October 27, 1993                           403 West Fourth Street North
                                           Newton, Iowa 50208
                                           Telephone: 515.792.3000
                                           MAYTAG
                                           Corporation
Ms. Maria Olsen VIA FAX TO: 202-514-0452

Re:   Meeting With Representatives of Maytag Company
      Friday, October 29, 1993
      10:00 a.m. E.D.T. to Noon E.D.T.
      Department of Justice Room 4039

Dear Ms. Olsen:

Thank you for agreeing to meet with representatives of Maytag Company.
Attending on  behalf of Maytag in addition to Mr. Horstman and myself will be
Doug Ringger,  Director, Product Planning; Dave Ellingson, Director, Advance
Engineering; Randy  Karn, Commercial Regional Sales Manager; and Steve
Holdsworth, Product Information  Specialist. I understand that attendees from
your offices will include at least  yourself and Mr. Wodatch. I also
understand that a member of Senator Grassley's  staff will also be attending.

Enclosed find copies of the following:
      1.     My September 1, 1992 letter to Mr. Wodatch (3 pages).

      2.     Various portions of ADA Accessibility Guidelines reference in
             enclosure #1 (4 pages).

      2.     The Department of Justice's July 21, 1993 letter (8 pages).

As you may be aware, the Department of Energy's May 14, 1991 (56 Federal 
Register  22250) final rules on energy standards caused the entire laundry 
manufacturing  industry to investigate the possibility of manufacturing 
horizontal axis washing  machines. Historically, these types of washing
machines were described as "front-loading". In general, horizontal axis
washing machines use less water (including less hot water) and therefore use
less energy than top-loading washing machines with which you are familiar (and
may have in your residence). Several European manufacturers are currently
producing top-loading horizontal axis machines.

Maytag has requested this meeting because it is rapidly approaching some 
critical  decisions concerning potential applicability of horizontal axis 
technology. Those  decisions will take into account the additional information 
you will provide.

Maytag needs additional information concerning the following regulations: ADA 
Title III, Uniform Federal Accessibility Standards, and Housing and Urban 
Development.  Specifically, Maytag would like to discuss and resolve the 
following issues:

     What ADA/UFAS/HUD/ANSI "requirements" apply to the "reach to load and
     unload clothes" from top-load clothes washers and clothes dryers (please
     refer to page 5, 91 of the DOJ's July 21, 1993 letter)?
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2.   Do you consider the Thomson & Miele machines (pictures of which will be  
     provided to you during our meeting) to be ADA accessible? If so, do you  
     consider them as meeting UFAS requirements?
     HUD requirements?

3.   Under UFAS and HUD (both based on ANSI 117.1-1986), front-load washers 
     appear to be conclusively presumed to be accessible.  Why? For example:

    a.   Many of their containers for detergent, fabric softener, and other
         laundry  aids (as well as coin slides) are placed over
         obstructions higher than  34".

    b.   Isn't it as easy for a disabled individual to load and unload
         clothing  from a top-loading washer as it is from a front-loading
         washer (for example, the Miele product)?

4.   How many (number/percentage) ADA-accessible machines must be installed   
     in the following circumstances:

    a.   New laundry facilities (coin store, common use laundry facilities
         in multi-family housing/dormitories).

    b.   "Altered" laundry facilities.

    c.   To replace existing equipment in otherwise unaltered pre-ADA 
         laundry facilities? At what point does replacing only equipment
         make the  facility become "altered", thereby possibly triggering
         path of travel alterations? (Two machines? Three?

    d.   Same questions concerning "front-loading" equipment

 5.   In addition to universities that receive Federal funds, what other types 
      of federal involvement would constitute the "receipt of Federal funds"   
      thereby requiring laundry areas to comply with UFAS?

 6.  Which, if any, of the ADA/UFAS/HUD regulations affect privately-owned 
     multiple family dwellings?

Sincerely,


James M. Gran
Associate Counsel

cc:  Doug Hortsman VIA FAX TO: 703-442-9587
     Randy Karm VIA M TO: 609-988-3842
     Doug Ringger
     Dave Ellingson
     Steve Holdsworth

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