20 north wacker drive
suite 123 chicago, illinois 60606
July 27, 1998
Mr. Donald S. Clark
Dear Mr. Clark:
The Association of Home Appliance Manufacturers (AHAM) values the opportunity to respond to the FTC's request for comments published in the May 8, 1998 Federal Register. AHAM is an international trade association that represents the majority of manufacturers that produce and/or sell home appliances, including home laundry equipment, in the United States.
AHAM membership also includes many manufacturers producing the commercial laundry equipment used in Laundromats, apartment complexes and dormitories.
In the May 8, 1998 Federal Register, FTC outlined four key areas in which consideration is being given to amend the Trade Regulatory Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods ("The Care Labeling Rule"). AHAM offers the following comments on these four key areas.
AHAM recommends that FTC amend the Care Labeling Rule to require the use of the following wash water temperatures:
TERM TEMPERATURE RANGES SYMBOL DOTSCold <86ºF (<30C)Warm 87ºF-111ºF (30C-44C)Hot 112ºF-145ºF (44C-63C)
When determining water temperature ranges, FTC must take into consideration that a vast majority of home laundry equipment delivers three distinct wash water temperature ranges that primarily depend on the consumer's installation conditions.
1. Cold: Tap water as it is delivered to the washer. The temperature ranged can be wide, based on geographical location and the seasonal outdoor temperature. An example of this existing range would be tap water temperatures in Minneapolis, Minnesota in January versus tap water temperatures in Phoenix, Arizona in July. While a minimum of 65øF would be preferred, for most products and areas of the country, this simply does not happen.
2. Warm: is a fixed mechanical mixture of cold water with hot water delivered by the water heater. Again, temperature variation is wide and dependent on incoming water temperature and the fixed ratio, (i.e., 40/60, 50/50) established by the product manufacturer.
3. Hot: is water delivered directly from the hot water heater to the washer. The temperature variation is caused by the water heater setting and the heat loss that occurs between the water heater and the washer.
This is the reality of how a typical clothes washer functions. The actual water temperature obtained when using the washing machine settings of hot, warm and cold, vary in North America by region, season, water heater settings, use of hot water in other areas of the home and regulations governing factory-set mixes of water.
Beyond these temperature ranges, AHAM opposes the use of the term "Very Hot." The "hot" range recommended by AHAM includes the temperature range proposed by the commission for "very hot." It is not just an issue of confusing consumers or whether some garments do not need to be cleaned with temperatures above 125ø, it is an issue of the temperatures a product (clothes washer) can provide with the existing water inlet temperatures.
AHAM clearly recognizes the challenge of reconciling water temperatures recommended for good garment care with the reality of the issues identified above. Based on the above considerations, AHAM recommends FTC provide "cold" "warm" and "hot" water temperatures consistent with the clothes washer options available to consumers in their homes.
Labeling for Home Washing
AHAM fully supports the FTC proposal requiring all garments and textiles provide home washing instructions for all products for which home washing is appropriate. The proposed amendment by FTC will result in consumers saving garment care dollars and will lead to reduction in adverse environment impact resulting from the use of perchloroethylene.
On the subject of "dual labeling," AHAM supports the Consumers Union position that the least expensive and least hazardous to the consumer and the environment be presented to the consumer.
Professional Wet Clean Instructions
AHAM recommends that the incorporation of "professional wet clean" instructions as part of the Care Labeling Rule be delayed until the manufacturers can establish a reasonable basis for this method of garment refurbishment. To do otherwise places proven technologies like dry cleaning and home washing at an unnecessary and inappropriate disadvantage. The use of the "professional wet clean" instructions will also lead consumers to believe that this is the most appropriate method though it lacks reliable evidence to document the recommendation.
Reasonable Basis Requirement of the Rule
AHAM supports the FTC proposal that requires garment and textile manufacturers and importers possess before sale, a reasonable basis for the care instructions provided to consumers. Without such information to support the care labeling system, we weaken the entire system and we decrease the potential for consumer satisfaction. Further, we increase the potential for higher garment care expense for consumers. The potential for harm to the environment due to the unnecessary use of dry-cleaning solvents is increased. The potential for using higher and unnecessary amounts of energy is increased. We should make consumers aware of the method most appropriate, least expensive and least harmful to the consumer and our environment.
AHAM strongly encourages FTC to pursue accurate and reliable evidence supporting the instructions on the care label.
Thank you for the opportunity for AHAM to submit comments on this important issue. As noted, AHAM remains concerned over the water temperature recommendations identified by FTC. The cold, warm and hot temperature ranges outlined by AHAM will serve the North American consumers well. AHAM is supportive of the FTC decision on labeling for home washing and the need for a reasonable basis for care label instructions. AHAM's basic position on wet clean instruction is that FTC delay this consideration until further standards and substantiation of the process is in place.
Again, thank you for your due consideration of the AHAM home laundry appliance industry comments on the proposed amendments to the Care Labeling Rule.
Larry M. Forssberg