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Federal Register / Vol. 86, No. 243 / Wednesday, December 22, 2021 / Proposed Rules
khammond on DSKJM1Z7X2PROD with PROPOSALS2

pump, successful sensor calibration, and machine cleaning without adding significant test burdens. In the August 2019 RFI, DOE requested comment on whether two preconditioning cycles were adequate or more than is necessary to calibrate the soil sensors. DOE also requested comment on whether using the water volumes from the second preconditioning cycle continued to be appropriate for determining the detergent amounts if the sensors were still being calibrated during the second preconditioning cycle. 84 FR 43071, 43076.
AHAM commented that although sometimes unnecessary, two preconditioning cycles ensure that the dishwasher under test is properly calibrated, and manufacturers prefer to keep the existing two cycles for certainty in test results as well. AHAM, No. 5 at p. 6 GEA supported AHAMs comment by reaffirming that two preconditioning cycles increased reliability and reproducibility in test results. GEA, No. 10 at p. 2.
No commenter suggested the use of fewer or additional preconditioning cycles. Based on the above discussion, DOE is not proposing to modify the requirement for two preconditioning cycles currently in appendix C1, and is proposing to apply this requirement to the new appendix C2.
5. Detergent Section 2.10 of appendix C1 specifies using Cascade with the Grease Fighting Power of Dawn powder as the detergent formulation. This section also provides the method to calculate the detergent quantities to be added to the pre-wash if available and main-wash compartments, which is based on the pre-wash if available and main wash water volumes, respectively. In the August 2019 RFI, DOE requested information on whether the current powder detergent specified in appendix C1 results in a test procedure reasonably designed to measure energy and water use during a representative use cycle or period of use and requested comment on the use of a reference detergent. 84
FR 43071, 43076. DOE also requested comment on the method for calculating detergent dosing, including: Whether to continue calculating the detergent dosing based on the measured water fill volumes in the second preconditioning cycle, or whether to specify a fixed amount of detergent; methods to differentiate between the different portions of a wash cycle and ways to appropriately calculate the corresponding detergent dosing; and reliance on manufacturer dosage recommendations. Id.

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AHAM suggested that detergent dosing be evaluated, but advised DOE to maintain the existing powder detergent formulation, stating that this formulation was still representative of powder formulations on the market.
AHAM also supported maintaining the current detergent dosage provisions.
AHAM further stated that detergent impacts performance testing more than it impacts energy testing; thus, it did not need to be changed for energy testing.
AHAM also commented that it would discuss updates to detergent usage as part of its AHAM DW1 process, but that more work is needed to understand the appropriate detergent and amounts to use, and how often formulations change. AHAM, No. 5 at p. 7 GEA
supported AHAMs comment and stated that there is insufficient data on the impact of detergents to the current test procedure or to other test procedures that may be run at the same time 19 to make any change to detergents at this time. GEA, No. 10 at pp. 1, 2
Whirlpool also agreed with AHAM and commented that the current powder detergent referenced in appendix C1 is representative of powder detergents on the market. Whirlpool further commented that, although single dose detergents are the most commonly used detergent type, given the recent rising popularity of single dose detergents, their formulations are not stable because detergent manufacturers make frequent changes and improvements. Whirlpool also suggested that further evaluation was needed to assess the impact of single dose detergents on energy use.
Whirlpool, No. 4 at p. 3 Since publication of the August 2019 RFI and the subsequent end of the comment period, AHAM informed DOE, during the task groups meetings to establish AHAM DW12020, that the powder detergent currently specified in appendix C1Cascade with the Grease Fighting Power of Dawnis no longer commercially available. Instead, a new powder detergent, Cascade Complete Powder, which has a slightly different formulation 20 from Cascade with the Grease Fighting Power of Dawn, is now available on the market. AHAM has updated AHAM DW22020 to 19 GEA did not specify which other test procedures it was referring to that may be run at the same time as the DOE test procedure.
20 Stakeholders mentioned during the AHAM task group calls that they were informed by the detergent manufacturer that the only difference between Cascade with the Grease Fighting Power of Dawn and Cascade Complete Powder is related to the enzymes used in the detergent. DOE was not able to verify this information independently because the ingredient list for Cascade with the Grease Fighting Power of Dawn is not available on product packaging or online.

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reference this new detergent for testing purposes. AHAM DW12020
references AHAM DW22020, both for detergent formulation as well as dosage.
In addition to a change in the detergent to be used for testing, both AHAM DW12020 and AHAM DW2
2020 also specify new dosage requirements in comparison to the current requirements of appendix C1.21
Section 4.1 of AHAM DW22020
specifies the detergent dosage as 1.8
grams per place setting in the main compartment of the detergent dispenser and 1.8 grams per place setting in the prewash compartment of the detergent dispenser or other location. Section 2.10.1 of AHAM DW12020 further specifies to use half the quantity of detergent that is specified in Section 4.1
of AHAM DW22020 for both prewash and main-wash detergent for the energy and water consumption tests. Prewash detergent is specified only for those units if it is recommended by the manufacturers instructions for conditions that are consistent with the test procedure. This includes, but is not limited to, manufacturer instructions that recommend the use of prewash detergent for the normal cycle, normally soiled loads, or for water hardness between 0 and 85 ppm. Additionally, if manufacturer instructions lead to the use of the prewash detergent requirements, the prewash detergent is placed as instructed by the manufacturer or, if no instructions are provided, the prewash detergent is placed on the inner door near the detergent cup.
DOE performed preliminary investigative testing on four standard dishwashers to compare the energy and water consumption results when using 1 the current detergent Cascade with the Grease Fighting Power of Dawn with the current dosage method; 2 the new detergent Cascade Complete Powder with the current dosage method; and 3 the new detergent with the new dosage method. Table III2
presents the detergent quantities for each of the three investigative tests for the four units. Table III3 presents the measured water consumption and estimated annual energy use for these four units when tested according to the three scenarios.
21 As discussed, the detergent dosage for appendix C1 is based on measurements of the prewash fill water volume, if any, and the main wash fill water volume measured during the second preconditioning cycle.

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