### U.S. Consumer Product Safety Commission

These comments are those of the CPSC staff, have not been review ed or approved by, and may not necessarily reflect the views of, the Commission. 

## Staff Review of Portable Generator Safety Briefing to the Commission October 26, 2006

## CPSC Strategic Goal to Reduce

CO Poisoning Deaths

Charcoal grills, charcoal,

5% Camp stoves, lanterns, 2% Other/multiple appliances, 8% Gas ranges/ovens, 2%

Engine-driven tools other than generators, 3% Generators, 24% Fuel-burning heating systems, 55% Gas water heaters, 0.5%
Charcoal grills/charcoal, 5% Other/multiple appliances, 8%

Gas ranges/ovens, 2% Camp stoves, lanterns, 2%

Engine -driven tools other than generators, 3% Generators, 24% Fuel- burning heating systems, 55% Gas water heaters, 0.5% Estimated CO Deaths by Category of Consumer Products, 2002

# Product Information • Fuel: Gasoline, diesel, propane, natural gas • Electricity out: Cord - connected to appliances via receptacles (120v, 240v) or to house wiring via transfer switch • Primarily contractor market before 1999 • Consumer market growing rapidly since pre- Y2K • Sold through home centers, hardware stores, discount retailers

# Hazards from Portable Generators • CO poisoning • Shock and electrocution • Fire • Thermal contact burns* For the years 1990 through 2001, these were the number reporte d to CPSC as of 6/27/2005.

For the years 2002 through 2005, these were the number report ed to CPSC as of 6/1/2006. ** The ICD - 10 System was implemented in 1999. Generator-Related Deaths Reported to CPSC

0 10 20 30 40 50 60 70

1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 YearDeaths Fire-related (rpt'ed as of 12/7/05) Electrocution (rpt'ed as of 11/4/05) CO *Deaths1990199119921993199419951996199719981999 **200020012002200320042005 Year

# Estimates of CO Injuries • Reports of fatal generator CO incidents often include survivors with severe CO injuries • CPSC staff does not make national estimates of CO injuries

– NEISS records lack enough detail to confirm injury and associated consumer product

– Mild CO poisoning cases may be confused with common illnesses • Survivors of serious CO exposures, from any source of CO, could be affected with severe disabilities

– Permanently with blindness, Parkinsonism, paralysis

– Temporarily with emotional instability, memory loss, dementia, psychosis, incontinence, peripheral neuropathy, blindness, Parkinsonism, paralysis

## Summary of Investigated Fatal CO Incidents* Out of 137 fatal incidents involving 189 deaths: • 60 deaths : generator used during weather - induced power outage or problem with power distribution. • 146 deaths : occurred at home; majority with generator in the basement/crawlspace, garage/enclosed carport, or living space of the home. • 24 deaths : appears consumer attempted to vent the indoor space where generator was operated. • 5 deaths : generator was outside the home but near an open window, door, or vent. * From incidents that occurred through 2004 that were reported to CPSC by 6/27/05, a total of 274 deaths. National totals may not be deri ved from this data as it is not a statistical sample.

## Summary of Investigated Fatal CO Incidents* • 5.0 kW – 5.9 kW generator most commonly involved, when identified in IDI • Two most common reasons for using the generator indoors:

– Fear of generator theft

– Concern about noise to neighbors 

### • Almost all generators were referred to as gas or gasoline generators * From incidents that occurred through 2004 that were reported to CPSC by 6/27/05, a total of 274 deaths. National totals may not be deri ved from this data as it is not a statistical sample.

## Consumer Portable Generator

Ownership and Sales

Sources: * Synovate , Inc.

** Multi- Client Research Group, Synovate , Inc. 

### • 10.6 million units estimated in households in 2005, up from 9.2 million units in 2002* • >1 million/year bought in 2003 - 2005** • Approximately 40% bought in 2003 -2005 were rated 5.0 kW to <6.5kW • 60% of sales to consumers cost $300 - $800 per unit • 98.7% of portable generators sold in 2003 -2005 were gasoline- fueled

## Societal Cost Estimate of

Generator CO deaths • 51 CO deaths/year, 2002 - 2005 average • Average annual societal cost is $255M; ~$25 annual societal cost per generator • Based on 7 - yr product life, estimated present value of expected societal cost/generator is $157 • Expected benefits for reduction in the hazard resulting from intervention

– 50% effectiveness: $79/generator

– 75% effectiveness: $118/generator Estimate does not include societal costs related to deaths from electrocution and fire or any injuries

## Possible Strategies to Address

CO Poisoning Hazard • Reduce consumer exposure to CO through technical means

– Engines with substantially reduced CO emissions

– Automatic shutoff devices 

### • Enable and encourage proper generator placement

– Weatherization requirements • For safe outdoor use in wet conditions • For engine operation in icing conditions

– Theft deterrence

– Noise reduction

– Improved CO warning label and manufacturers ’ guidance

## Possible Strategies to Address

CO Poisoning Hazard (cont) • Private sector consortium • Information and education

## Technical Approaches to Reduce

Consumer Exposure to CO Goal : Protect consumers against CO poisoning that can result in death or in serious and/or lasting adverse health effects if they inadvertently operate generator in

improper location NOT TO MAKE GENERATORS SAFE FOR

INDOOR USE!

# CO Hazard Characterization • Testing to determine CO generation rate of 5.5 kW generator • Modeling of most common incident scenario with generator operated in basement

– Predicted all occupants dead before fuel tank exhausted • 40 minutes for person in basement • Less than 5 hours for person in 2 nd floor bedroom 

## • 10 hp generator engine produces CO at rate 450 - 1000 times that of modern idling cars*

* Reference for idling automotive emissions: Frey, H., et al., On -Road Measurement of Vehicle Tailpipe Emissions Using a Portable Instrument , Journal of the Air & Waste Management Association, Vol. 53, August 2003.

## Engines with Reduced CO Emissions • Most reliable way to limit consumer exposure is to limit production of hazardous CO levels at the source • Automotive engines

– Catalytic converters reduced CO emission by 96%

– Still unsafe to run in garages, but unintentional CO deaths declined >80% 

### • Marine generator engines

– 2 major manufacturers voluntarily reduced CO emissions >99% using catalytic converters and electronic fuel injection

– Reduce CO poisonings on and around houseboats

## Are Substantial CO Emission Reductions

Possible for Generator Engines? • Respondents to RFI assert 90 - 95% reduction in CO emissions is readily achievable

– Catalytic converters alone or in conjunction with electronic fuel injection 

### • CPSC staff awarded contract to develop a low - CO generator prototype and demonstrate technical feasibility

## Potential Impact of CO Emission Reductions • Staff predicts that 90 - 95% reduction will result in improved survivability for most common incident scenario with generator improperly operated in basement

– Can likely result in significant delay and reduced severity of C O exposure for all occupants, except those persons in the basement

– Allows them more time to become aware of symptoms and escape

– Depending on where they are in the house, they could survive wit hout serious adverse effects even if they didn ’t leave the house
• Established interagency agreement with NIST to estimate minimum CO emissions reductions to improve survivability when generator improperly operated in garage

– Identify engine modifications necessary to achieve this level of reduction

## Are Substantial CO Emission Reductions

Practical for Generator Engines? • Catalysts are in use on motorcycles in U.S., motor scooters in Asia • Catalysts will be introduced onto engines used on generators to meet proposed CARB and yet to - be proposed EPA regulations • Address technical and human factors issues

– Potential for catalyst heat increasing fire and burn hazards

– False sense of security leading to improper placement

## Interlocking or Auto Shutoff Devices
• Sensors shutoff generator if CO buildup is detected • CPSC staff demonstrated proof - of- concept for two approaches

– Detect CO in vicinity of operating generator • CO sensor mounted on generator

– Detect CO where occupants are located • CO sensor in home with wireless connection to generator 

### • Address technical and human factors issues

– Sensor reliability and durability

– Locating in - home sensors in proper locations

– False sense of security

## • Generators are not constructed for safe use in wet conditions

• Wet conditions often exist when there is a power outage • Current CO warning labels do not unequivocally advise against indoor use Enable and Encourage Proper Generator Placement: Weatherization Requirements

## Examples of CO Warnings Found

on Generators

Provide proper ventilation! Do not operate in a confined area due to carbon monoxide poisoning!

## Examples of CO Warnings Found on

Generators, cont ’ d

# Weatherization Features • Raintight or rainproof enclosure • In - use weatherproof receptacle covers • Ground fault protection for all receptacles
• These features may not be practical for some generator models or eliminate electrocution risk under severe conditions (e.g., flood)

## Weatherization Requirements Icing conditions that can bring down power lines

can also cause engine to stall

## Encourage Proper Generator Placement
• Deter generator theft

– Mechanical devices to anchor, lock generator 

## • Reduce engine noise

## Improve On - Product CO Warning Label

## Improve Manufacturers ’ Guidance

Current guidance may mislead consumers:

## Private Sector Consortium • A formal collaboration among manufacturers to develop effective technologies to address the hazard

– Needs Dept. of Justice approval

– Pooling resources to achieve common goal

– Can accelerate product development: or

– Can also impede progress if no consensus on approach 

## • Consortium developed Flammable Vapor Ignition Resistant water heaters

# Information and Education • CPSC ’ s Office of Public Affairs

– Press releases, VNRs , posters, publications

– Targeted distribution to regional outlets in anticipation of major storms or in conjunction with widespread outages 

### • Expansion of I&E efforts to include all stakeholders

– Establish consistency in messages concerning the hazard and proper operation of generator

– Initiative with retailers to increase public awareness of the CO hazard associated with generators

– National education program delivered at community level

# Cost Estimates of Strategies • Engines with substantially reduced CO emissions: $40 - $200 per RFI respondents

– In anticipation of CARB/EPA compliant engines with catalysts, staff expects lower cost 

## • Remote CO detection auto shutoff device: $100 • Theft deterrent features/accessories: $20 • National education program: > $3M per year

# Standards & Regulations • Draft voluntary standard UL 2201 • UL Outline of Investigation, Subject 2201 • ISO 8528 - 8:1995(E) • CSA C22.2 No. 100 - 04 • OSHA regulations

## Participation in Development of UL 2201 • CPSC staff is non - voting member of STP that is drafting the first proposed edition of UL 2201, Portable Engine - Generator Assemblies . • Staff has recommended requirements be developed to address:

– Consumer exposure to unsafe CO emissions

– Safe outdoor use in wet conditions

– Satisfactory engine operation in icing conditions

– Cautionary markings on product and packaging and in instruction manual 

### • Draft standard addresses CO hazard only through cautionary markings. • STP consensus not yet achieved on draft standard.

## UL Outline of Investigation, Subject 2201 UL issued an Outline of Investigation, Subject 2201

on April 7, 2006 • Establishes certification requirements for generators to receive the UL mark • Includes requirements for

– features that will permit safe use in wet conditions

– warnings about CO poisoning on product and packaging and in instruction manual 

### • UL sought and received staff ’ s comments and recommendations • Not currently a consensus document

# ISO, CSA, OSHA Requirements • ISO 8528 - 8:1995(E) Reciprocating IC Engine Driven AC Generating Sets – Part 8: Requirements and Tests for Low - Power Generating Sets

– CO hazard addressed through labels and markings

– Requires start - up and operation at temps 5o F to 104 o F 

### • CSA C22.2 No. 100 - 04 Motors and Generators

– No requirements to address CO hazard 

### • OSHA Regulations

– Define proper installation and use of portable generators at a temporary construction site or permanent workplace in which portable generator is supplying power

– Address grounding and ground -fault protection 

### These documents do not adequately address the CO poisoning hazard for portable generators.

# Conclusions and Recommendations

Effective intervention is urgently needed to address increasing CO deaths. • Deaths occur predictably with severe weather. • They also occur throughout the year, independent of weather. • Consumer ownership is increasing. • There is inadequate progress in developing effective voluntary standards that address the CO poisoning hazard. • Most reliable way to address consumer exposure to CO is to reduce it at its source. This appears to be achievable. Cost and practicality will be assessed. • Enabling and encouraging consumers to operate their generators in safe locations will help. 

### Staff recommends publishing an ANPR to initiate rulemaking in addition to pursuing

non - regulatory options.