Measuring water use in a commercial clothes washer

We are looking to verify how the water use in a commercial clothes washer is calculated to see if it complies with the baseline of 9 gal/ CF/ cycle. The washer in question (60 gal; 9.5 cf) has an empty drum water use of 8 gal/ CF/ cycle. However, depending on how many clothes are added, and if an additional rinse cycle is added to a specific load, the water use can go up to 12 gal/ CF/ cycle. We are unable to use the Energy Star Water Factor since washers of this size are not Energy Star certified. Does anyone have any knowledge if this is measured based on empty drum, average drum use, full drum use, extra rinse cycles, etc.? This item is challenging with not much information in the Reference Guide. Thanks in advance.