To: The U.S. Consumer Product Safety Commission. RE: Unvented Gas Fireplaces
Jun 19 '02
The Bottom Line The Gas Appliance Manufacturer's Association, (GAMA) have refused to produce proof that unvented gas fireplaces are safe, because they know,... they are not safe. They simply sell well.
The following is an open letter to the U.S. Consumer Product Safety Commission. I believe it is self explanatory. The form used for this complaint is one of their online forms.
Consumer Product Incident Report
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6/19/02 12:19:17 PM
Name of Victim = Potentially thousands of American families each year.
Victim's Address = U.S.A.
Victim's City = Most
Victim's State = 47 States
Victim's Zip = Multiple
Victim's Telephone = Multiple
Describe the incident or hazard, including description of injuries:
To whom it may concern,
The Gas Appliance Manufacturer's Association (GAMA) refuse comment on specific concerns involving the true safety statistics which may be attributed to the use of the ODS safety-pilots and unvented natural gas and propane fueled fireplaces in general.
GAMA's Vent-Free Gas Products Alliance division promotes the use of vent-free gas heaters and fireplaces in homes. In fact, they boast over 1,000,000 new unit sales per year within the United States. Despite CPSC's own press release's to the contrary, their website uses the CPSC's name to promote the safety of unvented gas space heaters and fireplaces. It is important that the reader understands the distinction I am trying to make here, between a low Btu/H unvented gas space heater and a relatively high (39,000 Btu/H) unvented gas fireplace.
http://www.gamanet.org/consumer/ventfree/
QUOTE FROM GAMA WEBSITE AT ABOVE ADDRESS:
"Oxygen detection safety-pilot (ODS) technology was adopted by U.S. manufacturers for all vent-free gas products in the early 1980s.
ODS technology originated in Europe, and has been used in European gas heating appliances for more than 45 years with an outstanding record of safety.
Consumer Product Safety Commission (CPSC) accident/incident data accumulated since 1980 show no documented deaths due to emissions associated with the use of an ODS-equipped vent-free gas heating appliance.
Industry engineers say the ODS pilot is to gas what a circuit breaker is to electricity."
END QUOTE FROM GAMA WEBSITE
"...no documented deaths due to emissions..."
The contradiction or perhaps a better word would be, misrepresentation of the CPSC's positions and news releases is partially highlighted in the following quote from an CPSC news release, dated January 15th of this year.
QUOTE CPSC News Release
"FOR IMMEDIATE RELEASE"
January 15, 2002
Media Contact: Ken Giles Release #02-083 (301) 504-0580 Ext. 1184
CPSC Offers Tips to Prevent Home Fires Caused by Space Heaters
Devices Associated with 21,800 Fires and 300 Deaths Annually
WASHINGTON, D.C. - As fire departments across the country battle winter home fires, the U.S. Consumer Product Safety Commission (CPSC) reminds consumers to demonstrate care when purchasing and using space heaters. CPSC estimates that space heaters, including both fixed and portable heaters, are associated with about 21,800 residential fires every year. About 300 people die each year in fires started by these heaters. Fuel-burning space heaters also can cause carbon monoxide poisoning and indoor air pollution, because of improper venting or incomplete combustion.
"We're still seeing too many space heater fires," said CPSC Acting Chairman Thomas Moore. "While CPSC has worked hard with industry to improve safety standards for space heaters, consumers must exercise care in their purchase and use." Consumers should be aware that older space heaters might not meet the newer safety standards.
The CPSC has worked to upgrade the industry standards on electric, kerosene and unvented gas space heaters. An automatic cut-off device is now required, which turns off electric or kerosene heaters if they tip over. More guarding around the heating coils of electric heaters and the burner of kerosene heaters also is required to prevent fires. CPSC worked to upgrade the industry standard on unvented gas heaters, as well, to provide an oxygen depletion sensor to shut off the heater if the oxygen level drops too low."
END QUOTE FROM CPSC NEWS RELEASE
If we accept that fire is a by-product of combustion, we must accept that fire is an emission from an unvented gas space heater and/or fireplace. Particularly, if it was involved in one or more of the 20,000 + incidents reported by the above U.S. CPSC news release.
I believe it would be less than prudent, of the U.S. Consumer Product Safety Commission, to allow the broad use of their reputable name in an endorsement of the safety records for all vent-free gas space heaters and fireplaces currently being sold.
I further submit, that while the introduction of the oxygen depletion system (ODS) pilot for vent-free gas appliances was an innovative corrective measure, it is by no means a safety device, that will prevent some of the reported thousands of CO poisoning cases throughout the United States each year. Nor can the ODS pilot system reduce the numbers of fires, property damage, injuries and deaths attributed to unvented gas space heaters.
The ODS safety pilot is simply a device that will react to a small reduction (3%) in the oxygen levels in healthy ambient air. Even that claim is questionable, when we consider the laboratory conditions under which these devices are tested. It, (the ODS system) does not detect flame impingement and flame starvation, on the main burners, due to improper mixing of primary, secondary airs and gas, which are the highest causes of carbon monoxide generation in a gas appliance. There are very, very few incidents involving a general reduction of oxygen levels within the home envelope. I think we would have seen such reports if the oxygen levels truly fell to 18% or below, under any sort of normal household environment .
Additionally, I submit that the highest concern for the U.S. Consumer Product Safety Commission, should be the Gas Appliance Manufacturer's Association specific ongoing promotion of unvented, vent-free or ventless gas logs, zero clearance fireplaces and freestanding gas fireplaces which exceed 20,000 Btu's per hour. These are perhaps, one of the most dangerous products being marketed today, by industries who know the dangers to consumers and refuse to acknowledge them.
The intimate mixing of gas flames with artificial logs, whether concrete or ceramic fiber, in such a way that the flame is designed to produce wood-like flame effects, complete with glowing ceramic fiber coals and mineral wool is dangerous.
Carbon monoxide levels, generated from a cold start are almost always high, due to a designed reduction in the primary air mixed with the gas to produce a yellow flame and designed flame impingement on artificial logs and coal beds. These two design requirements to create the wood fire illusion are virtually impossible to separate from the production of carbon monoxide and soot. All of which must be flowing into the occupants living quarters, in the case of any unvented fireplace.
Even the catalytic scrubbing systems which a few of these manufacturers have added are band-aids on a much larger problem. The accepted functional life expectancy of the catalytic ceramic tiles is far less than the life expectancy of the appliance and extremely expensive. There are also no means by which the consumer would know if and when the catalytic tiles had plugged and/or ceased to serve any useful function. I believe these issues are enough food for thought, although, there are other concerns, such as, nitrogen dioxide, water vapor, carbon dioxide and a number of unknown impurities, from other sources of indoor air pollution and which join the combustion process. All of these are serious health issues which should be addressed.
The Gas Appliance Manufacturer's Association, and their Vent-Free Gas Products Alliance members, refuse to address fresh concerns. In fact, they are using misleading statements to make their case for the products they produce. The fact that they are using the U.S. Consumer Product Safety Commission's name in their advertisements should concern you. They are also using an out of date safety study, commissioned by themselves and published by the American Gas Association Research Division.
Having read the AGAR report, which began in 1996, I find that their test methodology was flawed. They failed to focus on higher Btu/H fireplace technology. Their recommendations as to how this unvented technology should be employed across the United States, was confusing to say the least and is almost totally ignored in reality. Most installation contractors could not even explain it to each other. In theory, they attempted to split the country into five various regions, based on climate and atmospheric conditions. In theory, everything can work. In reality, if it is too complicated for the average person to understand, it rarely works.
Finally, I submit, that the U.S. CPSC has issued warnings about the use of unvented gas heaters and fireplaces. The U.S. EPA, has issued warnings about their use. The U.S. CDC has posted warnings about the use of unvented gas space heaters. Additionally, the Mayo Clinic and the ALA have posted warnings to consumers. However, sales continue to rise and according to published statistics, which are perhaps better recorded than in the past, over 10,000 people are treated in emergency rooms annually for unintentional carbon monoxide poisoning and an estimated 300 of those people die each year. These numbers do not reflect incidents involving automotive vehicles or incidents which were found to have been intentional.
Certainly, it could be argued that a high percentage of these incidents are from sources, other than, unvented gas space heaters and fireplaces.
* Does anyone really know what percentages may be attributed to unvented gas space heaters and fireplaces?
*Do unvented gas appliances not seem to be an obvious high profile potential source of these incidents?
Statistics continuously suggest the involvement of unvented space heaters and fireplaces in both the 20,000+ incidents of fires and 10,000+ incidents of unintentional carbon monoxide poisoning annually, across the United States. That represents more than 30,000 emergency situations each year, and accounts for more than 600 accidental deaths annually, according to your own government statistics.
I would hate to imagine what these cold hard statistics mean in terms of costs in property damage, human health, loss of life, and emergency services.
I trust this letter will be examined seriously, by the reader. I have no personal interests in the sales of venting products, or vented gas space heaters. Although, I have been involved in the development of such products for over 25 years.
I have a healthy concern for humanity and for the reputation of the gas heating industry in general. Despite GAMA's reluctance to discuss these issues openly.
I can provide a more indepth technical review on the shortcomings of the ODS pilot system, if it is required. I have attempted to keep this letter brief, discussing the highlights of my concerns and the concerns of others within the heating, ventilating and air conditioning industry. I can cite several manufacturers who have refused to participate in the production of unvented gas fireplaces and who have openly criticized other members of the manufacturing sector for their negligent approach to health and safety.
Incidentally, you will note that I am a Canadian citizen. These products continue to be banned for sale in Canada, due to health and safety concerns. Although there are, sadly, a couple of Canadian based manufacturer's who take advantage of the approved status of these products in the United States. This correspondence is about the health and safety of American citizens in the 47 states which currently allow these products.
I look forward to your considered response.
Sincerely yours,
My Real Name and Address Was Used.
Victim's age at time of incident= all ages
Victim's sex = All inclusive
Date of incident = Annual & Ongoing
Product involved = Unvented gas space heaters and fireplaces
Product brand name/manufacturer = Multiple Listings
Place where manufactured (City and State) = U.S.A., Canada, Europe, and ?
Product involved still available = Yes
Product model and serial number = Multiple Listings
Date product purchased = Ongoing
Name Release = Release name to the manufacturer and public
Take care,
The Gasman
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