Federal Register - December 22, 2021
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Source: Federal Register
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Federal Register / Vol. 86, No. 243 / Wednesday, December 22, 2021 / Proposed Rules similar factor for soil-sensing dishwashers. Samsung No. 9 at p. 3
The soil load specified in appendix C1 has been developed by DOE to produce a measure of energy and water use of soil-sensing dishwashers in a representative usage cycle. At this time, DOE does not have data on the operation of a soil-sensing function that would suggest that a field use factor to adjust testing results would be appropriate. Therefore, DOE is not proposing in this NOPR a field use factor for appendix C1 or the new appendix C2.
DOE did not receive any data regarding pre-rinsing by consumers.
Although Samsung stated that there has been consumer advocacy to reduce prerinsing in recent years, no data have been presented to indicate whether or to what degree consumers have changed pre-rinsing habits. Absent such data, DOE is not proposing any changes to the soil loads.
DOE continues to request feedback and data regarding soiling level and whether there have been changes to consumers pre-rinsing behavior. DOE
also seeks information regarding the impact of different soil levels on energy and water use in dishwashers currently on the market.
Section 2.7.4 of appendix C1 states that the soils shall be as specified in Section 5.4 of ANSI/AHAM DW1
2010, except for the following substitutions:
Margarine. The margarine shall be Fleischmanns Original stick margarine.
Coffee. The coffee shall be Folgers Classic Decaf.
Additionally, Section 2.7.5 of appendix C1 states that soils shall be prepared according to Section 5.5 of ANSI/AHAM DW12010, with the following additional specifications:
Milk. The nonfat dry milk shall be reconstituted before mixing with the oatmeal and potatoes. It shall be reconstituted with water by mixing 2x 3 cup of nonfat dry milk with 2 cups of water until well mixed. The reconstituted milk may be stored for use over the course of 1 day.
Instant mashed potatoes. The potato mixture shall be applied within 30 minutes of preparation.
Ground beef. The 1-pound packages of ground beef shall be stored frozen for no more than 6 months.
DOE notes that Table 3 in Section 5.4
of AHAM DW22020 specifies FleischmannsTM Original Stick margarine and FolgersTM Classic Decaf coffee, consistent with DOEs substitutions in Section 2.7.4 of appendix C1. These AHAM DW22020
soiling specifications are also referenced
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in Section 2.7.4 of AHAM DW12020.
Therefore, DOE proposes to remove the substitution for margarine and coffee from regulatory text in appendix C1 and apply the soiling requirements in Section 2.7.4 of AHAM DW12020
instead.
Additionally, Section 2.7.5 of AHAM
DW12020 includes the additional soil preparation requirements for milk, instant mashed potatoes, and ground beef, which are currently specified in appendix C1. Therefore, DOE proposes to remove the additional soil preparation specifications from Section 2.7.5 in appendix C1 and apply the requirements in Section 2.7.5 of AHAM
DW12020 instead.
DOE requests comment on its proposal to remove the soil substitution and soil preparation requirements from Sections 2.7.4 and 2.7.5 of appendix C1
and apply these same requirements from AHAM DW12020 instead. DOE
particularly requests data and information on how the proposed soil composition would affect energy and water use in current dishwashers.
3. Loading Pattern Section 2.6 of appendix C1 references Section 5.8 of ANSI/AHAM DW12010
for loading the dishwasher prior to running active mode tests, which requires loading in accordance with the manufacturers recommendation. In the August 2019 RFI, DOE requested feedback on whether any additional instructions are needed beyond referencing a manufacturers loading recommendation. 84 FR 43071, 43076.
DOE also requested information on how consumers typically load dishwashers.
Id. DOE stated that although manufacturer instructions may optimize loading patterns to maximize loading capacity and dishwasher performance, consumers may use other loading positions and alignment, leading to variability in dishwasher performance.
Id.
AHAM stated that the lack of loading specificity in appendix C1 is a source of test procedure uncertainty. AHAM
stated that the positioning of soiled items relative to unsoiled items may impact the rate at which soils are removed from the test load items, which may impact soil sensor responses.
AHAM recommended that the test procedure establish the same loading instructions as Section 5.1D of the ENERGY STAR Cleaning Performance Test Method. AHAM added that the purpose of a specific loading pattern is to reduce variation in testing results, not necessarily to emulate consumer use.
AHAM commented that consumer loading patterns are likely difficult to
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replicate in the test procedure. AHAM, No. 5 at p. 6
GEA also supported changing the loading pattern to conform with Section 5.1D of the ENERGY STAR Cleaning Performance Test Method. GEA, No. 10
at p. 2 The Joint Commenters stated that they support additional specificity to the test procedure regarding the loading pattern to improve reproducibility of test results among test laboratories. Joint Commenters, No. 8 at p. 1.
As stated in the August 2019 RFI, DOE recognizes that the positioning of soiled test load items in relation to unsoiled ones could impact the rate at which soils are removed from the test load items, and therefore also impact soil sensor responses. 84 FR 43071, 43076. This could lead to variation in energy and water consumption.
Specifying a loading pattern requirement would improve the repeatability of the testing procedure and reproducibility of results across both individual tests and testing facilities. Since submitting its comments, AHAM has included the loading pattern requirements specified in the ENERGY STAR Cleaning Performance Test Method in Section 2.6.3.4 of AHAM DW12020. These requirements are applicable to soilsensing dishwashers that are tested with both, clean and soiled place settings.
DOE proposes to apply these AHAM
DW12020 loading requirements to appendix C1 and the new appendix C2
to reduce potential variation in the test procedure. Additionally, these loading requirements would apply to both soilsensing and non-soil-sensing dishwashers as non-soil-sensing dishwashers would be required to use soil loads for testing under DOEs cleaning index threshold proposal discussed in Section III.G of this document.
DOE requests input on its proposal to use the loading requirements specified in Section 2.6.3.4 of AHAM DW1
2020.
4. Preconditioning Cycles Section 2.9 of appendix C1 requires manufacturers to precondition the dishwasher by running the normal cycle twice with no load after the testing conditions are established. The prewash fill water volume, if any, and the main wash fill water volume are measured during the second preconditioning cycle to calculate the detergent amounts to be used during the energy and water consumption tests. The prescribed procedure ensures an accurate calculation of detergent dosing, priming of the water lines and sump area of the
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