# Technology Demonstration of a Prototype Low Carbon Monoxide Emission Portable Generator

GIE+Expo , Louisville, KY October 26, 2012
Janet Buyer Project Manager, Portable Generators U.S. Consumer Product Safety Commission

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.

1 

## U.S. Consumer Product Safety Commission

# Overview

• What is the U.S. CPSC?

• Generators: Why CPSC Is Concerned

• CPSC Portable Generator Project History

• Technology Demonstration

• Conclusions

• Q & A 2

# U.S. CPSC

3



## • CPSC is an independent regulatory agency created “to protect the public against unreasonable risks of injury associated with consumer products.” 1

– Develops voluntary consensus safety standards in cooperation with industry

– Adopts and enforces mandatory standards or bans consumer products if no feasible voluntary standard would adequately protect the public

– Obtains the recall of products and arranges for their repair, replacement, or refund

– Conducts research on emerging and potential product hazards

– Informs and educates consumers through the media, state and local governments, private organizations, and responding to consumer inquiries

1 Section 2(b)(1) of the Consumer Product Safety Act, 15 U.S.C. § 2051(b)(1).4 

# What Is a Consumer Product?

 Jurisdiction over thousands of consumer products under the Consumer Product Safety Act

 Excludes some products covered by other federal agencies, such as:

– Cars and related equipment (NHTSA)

– Boats (Coast Guard)

– Airplanes (FAA)

– Food, drugs, medical devices, cosmetics (FDA)

– Firearms (ATF)

– Pesticides (EPA)

– Tobacco Products (ATF)5 

# Four Types of Safety Concerns

• Product fails to comply with a mandatory safety standard or ban under the CPSA

• Product fails to comply with voluntary standards relied upon by the Commission

• Product contains a defect which could create
a “substantial product hazard”

• Product creates an “unreasonable risk” of serious injury or death

# Generators: Why CPSC Is Concerned

6 6

108 138
121 181

153 168 190 180 180 189

50 82 71 93

67 85

47 49 66
67

22 37 26 47

29 43

14 30 31 32
7 19 20 42 49

41 88 85

62 86

0 20 40 60 80 100 120 140 160 180 200

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008Estimated Number of CO Deaths

Year

Total from all Consumer Products All Heating Systems Furnaces Generators Estimated Number of Non

- Fire Consumer Product Related CO Deaths

Source: Hnatov, Matthew, Non

- Fire Carbon Monoxide Deaths Associated with the Use of Consumer Products, 2008 Annual Estimates , U.S. Consumer Product Safety Commission, Bethesda, MD, December 201144 80

6 21 23 48 57

47 103 95

70 94

67

0 20 40 60 80 100 120

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011Nuber of Reported Non-Fire CO Deaths Due to Generators

Year
Serie s2

Serie s1

Reporting for years 2010 and 2011 is considered incomplete and islikely to change in future reports.

Reporting for years 1999

- 2009 is considered largely complete but may change to a relatively small extent in future reports. 

# More Data Supports Our Concern...

7 Number of Reported Non

- Fire CO Deaths Due to Portable Generators

Source: Hnatov, Matthew, Incidents, Deaths, and In

- Depth Investigations Associated with Non

- Fire Carbon Monoxide from Engine

- Driven Generators and Other Engine

- Driven Tools, 1999

- 2011 , July 2012.Living space (non

basement)



### 31% Attached garage or enclosed carport 

### 24% Basement or crawlspace



### 28% Closet, doorway, inside home no further information

reported

11% Outside home, 2%

Unknown location but at home 4% Fixed

structure home 

## 73% Non

- fixed home or temporary shelter 

### 18%

External structure at home 

### 6%

Unknown or other locations 

### 3% 

# Some of Our Hazard Analysis...

8 8 Location where incident occurred

Specific location of generator in incidents that occurred in fixed

structure homes

# CPSC Portable Generator Project History

• 2003 : Began participation as nonvoting member on STP for UL 2201, to advocate for requirements to address CO hazard

• 2004 : Hosted roundtable to discuss hazard and solicit ideas

• 2006 : Released staff report, “Review of Portable Generator Safety” and briefed Commission, recommending that most reliable way to reduce the CO poisoning risk is to reduce CO emission rate

Staff’s goal is not to reduce the CO emission rate to make generators safe to run indoors but, to reduce it enough , such that CO poisoning symptom onset is delayed, and the rate of progression of worsening symptoms is significantly reduced to provide a longer time interval for exposed occupants to escape before being incapacitated.

• 2006 : Commission voted to approve ANPR to investigate technologies to reduce hazard

• 2007 : FR for mandatory label, effective May 2007

• 2006 to present : Performed, documented, and released report on technology demonstration 9

# Mandatory Label

DANGER Using a generator indoors CAN KILL YOU IN MINUTES. Generator exhaust contains carbon monoxide. This is a poison you cannot see or smell.

NEVER use inside a home or garage, EVEN IF doors and windows are open. Only use OUTSIDE and far away from windo ws, doors, and vents. 10

# Develop Prototype 

# 2

- Part Technology Demonstration

11 

# Model Health Effects on Occupants Durability Test Engine in Generator

Conduct Certification Emission Testing at End of Life 11



# Operate Generator in Attached Garage

Determine Time Interval for “Egress”12 

### University of Alabama Design specifications :

• Adapt existing emission control technology on 5.0 kW generator

• 30 g/kW

- hr target CO emission rate

• Do not negatively impact engine power output, engine durability, maintainability, fuel economy, and risk of fire/burn

• Maintain compliance with EPA emission standard to which engine was originally certified

Prototype configuration :

• Modified 8.2 kW (11 hp ) Class II engine with 500

- hour rated useful life, certified to EPA Phase 2 standard

• A dapted EMS with closed loop EFI

• C alibrated for stoichiometric (14.6) AFR at all loads

• Integrated 3

- way catalyst, primarily to target NOx reduction, into shrouded muffler 

# Prototype Development

12Mode 1 2 3 4 5 6

Load B ank S etting (kW) 5.5 * 4.7 + 3.2 + 1.5 + 0.6 + No resistive load

Duration (minutes) 5.5 12.0 17.5 18.0 4.0 3.0 

# Durability Testing

Hourly Load Profile Applied Throughout 500

- hour Durability Program Mode 1 2 3 4 5 6

Engine Power 100% 75% 50% 25% 10% No load

Weight Factor 0.09 0.20 0.29 0.30 0.07 0.05 

### Load Profile derived from EPA 6

- mode test cycle in 40 CFR part 1065

* highest sustainable load without tripping generator’s circuit breaker (found to be 500 watts greater than generator’s advertised rated power output.) + derived by applying alternator efficiency curve to engine’s rated power of 8.2 kW 13

### • After 500 hours, compared to the unmodified OEM unit , the prototype demonstrated:

– 93% reduction of CO

– 30% reduction of HC+NOx

– 20% reduction in average fuel consumption

– S urface temperature of prototype’s muffler shroud was 110 ° C max, compared to 434 ° C for the OEM’s unshrouded muffler surface.



### • On the prototype engine :

– 220 ° C max cylinder head temperature, below the engine manufacturer’s limit

– Exhaust manifold gas temperature at all modes was within the catalyst manufacturer’s recommended operating range. 

# Durability Testing Conclusions

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## Intertek Carnot Emission Services

• Facility is lab

- to

- lab correlated with EPA and major manufacturer emission test facilities.

• Conducted exhaust emission testing in accordance with EPA regs to verify Phase 2 compliance on:

• P rototype engine with muffler with integrated, aged catalyst

• Prototype engine with muffler without catalyst



### • Performed tests with the engine installed in the generator

• D etermined the engine power achieved for each mode during durability program 

# End

- of

- Life Emission Testing

15• With catalyst muffler:

• HC+NOx was 6.7 g/kW

- hr 

# →

• CO was 6.0 g/kW

- hr 

# → 95% CO emissions reduction compared to the published certification data for the unmodified engine

• <240 ° C max cylinder head temperature, below the engine manufacturer’s limit

• Exhaust manifold gas temperature at all modes was within the catalyst manufacturer’s recommended operating range

• Delivered a maximum power of 7.9 kW, within 0.3 kW of the advertised rated power for the unmodified OEM carbureted engine 

# End

- of

- Life Emission Testing Conclusions

16

45% below Phase 2 standard 16% below Phase 3 standard• Muffler w/o catalyst:

• HC+NOx was 13.0 g/kW

- hr 

# → above Phase 2 standard

• CO was 28.1 g/kW

- hr

• Correlation of engine fuel consumption in the generator to the dynamometer revealed max sustainable load on generator was 75% of full engine power.

Dynamometer testing at mode 1 does not represent consumer use. The CO emission rate of the engine at the loads it achieves in the product is what is important . The prototype engine produced less than 25 grams/hour of CO at each mode of the load profile applied to the generator. 

# End

- of

- Life Emission Testing Conclusions
17

# Develop Prototype 

# 2

- Part Technology Demonstration

18 

# Model Health Effects on Occupants Durability Test Engine in Generator

Conduct Certification Emission Testing at End of Life 18



# Operate Generator in Attached Garage

Determine Time Interval for “Egress”

# Operate Generator in SFH Attached Garage National Institute of Standards and Technology (NIST)

4 scenarios tested to compare prototype with catalyst to OEM unit (varied by positions of bay door, utility door, HVAC fan) 19

Garage

generator20 

### Garage and Family Room CO Concentration Profiles Garage Bay Door Fully Closed, Garage/Utility Room Door Fully Closed, and HVAC Fan On 20

0 1000 2000 3000 4000 5000 6000 7000 8000 9000 10000 11000 12000 13000 14000 15000 16000 17000 18000 19000 20000 21000 22000

0 30 60 90 120 150 180 210 240 270 300 330 360 390CO (ppm)

Time (min) CO in garage from unmodified unit CO in FAM from unmodified unit CO in garage from prototype CO in FAM from prototype

Unmodified unit stopped and forced venting initiated Prototype stopped and forced venting initiated 97% reduction0 10 20 30 40 50 60 70 80 90 100

0 30 60 90 120 150 180 210 240 270 300 330 360 390COHb (%)

Time (minutes) COHb in garage from unmodified unit
COHb in FAM from unmodified unit COHb in garage from prototype COHb in FAM from prototype 

# Health Effects Modeling

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Death

Mild symptom onset Obvious symptom onset Incapacitation0 10 20 30 40 50

0 30 60 90 120 150 180 210 240 270 300 330 360 390COHb (%)

Time (minutes) COHb in garage from unmodified unit
COHb in FAM from unmodified unit COHb in garage from prototype COHb in FAM from prototype 

# Time Intervals for “Egress”

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8 min in garage 29 min in FAM

96 min in garage

FAM doesn’t reach 20% COHb in 6 hrs of engine run time Incapacitation (loss of chance for self
- rescue)

Obvious symptom onset

For these tests, if a CO alarm were in the MBR:

- With the unmodified unit in the garage, the CO concentration in the garage at the time of alarm activation would be 18,500 pp m. This would incapacitate anyone who entered the garage within 3

minutes.

- With the prototype in the garage, the CO alarm activation criteria was not met. However, staff projects that it would activa te at 400 minutes, assuming the CO in the MBR remained above 70

ppm. The CO in the garage at that time is projected to be below 1,200 ppm, a level defined by NIOSH as being Immediately Dangerous to Life and Health (IDLH, “An acute respiratory exposure that poses an immediate threat of loss of life, immediate or delayed irreversible adverse effects on health, or acute eye exp osu re that would prevent escape from a hazardous atmosphere within 30 minutes.”. Time (minutes)

# Conclusions

• P rototype reduced the CO emission rate by 93%

- 97% → more time for victims to escape.

• Dependent on human behavior, but additional time expected to result in fewer deaths.

• Urging manufacturers to voluntarily implement CO emission reduction control strategies to produce a significantly reduced CO emission rate when installed in the product.

• P rototype used same commercially available, low

- cost EMS used in Asian market for powered scooters and small motorcycles and used by EPA in Phase 3 development work over 6 years ago. 23

# Questions?

• Staff report “Technology Demonstration of a Prototype Low CO Emission Portable Generator” available online at: http :// www.cpsc.gov/library/foia/foia12/os/portgen.pdf (Or go to www.cpsc.gov and search for “Technology Demonstration”)

• Please send your comments to CPSC’s Office of the Secretary , cpsc
- os@cpsc.gov by November 13, 2012.

• For further info: Janet Buyer, Project Manager jbuyer@cpsc.gov 301

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