Public Comments on CPSC staff report Technology 

Demonstration of a Prototype Low Carbon Monoxide 

Emission Portable Generator, dated September 14, 2012 

(as of January 23, 2013) 
Secretary/Treasurer: 

THOMAS ASSOCIATES, INC. 

Ms. Janet L. Buyer 

Project Manager 

Directorate for Engineering Sciences 

U.S. Consumer Product Safety Commission 

4330 East West Highway 

Bethesda, MD 20814 

November 12, 2012 

SUBJECT: PGMA Comments on CPSC Report "Technology Demonstration of a 

Prototype Low Carbon Monoxide Emission Portable Generator" 

Dear Ms. Buyer: 

The Portable Generator Manufacturers' Association (PGMA) is pleased to offer its 

comments on the recently released CPSC report entitled "Technology Demonstration of a 

Prototype Low Carbon Monoxide Emission Portable Generator" . 

PGMA is a trade association that seeks to develop and influence safety and performance 

standards for our industry's products. As the history of both PGMA and the individual 

members of PGMA demonstrate, our commitment to safety is sincere and backed by 

repeated actions. Since our members include the major industry manufacturers of 

portable generators sold in North America and a significant majority of the industry, we 

are the recognized voice of the portable generator industry, particularly with respect to 

safety. 

Our member companies include: 

• American Honda Motor Company 

• Briggs & Stratton Power Products Group 

• Champion Power Equipment 

• Generac Power Systems 

• Pramac America 

• Subaru Industrial Power 

• Techtronic Industries, North America 

• Wacker Neuson Production Americas 

• Yamaha Motor Corporation USA 

1300 Sumner Ave. • Cleveland, Ohio 44115-2851 • 216-241 -7333 • Fax 216-241-0105 

URL: v..ww.pgmaonline.com E-mail: pgma@pgmaonline.com 
PGMA shares with CPSC the goal of promoting and continuously improving the safe and 

proper use of portable generators, and we look forward to continuing discussions on this 

very important topic. 

We welcome the CPSC report as a valuable contribution to the many efforts already 

expended by PGMA, CPSC, and others aimed at achieving this shared goal and 

congratulate you on the completion of your study. The comments that follow are offered 

in a spirit of cooperation and we look forward to working with you to make the use of our 

products even safer. 

The CPSC report is based on the premise that reduced CO emission rates from common 

portable generators "can provide additional critical time for consumers to recognize and 

escape," and thus reduce the number of CO deaths from portable generators. We did not, 

however, see any documentation or studies confirming that increasing the time between 

initial exposure and the onset of critical symptoms will actually lead to more escapes. 

Given the importance of the premise to the report, PGMA encourages CPSC to provide 

the study on which the premise is based or to conduct a study to validate it. While the 

proposition may seem intuitive, it could also be possible that someone experiencing 

minor symptoms from reduced CO emissions will be even less likely to attribute them to 

CO than someone exposed to emissions from an unmodified generator. Moreover, 

decreasing the rate of symptom onset would not benefit someone who is sleeping and 

could reduce awareness that a serious problem is at hand. 

There are, as you are certainly aware, no warning signs commonly and uniquely 

associated with carbon monoxide poisoning regardless of how quickly the carbon 

monoxide poisoning occurs or begins to occur. This is because the headache and nausea 

associated with carbon monoxide poisoning are such common, everyday occurrences for 

virtually everyone that it is questionable whether those symptoms would be recognized as 

being caused by carbon monoxide exposure. Empirical data would be extremely valuable, 

and probably necessary, to support the proposition that a consumer experiencing early 

reactions to carbon monoxide poisoning would realize the source of the symptoms as 

carbon monoxide and react in the manner desired, that is to quickly leave the area for a 

place with fresh, untainted air. 

We wholeheartedly agree with the statement in the CPSC's Press Release for the report 

that recognizes that a carbon monoxide (CO) hazard would continue to exist even if the 

technology applied to the prototype generator were applied to commercially available 

generators, and that educating owners about the proper use of their generators will 

therefore remain the first line of defense: 

"The CPSC continues to urge consumers to never run their portable 

generators in their attached garages, in or even near their houses, including 

avoiding placement near windows or vents. Generators should only be used 

outside, far away from homes. CPSC cautions that even if portable gasoline 

powered generators were to incorporate this technology, they would still need 

to be used outside, far from the home. The technology does not make them 

safe for indoor use." (CPSC Press Release #12-278, September 14, 2012). 
For this reason, PGMA encourages CPSC to conduct a study that includes a human 

factors analysis to determine the effectiveness of the CPSC mandated CO warning 

adopted in 2007. In any event, PGMA encourages CPSC to revise the mandated warning 

to incorporate the standards and format in ANSI Z535.3-2011 and Z535.4-2011. 

CPSC also recognizes that "[a]nother important line of defense against CO poisoning is 

having CO alarms on each level of the home and outside sleeping areas. Based on 

available alarm data, 93 percent of CO-related deaths involving generators take place in 

homes with no CO alarms. Much like smoke alarms designed to alert consumers about 

smoke or fires, CO alarms are designed to alert consumers to dangerous CO levels and 

give them time to get out of the house before becoming incapacitated." (CPSC Press 

Release #12-278, September 14, 2012). States and local communities throughout the 

United States have recognized the role CO monitors play in protecting consumers from 

the multiple sources of CO present in everyday life - furnaces, space heaters, and 

charcoal grills to name a few. As a result, the number of states adopting mandatory CO 

monitor laws and codes has increased significantly over the last 5 years. PGMA 

encourages the adoption of such a requirement in every state as a cost effective means of 

significantly reducing the CO hazard from multiple sources. CPSC could use its 

influence to further promote the adoption of statutes, regulations and building codes 

requiring the use of CO monitors in living spaces as a means of implementing its 

objective of protecting consumers. 

PGMA also encourages CPSC to analyze the data it has collected on CO poisoning and 

deaths to develop a public awareness campaign that is targeted based on use conditions 

and user groups, similar to what has been done with hazards such as fires and severe 

weather. PGMA would support such an effort by CPSC. 

With respect to the demonstration project, if the fuel injectors, catalytic converters, 

electronic sensors, etc., employed on the prototype generator were installed on currently 

available generators, it would result in significant changes to the product that is on the 

market today. The study does not, however, identify or address what problems might 

arise in trying to incorporate such technologies. There are significant differences between 

the products on which those technologies currently are employed, such as cars and 

marine generators, and portable gasoline powered generators, as well as significant 

differences in how the various products are used by consumers. The Commission report 

cites marine generators as an example to be followed by the portable generator 

manufacturers, however they are distinctly different products in that marine generators 

are typically fixed in place on boats, are water cooled with access to large quantities of 

water to accomplish cooling and are priced between $6,000 to $8,000. 

Further, the road from prototype to commercial viability is typically as long and fraught 

with as many issues as the initial stages of development. Indeed, the CPSC study itself 

was 5 years in development for a single prototype. It used a commercial grade of engine 

on the market today installed in an open-frame design that allows for maximum heat 

dissipation. It is reasonable to conclude that had the staff used a more typical residential 

model that is on the market today the results would have been different. 

Assuming the practical challenges could be overcome, one would not be surprised to fmd 

a significant difference between the cost to manufacture the product on the market today 

and that to make products that incorporate the technology used with the CPSC prototype 
model. If there is a significant difference, the speed with which new product penetrates 

the market will be adversely affected. A significant cost difference is also likely to result 

in the increase of repairs to older product and an active used portable generator market, 

again negatively reducing market penetration of new product. The price difference also 

raises implementation concerns with the viability of the CPSC' s suggested approach of a 

voluntary standard. The report does not provide an analysis of the market impact of the 

technology price difference and voluntary standard approach which would be a factor in 

the success of the strategy set forth by CPSC to reduce CO deaths. 

For its part, PGMA continues to develop a portable generator safety standard by means of 

the canvass process of the American National Standards Institute (ANSI) and to pursue 

opportunities to raise awareness. As part of the ANSI process, PGMA would welcome 

the participation and support of CPSC Staff in order to maximize our shared goal of safe 

use of portable generators. In terms of raising awareness, PGMA is extremely 

encouraged by its recent discussions with the National Association of Regulatory Utility 

Commissioners about fmding ways to include and standardize the CO message being 

delivered via the utility industry's various forms of media. Reducing the number of 

portable generator related CO incidents that occur after a utility company shuts off the 

power, due to nonpayment for example, shows promise and this effort could be enhanced 

by the CPSC's participation. We have accepted an invitation from the National 

Association of Regulatory Utility Commissioners to present at their NARUC meeting in 

Washington, D.C. on February 3-6, 2013. We invite CPSC representatives to present our 

safety message with us at the NARUC Washington meeting. We also invite CPSC to 

work with PGMA collaboratively as other opportunities arise. 

Further, as the leading trade association of manufacturers of portable generators, PGMA 

would be pleased to meet in person with CPSC Staff to discuss the many technological 

and policy issues implicated by our mutual safety efforts. To attain the most 

advantageous level of safety, PGMA would be pleased not only to facilitate an in-person 

meeting of CPSC Staff with PGMA, but also to facilitate meetings of CPSC with 

individual corporate members of PGMA, so that CPSC Staff will have all relevant 

information available to it as it considers safe use of portable generators. 

JHA/jlb 

pgma 

Very Truly Yours, 

8Lc11~ 

JOHN H. ADDINGTON 

Executive Director 

PGMA 
I Truck & Engine 

Manufacturers 

Association"" 

333 West Wacker Drive, Suite 810 

Chicago, Illinois 60606 

Tel: (312) 929-1970 I Fax: (312) 929-1975 

www.truckandenginemanufacturers.org 

Bringing Cleaner Power to tile World Since 1968 "' 

November 13,2012 

VIAE-MAIL 

Ms. Janet L. Buyer 

Project Manager 

U.S. Consumer Product Safety Commission 

4330 East West Highway 

Bethesda, MD 20814 

Re: CPSC Report "Technology Demonstration of a Prototype Low Carbon 

Monoxide Emission Portable Generator" 

Dear Ms. Buyer: 

The Truck and Engine Manufacturers Association (EMA) appreciates the opportunity to 

provide comments regarding the above-referenced report. EMA is the trade association that 

represents the world's leading manufacturers of internal combustion engines. The engines 

manufactured by EMA's members include non-road spark ignition engines used to power 

portable generators such as those involved in the subject technology demonstration. 

EMA's comments and recommendations are based on EMA member · company 

experience designing, certifying, and manufacturing a wide variety of engines that comply with 

U.S. EPA Phase 3 Regulations including engines utilized in portable generators operating on 

gasoline, propane, and natural gas. 

EMA agrees with the comments submitted by the Portable Generator Manufacturers' 

Association. In particular, the significant engine design changes required to incorporate 

electronic control unit (ECU), manifold air pressme sensor (MAP), fuel pump, fuel injector, 

crank position sensor, toothed timing wheel, modified ignition coil, intake air temperature 

sensor, oil temperature sensor, exhaust oxygen sensor, catalyst aftertreatment muffler system, 

battery, and related electrical and mechanical connecting components. Engine designs that 

incorporate the repmt's design changes are possible, but may not be suitable for all engines, 

including many utilized to power pottable generators. This is especially true when considering 

the price point and reliability considerations associated with portable generators designed and 

sold to consumers for emergency or infrequent use. 

EMA is very concerned that the repmt proposes adoption of a voluntary program, which 

is likely to result in a significant price point discrepancy between compliant and non-compliant 

products. A significant number of pmtable generators are purchased by consumers at the onset 

A Non Governmental Organization in Special Consultative Status with the Economic and Social Council of the United Nations 
of an emergency situation whereby their normal electrical service is interrupted. In contrast to 

consumers who recognize a potential for electrical service interruption and therefore install fixed 

standby power systems, these "emergency purchasers" typically store their units upon resolution 

of the near term emergency that caused the pmtable generator to be purchased, typically without 

conducting any preventative maintenance until the next emergency. Even the simplest engine 

fuel system designs, which utilize gravity feed carburetors and self contained electrical systems 

(no battery), experience problems associated with fuel degradation and mechanical/electrical 

concerns during long-term storage. The added complexity associated with the numerous 

components associated with the prototype design developed in the technology demonstration 

project will only exacerbate these concerns. 

As noted during the U.S. EPA Phase 3 regulatory development process, the small sparkignition engine industry is very diverse, and engine designs must be viable for a wide variety of 

products. Although portable generator engines contain features that are different than typical 

lawn and garden engines, the vast majority of the engine design, including basic fuel and ignition 

systems, is uniform across all product lines. This uniformity provides both manufacturing 

flexibility and economy of scale. To the extent that implementation of the repotts proposal 

would require significantly different engine designs for portable generators, it raises significant 

concerns that impact both cost and availability. 

EMA notes that CPSC has not proposed a voluntary CO standard level beyond the 

original technology demonstration target of 30 g/kW-hr. EMA does not know the relationship 

between an engine's CO levels compared to the model home CO levels, but the measured CO 

levels for the prototype engine were in the 2 g/kW-hr range at zero hours and in the 18 g/kW-hr 

range at 500 hours. It is unclear if the CO exposure levels measured in the model house would 

be significantly different for engine out CO emissions of 2, versus 18, versus 30 g/kW-hr. 

However, it is clear that a deterioration factor for CO of 9 as reflected by the demonstration 

program prototype would require a new engine out CO level close to 3 g/kW-hr to achieve 

compliance with a 30 g/kW-hr standard at the end of the 500 hour useful life period. 

If CPSC determines that it wishes to pursue development of a voluntary CO standard for 

portable generators EMA would be very interested in working with it on the details of such a 

standard. In the interim, EMA is available for meetings and/or teleconferences if CPSC has any 

questions concerning small spark-ignition engines utilized to power portable generators. 

cc: Jed R. Mandel, President 

z,· 1 

Ror:G: Technical Director ~ 
November 13,2012 

Ms. Janet L. Buyer 

Project Manager 

Directorate for Engineering Sciences 

U.S. Consumer Product Safety Commission 

4330 East West Highway 

Bethesda, MD 20814 

H:OND.A 

American Honda Motor Co., Inc. · 

1 919 Torrance Boulevard 

Torrance, CA 90501-27 46 

Phone (31 0) 783-2000 

SUBJECT: Honda Comments on CPSC Report "Technology Oemonstration of a Prototype 

Low Carbon Monoxide Emission Portable Generator" 

Dear Ms. Buyer: 

American Honda submits the following comments on the recently published CPSC report titled 

"Technology Demonstration of a Prototype Low Carbon Monoxide Emission Portable 

Generator". 

Honda shares in the CPSC's objective to significantly reduce the number of incidents of CO 

poisoning that result from the misuse of portable generators. To accomplish that, Honda believes 

that a multi-pronged approach is necessary, one that includes raising consumer awareness 

through information and education, promoting CO detector use, and exploring technology that 

can reduce the level of CO that is generated at the source. 

In regards to the latter, Honda has been a leader in the development of new engine technologies 

that have driven improvements in efficiency and the reduction of harmful emissions. Our 

organization literally has decades of experience in developing low emission engines through the 

use of fuel injection, exhaust catalyzers, and innovative control systems. We also have a firm 

understanding of how our products are used and perform in the real world, and we continuously 

gather and use this infom1ation to drive improvements in quality and value for our customers. 

The foundation that has helped strengthen the Honda brand image beyond, perhaps, all others is 

the intensive testing and design qualification regimen utilized by our engineering departments. 

Indeed, the fact that the Honda GX390 engine used in the CPSC research withstood severe 

operating conditions for which it was not designed and, for the most part, withstood them 

without catastrophic failure is a testament to our philosophy of building products that exceed our 

customers' expectations. 

While we always enjoy hearing how our products perform under severe conditions such as these 

and, from that standpoint, would like to call the CPSC test a success, we also have to be realistic 

about its limitations. Specifically, from Honda's review of Figure 22 of the report, a photograph 

of the cylinder head from the prototype engine, it appears that combustion gases had been 

leaking to the outside because the head gasket on the prototype engine was in the early stages of 

failure prior to the time that the engine was disassembled. This determination is based on the 

discoloration caused by carbon deposits on the cylinder head fin and the inconsistent appearance 

on the cylinder head gasket surface compared to the baseline. This failure almost certainly was 
the result of increased combustion temperatures created by running the engine at stoichometric 

air/fuel mixtures, one of the fundamental challenges of applying a stochiometric air/fuel mixture 

to a stationary air cooled engine. 

While the researchers involved in this project may not have appreciated the incipient failure 

mode, failures such as these are to be expected under such circumstances and typically would be 

countermeasured by increased cooling. 'Automobiles, motorcycles, and marine engines (and 

marine generators), where water cooling or air-water cooling to manage the additional heat is 

practicable and feasible, are typically able to avoid this type of failure. For portable generators 

(as well as portable lawn and garden equipment powered by gasoline engines) that are used in a 

stationary manner, however, neither water cooling nor air-water cooling is feasible (and hence is 

not applied), and radiant cooling is insufficient to deal the increased heat load of stoichometric 

combustion. 

Another important, and related, point is that the engine in this demonstration only was tested to 

500 hours, the declared useful life of the subject engine under EPA phase 2 regulations. 

However, the comparable engine available today is declared to 1,000 hours useful life under 

EPA phase 3 and, as such, would be required to demonstrate twice the operating duration 

without showing any failure like the one noted above. Given that the head gasket already was 

leaking at 500 hours, complete failure due to the high operating temperatures certainly would 

have been realized and other component failures would also likely have occurred prior to 

reaching the 1,000 hour mark. It should go without saying that patterned head gasket failures 

and patterned failures of other emissions related components are violations of the Clean Air Act 

and would require product recall and remediation. 

Of similar importance is the fact that the engine only was tested using the 6 mode emissions test 

for a period of 500 hours. This test only tests emissions durability, and is in no way a test for 

overall product durability and fitness for a particular use, the requirements to which 

manufacturers are held under the principles of applied warranty. To meet our many obligations 

under Federal and state laws and regulations, as well as the needs and expectations of our 

customers, Honda utilizes more severe modes and requirements for product durability. Had the 

prototype engine been subjected to Honda's full array of durability testing, we are doubtful that 

there would have been satisfactory results. 

Additionally, the CPSC's testing did not evaluate engine and generator performance in transient 

load conditions, conditions to which portable generators typically are subjected in normal use. 

Transient in this context means that the mechanical load conditions applied to the gasoline 

engine vary, often significantly, as electrical loads fluctuate, such as when starting an electric 

motor that drives a refrigerator or an air compressor. These instantaneous start-up loads affect 

engine combustion in very dynamic ways, and an air-fuel mix condition richer than 

stoichiometric combustion is required to manage them to prevent engine hunting and surging. 

Without such instantaneous air/fuel management, the resultant unstable engine operation will 

produce variations in voltage and frequency that can permanently damage sensitive electrical 

equipment and cause unreliable operation of other equipment that leads to owner dissatisfaction. 
Finally, in terms of evaluating CO risk exposure from portable generators in confined spaces, it 

is important to understand that CO concentration in a given space depends not only g/kw-hr but 

also engine displacement. Smaller displacement engines that produce the same quantity of CO 

on a g/kw-hr basis as larger displacement engines inherently will take a longer time to raise the 

CO concentration to the same level as the larger engine. As compared to larger engines, smaller 

displacement engines may therefore provide a slower onset of CO poisoning that might provide 

consumers additional escape time, a theory often expressed by CPSC staff. This in tum suggests 

that, should the Commission elect to go forward with the approach outlined in the technical 

report, different targets for CO emission reduction may be appropriate based on engine 

displacement. This distinction has practical importance: Technically (and economically) it is 

easier to apply fuel injection and a catalyst to larger engines than to smaller engines, where the 

limited size and space to accommodate these technologies makes the application even more 

challenging. The GX390 engine used in the CPSC's project is a somewhat larger engine than 

those typically used on the very popular lkW to 3kW class of portable generators, and the 

relatively easier application of fuel injection and catalyst technology perhaps was a reason why 

this size of engine was selected. To avoid unfairly penalizing smaller engines in this regard, 

further research should be conducted to better understand the effects of engine displacement on 

potential risk exposure and reduction. 

Again, Honda shares in the CPSC objectives and would like to meet directly with CPSC staff 

and the University of Alabama research team to further discuss these and other issues as we 

move forward with our own efforts and research. 

Thank you for this opportunity to comment and please feel free to contact me with any questions 

you may have and to schedule a time when you may be available to meet. 
Manufacturers of Emission Controls Association 

2020 North 14th St. 

Suite 220 

Arlington, VA 22201 

(202) 296-4797 

November 7, 2012 

SUBJECT: MECA Comments on CPSC's Test Report Titled "Technology Demonstration of 

a Prototype Low CO Emission Portable Generator" 

TO: U.S. Consumer Product Safety Commission 

Office of Secretary 

Washington, DC 20207-0001 

cpsc-os@cpsc.gov 

FROM: Dr. Joseph Kubsh, Executive Director, MECA (e-mail: jkubsh@meca.org) 

The Manufacturers of Emission Controls Association (MECA) is pleased to provide our 

comments on the CPSC's summary report demonstrating the performance of a prototype portable 

generator that emits low levels of CO emissions. MECA is a non-profit association of the 

world's leading manufacturers of emission control technology for motor vehicles and stationary 

internal combustion engines. Our members have nearly 40 years of experience and a proven 

track record in developing and manufacturing emission control technology for a wide variety of 

on-road and non-road vehicles and engines. A number of our members have extensive 

experience in the development, manufacture, and commercial application of CO emission control 

technologies for stationary engines, as well as, expertise in applying catalyst technologies to 

small spark ignited engines less than 25 hp. 

We thank the CPSC for this opportunity to review the report and provide our comments. 

MECA has been engaged in the commission's efforts to improve the safety of portable 

generators in marine and domestic applications by reducing the level of CO emitted by these 

small, spark-ignited four stroke engines. Recent events associated with Hurricane Sandy on the 

east coast of the U.S. once again point to the potential deadly outcomes of operating gasoline 

generators that emit high levels of CO without proper ventilation. MECA has previously 

provided comments about the available technology for portable generator applications in 

response to CPSC's request for information on techniques to reduce CO from gasoline portable 

generators (MECA letter dated April28, 2006) and MECA's written comments to CPSC's 

ANPRM on portable generators (dated February 11, 2007). We commend the commission on its 

decision to demonstrate the effectiveness of state ofthe art combustion controls in combination 

with catalyst technologies to achieve CO reduction of over 90% from common portable gasoline 

generators. We believe that the demonstration program was well designed, well executed and 

meticulously documented in this fmal report. The test method used is sound and consistent with 

accepted practices in the field. The results of emission measurements on the baseline and 

modified pre and post-catalyst engines are logical and consistent with published ranges for the 

1 
technologies tested. MECA agrees with CPSC that the benefit of a catalyst-based emission 

control system on generators is not encourage the use of these generators in an enclosed 

environment, but rather to allow a person experiencing mild CO poisoning the additional time to 

respond to their symptoms before they become incapacitated. 

The conclusions support the experience of catalyst manufacturers and the 

recommendations provided by MECA on the effectiveness of the use of catalysts to reduce CO 

emissions and improve the safety of portable generators. Catalyst technology is a cost-effective 

technique for substantially reducing CO exhaust emissions from spark-ignited, gasoline portable 

generators. Catalyst technology for small gasoline engines like those used in portable generators 

draws from nearly 40 years of successful experience in the U.S. with catalytic converters applied 

to light-duty gasoline cars and trucks. Similar catalyst technology has been successfully applied 

to a wide variety of smaller, two-stroke and four-stroke gasoline engine applications including 

handheld equipment (e.g., chainsaws, leafblowers, string trimmers), non-handheld equipment 

(e.g., lawn mowers), motor scooters, motorcycles, marine engines, and forklift trucks. In many 

cases these catalyst systems have been engineered to provide high reductions of CO emissions as 

well as reductions in hydrocarbon and NOx emissions. The U.S. EPA in its small engine test 

program that was completed in advance of their Phase 3 small engine regulations (Phase 3 small 

engine emission regulations published in October 2008) clearly demonstrated that catalysts can 

be safely incorporated on Class 1 and Class 2 gasoline engines without any significant increase 

in muffler surface temperatures. MECA and MECA members were active participants in EPA's 

small gasoline engine test program. 

The published experience of catalyst performance on four-stroke gasoline engines 

indicates that high efficiencies for reducing CO emissions are strongly influenced by the air/fuel 

stoichiometry in the exhaust upstream of the catalyst. Maximum reduction efficiencies for all 

three regulated pollutants (hydrocarbons, CO, NOx) can be obtained if the air/fuel ratio of the 

exhaust stream is controlled to be near the stoichiometric ratio of reducing and oxidizing 

components in the exhaust stream. At or near this stoichiometric air/fuel ratio, catalyst 

efficiencies can be well in excess of 90% for all three pollutants provided that the catalyst 

temperature is above its activation temperature (typically 350°C or higher), and that a reasonable 

catalyst volume relative to the volumetric flow of exhaust gas is contained in the system. 

Catalyst formulations can be optimized for these small engine applications to deliver maximum 

CO reductions and/or NOx reductions depending on the fmal emissions target. Precious metal 

costs for these small engine catalysts are typically less than half the total cost of the fmished 

catalyst. The addition of a catalyst to a small engine would have only a very small impact on the 

cost of a gasoline generator. 

The most widely used method for accurate, and cost effective, air/fuel ratio control is 

through the use of fuel injector technology in combination with a closed-loop control strategy 

that employs a simple engine control unit (ECU) and an oxygen sensor present in the exhaust, 

upstream of the catalyst. The sensor provides a feedback loop to the engine's intake air and fuel 

metering system. The combination of closed-loop, electronic fuel injection with a catalyst 

reduces engine-out emissions and ensures consistent engine operation. This more stable, reduced 

engine-out emissions operation reduces the thermal stress on the catalyst and improves the 

catalyst durability. Such an approach has been applied to a whole range of spark-ignited engines 

from passenger cars to handheld lawn and garden equipment and effectively demonstrated on a 

small gasoline powered portable generator in CPSC's demonstration program. 

2 
MECA is aware of two manufacturers of four-stroke, gasoline generators that are already 

using properly designed exhaust systems with catalysts to reduce CO emissions by more than 

90% compared to uncontrolled levels: Westerbeke Corporation and Kohler Power Systems. 

Both of these companies have targeted marine applications for these ultra-low CO emission 

generators. The same strategy is applicable to portable generators for home use. MECA 

believes that the ultra-low CO emission generators offered by Westerbeke and Kohler employ 

the same type of strategy (controlled exhaust air/fuel ratio near the stoichiometric point) to 

achieve high CO conversion efficiencies across a catalyst as documented in the subject report. 

In summary, the commission has effectively demonstrated, documented and concluded in 

the subject report that catalyst-based exhaust emission controls are a proven, cost-effective, 

durable, and safe strategy for reducing CO emissions from small, four-stroke gasoline engines 

like those used in portable generators. The combination of precious metal-based, three-way 

catalyst formulations and precise air/fuel control has been shown to provide CO conversion 

efficiencies well in excess of 90% on a small four-stroke gasoline engine in a portable home 

generator. MECA strongly supports the CPSC's efforts in urging portable generator 

manufacturers to voluntarily implement these cost effective strategies to reduce CO emissions 

and improve the safety of home portable generators. In the absence of a voluntary standard, 

MECA believes that EPA should strongly consider adoption of a mandatory, low CO emission 

standard for gasoline generators. 

Sincerely, 

Joseph Kubsh 

Executive Director 

Manufacturers of Emission Controls Association (MECA) 

cc: Janet Buyer, CPSC 

3 
DEPARTMENT OF HEALTH AND HUMAN SERVICES 

Office of Secretary 

Consumer Product Safety Commission 

4330 East-West Highway, Room 502 

Bethesda, Maryland 20814 

Dear Sir or Madam: 

Public Health Service 

National Institute for Occupational 

Safety and Health 

Robert A Taft Laboratories 

4676 Columbia Parkway 

Cincinnati OH 45226-1998 

November 9, 2012 

We are writing in response to the request for comments on the report entitled. 

"Teclmology Demonstration of a Prototype Low CO Emission Portable Generator" dated 

September 14, 2012. We applaud the Consumer Product Safety Commission's 

effort to demonstrate the technical feasibility of preventing deaths and poisonings from 

generator emissions. This is an important teclmological achievement. The National 

Institute for Occupational Safety and Health (NIOSH) has been involved in the 

investigation and prevention of carbon monoxide (CO) poisonings from small gasolinepowered engines for many·years. We have continued to work on this problem following 

the identification of CO poisonings and deaths associated with marine engines and 

generators since 2000. The hazard associated with the emission of CO from portable 

generators continues to be a very serious concern for both the general public and U.S. 

workers. NIOSH remains a partner with the CPSC in working to prevent CO poisonings 

and deaths through increasing awareness of the hazard and encouraging the development 

of controls to reduce the risk associated with these products. 

In 1993, the NIOSH-sponsored Occupational Health Nurses in Agricultural Communities 

Surveillance Program identified several cases of CO poisoning related to the use of 

gasoline-powered pressure washers in Iowa [CDC 1993]. Around that same time other 

public health agencies across the U.S. were also beginning to document CO poisonings 

related to the use of small gasoline powered engines. This initial work led to the 

publication of a joint NIOSH/CDHPE/CPSC/OSHA/EPA Alert entitled, "Preventing 

Carbon Monoxide Poisoning from Small Gasoline-Powered Engines and Tools." This 

Alert showed that hazardous CO concentrations can be produced by small gasolinepowered generators within minutes. The need for temporary power following hurricanes, 

ice storms and other power outage situations coupled with the low cost associated with 

portable generators have resulted in an increase in the purchase and use of these products. 

As a result, the CDC and CPSC have documented CO poisonings and increasing numbers 

of deaths related to the use of these products [CPSC 2006, CDC 2005a, CDC 2005b, 

CDC 2006]. 

·-·-------- - ----------·---------
Page 2:. Office of Secretary 

Generator-related CO poisonings on houseboats have been investigated by NIOSH since 2000. 

From 1990-2008, over 800 CO poisonings have been identified based on hospital records, press 

accounts, and other sources, with over 140 of these poisonings resulting in death. Two hundred 

forty-two of the poisonings occurred on houseboats, with more than 200 of these poisonings 

attributed to generator ex:haustalone [National Case Listing 2008]. Following initial 

investigations which showed very high concentrations of CO on and around houseboats using 

gasoline-powered generators, NIOSH has conducted many field studies into the ambient levels 

of CO on and around houseboats and the effect of engineering controls on reducing those levels. 

NIOSH has shown that CO concentrations from gasoline-powered generators on houseboats can 

reach dangerous concentrations [Earnest et al. 2001 a, 2001 b, 2002; Dunn et al. 2001 b, 2003; 

Echt et al. 200~; Hall2000, 2001 ; Hallet al. 2000; McCammon etal. 2000]. CO measured in the 

exhaust and near the rear of boats has often exceeded the NIOSH Immediately Dangerous to Life 

and Health (IDLH) value of 1,200 ppm. These engines/generators routinely emit CO at 

concentrations well above the IDLii and concentrations exceeding the NIOSH workplace ceiling 

limit of200 ppm were measured at a distance of 12 feet from the stern of a boat with only the 

·generator in operation [Hallet al. 2000]. 

Initially, one of the major obstacles in·the safe use of gasoline-powered generators was 

the absence of emission controls. NIOSH researchers partnered with boat builders and 

marine engine manufacturers since 2001 ~o address this hazard. Work in that area has 

resulted in new low-emission generators and other engine technology which have greatly 

reduced the risk of CO poisoning in the marine environment. Two major manufacturers 

. of marine power generation systems, Westerbeke and Kohler, have developed low CO 

emission generators. Our evaluations have shown that the addition of technologies such 

as catalytic converters and electronic fuel injection to marine generators have helped 

. reduce the emissions of CO by over 99% [Earnest 2006, Garcia 2008]. NIOSH 

monitored the performance of these systems over extended hours of operation to evaluate 

the life of these catalysts. This effort resulted in comprehensive EPA regulations that 

dramatically reduced CO emissions from all new marine engines beginning in 2009. 

The development of catalytic converters has proven to be a life-saver in preventing motor 

vehicle-related CO ·poisonings. In 1970, Congress enacted the Clean Air Act which 

established automobile engine emission limits. In 1975, automobile manufacturers 

began installing catalytic converters on U.S. automobiles to comply. An analysis of the 

effect of these policies on CO-related mortality showed a drop of over 80% in 

unintentional vehicle-related CO deaths from 1975-1996 [Mott et al. 2002], 

Controlling exposures to occupational hazards is the fundamental method to protect 

workers. Traditionally, a hierarchy of controls has been applied. Following the hierarchy 

normally leads to the implementation of inherently safer systems, where the risk of illness 
Page 3 - Office of Secretary 

or injury is reduced. Implementing controls at the source using catalytic converters and 

direct injection engine technology represents a best practice approach for substantially 

reducing CO emissions. We recognize and support the development and wider use of 

these controls to prevent CO-related poisonings and deaths. 

Sincerely, · 

G. Scott Earnest, Ph.D., P.E., C.S.P. 

CAPT, U.S. Public Health Service 

Chief 

Engineering and Physical Hazards Branch 

. Division of Applied Research and Technology 
References 

CDC [1993]. Unintentional carbon monoxide poisoning from indoor use of pressure 

washers--Iowa, January 1992-January 1993. Morbidity and Mortality Weekly Report. 

MMWR 42(40):777-779, 785. . 

CDC [2005a]. Carbon Monoxide Poisoning from Hurricane-Associated Use of Portable 

Generators -Florida, 2004. Morbidity and Mortality Weekly Report. MMWR 

54(28);697-7QO. 

CDC [2005b]. Carbon Monoxide Poisonings After Hurricane Katrina--- Alabama 

Louisiana and Mississippi, September 2005. Morbidity and Mortality Weeldy Report. 

MMWR 54(39):996-998. 

CDC [2006]. Carbon Monoxide Poisonings After Two Major Hurricanes --- Alabama 

and Texas, August--October 2005. Morbidity and Mortality Weekly Report. MMWR · 

55(09):236-239. 

CPSC [2006]. Memorandum of August 16,2006, from M.V. Hnatov, Division of Hazard 

Analysis, Directorate for Epidemiology, to J. Buyer, Division of Combustion Fire 

Sciences, Directorate for Engineering Services, United States Consumer Product Safety 

Commission. 

Dunn KH, Hall RM, McCammon JB, Earnest GS [2001a]. An evaluation of an 

engineering control to prevent carbon monoxide poisonings of individuals on houseboats 

at Sumerset Custom Houseboats, Somerset, KY. Cincinnati, OH: U.S. Department of 

Health and Human Services, Public Health Service, Centers for Disease Control and 

Prevention, National Institute for Occupational Safety and Health, DHHS (NIOSH) 

Publication No. ECTB 171-26a. 

Dunn KH, Earnest GS, McCleery R, Hall RM, McCammon JB, Jones AL [200 1 b]. Comparison 

of a dry stack with existing generator exhaust systems for prevention of carbon monoxide 

poisonings on ho~seboats. Cincinnati, OH: U.S. Department of Health and Human Services, 

Public Health Service, Centers for Disease Control and Prevention, National Institute for 

Occupational Safety and Health, DHHS (NIOSH) Publication No. ECTB 171-28a. 

Dunn KH, Shulman SA, Earnest GS, Hall RM, McCammon JB, McCleery RE [2003]. Carbon 

monoxide and houseboats: an. evaluation of a stack ·exhaust system to reduce poisonings 

associated with generator exhaust. Professional Safety 48(11):47-57. 

Earnest GS, Dunn KH, Hall RM, McCleery R., McCammon JB [200 Ia]. An evaluation of an 

engineering control to prevent carbon monoxide poisonings of individuals on and around 

houseboats. Cincinnati, OH: U.S. Department of Health and Human Services, Public Health 

Service, Centers for Disease Control and Prevention, National Institute for Occupational Safety 

and Health, DHHS (NIOSH) Publication No. ECTB 171-25a. 
Earnest GS, Dunn KH, Hall RM, McCleery R, McCammon JB [2001 b]. An evaluation of an 

. emission control device, exhaust stack, and interlock to prevent carbon monoxide poisonings of 

individuals on houseboats. Cincinnati, OH: U.S. Department of Health and Human Services, 

Public Health Service, Centers for Disease Control and Prevention, National Institute for 

Occupational Safety and Health, DHHS (NIOSH) Publication No. ECTB 171-27a. 

Earnest GS, Dunn KH, Hall RM, McCleery RE, McCammon JB [2002]. An evaluation of an 

· engineering control to prevent carbon monoxide poisonings of individuals on and around 

houseboats. AIHAJ 63(3):361-369. 

Earnest GS, Echt A, Dunn KH, Hall RM, Hammond D, McCammon JB, McCleery RE [2003a]. 

Carbon monoxide emissions and exposures on recreational boats urider various operating 

conditions. Lake Mead, NV and Lake Powell, AZ. Cincinnati, OH: U.S. Department of Health 

and Human Services, Public Health Service, Centers for Disease Control and Prevention, 

National Institute for Occupational Safety and Health, DHHS (NIOSH) Publication No. EPHB 

171-05ee2 . . 

Earnest GS, Hall RM, Dunn KH, Hammond D, Valladares R [2003b]. An evaluation of vertical 

exhaust stack and aged emission control devices to prevent carbon monoxide poisonings from 

houseboat generator exhaust Callville Bay Marina, Boulder City, NV. Cincinnati, OH: U.S. 

Department of Health and Human Services, Public Health Service, Centers for Disease Control 

and Prevention, National Institute for Occupational Safety and Health, DHHS (NIOSH) 

Publication No. EPHB 171-32a. · 

Earnest GS; Hall RM; Garcia A; McCleery R [2006]. An evaluation of catalytic emission 

controls to prevent carbon monoxide poisonings from houseboat generator exhaust, Boulder 

. City, Nv, report no. EPHB-171-38a. NIOSH 2006 

Echt A, Earnest GS, Halnmond D, McCammon JB, Blade LM, Valladares R [2003]. Carbon 

monoxide emissions and exposures on recreational boats under various operating conditions, 

Lake Norman, NC. Cincinnati, OH: U.S. Department of Health and Human Services, Public 

Health Service, Centers for Disease Control and Prevention, National Institute for Occupational 

Safety and Health, DHHS (NIOSH) Publication No. EPHB 171-31a~ 

Garcia A; Hammond DR; Dunn KH; Hall RM [2008]. An evaluation of Kohler low emission 

technology to prevent carbon monoxide poisonings from houseboat generator exhaust, Boulder 

. City, NV, report no. EPHB-289-13a. NIOSH 2008. 

Hall RM [2000]. Letter of December 18, 2000, from R.M. Hall, National Institute for 

Occupational Safety and Health, Centers for Disease Control and Prevention, Public Health 

Service, U.S. Department of Health and Human Services to Dr. Rice C. Leach, Commissioner, 

Cabinet of Health Services, Commonwealth of Kentucky, Frankfort, KY. 

Hall RM and McCammon JB [2000]. Letter.ofNovember 21 , 2000, from R.M. Hall and J. B. 

McCammon, National Institute for Occupational Safety and Health, Centers for Disease Control 
and Prevention, Public Health Service, U.S. Department of Health and Human Services, to Joe 

Alston, Park Superintendent, Glen Canyon National Recreation Area, Page, AZ. 

Hall RM [2001]. Letter of April 5, 2001 , from R.M. Hall, National Institute for Occupational 

Safety and Health, Centers for Disease Control and Prevention, Public Health Service, U.S. 

Department of Health and Human .Services to John Stenseth, General Manager, Fun Country 

Marine, Muncie, IN. 

McCammon JB and Radtke T [2000]. Letter of September 28,2000, from J. McCammon, 

National Institute for Occupational Safety and Health, Centers for Disease Control and 

Prevention, Public Health Service, U.S. Department of Health and Human Services and T. 

Radtke, U.S. Department of the Interior, to Joe Alston, Park Superintendent, Glen Canyon 

National Recreation Area, Page, AZ . . 

Mott JA, Wolfe MI, Alverson CJ, Macdonald SC, Bailey CR, Ball LB, Moorman JE, Somers JH, 

Mannino DM, Redd SC [2002]. National Vehicle Emissions Policies and Practices and Declining 

US Carbon Monoxide-Related Mortality. Jotirnal of the American Medical Association~ 288 (8): 

988-995. 

National Case Listing, Boat Related Carbon Monoxide (CO) Poisonings [2008] Update: May 

2007-April2008 
From: 

To: 

Subject: 

Date: 

Attachments: 

Todd Stevenson 

CPSC-OS. 

Heags Angela; Buver. Janet 

FW: Response to report titled, TECHNOLOGY DEMONSTRATION OF A PROTOTYPE LOW CARBON MONOXIDE 

EMISSION PORTABLE GENERATOR 

Wednesday, November 14, 2012 11:42:56 AM 

jmage001 oog 

Director, The Secretariat 

(Office of the Secretary) 

Office of the General Counsel 

US Consumer Product Safety Commission 

(301) 504-6836, Fax (301) 504-0127 

''.. ·· ~ ' .. · .. ". ,. .. , ;, '• . . 

..,..o-nld'Uor.--...... CON UMll!. I'II.ODOCf 

SAF£TY COMMISSION 

From: Ken Fosaaen [mailto:kfosaaen@kerdea.com] 

Sent: Tuesday, November 13, 2012 2:49 PM 

To: CPSC-OS, 

Subject: Response to report titled, TECHNOLOGY DEMONSTRATION OF A PROTOTYPE LOW CARBON 

MONOXIDE EMISSION PORTABLE GENERATOR 

Unfortunately I only found out about this report late last week, so I have not been able to 

read it in its entirety. However, below are my comments based upon what I was able to 

read given my time limitations. 

The Executive Summary states, "Staffs goal is not to reduce the CO emission rate to make 

generators safe to run indoors so that occupants can remain in the exposure without serious 

health consequences, but rather, to reduce it enough, such that symptom onset is delayed, and 

the rate of progression of worsening symptoms is significantly reduced." Many engines 

today are designed to run indoors (Zam boni' s, forklifts, floor buffers, etc .. . ), so one can only 

assume the reason for not pursuing this goal is the cost of such a system. Efforts are 

underway to greatly reduce the cost of EFI systems for the motor scooter markets, and since 

these are VERY high volume systems, many companies have had great success in developing 

low-cost systems. It seems to me that leveraging this low-cost technology could make 

designing generator systems capable of indoor operation feasible (though I would still 

recommend discouraging indoor operation). 

The reported prototype engine operates as a closed-loop EFI engine operating at a target of 

lambda= 1; however, narrow-band sensors constantly cycle slightly rich and slightly lean, 

necessitating the CO generated in the rich segment to be converted to C02 in the catalyst. If 

the catalyst ages significantly or fails, significant amounts of the engine-out CO will flow 
through the catalyst unconverted and exit the system. This is dangerous if there is no catalyst 

monitoring system in this design (see next paragraph). Using a wide-band sensor, one can 

ensure the engine always operates in the lean region, greatly reducing the possibility of CO 

exiting the exhaust system. The biggest barrier to this is the cost of automotive wide-band 

sensors, however, newer technology is about to be introduced which significantly reduces the 

cost of wide-band sensors (provisional patent filed). Once commercialized, this will make 

lean control economically feasible . 

Some engines currently designed for indoor use, incorporate an exhaust monitoring system to 

disable an engine if it ever begins to run rich. Some companies have adapted Nemst-based 

oxygen sensors for this, however, this is dangerous since a failed sensor produces a signal 

similar to a sensor operating in a lean environment. Kerdea has filed a patent application for 

a better (and cheaper) safety switch, targeting engine applications designed for indoor use 

(fumaces, water heaters, forklifts, etc .... ). Commercialization of this safety sensor (see 

photo) is underway. 

I also recommend seeking out and leveraging technical advancements in the unmanned 

vehicle industry (see www.auvsi.org). This industry seeks to maximize the power-train's 

specific power (power to weight ratio) and fuel efficiency to increase "on station time". 

Though emissions is a very low priority in this industry, there are many new engine designs 

that maximize power while operating in the lean condition, and may be ideally suited for 

portable generators. I sent a potential contact at Wright Patterson AFB to Janet Buyer. 

Additionally, the military has probably invested some resources to deal with this issue, since 

they use so many generators in their field of operation. I would investigate their approach to 

this problem. 

Finally, the report is useful in determining the exposure under various hypothetical 

situations. Generator manufacturers are going to want the CO generation limitations 

expressed in a simpler, less subjective form that don't require a mocked up garage or building 

for certification. They will want it expressed as a value based upon the engine operating 

through an operation scenario, analogous to the FTP-75 drive cycle used for many years to 

determine emissions from cars. This would be similar to that which was imposed by the EPA 

on marine generators. Developing a model cycle based upon real world usage, then testing 

under the conditions described in this report would be the next useful step. 

Thank you for the opportunity to comment on this report. I hope my comments are 
helpful. 

Ken E. Fosaaen - Chief Technical Officer 

Kerdea Technologies, Inc. 

1800 N. Greene Street, Suite H 

Greenville, NC 27834 

(252) 916-7433 

kfosaaen@kerdea.com 

Skype: kefosaaen 
From: 

To: 

Cc: 

Subject: 

Date: 

Attachments: 

Todd Stevenson 

CPSC-OS. 

Buyer. Janet 

Heqgs. Angela 

FW: Technology Demonstration of a Prototype Low CO Emission Portable Generator 

Monday, December 03, 2012 9:16:11 AM 

imageOOl.ong 

Director, The Secretariat 

(Office of the Secretary) 

Office of the General Counsel 

US Consumer Product Safety Commission 

(301) 504-6836, Fax (301) 504-0127 

From: Dippner, Mark [mailto:MDippner@jardensafety.com] 

Sent: Friday, November 30, 2012 3:56 PM 

To: CPSC-05, 

Subject: Technology Demonstration of a Prototype Low CO Emission Portable Generator 

These comments are from Mr. Mike Rabbett... 

I see three main problems with fitting a CO sensor to a generator; the exhaust from a generator is 

going to be at high temperature with a very high moisture content and it is going to be depleted in 

oxygen. All of these, except perhaps the oxygen depletion, could be mitigated by adding extra 

hardware to cool a sample of the exhaust gases prior to measurement by an electrochemical or tin 

oxide sensor. The oxygen depletion is going to significantly affect the behavior of these types of 

sensor because they are based on the balance between oxidizing and reducing species . If I 

remember correctly, a correctly operating internal combustion engine has an exhaust content of 

about 4% (ref 20% for natural air). Oxygen starved combustion, when the production of CO rises 

significantly, can reduce the oxygen concentration to near zero. From that point of view, an 

oxygen sensor makes much more sense as an indicator of carbon monoxide generation and I would 

think that the control unit attached to the generator already has this. 

If the CPSC must fit a separate CO sensor, then it is possible that the type of sensor that we use 

would work (given that a sample of the exhaust could be cooled effectively), but the signal may 

well be caused by the oxygen reduction rather than by the CO emission. To measure CO properly 
under these conditions, what is really needed is an infrared absorption based CO sensor, which 

would be indifferent to the lack of oxygen or the high water vapour concentration. 
Janet Buyer, Project Manager 

Directorate for Engineering Sciences 

U.S. Consumer Product Safety Commission 

4330 East West Highway 

Bethesda, MD 20814 

Submitted via email: jbuyer@cpsc.gov 

Dear Ms. Buyer, 

ti n of 

November 13, 2012 

I submit these comments in response to the request for comment concerning the Technology 

Demonstration of a Prototype Low Carbon Monoxide Emission Portable Generator 

(Demonstration). We appreciate that the Demonstration, dated September 2012, is open to public 

comment. 

In February of2007, in response to the public request for comments and information on the 

Advanced Notice ofProposed Rulemaking (ANPR) for Portable Generators, CFA submitted 

comments along with Consumers Union. In those comments, we strongly suggested that the 

CPSC not rely solely on education and labeling due to the lack of effectiveness of these factors 

to demonstrably decrease generator-related carbon monoxide poisoning. We appreciate that the 

Demonstration looks beyond these factors to consider an approach that seeks to limit carbon 

monoxide emissions, however, we urge the CPSC to also consider an approach that would 

include an automatic shut off on generators when carbon monoxide levels become dangerous. 

CPSC should consider all available technical solutions that could lin1it carbon monoxide 

poisoning. 

In our 2007 comments, we stated that we believed that the most effective way to reduce injuries 

and deaths from carbon monoxide poisoning would be for all manufacturers to equip generators 

with carbon monoxide detectors that would automatically shut off generators if they detect that 

carbon monoxide levels have reached dangerous levels. We also stated that at the time, many 

generators on the market had a similar automatic shut off system designed to turn off the 

generator when it detected that the oil level was low. In addition, we pointed out that the CPSC, 

itself, had demonstrated proof-of-concept of CO detection safety systems on portable generators 

in its own labs. 

We stand by those comments and reiterate them. We have been disappointed that CPSC has not 

proceeded quickly to require carbon monoxide detection and automatic shut-off safety 

mechanisms on all portable generators. We continue to be disappointed that this solution is not 

adequately addressed, considered, nor embraced in the Technology Demonstration of a Prototype 

Low Carbon Monoxide Emission Portable Generator. This failure to address a significant 

solution to carbon monoxide poisoning is notable and should be remedied. A substantive 

1620 I Street, N.W., Suite 200 . Washington, D.C. 20006 . (202) 387-6121 • Fax (202) 265-7989 

www.ConsumerFed.org 
evaluation of carbon monoxide detection and automatic shut-off safety mechanisms should be 

included in this document and should be meaningfully considered in future CPSC efforts to 

address generator-related carbon monoxide poisoning. 

We look forward to the CPSC's evaluation and potential inclusion of carbon monoxide detection 

and automatic shut-off safety mechanisms on all portable generators in its future work to protect 

consumers from carbon monoxide poisoning due to generators. 

Sincerely, 

~~0~ Rachel Weintraub 

Legislative Director and Senior Counsel 

Consumer Federation of America 

1620 I Street, N.W., Suite 200 . Washington, D.C. 20006 • (202) 387-6121 • Fax (202) 265-7989 

www.ConsumerFed.org 
From: 

To: 

Subject: 

Date: 

Attachments: 

Todd Stevenson 

CPSC-OS. 

Buyer Janet 

FW: "Technology Demonstration of a Prototype Low CO Emission Portable Generator" 

Tuesday, September 25, 2012 9:26:01 AM 

2012Sx v COHb.odf 

Director, The Secretariat 

(Office of the Secretary) 

Office of the General Counsel 

US Consumer Product Safety Commission 

(301) 504-6836, Fax (301) 504-0127 

-----Original Message-----

From: Hampson, Neil [mailto:Neji.Hampson@ymmc.org] 

Sent: Monday, September 24, 2012 6:24 PM 

To: CPSC-OS, 

Subject: "Technology Demonstration of a Prototype Low CO Emission Portable Generator" 

To Whom It May Concern; 

I would like to congratulate the CPSC for focusing on the problem of CO poisoning from gasolinepowered electrical generators and the development of a low emission generator. It would undoubtedly 

save lives if widely applied. As a recognized national expert in the area of CO poisoning in the US, I 

have published several papers about the problem of generators and CO poisoning. 

However, I have problems with the methodology utilized to develop the conclusions reported. Levels of 

ambient CO were measured, which is fine. Levels of COHb were then predicted by accepted methods, 

which is also fine. However, prediction of confusion and incapacitation from COHb levels is not 

possible. In our paper published earlier this year (Hampson NB, Dunn SL, Members of the UHMS/CDC 

CO Poisoning Surveillance Group. Symptoms of acute carbon monoxide poisoning do not correlate with 

the initial carboxyhemoglobin level. Undersea Hyperb Med 2012; (39)2: 657-665.), we clearly 

demonstrate in over 1,300 patients that symptoms of CO poisoning do not correlate well with COHb 

levels. We point out in the paper that your first Table 4, while commonly quoted, was derived from an 

almost identical table in a 1923 Bureau of the Mines publication. As discussed in the manuscript, that 

table was derived from a 1922 Bureau of Mines publication describing experiments performed by 3 

investigators who exposed themselves to CO and recorded the effects. They performed 10 exposures in 

total, achieving a maximum COHb level of 28%. The source for the remainder of the data in their table 

is speculative. 

I do not believe that it is correct to use COHb levels to calculate egress times from a CO-containing 

environment. There are no data to support the method. I have attached a copy of our manuscript for 

your review. 

Thank you for the opportunity to comment. I would be happy to discuss this further. 

Neil B. Hampson, MD 

Emeritus Physician 

Virginia Mason Medical Center, Seattle 

****************** CONFIDENTIALITY DISCLAIMER ****************** 

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call the Virginia Mason Privacy Officer through the Virginia Mason Operator at (206) 223-6600. Thank 

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If you need emergency attention, call 911. 
11/13/06 

TO: JaRet 81.1yer, CPSC pre€Jram maRa€Jer fur pGrtaele €JeReratGrs Janet Buyer. Project 

Manager 

Directorate for Engineering Sciences 

U.S. Consumer Product Safety Commission 

4330 East West Highway 

Bethesda. MD 20814 

Submitted via email toJbuyer@cpsc.gov 

CC: Hal Stratton. Jr .. Brownstein Hyatt Farber Schreck 

Rachel Weintraub. Consumer Federation of America 

Peter Sawchuk, Consumer's Union 

Kenneth Frank 

Daniel Ryan and Hugo Lopez. Underwriters' Laboratories 

Keith Jackson. MariTech Industries 

Bill Rice. INTEC Controls 

CC: ~al StrattGR, Jr., QrewRsteiR ~yatt j;areer Sshresk 

Rashell/'oleiRtrabl9, CeRsblmer j;eeJeratieR gf/\merisa 

Peter Sa•.vshblk, CGR&blmer's URiGR 

KeRReth j;raRk 

QaRiel RyaR aRa ~bi€JG bGpei!:, URaefWriters' ba9GratGries 

Keitl'l JasksGR, MariTesh IRGbiStries 

Qill Rise, IRtes CGRtrels 

FROM: Albert Donnay, consulting toxicologist, adonnay@jhu.edu 

5505 42nd Ave, Hyattsville MD 20781 

RE: mments on undated CPSC staff report entitled 

"Technology Demonstration of a Prototype 

Low Carbon Monoxide Emission Portable Generator" (draft TD> 1 

-----------------------------------------------------------------

Thank you for making this report available for public comment. 

My last comments to you on the subject of improving portable generator safety were sent in 

2007 in response to the Advanced Notice of Proposed Rulemaking (ANPR) CPSC published in 

the Federal Register on December 12, 2006, in which the Commission said it "was interested 

in receiving the following information: 

1. Any information related to reducing the CO [carbon monoxide] emission rate of engines 

used on p!f tRey Ra'.'e ta get a fli aRfi wReR tReR Reed it, appi)' IJflt NOT 2()7§ fuRless 

•-----r Fonnatb!d: Left: 1", Right: 1", Different first 

[ page header 

~ Fonnatted: Font: (Default) Arial, 11 pt 

'""-.._ Fonnatb!d: Indent: Left: 0", Hanging: 0.38", 

Don't adjust space between Latin and Asian text 

~ Fonnatb!d: Font: Not Italic 

~ ~ Fonnatted: Font: (Default) Arial, 11 pt 

1 draft TO =."Technology Demonstration of a Prototype Low Carbon Monoxide Emission Portable Generator.· Janet ....-----{ Fonnatted: Font: Anal Narrow 

Buyer. CPSC Directorate for Engineering Sciences, undated but 2012. Accessed 11/12/12 free at 

http://www.cpsc.gov/librarv/foia/foia12/os/oortgen.pdf via link to "Research Reports" posted under "Voluntary 

Standards" at http://www.cpsc.gov/volstd/research/research.html 
ll/13/12 Public Comments ofDonnay to CPSC re. draft TD page 'l_ 

the;' iRS91'perate 3R)' eRe ef the JVIGSF-f liFR!ts er AU. ef the IJI..~()J4 /iFR!ts} portable 

generators, weatherization of portable generators, or interlocking device concepts." 2 

Consumers Union, the Consumer Federation of America, Kenneth Frank (an ex-VP of 

operations for Coleman), and I all separately recommended that CPSC require portable 

gasoline-powered generators to be fitted by the manufacturer with a CO detector linked to an 

alarm and automatic cut-off switch. This "CO controller" would warn users and stop the 

generator as soon as a dangerous level of CO was detected, indoors or out. 3 

~ Fonnatted: Underline 

Fonnatb!d: Underline 

Now almost six years-and over 450 generator-related CO deaths later- 1 still believe this is the 

best possible solution to prevent CO-related deaths and non-fatal poisonings from portable 

generators. This is because already available CO controllers, such as those widely used for 

decades to tum exhaust fans on in commercial parking garages when CO levels exceed 25ppm 

(and alarm if levels exceed 100ppm) rely solely on proven technology that does not require any 

input on the part of the operator except to annually test the sensor and replace it when 

indicated, approximately every 5 year. 4 

Only an automatic CO controller set at such a low threshold can stop a portable generator 

quickly enough to prevent significant CO poisoning of anyone in the immediate vicinity and also 

prevent any significant CO contamination from accumulating in any room in which the generator 

may be running -which will protect anyone going to check on the generator if and when it shuts 

off for any reason from being poisoned by CO in the vicinity. 

Given that CPSC "staff began working on ways to reduce CO emissions from engine-powered 

equipment, including portable generators, in 2002," including "investigating the feasibility of a 

gas-sensing interlock mechanism;" and given that then Chairman Stratton instructed the 

executive director in 2005: "to undertake a thorough review of the status of portable generator 

safety, ... to address, at a minimum, the following issues: (1) Feasibility of safety cut-offs that 

would shut down a generator before CO reaches unsafe levels;"5 I expected that the staff 

would proceed expeditiously to review the public comments it received and complete its report 

to the Commission. 

I expected this "thorough review" would include the results from the testing of any options 

CPSC evaluated including cut-off devices. And I also, of course, hoped that the Commissiononce informed by these results-would proceed quickly to propose engineering controls that 

could stem the rising tide of CO deaths. 

z Portable Generators; Advance Notice of Proposed Rulemaking; Request for Comments and Information, 71 FR 

74472.4, 12/12/2006. Accessed free at httpsJifederalregister.govla/E6-21131 

J All comments available at http://www.cpsc.gov/librarylfoia/foia071pubcom/portgenanpr.pdf 

As indexed by CPSC, QeAAay-comments - cc 97 a 9, cu & CFA= cc 07-3-10, aM-Frank-= cc 07-3-1 Iand 

Donnay= CC 07-3-9 

4 CO controllers for exhaust fans have a more limited range, usually 0-250ppm, and are designed to meet both UL 

2017 and section 201 .1 of the International Mechanical Code. which requires exhaust fans to come on at 25ppm and 

alarms at 1 OOppm. Most aRe are belli FRere aselirale aRe reliable !liaR l'leFRe CO alaFFRs. Tl'ley alse can be 

configured to fail-safe when their battery or sensor need replacing or if other critical components such as alarm 

circuits fail during automated self-testing. 

s memo from Commission Chairman Hal Stratton to Executive Director, October 12, 2005, as cited in the 12/12/06 

ANPR 

9 
11/13/12 Public Comments ofDonnay to CPSC re. draft TD page 3 

The Commission, however, moved quickly only to upgrade the CO "WARNING" label on 

portable generators to a pictogram-style "DANGER" label. While label improvements were 

needed, it is clear from the statistics and case reports compiled since by CPSC that new labels 

have not stopped CO deaths and poisonings from continuing . Effective engineering controls are 

clearty still needed. 

Given the availability of fail-safe CO controllers, I am appalled that CPSC has allowed the easily 

resolved problem of CO poisoning caused by portable generators to remain uncorrected for so 

long. The staffs latest report notes that CO deaths have increased significantly since CPSC 

began working on this in 2002, with over 650 lives lost in the last decade-- more than CPSC 

attributes to any other type of combustion appliance it regulates. 

When the ANPR was issued in December 2006, its wording suggested that CPSC was open to 

considering a variety of options for reducing CO deaths and had not yet ruled any in or out of 

further consideration . The ANPR did not disclose, however, that CPSC staff had already 

completed their review of CO shut-off switches or that, when presenting their findings to the 

Commission in October 2006, they had already stated "their belief' "that the most reliable way to 

limit consumer exposure to harmful CO was to limit the engine's CO emission rate."6 (My 

comments on this option follow below.) 

Only now six years later, in your draft repert GQRGemiR~ perta91e ~eReFat9FS eRtitle9 

"Technology demonstration of a prototype low carbon monoxide emission portable generator," is 

this history disclosed. 

7 But even this latest report does not fully disclose the extent or results 

of the staffs testing of shut-off devices, which apparently ended in 2006 before the ANPR was 

even issued. 

The draft TO Yellr repert does not disclose that one CPSC engineer tested and published the 

results of using a remote CO detector to wirelessly shut down a generator located up to 50' 

away in August 2006,

8 or that at least one other CPSC engineer tested at least one hard-wired 

CO controller but never published the results. 

In response to J!!Y..el:lf'-recent inquiries, you FSGeRtly claimed that the results from testing the 

hardwired controller were not publicly available because they were not "cleared" for release. 9 

But if so. eveR if Ret Gleare9 fer release, CPSC staff.should still have disclosed to the public that 

this testing was done, why the results were not cleared for release, and why no further testing 

was attempted. 

If the hardwired results were not cleared pre-2006 due to problems with the quality or integrity of 

the research or the experimental design, why did you not assign more capable engineers to 

design and conduct more appropriate tests? But if not cleared due to problems with the hardwired CO controllers that were tested , why has CPSC not initiated any further investigation of 

6 Janet Buyer Staff review of portable generator safetv. CPSC Directorate for Engineering Sciences 10/11 /06 

Accessed 11 /11/12 at htto://www.cpsc.gov/library/foialfoia07/brie6'PortableGenerators.pdfStaff 9FieliR!J paskage te 

CeRlRlissieR eR peFtaele geReFater safe!}', Gsteeer 2QOO. 

Also disclosed in draft TDiatest llRaatea staff repert, p11 . 7 "TesARelegy aeRlaRstratiaR ef a pretal}'pa lew saFbeR RlBR9lliae eRlissiaR peFtaele geRarater" JaRat Bl:Jyer, Prejest 

MaRager, l:JRaatea Bl:JI 2Q12, draft TD. p10. 8 "Demonstration of a remote carbon monoxide sensing automatic shut off device" Arthur Lee, Electrical Engineer, 

August 2006. Accessed 11/12/12 at http://www.cpsc.gov/volstd/engine/COaslpostvet2.pdf 9 email from Janet Buyer, Project manager, to Albert Donnay, 11/10/12. 

9 

~ Formatted: Underline 

Formatted: Underline 
11113/12 Public Comments ofDonnay to CPSC re. draft TO page,4 

these devices? Hundreds of thousands are already installed in parking garages and other 

potentially hazardous high CO environments nationwide. 

~ Formatted: Underline 

Formatted: Underline 

I urge staff to disclose in this latest report exactly what type(s) of hard-wired CO controllers were 

tested by whom and with what CO alarm points. Staff also should disclose when this option--

which you described in the 2006 review as "currently being evaluated by CPSC staff' 10--was 

completed, when if and when any staff sought clearance to release the results, and most 

importantly of course, why clearance (if sought) was refused.

44 

Staff also should include cost estimates for hardwired CO controllers, just as they have 

published for remote CO controllers in their 2006 review, and they need to consider more than 

one make or model. 

While I was pleased to see that staff provided the Commission with a one-page advertisement 

for a commercially available CO controller in their 2006 review.lZ_same eriefiRS paGkase, the 

marine model they chose is meant only for use on boats and not appropriate for portable 

generators. Its CO sensor is not located at the source (in the boat's engine or generator 

compartment) but in the boat's cabin, and the sensor is nothing more than a standard UL 2034-

listed home CO alarm. 13 

As a result, the shut off on this device is not triggered when a specific CO level is exceeded as 

in commercial CO controllers for garage fans , but only when the one of three time-weighted 

alarm ranges of UL2034-Iisted home CO alarms are exceeded. 

As CPSC should recognize, it is fatally inappropriate to use home CO alarms as controllers for 

portable generators that can produce lethal concentrations of CO when used indoors that far 

exceed the 1200ppm level designated by NIOSH as "immediately dangerous to life and health' 

-and according to your results, in less than 10 minutes. 

The UL2034 standard in contrast, requires alarms to be delayed at least 4 to 15 minutes over 

400ppm. and as long as one to four hours (if continuously over 70ppm.

14 

While I agree with the "CPSC staffs preferred approach in addressing any hazard" which is "to 

attempt to eliminate or reduce the hazard at the source," I strongly disagree with your 

conclusion that "therefore, the strategy of substantially reducing the engine's CO emission rate 

10 Janet Buyer. Staff review of portable generator safetv. CPSC Directorate for Engineering Sciences 10/ 11 /06. 

JIIBet Iht)·er. 2QQii . eJl eit. p 13. 11 If 111e reEHllls ef testiA!J J:larawirea CO seAtrelleFS were Ret slearea a~:~e te prebleFRs ·NitA 111e q~:~ality er iAIS!JFily ef IRe 

researsJ:t er 111e ellpefiFReAtal aesigA, wl:ly aia CPSC Rat siFRply assigA FRere sapaele BA!JiAeeFS te seAa~:~st FRere 

apprepfiate tests? iM if Ret slearea a~:~e te prebleFRs 'Nill1111e J:tara wires CO saAtrelleFS 111at ,...,ere testes, •NAY J:tas 

CPSC Ret iAitiatea aAy fllrll1er iA'IestigatiaA ef 111ese ae•1ises, siAse teAs ef IJ:le~:~saAEis FRase by e11er a aezeA 

FRaA~:~faslllreFS FRaRy '1Jill1 prea~:~stieA Raw bases iA Cl:liAa are alreaay iAstallea iA paFkiA!J garages aRe ell1er Ri!)R 

CO 8A'IireAFReAis AatieAwiae? 12 Janet Buyer. Staff review ofportab1e generator safety. CPSC Directorate for Engineering Sciences. 10/11/06. Tab 

R. page 161 . Accessed ll/11 /12 at www.cpsc.gov/library/foia/foia07/brie17PortableGenerators.pdf 

13 phone call eA 11/1 :Y12 with Keith Jackson of Maritech Safety( a division of IPCD Associates). 11/12/12 14 ANSI/UL 2017 applies to CO controller/central control units and ANSI/UL 2075 applies to linked sensors and 

transmitters. Details on these and other CO-related device standards were accessed 11/12/12 

at www.inteccontrols.com/pdfs/Overview of Standards for CO Detection Products.pdf 

9 
ll/13/12 Public Comments ofDonnay to CPSC re. draft TO page 5 

is considered the most appropriate for addressing the CO poisoning hazard associated with this 

product." 15 

My opinion in this regard is echoed in a survey of fire and rescue personnel in Palm Beach 

County entitled "An evaluation of the use of portable generators and carbon monoxide 

poisonings and deaths following hurricanes in Florida." 16 I assume the findings of this 2008 

report are known to CPSC and urge that they be acknowledged and referenced in the latest 

report. 

In response to being asked "Which of the following is the most important improvement a 

generator manufacturer should implement to lower incidents of carbon monoxide poisonings 

and death?", representatives from 15 of the county's 18 fire and rescue departments voted as 

follows: 

• 1 chose the Commission's priority to "improve signage and warnings"; 

• 4 chose the staffs priority to "reduce carbon monoxide emissions"; 

• 16 agreed with our priority, 'detection equipment that shuts the unit down when elevated 

carbon monoxide levels are detected." 

They apparently recognize, as I am concerned CPSC staff do not, that it is far better to 

automatically shut-off a generator before anyone can be seriously CO poisoned by it than to 

lower the CO level to which users are exposed but still allow them to be poisoned indefinitely 

without any warning. 

While I support any reasonable effort to reduce CO emissions from any source, CPSC is not an 

air quality agency, and it should not make this a priority over more effective and less expensive 

approaches that could actually prevent more-if not all-generator related CO deaths. 

The laudable 93% reduction in CO emissions that CPSC achieved in their testing program of an 

extensively modified generator--including an expensive catalytic converter-did not make 

generators safe to use indoors even for brief periods. 

As shown in the presentation you gave at the GIE+Expo in Louisville last month, CPSC's best 

prototype still produced sustained CO concentrations of up to 1 OOOppm in a closed garage, and 

over 100ppm in a doublewide prefab home to which the garage had been attached by NIST for 

these experiments.

17 While these levels are less than the NIOSH IDLH level of 1200ppm that 

you cite for comparison in your report and presentation , the maximum allowed level of acute CO 

15 draft TD JaAet 811yeF. TI!C~NOLOGY DI!MONSTRATION Or: A P~OTOTYPI! LOW A.~80N MONOXIDE 

EMISSION PO~TA8LE GENERI\TO~. IIAElateEl, pHF. 16 Gregory Giaccone, February 2008, Delray Beach Fire Rescue. "An applied research project submitted to the 

National fire Academy as part of the Executive Fire Office Program" Accessed 11/13/12 at 

http :1/www .usfa. fema.gov/pdf/efop/efo41768 .pdf 17 Janet Buyer. CPSC Directorate of Engineering Sciences.- ''Technology demonstration of a prototype low carbon 

monoxide emission portable generator" Presentation at GIE+Expo, Louisville KY, October 26, 2012. ~ 

Carries disclaimer that "The material contained in this presentation is that of the CPSC staff and has not been 

reviewed or approved by, and may not necessarily reflect the views of, the Commission."_Accessed 11 /11/12 at 

http://www.cpsc.gov/volstd/engine/portgenpres.pdf 

9 

Formatted: Underline 

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11113/12 Public Comments ofponnay to CPSC re. draft TO page 6 

exposure that CPSC should be concerned about is the NIOSH workplace ceiling level of 

200ppm, as the staff cited in their October 2006 review.

18 

This is the level at which NIOSH recommendations the immediate evacuation of any workplace, 

and it is consistent with CPSC's own literature on CO poisoning which warns that "at 

concentrations above 150 to 200 ppm, disorientation, unconsciousness, and death are 

possible." 19 

Have CPSC staff noticed that the UL 2034 standards for home CO alarms that it promotes do 

not allow an instant alarm at the NIOSH ceiling of 200ppm, but instead require a delay of 10 to 

50 minutes in this range? Even at twice or more the NIOSH ceiling limit, UL 2034 still requires 

a delay of at least 4 to 15 minutes. But it is actually the lowest alarm threshold of UL2034-

which requires a one to four hour delay if CO is continuously in the 70 to 150ppm range--that 

allows the greatest inhaled dose of CO over time without any warning , up to 600 ppm*hours 

(=150x4). 

At 600ppm*hours. the maximum CO dose allowed by home CO alarms is almost +J:»s..more 

300% is far A'lere more than the maximum daily inhaled CO dose allowed by US EPA for the 

public (=216ppm=9x8x3) and 50% more than the 400ppm*hours allowed by US OSHA for 

healthy workers. QQQQQQQQ 

CO alaFA'ls like SA'leke alarA'ls st:le.,.ld be re~:J.,.ired te pre•tide as A'li,!Gt:l Ret as li"'e reliable 

early waA'liR~ te GeRS~,JA'lers as teGt:IRiGally pessible se tt:lat tt:ley GaR step tt:leir peiseRiR~ as 

I:JI,IiGkly as pessible. 

Pest Ne.,.reRb.,.~. tt:le QeiA'leRt repert aRd tt:le CeA'lA'leR ~.,.le , tihere is no moral justification for 

UL requiring that consumers be exposed to CO continuously for one to four hours at levels 

above 70ppm before they can be warned about their CO exposure. CO alarms like smoke 

alarms should be required to provide as much-not as little-reliable early warning to 

consumers as technically possible so that they can stop their poisoning as quickly as possible. 

It appears is similarly unethical for CPSC to recommend lowering CO emissions from portable 

generators in order to deliberately prolong and delay the progression of CO poisoning 

symptoms in the hope that such delays will give otherwise unsuspecting victims more time to 

recognize the onset of dangerous symptoms} 

CPSC staff say they does not want to make generators safe for consumers to operate indoors. 

but this dangerous behavior cannot be stopped by lowering emissions. 

Depending on how such CO reductions are promoted by portable generator manufacturers, we 

I am af&-Concerned tHat-they may create SYGA-a false sense of security among consumers and 

lead more people to try running their generators indoors, which would only increase cases of 

CO poisoning if not also CO deaths. Consider the automobile analogy: while catalytic 

converters reduced CO emissions nationwide and so have lowered ambient levels a few ppm 

per decade, they do not lower emissions enough to prevent CO deaths and poisonings that still 

18 Janet Buyer. "Staff Review of Portable Generator Safety" 10/11/06, included in ANPR briefing package from staff 

to Commission, 10/11/06, p17. AGGessea 11/11/12 at 

11ttp:/!>M•,w.GflSG.!JaWbi8RAR¥!r;OIMOI.A.Il7/brief/PertableGeReraters.paf 19 CPSC: Carbon Monoxide Questions and Answers. CPSC Document #466. Accessed 11/12/12 at 

http://www.cosc.gov/coscpub/pubs/466.html 

~ Fonnatted: Underline 

Fonnatted: Underline 

9 
11/13/12 Public Comments ofDonnay to CPSC re. draft TD 

occur when people leave their vehicles idling inside attached garages. 

page 7 ---<::t Formatted: Underline 

Formatted: Underline 

There is simply no research evidence to support sStaff belief belieY&-that a lower CO emission 

rate W91:HG-will reduce CO deaths by first delaying the onset of CO symptoms among poisoning 

victims and then by slowing the rate of symptom progression from mild to incapacitating so that 

victims may have more time to recognize their symptoms and also to escape to fresh air. 

This approach would not necessarily reduce CO poisonings, however, because the total 

inhaled dose of CO (which equals the average concentration inhaled multiplied by the time of 

exposure) could easily be greater than if occupants had been exposed to much higher levels of 

the generator's CO emissions wet=e FRilGt:l t:li!Jt:ler, as higher exposure wiU-would provoke 

symptoms sooner and lead to faster activation of any home CO alarms, whether in the same 

room as the generator or elsewhere. 

The difference in alarm response time between the lowest and highest thresholds is significant: 

generator users could be warned of a CO danger after as few as 4 minutes at exposures over 

400ppm as compared to as leR!J as 4 hours if their exposure stayed above 70 but did not 

exceed 150ppm for 10-50 minutes. 

20 Notably and of great concern is that the home CO alarms 

CPSC tested in the ki,Gt:leRs kitchen while !:l_generator_s-ran in garages were-never activated, 

even though the after 't:le generator ran for over an hour. s t:la9 seeR FilARiA!} fer aR t:le~Jr er 

R**9_, ell' eveR if leGa,e9 iR 't:le !JaFa!Je, a t:leme CO alarm Ge~JIG still ~ke 15 miRiltes ever 

4QQJlJlFR te alarm, at wt:liGt:l JleiRt aAnyone entering the garage to check on the generator at that 

point GeYkk:ould be exposed to thousands of ppm and quickly incapacitated er kille9. 

The staffs stated goals of delaying both the onset of CO symptoms and the rate of their 

progression from mild to incapacitating are misguided because any debEay in recognizing the 

problem and stopping further exposure will only needlessly extend the victims' exposure time 

and worsen their cumulative CO poisoning, without any assurance that they will be sufficiently 

educated, alert and able to respond as CPSC staff hope by moving promptly to fresh air. 

CPSC staff acknowledge that this approach depends entirely on those who are being CO 

poisoned to: 

a) "recognize that their symptoms are indicative of dea.Qeveloping hazardous situation" 

and 

b) "even if they are not aware of the cause" (likely since CO poisoning usually begins with 

very common flu-like symptoms), "remove themselves from the exposure before being 

incapacitated. "

21 

But staff have not presented any human data in this report or their 2006 review to support their 

belief that that consumers with no prior experience of CO poisoning and no CO alarm to warn 

20 The total inhaled dose from 400ppm of CO exposure for 15min is 100ppm*hours and, §Q.the same as after 4 hours 

of exposure to 100ppm. but the health effects of low and slow CO exposures are often more serious because lower 

CO levels are not as aggressively sequestered in blood as COHb. which allows relatively more free CO to diffuse 

from plasma into tissues., Bl:lt tt:le lligller IEJ><el ef eM~es~:~Fe is asl~:~ally Better leleraleElBesa~:~se meFe aggressi•;ely 

seqliestered ey llem9!Jie9iA iA eleed, ail9'o'liA!I relati·tely less ef tt:le letal eM~esliFe le difk!se ffem Bleed iAte tisslie 

wllere GO asll:lally sa~:~siR!I sym~lems tt:lre~:~gll ils BiRdiR!I witt:l FRy9!JieBiR, Rei:IFe!JieBiR, sytest:lFemes aRd elller lleme 

~FeteiRs tt:lat aFe m~:~sll mereBieastive tt:laR lleFRegleBiA. J 

21 draft TO. p11 . 

9 
them will either recognize their early flu -like CO symptoms as 'dangerous' or know -what 

response is appropriate if they do.respeRe appreprialely. 

Consumers who develop common early warning symptoms of CO poisoning such as headache 

and fatigue during whatever stressful emergency has led them to use their portable generator 

are unlikely to think of these as "dangerous" and more likely to simply take an aspirin or a nap 

than to go outside into fresh air, especially if they are in the midst a storm or other inhospitable 

weather. 

Most critically8wt etJeR if there were eata te swpparl this hwmaR saRa f)' appreash , it is 

completely unethical-and thankfully unnecessary- to put the burden of reducing excess CO 

deaths from portable generators on consumers by expecting them to use their own bodies as 

CO detectors, aspasially when fail-safe CO controllers for exhaust fans are available fer wReer 

that activate within 60 seconds above 25ppm and could therefore prevent both COrelated poisonings and deaths. It would be a giant leap backwards for CPSC to ignore this 

proven if il ware ta abaReeR pretJeR technology without at least first giving it a fair aoo 

traRspareRt test. 

Wl:lile-§&taff have repeatedly raised se•;eral concerns dating back to the 2006 review about the 

durability switability of attaching iRte§ralee CO controllers attached to fer wse eR portable 

generators-citing the need to protect them iRslweiR§ prelesliR§ lhem from extreme weather, 

heat, and vibration . But ee2:eRs ef is Re 2!2!2!2!2!2!those designed 

sherla9e ef semmersially a>Jailable ee>Jisesfor year-round use in parking garages to 

specifications ofthe International Mechanical Code and UL 2017 are already able to survive 

such stresses. 

22 

8wt we rejest aRe They are not, however, designed WF§e CPSC staff la reseRsieer their 

2QQ9 assessmeRt that 

"AR effesli•;e CO alaFFR shewle be able te "to discriminate between a small 

.temporary pocket of CO and a otentiall lethal cloud " as !!CPSC staff claim "an effective CO 

alarm should be able to." 2 

To offer the most possible protection against potentially lethal CO clouds, however, we-will 

always waRt CPSC should whate>Jer want CO controllers to shut off is attashee te a portable 

generator.§. tG-_alafm..whenever their -4t&-threshold set paiRl is exceeded , even if outside. 

, either immeeiately ar after •.vhate•;er brief leR§th af lime meeisal eJEperls •A•awle saRsieer 

asseptable ta i§Rare as a haFFRiess aRe ~eetiR§ elEpaswre. 

What staff view as "a disadvantage of this approach" -namely that "the CO sensor may impair 

the ability of the generator to run when properly operated outdoors if the exhaust accumulates 

or circulates around the generator" - is in fact one of its advantages because it can GaR-prevent 

inadvertent CO poisoning.§. from generators set up improperly either indoors or outeeers as well 

as iReeers, 

22 See, for example, CO controller model SPC3-1112 by lntec Controls, which is weatherproof from -14F to 122F, 

and has a user-replaceable sensor with a 5 year life expectancy as well as a digital display of the current CO level 

and audio/visual alarm signals. Accessed 11 /13/12 at www.inteccontrols.com/pdfs/SPC3-1112.pdf 

23 "Demonstration of a remote carbon monoxide sensing automatic shut off device" Arthur Lee, Electrical Engineer, 

August 2006. p4. Accessed 11/11/12 at http://www.cpsc.gov/volstd/engine/COaslpostvet2.pdf 

9 

Formatted: Underline 

Formatted: Underline 

Formatted: Font: (Default) Arial, 11 pt 

Formatted: Font: (Default) Arial, 11 pt 
11/13/12 Public Comments ofDonnay to CPSC re. draft TD page 9 ~ Formatted: Underline 

Formatted: Underline 

If a CO controller shuts of a generator outdoors. it will most likely be because the generator &H 

a-was located CO GeAlFGIIer is FRliGR mere likely te SRlll eff a geAerater eperatiA§ iFRpFGperly 

el!tQeers tt:laA pFGperly, SliGR as wt:leA plaseg closer than tt:le maAllfaGtllrer recommended& to 

potential obstructions such as buildings, vehicles, and hedges wAiGR-that can block the -

dissipation of exhaust. 

Generators should be prevented from running in such conditions, and it should not take too 

many CO alarms for users to realize they the need to place the generator further from 

obstructions and/or rotate the frame so that the exhaust stream blows downwind instead of back 

towards the generator. 

The fact that "small pockets of CO may cause the sensor to alarm and shut off the generator 

even though CO has not entered the home" is not too high a price to pay to protect people who 

might otherwise be severely poisoned simply by standing outside next to a generator for a few 

minutes. 

!We urge CPSC to more thoroughly test commercially available CO controllers with 35ppm 

thresholds for their ability to shut off portable generators both indoors and out - and to warn 

users- before CO poisoning occurs. These tests should be done with devices listed to UL 

2017 and/or UL2075 standards, not UL 2034.

24 

If these tests prove successful, !we-wi» urge the Commission to move quickly to require that 

manufacturers install a CO controller on all new portable generators. Given their proven lifesaving potential in other applications, this should be the Commission's highest priority, 

regardless of any other technological or educational approaches they may consider. The 

Commission also should ask We 'N9lllg like te see manufacturers voluntarily recall and install 

effective CO controllers on all previously sold generators, or at least GffeHG-make this upgrade 

available at cost fer.out-of-warrantv customers who request it. 

If generator manufacturers formed a consortium to jointly purchase a mutually agreed upon 

model of CO controller for the largest possible economy_ies-of scale, their unit cost would be 

less than that of currently available hardwired home CO alarms designed to the UL 2034 

standard with a digital display and 9v battery backup. !We estimate this additional cost to be 

in the range of 2Q4.0- . , Bllt eveR Even if twice this amount, however. CO controllers are 

tt:lese will ee still a far more cost oost-effective-at method of preventing CO deaths aoo 

peiseAiA!JS than a-reducing iiiei="ate of CO emissions. which even if successful in preventing 

some deaths. will only needlessly prolong many more CO poisonings. QJ% F9QliGtieA iA CO 

emissieAs 

I Thank you for your consideration." 

24 The SPC3-1112 from lntec Controls meets UL 2075 and 201 7 and is made in USA. 

9 
Comments on CPSC's Technology Demonstration of a 

Prototype Low Carbon Monoxide Emission Portable Generator 

p. ix While the report mentions that the modeling was based on an adult male 

because most deaths fit this category, you might want to consider also using model 

inputs for small children and the elderly since they tend to be most vulnerable to the 

effects of CO, e.g., children's breathing rate is faster. 

p. 21 Double check the floor area values for the home and garage. The report lists the 

house floor area as 140 m2 (1500 ft2

) and the garage floor area as 105 m2 (1130 ft2

). 

The garage seems very large in comparison to the house when you compare the aerial 

view in Figure 8 and the floor plan in Figure 9 with the measurements listed on p. 21. 

p. 24 It looks like having the exhaust pipe pointing toward the house wall is for a worstcase scenario, but it seems like you should also test what happens when the exhaust 

pipe is pointing away from the house wall because it could still generate enough CO to 

affect people's health. 

w:\stephanie\combustion pollutants\comments on cpsc prototype low-co generator.docx 
From: 

To: 

Cc: 

Subject: 

Date: 

Attachments: 

Hi Janet, 

Parent. Stephanie@ARB 

Buyer Janet 

Jenkins. Peqgy@ARB 

Unofficial Comments re: the CPSC staff report 

Wednesday, November 14, 2012 4:38:31 PM 

Comments on CPSC Prototvoe Low-co Gene@tor.Qdf 

Thank you for the opportunity to comment on CPSC's staff report, "Technology Demonstration of a 

Prototype Low CO Emission Portable Generator." Attached are informal and unofficial comments. 

My apologies that they are a day late. 

Overall I felt the report was good as well as the idea to research how to develop a low CO emission 

portable generator. 

Please let me know if you have any questions about my comments. 

Sincerely, 

Stephanie 

Stephanie Parent 

Air Pollution Specialist 

Research Division - Indoor Exposure Assessment Section 

1 001 I Street 

Sacramento, CA 95814 

Phone: (916) 324-0551 

Fax: (916) 322-4357 

sparent@arb,ca goy 

www arb ca goy 

The energy challenge facing California is real. Every Californian needs to take immediate action to 

reduce energy consumption. See a list of simple ways (www.fypower.org ) you can reduce demand and 

cut your energy costs. 

If you would like to give us feedback on our customer service, please complete the customer 

satisfaction survey located at www calepa ca govLCustomer!CSForm asp. 

From: Buyer, Janet [mailto:JBuyer@cpsc.gov] 

Sent: Monday, October 29, 2012 5:49 AM 

Subject: CPSC presentation summarizing staff report on Technology Demonstration of the 

Prototype Low CO Emission Portable Generator 

Hello all, 

Attached is a copy of a presentation I gave at a workshop last week that gives a "reader's 
digest" summary of the CPSC staff report " Technology Demonstration of a Prototype Low 

CO Emission Portable Generator" that was recently released (see e-mail below). I am 

forwarding it around as a way of encouraging folks to send us your comments on the 

report. I'd be happy to walk anyone through it- I could do it in about 10-15 minutes. The 

comments we receive will help CPSC forge the path forward. Comments are due to~ 

os@cpsc.gov by Nov 13. Feel free to forward this to anyone you think should or would be 

interested. 

Regards, 

Janet Buyer 

Project Manager, Portable Generators 

U.S. Consumer Product Safety Commission 

Directorate for Engineering Sciences 

5 Research Place 

Rockville, MD 20850 

301-987-2293 

From: Buyer, Janet 

Sent: Friday, September 14, 2012 12:42 PM 

Subject: CPSC releases staff report on staffs technology demonstration of a prototype low CO 

emission portable generator 

I am pleased to inform you that the U.S. Consumer Product Safety Commission (CPSC) has 

released a report on staff's technology demonstration of a prototype low carbon monoxide 

(CO) emission portable generator. This staff report, available on-line at 

http://www.cpsc.gov/library/foialfoia12/os/portgen.pdf, fully documents staff's research 

performed under the agency's advance notice of proposed rulemaking (ANPR) to address 

the CO poisoning hazard associated with portable generators. CPSC's press release 

announcing the report is included below. Staff welcomes your comments on the report; 

please submit them by e-mail to CPSC's Office of Secretary, cpsc-os@cpsc.gov by 

November 13, 2012. If you are unable to submit comments by e-mail, you may submit 

written comments to: 

Office of Secretary 

U.S. Consumer Product Safety Commission 

Washington, DC 20207-0001 

Please include the report title "Technology Demonstration of a Prototype Low CO Emission 

Portable Generator" in your correspondence. 

Regards, 

Janet Buyer 
Project Manager for Portable Generators 

U.S. Consumer Product Safety Commission 

5 Research Place 

Rockville, MD 20850 

301-987-2293 

jbuyer@cpsc.gov 

For Immediate Release 

September 14, 2012 

7908 

Release #12-278 

CPSC Hotline: (800) 638-2772 

CPSC Media Contact: (301) 504-

Escaping the Invisible Killer: New CPSC Research 

Demonstrates Technology That Can Significantly Reduce 

Poisonous Carbon Monoxide from a Generator 

Consumers' escape time increased from eight minutes to 96 minutes 

WASHINGTON, D.C. -A new study released today by the U.S. Consumer Product Safety 

Commission (CPSC) demonstrates that readily available technology can dramatically 

reduce deadly carbon monoxide (CO) emission rates from certain common portable 

gasoline-powered generators. The technology can provide additional critical time for 

consumers to recognize and escape from the deadly hazard of carbon monoxide poisoning. 

With the adaptation of existing emission control technology, CO rates can be lowered to 

levels that would save lives. On average, carbon monoxide from portable gasolinepowered generators kills more than 70 people every year. 

CPSC staffs study outlined one method to reduce the generator engine's CO 

emission rate by using closed-loop electronic fuel injection and a small catalyst-the same 

emission control technology used on motor scooters and small motorcycles. This 

significantly increased the predicted escape time by twelve times the current time-from 

eight minutes to 96 minutes- for the deadly scenario when a consumer is in their garage 

while they are running their generator there. 

CPSC's study also showed that the predicted escape time for those consumers 

inside the house, as opposed to the garage, was even greater. The escape time is the time 

between onset of obvious symptoms and incapacitation. 

The CPSC continues to urge consumers to never run their portable generators in 

their attached garages, in or even near their houses, including avoiding placement outside 

near windows or vents. Generators should only be used outside, far away from homes. 

CPSC cautions that even if portable gasoline-powered generators were to incorporate this 

technology, they would still need to be used outside, far from the home. The technology 

does not make them safe for indoor use. 

Another important line of defense against CO poisoning is having CO alarms on 

each level of the home and outside sleeping areas. Based on available alarm data 93 
percent of CO-related deaths involving generators take place in homes with no CO alarms. 

Much like smoke alarms are designed to alert consumers about smoke or fires, CO alarms 

are designed to alert consumers to dangerous CO levels and give them time to get out of 

the house before becoming incapacitated. 

Deaths involving portable generators have been on the rise since 1999 when 

generators became widely available to consumers. There have been at least 755 CO deaths 

involving generators from 1999 through 2011. While reporting of incidents for 2011 is 

ongoing, there were at least 73 CO related deaths involving generators last year. 

Generators are responsible for the largest number of estimated non-fire CO deaths 

associated with consumer products. From 2006 through 2008, generators accounted for 43 

percent of CO deaths compared to 33 percent for heating systems, such as furnaces. 

Furnaces had historically been responsible for the most CO deaths. 

Generators are used by consumers to keep lights, electrical appliances or heating 

and cooling units running in their homes during power outages. Incapacitation or death can 

occur within minutes if consumers use a generator inside a home, garage, shed or use it 

outside near windows or vents, because dangerous levels of CO from a generator's fuelburning engine build up quickly. 

With the release of this study, CPSC is urging manufacturers to voluntarily adopt a 

stringent CO emission standard for engines used in portable gasoline-powered generators 

with the expectation that it will improve safety and save lives, just as the marine industry 

did in 2005. That year, manufacturers of small marine generator engines, voluntarily 

adopted a stringent CO emission standard to address the hazard of acute poisoning that was 

causing fatal and serious injuries to boaters exposed to marine generator engine exhaust. 

For this study, CPSC worked with the National Institute of Standards and 

Technology (NIST) and the University of Alabama to develop and test the portable 

gasoline-powered generators. 

*****!!!Unless otherwise stated, any views or opinions expressed in this e-mail (and 

any attachments) are solely those of the author and do not necessarily represent those 

of the U.S. Consumer Product Safety Commission. Copies of product recall and 

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they are released by CPSC. To subscribe or unsubscribe to this service go to the 

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SOUTHWEST RESEARCH INSTITUTE ® 

6220 CULEBRA ROAD • POST OFFICE DRAWER 28510 • SAN ANTONIO, TEXAS, USA 78228-0510 • (210) 684-5111 • www.swri.org 

ENGINE, EMISSIONS, AND VEHICLE RESEARCH DIVISION HTTP://ENGINEANDVEHICLE .SWRI.ORG 

FAX: (210) 522-3950 /SO 9001 Certified 

Janet Buyer, Project Manager 

Directorate for Engineering Sciences 

November 13, 2012 

U.S. Consumer Product Safety Commission 

4330 East West Hwy, Room 611 

Bethesda, MD 20814 

/SO 14001 Certified 

Re: 'Technology Demonstration of a Prototype Low Carbon Monoxide Emission Portable Generator' 

Dear Ms. Buyer, 

I have read CPSC's report titled 'Technology Demonstration of a Prototype Low Carbon Monoxide 

Emission Portable Generator.' I am very familiar with the approaches used to demonstrate CO reduction 

in spark-ignited engines. I am not familiar with the NIST protocols used in the 'test house', nor their 

airflow simulation programs. I am not familiar with the physiological effects of CO poisoning. 

Comments: 

• Scientifically and empirically sound report 

• Carbon monoxide reduction approach consistent with current emission reduction technologies 

• Carbon monoxide reduction efficiency was consistent with the adopted engine control strategy 

and aftertreatment 

• Test procedures for engine emission testing consistent with current practice 

• Triplicate tests of the engines is appropriate as these engines' emissions can fluctuate 

• CPSC's conclusions regarding engine emissions are consistent with this report's data 

• CPSC's conclusion regarding increased 'opportunity' for home occupants to 'recognize and react 

appropriately to a developing CO exposure' are consistent with this report's data 

• Cost of implementation of the engine's CO reduction approach and aftertreatment is not projected 

• No reported repeat tests conducted in the NIST 'test house' 

Thank you for the opportunity to review your work. It is a well done project and I commend your 

tenacity in following through over such a long period. 

Pnncipal 

~.J;i~ Engineer 

Dept. ofEngine Design and Development 

Engine, Emissions and Vehicle Research Division 

S AN ANTON I O , T E X AS 

HOUSTON, TEXAS • WASHINGTON, DC • ANN ARBOR, Ml