Carbon Monoxide Legislation

Larry (from OSHA)

on the front page right on top was this article about the impending requirements for residential CO monitors in all dwellings. Spurred by a tragic death, this will require the current variety of CO monitors available to be installed.

I will be contacting the reporter who wrote this article. I need some facts before I do.

Mark Hunt (and anyone else) are you able to help me?

If anyone can provide some hard data on detector quality, etc. I would greatly appreciate it. Reporters thrive on facts and I'd love to provide some good information.

The story link is here:

<a href="http://www.startribune.com/462/story/471785.html">CO</a>

You will note that lobbying from the CO monitor manufactures was apparently a large part of this happening. I believe that they would make detectors to whatever specs were required. I would like to get the specifications for residential carbon monoxide monitors changed to be more protective.

Any help will be greatly appreciated.

Thank you.

Larry

Unknown

Larry get in touch

with George Kerr at e-mail gekerr@tds.net or call him at 417-426-5504 he will be able to give you plenty of good information. He owns CO Experts the manufacturer of a low level CO detector.

Rudy

Hi Larry

Feel free to give me a call as well. Got Jury Duty tomorrow first thing, we'll see how that pans out!!

412-576-1350

IMHO, the manufacturer's are going to only want UL2034 alarms approved, even though all of them recommend low level (non-UL approved) alarms in their own literature for homes with elderly, children and folks with health problems... Go figure

Robert O'Connor_12

CO detectors

Good bill.

I'm glad other states are catching on!

Here is the great state of New Jersey's adoption.I'll see if I can get more info.


http://www.state.nj.us/dca/dfs/carbonmonoxidedet.pdf

http://www.state.nj.us/dca/dfs/bullet2003three.doc





Robert O'Connor/NJ

Weezbo

Larry,i expect the Electrical code will be changed in the next

few years to reflect just that perspective . In order to make these changes generally requires that people unite for a common cause to communicate corrective changes,until then presenting and compiling the information and puting that together as you are doing will bring you to the table well equiped to clarify the minor technicalities involved.
Presenting that information is like farming,not everyone everywhere will gather what you are saying the first go around,no problem,information takes time to sink in

Did you check in at the Beans site,HealthyHeating .com and check in on The CO forum? the more outlets to the educated reasoning public the better Good Luck.

Mark Hunt

Gimme a bit


to study the complete story.

The time is drawing near when this @!#$# is going to stop.

Mark H



To Learn More About This Professional, Click Here to Visit Their Ad in "Find A Professional"

Bob Harper

UL 2034

Here's one place we need to attack the problem:
The Standards Technical Panel (STP) for Carbon Monoxide Alarms & Gas Detectors, STP 2034, is seeking members in the interest category of user. This STP is responsible for UL 2034, Standard for Single & Multiple Station Carbon Monoxide Alarms and UL 1484, Standard for Residential Gas Detectors; and UL 2075, Standard for Gsa and Vapor Detectors and Sensors.
This is a call for members for the UL STP for CO alarms. STPs need a mix of members from mfg., education, contractors, etc. to provide a balanced view. I suggesty Mark Hunt, Rudy Leatherman, and Timmie McElwain check into membership.

There is so much info. out there now about how miserable current off the shelf CO alarms are I can't understand why UL 2034 has not seen a storming of the Bastille. That piece Rudy did with the TV station was an eye opener for many hardliners. Before we pass more panic legislation, we need the voice of reason.

Aside from requiring reliable low level CO alarms, there is a whole iceberg floating around the ocean which everyone seems to be avoiding. We all know the value of a comprehensive program for performance testing of combustion equipment but no one wants to take it on. We keep beating around the bush. Sure, it will take a lot of arguing and negotiating and not everyone will be happy with the end product but it needs to start somewhere. There are some great models to draw on such as Europe. In Germany, everything from design, to commissioning to annual checkups are state mandated, enforced, and accepted. The chimney sweeps are very highly trained to study plans, run calculations, inspect, measure, and verify systems. They measure the actual flue volume and test for patency of the flue. They run combustion analysis and house pressure diagnostics.

Yes, we can all dream. Done correctly, legislation can save lives and force builders and contractors to build better homes. Rushed through in response to public furor in an election yr. can be disastrous and a logistical nightmare such as Mass.

Larry (from OSHA)

Thanks

to all who have responded. We'll see where this one goes.

Larry

John R. Hall

One baby step at a time

I applaud the Minnesota legislature for moving forward with requiring CO detectors in new and existing homes, albeit reative rather than proactive. At this stage of the game, all legislature is reactive anyway. But I also know that their step, like others, is a small and necessary one. Is it a good step or just a step? I believe it is just a step, as my distinguished and experienced friends here would probably agree with.

Should UL 2034 be challenged and reworked? Absolutely. I am all for a much stronger testing standard and better CO detector. But let's be somewhat realistic, too.

Look how long it took legislators to realize that drunk driving was killing thousands of people a year. So they passed laws that would require a blood alcohol level of .10 for people to be legally drunk and removed from their vehicles. That saved lives I am sure. But it wasn't good enough. So the tolerable blood alcohol level was lowered to .08. And more lives have been saved.

Requiring ANY CO detector is going to save lives, espcially those who are exposed to high levels of CO in a short period of time, i.e. an unvented propane heater or gas generator. Some of these CO detectors will not alarm to low levels of CO over an extended period of time, i.e. a restricted or blocked vent. That problem still needs to be attacked.

But we have made progress. Lives have been saved. let's not forget that when we push for tougher standards. Keep a balance and be glad that people have finally started to address this silent killer.

There are many good people here at The Wall who have led the charge to educate the HVAC industry and it's customers on the need for testing, servicing, and maintaining fossil fuel burning appliances. I am sure their efforts have saved lives and prevented injuries. My hat (if I were wearing one) is off to each. Keep fighting. One lost life is one too many.

Jim Davis_3

CO Safety or Inconvenience?

When it comes to CO safety it is really not about safety at all but about who is going to get inconvenienced. Which group of people are the ones that are responsible for the high level that CO Alarms are set for? Fire Departments. They are the first people that everyone is told to call. Low level monitors alert people before they are in need of medical attention. Wasted trip for Fire Department. Let's set the levels high enough to insure people need medical attention. Contractors could sell Low Level monitors but then they would get all the calls. And if the CO was caused from the equipment they worked on they are increasing their liability. Between the NSI3000 & CO Experts I would bet less than 10% of all contractors on the Wall are selling either to all their customers.

27ppm causes and increase in cardio respiratory problems. 30ppm causes exercise induced angina. American Journal of Health reports that tens of thousands of patients suffer congestive heart failure when the levels outdoors get above 9ppm. And why is the OSHA levels in factories 50ppm for 8 hours? Don't want to inconvenience anyone. Might not allow propane lift trucks to be used indoors anymore and the propane industry might not survive. That is why lowering the limits to 35ppm a few years ago never happen. We should just re-name all buildings parking garages and then the International Building Code does not allow more than 25ppm. But then shouldn't home be safer than parking garages?? Mine is!!!

Bob Harper

the real issue?

John, I agree that we need to measure each victory and that Rome wasn't built in a day. However, at some point somebody got tired of looking at those hills and started cutting stone. They didn't just build huts & shacks but edifices to remember. You've got to have goals knowing each step will come up a little short but the goals get constantly revised, too.

Is the real issue here detecting CO and alerting the occupants or keeping the CO out in the first place? We all know ways to install combustion appliances in the home that make a little CO with the potential to make a lot of CO. Even then, the question arises, will the installation contain and exhaust the CO or leak it into the home?

In the case in Mass, we have anecdotal evidence so far--it has not been proven in court what happened. Yet, there is panic legislation based upon this event. So, which is better: require CO alarms of dubious technology and sensitivity to be interlocked to combustion equipment or install and inspect the equipment so it is operating properly? We all know the pitfalls of interlocking one more thing to heating equipment--callbacks and reliability. As I understand it, the interlocking portion was not adopted in Mass but they tried.

I guess what I'm stating is my frustration over one State Fire Marshal being able to make an entire industry dance on a string, right or wrong.

Larry (from OSHA)

John

I appreciate and agree with your perspective completely. Trust me when I say that I am fully aware of the pace at which change takes place. Be it OSHA laws, driving laws, or carbon monoxide detector requirements.

My intent is to raise the awareness of those who have had their hands on this issue here in Minnesota, ie. reporters and legislators. I hope that if these people are made aware that there is more to this story than just getting the current generation of CO detectors in the homes of more people, some additional progress can be made to eventually get the UL requirements to be more protective.

I agree that lives have been saved by the use of the current generation of CO detectors, but I have heard that not all new CO detectors function as intended right out of the box. If this is true, I feel that has the potential to give homeowners or other users of these units a false sense of security.

This is an area that strikes a particular nerve with me as I see this periodically with machine safeguarding devices that have not been used or set up properly and the result has been body parts being removed from employees by those machines because those workers mistakenly thought they were protected by a safety device.

The issues at hand would seem to be the UL listing criteria for detectors, the failure rate of new detectors, the test button and what it tests, and the actual hazards associated with low level exposure to CO.

I would not want to imply to anyone that what is being enacted by this new legislation is not a good thing. I could not for a minute diminish the efforts of greiving parents who pressed for this.

Small steps are good. I feel it is best for the public safety that these small steps continue.

Larry

Larry (from OSHA)

Jim

Thanks for your perspective and input. Just so you know, here in Minnesota we require that workplaces have no more than 35 ppm over 8 hours and a ceiling limit of 200 ppm in 5 minutes. There is also a quarterly environmental monitoring requirement and tailpipe testing of forklifts.

You have to remember that OSHA enforces minimum requirements. When I left private industry for OSHA, my boss had to basically beat into me the concept that we enforce the ground floor minimums and not best safety practices. That was kind of tough for me but I am still continually challanged to get employers up to that minumum compliance level.

Unknown

I am all for

CO alarms for whatever reason. I would prefer to see low level CO detectors as mandatory. I would also like to see a system that shuts off equipment that is making CO above safe levels.

Most of all however I would like to see mandatory testing of all fossil fuel equipment on an annual basis. In addition a requirement that combustion testing be done at the time of installtion by installers.

Jim Davis_3

Minimum is right!

Glad to see you are on top of it in Minnesota and I am sure you would agree this is not the common practice nationwide. Seems like every rule we have to follow is "minimum" including the regular building codes, which in reality ignor real safety issues. "Better than nothing" should only apply when there is nothing better but it seems to be the modern day cop out. Baby steps are for babies and it is time we grow up! Those who attempt to make things better are either stopped by authorities or ridiculed. Of course when you hear comments that there is very little proof that appliances emit that much CO into buildings you just have to wonder how naive can we keep getting.

Larry (from OSHA)

Very good points Tim

I think you have identified a few distinct issues, each very important but each having its own place on the agenda.

From my limited perspective, I feel that low level detectors would be most appropriate for residential applications. Some training would need to accompany those.

CO sensitive interlocks on fossil fuel appliances, while also a good idea from a safety perspective, have potential for other headaches. If they are sensing ambient air in the vacinity of the appliance, a lockout may be reasonable, but if it is sensing what's in the flue, an alarm to alert the need for service might be a good way to go. There are cost issues here and systems that are effective, reliable, and not prone to nuisance lockouts may be more costly than the general public could stomach.

Annual testing is a requirement that in my opinion is way overdue. But some folks may balk at yet another government regulation, no matter how well intended. There would be cost issues galore from who administers this to who does the testing. Testing at time of commissioning however is absolutely a no brainer.

But going back to the original concern I had, any CO detector needs to be protective of the occupants in the building. A device dealing so intimately with life safety should, in my opinion, be VERY reliable and provide protection for ALL occupants, not just healty adults.

I have not yet heard from anyone having data on reliability of CO detectors. ie. non-functioning right out of the box or not alarming when exposed to levels where it should (by the current UL listing).

If anyone has this info. please pass it along.

Bob Harper

off the shelf reliability?

Go to Bacharach's Training Room and see the video where Rudy followed several alarms with a freshly calibrated analyzer. Pretty miserable performance!

Unknown

Larry,


Larry,
I think you have identified a few distinct issues, each very important but each having its own place on the agenda.

Ans: You are correct and it really behooves code developers to address each and every issue.
From my limited perspective, I feel that low-level detectors would be most appropriate for residential applications. Some training would need to accompany those
One of the good things about the low level detectors they are mostly sold to consumers by contractors. The NCI unit that is a requirement I believe. This means that the contractor is going to educate the consumer on the proper use of their detector. In particular a low level alarm does not typically require evacuation nor do you need a “first responder” (Fire dept or gas utility)
CO sensitive interlocks on fossil fuel appliances, while also a good idea from a safety perspective, have potential for other headaches. If they are sensing ambient air in the vicinity of the appliance, a lockout may be reasonable, but if it is sensing what's in the flue, an alarm to alert the need for service might be a good way to go.

Larry
There are cost issues here and systems that are effective, reliable, and not prone to nuisance lockouts may be more costly than the general public could stomach.

Answer
High efficiency systems are already prone to some nuisance shut downs and lockouts one more would not be the end of the world if it saved lives. Most electronic systems in place today are using some sort of a printed circuit board with a microprocessor. Only about 5% to 10% of the microprocessor is used. It would be very simple to add a CO sensitive device to either shut the system down completely or at least create a lockout. We already have that concept in place if the flame is not producing a good microamp signal we will shut down and retry ignition. It seems to me that if the level of CO went above 400 PPM in the flue (allowable level by ANSI standard) we could shut the system down. If the level went above 100 PPM a series of warning lights would come on and an alarm to alert the customer would suffice. This would generate a service call and the problem could be resolved by a service and combustion test.

Larry
Annual testing is a requirement that in my opinion is way overdue. But some folks may balk at yet another government regulation, no matter how well intended. There would be cost issues galore from who administers this to who does the testing. Testing at time of commissioning however is absolutely a no brainer.

Answer
It is the responsibility of anyone who installs equipment that burns to service that equipment forever. They are not doing their job if they do not do a combustion test on that equipment and time of start up. That includes heating, water heating, gas ranges, grills, dryers etc. They should then be selling the customer annual service on that equipment and following up to make sure it is done. It is actually an opportunity for the contractor to make money and to have work when things get slow. It is not hard to sell customers (particularly women) on safety issue about equipment that could kill them or their family.

Larry
But going back to the original concern I had, any CO detector needs to be protective of the occupants in the building. A device dealing so intimately with life safety should, in my opinion, be VERY reliable and provide protection for ALL occupants, not just healthy adults.

Answer
Things in this area are getting somewhat better. Even the over the counter detectors are starting to clean up their act. We still have along way to go.

Larry
I have not yet heard from anyone having data on reliability of CO detectors. I.e. non-functioning right out of the box or not alarming when exposed to levels where it should (by the current UL listing).
If anyone has this info. please pass it along.

Answer
I am sure George Kerr, Jim Davis, Rudy Leatherman, Bill Spohn and others could make that information available to you. I am not sure if Mark Hunt has saved a lot of the data he collects. Some one else who seems to be on top of this is Gary Reecher.

jp_2

need improved NCI detectors

I like the nci detectors. but I think they need to go two steps further!

1.)hardwire capabilty.

2.)digital message display. i.g.

"have appliances serviced"
"evacuate building", etc....

unfortunately you can't "train" everybody. and consummers far less.

also what I see needs to be changed is the response actions.
if the fire dept. is called just "one" responder neeed to check out the situation. you have a far better chance training the local FD then consumers.

did you hear the story on the "bob and Tom" show. his detector went off, called the FD and fire trucks came and the whole nine yards.

if i remember right, he had a malfunctioning appliance.

jp_2

odd statement??

"""The law does not include financial penalties for failure to comply. """

why is it not just introduced into the code?

if you do not comply with code, you fail inspections, plain and simple! nobody moves in, theres the finanical penalty.

Mark Hunt

Bob


Do you have a link for this?

STP???

Mark H

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Jim Davis_3

Bob Harper

link to UL Standards Technical Panel 2034

http://ulstandardsinfonet.ul.com/stp/active-stps.html

Mark, try this link. Dan Ryan, who heads this STP also heads up STP 103, which covers venting so he's a guy you want to meet. I have his card out at my office but you can get his contact info. off the site. Also ask for Tim Corder.

Keep up the good fight!