A REPORT ON THE PARTICULATE EMISSIONS 

PERFORMANCE OF MASONRY HEATERS – DEFINTION, 

DATA, ANALYSIS AND RECOMMENDATIONS 

Prepared for: The Masonry Heater Caucus of the Hearth, Patio and Barbecue Association 

Prepared by: Robert Ferguson 

 Ferguson, Andors & Company 

 P.O. Box 678 

 South Royalton, VT 05068 

Date: February 13, 2008 

The scope of this report is to provide the U. S. Environmental Protection Agency with 

chronologically organized information about the particulate emissions performance of 

masonry heaters as a defined product class and to provide conclusions and 

recommendations based on that information. 
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Table of Contents

Introduction .................................................................................... 3 

Background ..................................................................................... 3 

Definition ....................................................................................... 5 

Data Summary ................................................................................. 5 

Conclusions .................................................................................... 7 

Recommendations .............................................................................. 7 

Attachment 1: Excerpt from Federal Register (Footnote 1) ............................. 8 

Attachment 2: Best Available Control Measures Document Excerpts (Footnote 2) . 9 

Attachment 3: Renner Memo (Footnote 3) ................................................ 11 

Attachment 4: McCrillis Memo Excerpts (Footnote 4) .................................. 14 

Attachment 5: ASTM E1602-03 ............................................................. 19 

Attachment 6: Test Report Summary Table ................................................ 28 

Attachment 7: Referenced Report Bibliography ........................................... 29 

Attachments 8 – 21: Referenced Report Cover Pages and Excerpts ..................... 31 
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Introduction

This White Paper is submitted by the Masonry Heater Caucus of the Hearth, Patio and 

Barbecue Association to support its request that the Office of Air Quality Planning and 

Standards (OAQPS) recognize that Masonry Heaters are a class of solid fuel heating 

devices that are inherently clean-burning and can be a viable emissions control option in 

PM-impacted areas. The White Paper has five parts: 

Background 

o Provides relevant background information on regulatory status, numbers 

installed annually, data sources, etc. 

Definition 

o Defines what comprises a clean-burning masonry heater including a list of 

critical features. 

Data 

o Summarizes the available North American emissions performance data. 

Conclusions 

o Summarizes our conclusions on emissions performance. 

Recommendations 

o A section containing our recommendations that includes procedures that 

can be used to provide assurances that masonry heaters built in the field 

include the critical elements identified in the definition of clean-burning 

masonry heater. 

Background

Modern masonry heater designs originated in Europe and those designs have been in use 

for many decades, if not centuries. While masonry heaters are installed in relatively large 

numbers across Europe, they represent only a small niche in the solid-fuel burning market 

in the United States. Masonry heaters are site-built, often by individual masons, making 

it hard to provide a precise number of installed units. The Masonry Heater Caucus 

estimates that between 600 and 1,000 masonry heaters are installed in North America 

each year. This represents only a fractional percentage of all solid-fuel burning appliance 

sales and installations. 

EPA's wood stove New Source Performance Standard (NSPS), 40 CFR Part 60, Subpart 

AAA, specifically exempts masonry heaters because the Regulatory Negotiation 

Committee recognized that they are inherently clean-burning due to their high burn rates 

and air-rich characteristics. This is explained in the preamble to the proposed 

regulations1

 as follows: “The 800 kg cutoff was established as an easy means of excluding 

 

1

 Federal Register/Vol. 53, No. 38/February 26, 1988/Rules and Regulations/Page 5864. See Attachment 1. 
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high mass fast-burn wood-burning appliances known as “Russian stoves” or “European 

tile stoves.” These devices typically operate at hot, fast burn rates and cannot be 

damped. It is also likely that they are incapable of meeting the 5 kg/hr minimum burn 

rate. The intent of the committee was to exempt from the standards these appliances 

which rely on clean-burning air-rich conditions and which have high combustion 

efficiencies.” 

Notwithstanding EPA's clear determination in the NSPS rulemaking that masonry heaters 

are inherently clean-burning, because of their high burn rates and air-rich characteristics, 

masonry heaters have had a difficult time getting accepted by SIP planners as viable 

control options for PM-impacted areas. In some jurisdictions, only NSPS-certified wood 

stoves have been allowed. While the intent may have been to eliminate “loop-hole” 

products as a means of improving air quality, the result for some product classes, 

including masonry heaters, has been to effectively ban a clean-burning alternative. Other 

areas have followed EPA's RACM/BACM guidance2

 and allowed NSPS-certified 

appliances, along with other appliances that have been shown to be “equivalent.” [See 

also Renner memo3

.] However, these equivalency provisions, although written with good 

intent, are flawed in concept. The NSPS emission limits were based on Best 

Demonstrated Technology (BDT) for traditional wood-burning stoves and inserts and 

were supported with significant data from the Oregon woodstove certification program. 

These levels do not translate to appliances employing different technologies and, 

therefore, with different BDT. Masonry heaters are not designed nor do they operate like 

NSPS certified stoves or inserts. Moreover, the very different operating profiles for 

masonry heaters compared to woodstoves present difficult issues when attempting to 

make "equivalency" findings. The fuel load in a masonry heater is fully-consumed in a 

short period of time. This heats a large mass of refractory, which in turn discharges the 

stored heat over many hours. Woodstoves are also batch loaded, but the heat is delivered 

as the fuel load is consumed. The length of the burn depends on how the operator sets 

the air controls. When comparing emissions performance on a gram/hr basis, the 

masonry heater emissions must be averaged over the period of time that useful heat is 

being provided to the home in order to compare them with woodstoves on an "apples to 

apples" basis. Finally, the fact that air quality planning agencies frequently require costly 

case-by-case showings of "equivalency" has been an additional, significant obstacle to 

masonry heater builders. 

We are presenting the results of masonry heater testing that has been conducted in North 

America, but it is important to recognize that considerable testing has also been 

conducted in Europe and that testing corroborates the clean-burning performance of 

masonry heaters as a class of products. 

 

2

 Technical Information Document for Residential Wood Combustion Best Available Control Measures, 

U. S. Environmental Protection Agency, Office of Air and Radiation, Office of Air Quality Planning and 

Standards, Research Triangle Park, NC, September 1992. See Attachment 2. 3

 Memo: F. H. Renner to Chief, Air Branch, Regions I – X, September 23, 1991, Interpretation of EPA’s 

Guidance for Residential Wood Combustion Emission Control Measures. See Attachment 3. 
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Definition

It is also necessary to establish a way to determine what masonry heater designs should 

qualify for recognition in that class and for that the following definition is proposed. 

“A masonry heater is a site-built or site-assembled, solid-fueled heating device 

constructed mainly of masonry materials or soapstone in which the heat from intermittent 

fires burned rapidly in its firebox is stored in its massive structure for slow release to the 

building. It has an interior construction consisting of a firebox and heat exchange 

channels built from refractory components.” 

Specifically, a masonry heater has the following characteristics: 

Site-built or site-assembled. 

A mass of at least 800 kg. (1760 lbs.). 

Tight-fitting fuel loading doors that are closed during the burn cycle, 

An overall average wall thickness not exceeding 250 mm (10 in.). 

Under normal operating conditions, the external surface of the masonry heater, 

except immediately surrounding the fuel loading door(s), does not exceed 110 C. 

(230 F.). 

The gas path through the internal heat exchange channels downstream of the 

firebox includes at least one 180-degree change in flow direction, usually 

downward, before entering the chimney. 

The length of the shortest single path from the firebox exit to the chimney 

entrance is at least twice the largest firebox dimension. 

A combustion air control that is designed to provide a high-fire burn rate only. 

A combustion air introduction system that directs the majority of the combustion 

air to the area in the firebox that is at or above the level of the fire. 

Constructed or installed by qualified masonry heater builders. 

ASTM E-1602 “Standard Guide for Construction of Solid Fuel Burning Masonry 

Heaters” provides design and construction information for the range of masonry heaters 

most commonly built in the United States and can be used as the basis for determining 

whether a particular design qualifies for recognition as a masonry heater. A copy for 

reference purposes only is included as Attachment 5. 

Data

A table showing the reports from testing in North America that provides data relevant to 

types of masonry heaters that meet the above definition is included as Attachment 6. The 

table includes a brief description of the test parameters and the average emission results. 

The data comprises the results from research studies, test method development efforts, 

and testing for certification to state masonry heater rules. The average particulate 
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performance is presented as emission factors (grams of particulate per kilogram of fuel 

burned). This format provides the best way to compare emissions from high-burn-rate, 

high-combustion-efficiency, intermittently-fired appliances. Emission rates, when 

available in the reports, have also been provided. However, as was briefly discussed in 

the Background section, emission rates (grams of particulate per hour) can be deceiving 

when evaluating intermittently fired high-mass appliances. One or two fires that last only 

a few hours can provide heat for a full twenty-four hour period. Emission rates should 

therefore be normalized over the period of time that heat is being provided by the 

masonry heater if they are to be used to compare different appliance types. The emission 

rates we are reporting here may not have been calculated using the same procedures in 

each case. Some values have been normalized, some have not. These differences should 

be taken into consideration when comparing individual values. We have also included 

ranges for data, as well as results from individual heaters when available in the reports. 

The data that we are presenting represents all data from masonry heater testing in North 

America that we have been able to obtain with the exception of data from a test series 

conducted on four products from one manufacturer4

. Please note that some additional 

reports have been issued that address sub-sets of testing results from the reports we have 

cited. Those reports have not been included if their data are contained within the cited 

reports. The table also includes a reference to the AP-42 emission factor for masonry 

heaters. Full references for each cited report are included in Attachment 7. 

Report cover pages and extracted summaries or excerpts from the reports, when 

available, are included in Attachments 8 - 21. Copies of the full reports can be made 

available upon request. 

Reference C (Attachment 10) is the report on the field testing of five heaters that 

represent a cross-section of the masonry heater designs that were being built across the 

country. This study from 1991-1992 was funded by Masonry Heater Association 

members. Ultimately, EPA was approached and agreed to monitor and audit this test 

program. In an EPA memorandum5

, Dr. Robert C. McCrillis presents his evaluation of 

the test results from the masonry heater test program. These results (which covered a 

broad range of heater designs) were used by EPA to calculate the 2.8 g/kg emission factor 

for masonry heaters that is listed in EPA’s AP-42 document “Emission Factors from 

Residential Wood Combustion”. 

 

4

 These data were excluded because the tests were not conducted following a masonry heater test protocol 

but were instead generated using a fueling and operating protocol for factory-built fireplaces. 5

 Memo: R. C. McCrillis to D. Mobley, May 8, 1992, Masonry Heater Field Performance Data. See 

Attachment 4. 
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Conclusions

The test data support previous conclusions regarding the particulate emission 

performance of masonry heaters as a class and further defined as those designs that meet 

the criteria outlined earlier in this paper. Using a variety of test procedures, fueling 

protocols and fuel types, emission measurement methodologies, laboratory and in-situ 

measurements, the resultant average particulate emissions have ranged from 1.4 to 5.8 

grams of particulate per kilogram of fuel burned. The average of the averages for this 

data is 2.9 g/kg. Again, the current AP-42 emission factor for masonry heaters is 2.8 

g/kg. Note: We have not included the emission results for the Russian Heater cited in 

Reference B (Attachment 9). This heater was constructed by a mason inexperienced and 

untrained in masonry heater construction and the emission performance is considered as 

an outlier when compared to all other available data. 

The low average particulate emissions from masonry heaters combined with the small 

number of annual installations justifies allowing masonry heater installations to continue 

without imposing undue burdens on the installers of these appliances. The cost 

associated with testing individual masonry heaters is simply prohibitive and does not 

represent a needed expenditure to protect air quality. Another means of satisfying air 

quality regulators is appropriate in this case. 

Recommendations

Masonry heaters as a class should be accepted by EPA as clean-burning and EPA should 

give the appropriate guidance, in the form of a letter from the Office of Air Quality 

Planning and Standards, to state, local and tribal air quality regulators. That letter should 

recommend allowance of the installation and operation of qualified masonry heaters in 

PM-impacted areas as a viable strategy for PM reduction from Residential Wood 

Combustion (RWC). We suggest that the current AP-42 emission factor of 2.8 g/kg 

continues to be representative of the expected performance of masonry heaters as a class. 

Qualified masonry heaters are defined as those in conformance with the masonry heater 

definition included in this paper. 

Conformance with the specified masonry heater design parameters should be confirmed 

and documented by an independent third party laboratory for each masonry heater design. 

This would be an engineering evaluation based on design drawings provided by the 

masonry heater builder or manufacturer. The conformance report would be applicable to 

each heater that is installed in accordance with the conforming design. Additional 

affirmations by the masonry heater installer or builder that the design as built in the field 

is in conformance with the design drawings could be considered if needed. 
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Attachment 1: Reference 1 – Excerpt from Federal Register 
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Attachment 2: Reference 2 – Cover page 
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Attachment 2: Reference 2 – Excerpt 
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Attachment 3: Reference 3 – Renner Memo 
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Attachment 4: Reference 4 – McCrillis Memo Excerpts 
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Copyrighted page(s) removed. Copyrighted 

material is not available in Regulations.gov since 

it may not be reproduced without consent of the 

copyright holder. 

Removed pages can be viewed at the USEPA 

Docket Center, Public Reading Room. 

Address: 1301 Constitution Ave, NW 

Room 3334 

Washington, DC 20004 

Telephone: 202-566-1744 

Email: docket-customerservice@epa.gov
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Attachment 6: Summary of Emission Test Reports for Masonry Heaters 

Attachment 7: Reference Reports 
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A. Stern, C. H, Jaasma, D. R. and J. W. Shelton, Masonry Heater Emissions Test 

Method Development, Wood Heating Alliance, March 1990. 

B. Barnett, S. G., In-Home Evaluation of Emissions from Masonry Fireplaces and 

Heaters, Western Clay Products Association, Prepared by: OMNI Environmental 

Services, Beaverton, OR, Report # 80-10201, September 6, 1991 

C. Barnett, S. G., Summary Report of the In-Home Emissions and Efficiency 

Performance of Five Commercially Available Masonry Heaters, Masonry Heater 

Association, Prepared by: OMNI Environmental Services, Beaverton, OR, Report # 

80-13301, May 22, 1992 (Revised June 1, 1993). 

D. Barnett, S. G., McCrillis, R. C. and R. B. Crooks, Evaluation of Emissions from 

Masonry Heaters and Masonry Fireplaces, OMNI Environmental Services, U. S. 

Environmental Protection Agency, Mutual Materials Company, Report # 92-118.06, 

1992 

E. Bighouse, R, and S. G. Barnett, In-Home Evaluation of Emissions from a Temp-Cast 

2001 Masonry Heater, Temp-Cast 2000 Masonry Heater Manufacturing, Inc., 

Prepared by: OMNI Environmental Services, Beaverton, OR, Report No. 80131-01, 

May 8, 1992 

F. In-Home Evaluation of Emissions from a Mastercraft Swedish Heater Kit Masonry 

Heater, Mastercraft Masonry, Brush Prairie, WA, Prepared By: Science Applications 

International Corporation, Beaverton, OR, March 23, 1993. 

G. Evaluation of Efficiency and Emissions from a Moberg/Royal Crown MRC-3036 

Masonry Heater, FireSpaces, Inc., Portland, OR, Prepared by: OMNI Environmental 

Services, Beaverton, OR, Report No. 001S-013B, May 28, 1994. 

H. H1: Moberg 3042 Masonry Heater Emissions Testing Report (Compliance with 

Colorado Regulation No. 4), FireSpaces, Inc., Portland, OR, Prepared by: OMNI 

Environmental Services, Beaverton, OR, Report No. 001-S-02-3-B, January 1996. 

H2: Moberg 3042 Masonry Heater Emissions Testing Report (Compliance with 

Washington State UBC Section 31-2), FireSpaces, Inc., Portland, OR, Prepared by: 

OMNI Environmental Services, Beaverton, OR, Report No. 001-S-02-3-A, January 

1996. 

I. Report on Revisions to 5TH Edition AP-42 Section 1.10 Residential Wood Stoves, 

Contract No. 68-D2-0160, U. S. Environmental Protection Agency, Research 

Triangle Park, NC, July 29, 1996. 

J. J1: Test Report: Masonry Heater Particulate Emissions and Overall Efficiency. 

Tulikivi Oy Model KTU-2100, Tulikivi Oy, Juuka, Finland, Prepared by: OMNITest Laboratories, Inc., Beaverton, OR, Project # 020-S-01-03, May 1997. 
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J2: Test Report: Masonry Heater Particulate Emissions and Overall Efficiency. 

Tulikivi Oy Model KTU-2100, Tulikivi Oy, Juuka, Finland, Prepared by: OMNITest Laboratories, Inc., Beaverton, OR, Project # 020-S-01-03, May 1997. 

K. Tulikivi Oy; Model TU 1000 Emission Testing Report (Protocol Conformance with 

Colorado Regulation No. 4), Tulikivi Oy, Juuka, Finland Prepared by: OMNI 

Environmental Services, Beaverton, OR, Report No. 020-S-06-3, April 29, 1999. 

L. Tulikivi Oy; Model TU 2200 Emission Testing Report (Protocol Conformance with 

Colorado Regulation No. 4), Tulikivi Oy, Juuka, Finland Prepared by: OMNI 

Environmental Services, Beaverton, OR, Report No. 020-S-06-3, April 29, 1999. 

M. Tulikivi Oy; Model TU 2450 Emission Testing Report (Protocol Conformance with 

Colorado Regulation No. 4), Tulikivi Oy, Juuka, Finland Prepared by: OMNI 

Environmental Services, Beaverton, OR, Report No. 020-S-06-3, April 29, 1999 

N. N1: Emissions Report, Swedish Kakelugn Style Masonry Heater, Built by Jerry 

Frisch, Prepared by: OMNI-Test Laboratories, Inc., Beaverton, OR, 2006. 

N2: Emissions Report, Swedish Kakelugn Style Masonry Heater, Built by Jerry 

Frisch, Prepared by: OMNI-Test Laboratories, Inc., Beaverton, OR, 2006. 
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Attachment 8: Reference A - Report Cover Page 
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Attachment 8: Reference A - Executive Summary 
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Attachment 9: Reference B – Cover Report Page 

 
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Attachment 9: Reference B – Executive Summary 
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Attachment 9: Reference B – Executive Summary (cont.) 
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Attachment 9: Reference B – Emission Comparison 
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Attachment 10: Reference C - Report Cover Page 
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Attachment 10: Reference C - Executive Summary 
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Attachment 10: Reference C - Executive Summary (Continued) 
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Attachment 10: Reference C – Emission Results 
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Attachment 11: Reference D – Cover Page 
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Attachment 11: Reference D – Excerpt from Summary 
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Attachment 11: Reference D – Data Summary 
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Attachment 11: Reference D – Emission Comparison Chart 
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Attachment 12: Reference E – Report Cover Page 
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Attachment 12: Reference E – Excerpt from Report 
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Attachment 12: Reference E – Data Summary 
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Attachment 12: Reference E – Graphical Presentation 
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Attachment 13: Reference F – Report Cover Page 
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Attachment 13: Reference F – Executive Summary 
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Attachment 13: Reference F – Data Summary 
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Attachment 13: Reference F – Graphical Presentation 
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Attachment 14: Reference G – Report Cover Page 
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Attachment 14: Reference G – Summary Page 

 
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Attachment 15: Reference H1 – Report Cover Page 
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Attachment 15: Reference H1 – Summary Page 
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Attachment 15: Reference H2 – Report Cover Page 
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Attachment 15: Reference H2 – Summary Page 
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Attachment 16: Reference I - AP-42 Revision Report Excerpts 
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Attachment 16: Reference I - AP-42 Revision Report Excerpts 
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Attachment 16: Reference I - AP-42 Revision Report Excerpts 
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Attachment 16: Reference I - AP-42 Revision Report Excerpts 
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Attachment 17: Reference J1 and J2 – Report Cover Page 
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Attachment 17: Reference J1 and J2 – Summary Page 

This page redacted from docket version due to claim of confidentiality on page 63 above. 

For further information, contact OMNI Test Laboratory or Tulikivi at addresses shown on 

page 63.
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Attachment 18: Reference K – Report Cover Page 
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Attachment 18: Reference K – Summary Page 

This page redacted from docket version due to claim of confidentiality on page 65 above. 

For further information, contact FireSpaces, Inc., Portland, Oregon; tel. (503) 227-0547
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Attachment 19: Reference L – Report Cover Page 
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Attachment 19: Reference L – Summary Page 

This page redacted from docket version due to claim of confidentiality on page 67 above. 

For further information, contact FireSpaces, Inc., Portland, Oregon; tel. (503) 227-0547
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Attachment 20: Reference M – Report Cover Page 
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Attachment 20: Reference M – Summary Page 

This page redacted from docket version due to claim of confidentiality on page 69 above.

For further information, contact FireSpaces, Inc., Portland, Oregon; tel. (503) 227-0547
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Attachment 21: Reference N1 and N2 – Report Cover Page 
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Attachment 21: Reference N1 and N2 – Summary Page