturers and test laboratories. 85 FR 31065, 31071.
DOE has received a request from members of the AHAM Test Cloth Task Force to add to Appendix J3 additional steps to the qualification procedure that have historically been performed on each new lot of test cloth to ensure uniformity of RMC test results on test cloths from the beginning, middle, and end of each new lot. Id. Industry practice is to perform this uniformity check before conducting the procedure to develop the RMC correction factors currently specified in the DOE test procedure, as described previously. Id.
Specifically, the uniformity check involves performing an RMC
measurement on nine bundles of sample cloth representing the beginning, middle, and end locations of the first, middle, and last rolls of cloth in a new lot. Id. The coefficient of variation across the nine RMC values must be less than or equal to 1 percent for the test cloth lot to be considered acceptable for use. Id.
In the May 2020 RFI, DOE sought comment on whether it is necessary to specify any qualification procedure that must be conducted on all new lots of energy test cloth prior to use of such test cloths, as opposed to simply providing requirements for the test cloth without specifying in DOEs regulations the procedure for achieving those requirements. Id. Industry could then
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continue with its current prequalification process, making changes as it determined necessary to improve that process, without the need to seek permission from DOE and participate in a rulemaking proceeding to make such improvements. Id. DOE
also requested comments on whether it is necessary to incorporate the aforementioned test cloth uniformity check into Appendix J3, or whether the current regulations, with the existing requirements for test cloth and qualification procedure, are sufficient to ensure the quality of the test cloth. Id.
DOE requested comment on any burden that results from the current qualification procedure, or would result from incorporating the discussed uniformity check, particularly for small businesses. Id.
AHAM commented that the existing cloth uniformity test is effective and does not need to be changed. AHAM, No. 5 at p. 9 AHAM added that DOE
should consider requiring that each load that is used for testing contains a mix of cloth from the beginning, middle, and end of the lot so that it is representative of the entire lot. AHAM further added that more sampling may be necessary if test cloth lot sizes increase. Id.
With regards to DOEs consideration of test burden, AHAM commented that the current process works well, and that it is not necessary to develop a particular qualification procedure. Id.
NEEA encouraged DOE to adopt an additional test cloth qualification procedure if one is needed to maintain reproducibility, as it would improve transparency. NEEA, No. 12 at p. 25
In this NOPR, DOE is proposing to codify in Appendix J3 the uniformity check described above and to restructure Appendix J3 to improve the overall logical flow of the procedure.
The sections of Appendix J3 are currently structured as follows: 1
Objective; 2 Definitions; 3 Testing Conditions; 4 Test Loads; 5 Test Measurements; 6 Calculation of RMC
Correction Curve; and 7 Application of the RMC Correction Curve.
DOE is proposing to update the objectives included in section 1 to specify that Appendix J3 now includes:
1 Specifications for the energy test cloth to be used for testing clothes washers; 2 procedures for verifying that new lots of energy test cloth meet the defined material specifications; and 3 procedures for developing the RMC
correction coefficients.
In section 2 of Appendix J3, DOE is proposing to add a definition for the term roll, which refers to a subset of a lot, and to remove the definition of roll from Appendix J2.
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DOE is proposing to create a new section 3, Energy Test Cloth Specifications, that would specify the test cloth material, dimensions, and use requirements as currently specified in section 2.7 of Appendix J2.
DOE is proposing to change the title of current section 3 of Appendix J3, newly renumbered as section 4, from Testing Conditions to Equipment Specifications. This section would contain the specifications for the extractor currently specified in section 3.2 and the bone-dryer currently specified in section 3.3. DOE proposes to merge the current specification in section 3.1 of Appendix J3 which specifies the extractor spin conditions to be used with the proposed edits to newly renumbered section 8 RMC
Correction Curve Procedure, as described below.
DOE is proposing to create a new section 5, Pre-Conditioning Instructions, in Appendix J3 that would specify the instructions for preconditioning test cloth, as currently specified in section 4.1 of Appendix J3, with a clarifying wording change.
Currently, the second paragraph of section 4.1 in Appendix J3 specifies Perform five complete wash-rinse-spin cycles, the first two with current AHAM
Standard detergent Formula 3 and the last three without detergent. The last sentence of that paragraph specifies:
Repeat the cycle with detergent and then repeat the cycle three additional times without detergent, bone drying the load between cycles for a total of five complete wash-rinse-spin cycles.
DOE is concerned that the wording of the last sentence could be misconstrued as requiring the repeating of the entire sequence of five wash-rinse-spin cycles specified in the first sentence. To avoid this potential misinterpretation, DOE is proposing to replace the last sentence with the following: Dry the load to bone-dry between each of the five washrinse-spin cycles.
DOE is proposing to create a new section 6, Extractor Run Instructions, in Appendix J3 that would specify the instructions for testing test cloth in the extractor at specific spin speed and time conditions, as currently listed in sections 5.1 through 5.10 of Appendix J3, with some minor organizational changes.
DOE is proposing to create a new section 7, Test Cloth Material Verification Procedure, in Appendix J3
that codifies the uniformity check procedure described above.
DOE is proposing to add a new section 8, RMC Correction Curve Procedure, in Appendix J3 which would consolidate the provisions
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