From: Joseph Harding

To: Buyer, Janet

Cc: Church, Colin; Heggs, Angela

Subject: PGMA Comments on CPSC Staff Request for Formation of a Working Group

Date: Friday, March 07, 2014 4:17:33 PM

Attachments: CPSCBuyerLtrCmtsRequestForWorkingGroup030714.pdf

To:          Ms. Janet L. Buyer, Project Manager

                U.S. Consumer Product Safety Commission

cc:           Colin Church, CPSC

                Angela Heggs, CPSC

SUBJECT:             PGMA Comments on CPSC Staff Request for Formation of a Working Group

Please see the attached correspondence for your review and consideration.

If you have any questions, please contact the PGMA office.  We look forward to hearing from you.

Very Truly Yours,

Joseph Harding:jlb

Portable Generator Manufacturers' Association

1300 Sumner Avenue

Cleveland, Ohio 44115-2851

Ph: 216-241-7333

Fax: 216-241-0105

Email: jharding@thomasamc.com

Web: www.pgmaonline.com

The information contained in this communication is confidential, and is intended only for the use of

the individual or entity named above.  We cannot accept any liability for any loss or damage

sustained as a result of software viruses.  It is your responsibility to carry out such virus checking as

is necessary before opening any attachment.  If the recipient of this communication is not the

intended recipient, you are hereby notified that any dissemination, distribution, or copying of this

communication is expressly prohibited.  If you received this communication in error, please notify us

immediately by telephone and return the original communication to us at the address listed above. 

We apologize for any inconvenience, and thank you for your cooperation.
Secretary/Treasurer: 

THOMAS ASSOCIATES, INC.

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

URL: www.pgmaonline.com E-mail: pgma@pgmaonline.com

 March 7, 2014 

Ms. Janet L. Buyer 

Project Manager 

Directorate for Engineering Sciences 

U.S. Consumer Product Safety Commission 

4330 East West Highway 

Bethesda, MD 20814 

SUBJECT: PGMA Comments on CPSC Staff Request for Formation of a Working 

Group and CPSC Staff's Recommendations for Requirements to Address 

the CO Poisoning Hazard Associated with Portable Generators

Dear Ms. Buyer: 

The Portable Generator Manufacturers’ Association (PGMA) would like to offer its 

comments on CPSC's letter to Underwriters Laboratories, Inc. dated January 14, 2014 

regarding "CPSC Staff Request for Formation of a Working Group and Staff's 

Recommendations for Requirements to Address the Carbon Monoxide Poisoning Hazard 

Associated with Portable Generators". 

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 

the paramount issue of the safety of our respective customers. 

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 

I. IT IS NOT APPROPRIATE TO ESTABLISH A WORKING GROUP TO MODIFY 

UL 2201

PGMA does not believe that establishing a working group to develop proposals for 

modifying UL 2201 would be an effective method for improving the safe and proper use 

of portable generators, for the reasons detailed below: 

• UL 2201 was first published in March 2009 without an ANSI designation. The 

Standards Technical Panel for UL 2201 was unable to achieve the necessary 

consensus for ANSI designation despite over six years of effort prior to March 

2009. During this time period, there were five failed ballots for ANSI 

designation. 

• Since UL 2201 was published nearly five years ago, PGMA is not aware of any 

portable generator manufacturer that has a listing to this standard. 

• In January 2013, PGMA provided UL with a list of 37 remaining issues with UL 

2201. 

• It is not appropriate for UL to form a Working Group in advance of CPSC 

responding to all the public comments it received on the report entitled 

"Technology Demonstration of a Prototype Low Carbon Monoxide Emission 

Portable Generator" that was released in September , 2012. 

II. CPSC SHOULD SUPPORT PGMA's ANSI ACTIVITIES

• PGMA was approved as an ANSI accredited standards developer in December 

2011, and submitted a PINS for a safety standard for portable generators in May 

2012. 

• PGMA plans to begin the ANSI canvassing process for the safety standard in 

2014. We plan to invite personnel from CPSC and UL to participate in the 

canvass. 

III. CPSC NEEDS TO CONDUCT A STUDY TO DETERMINE WHETHER 

REDUCING CO EMISSIONS WILL REDUCE THE NUMBER OF CO DEATHS 

FROM PORTABLE GENERATORS 

The letter suggests that the development of CO emission rate limits would "address the 

source of the hazard and make a direct impact on reducing the risk of CO poisoning death 

and injury associated with the use of portable generators". This appears to be based on 

the premise in the CPSC report entitled "Technology Demonstration of a Prototype Low 

Carbon Monoxide Emission Portable Generator" (released in September 2012) 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. PGMA is not aware of any documentation or studies 

confirming the validity of that premise. 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. Indeed, a person experiencing the symptoms 

of carbon monoxide poisoning may decide to take a couple of pain relievers and/or 

sleeping aids and go to bed, rather than go outside. 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 

remove himself or herself from the area to a place where there was fresh, untainted air. 

IV. CPSC SHOULD CONDUCT A HUMAN FACTORS STUDY TO EVALUATE 

THE EFFECTIVENESS OF THE EXISTING MANDATORY CO LABEL AND 

REVISE IT TO CONFORM WITH ANSI Z535 

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 review all In-Depth Investigation (IDI) 

reports involving portable generators manufactured since 2007 to understand why those 

users ignored the product labeling and 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. 

V. CPSC SHOULD PROACTIVELY ENCOURAGE STATES AND 

MUNICIPALITIES TO MAKE CO MONITORS IN LIVING SPACES 

MANDATORY
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 and its member companies would be willing to work 

cooperatively with the CPSC in an effort to encourage states and municipalities to 

mandate CO detectors. 

VI. PGMA IS ACTIVELY INVOLVED WITH EDUCATION/AWARENESS 

 EFFORTS

In addition to developing a portable generator safety standard by means of the canvass 

process of the American National Standards Institute (ANSI), PGMA has been actively 

involved with several efforts to raise awareness of the carbon monoxide hazard 

associated with portable generators. It is important to recognize that any potential 

technical approach to the CO issue would only address products manufactured in the 

future. Legacy products must be addressed through education/awareness campaigns, 

since portable generators tend to have a very long life due to infrequent use. 

Recent PGMA education/awareness activities are detailed below: 

• In February 2013, PGMA made a proposal at a National Association of 

Regulatory Utility Commissioners (NARUC) meeting to standardize the portable 

generator safety information regarding carbon monoxide on all electric utility 

websites. The standardized information was developed by PGMA. In July 2013, 

NARUC approved a resolution that this information should be posted on utility 

websites. 

• In December 2013, PGMA launched its "Safety First" carbon monoxide 

awareness campaign. Campaign kits were sent out to approximately 1300 media 

outlets, which included the following: 

o Carbon Monoxide Alarm Facts 

o Emergency Checklist 

o Carbon Monoxide facts 

o News Release 

o Public Service Announcement Radio Script 

o Video 

• PGMA is currently planning substantial additional education/awareness activity 

for 2014. 
In closing, PGMA remains committed to the development of an appropriate safety 

standard for portable generators as well as continued education/awareness efforts in the 

future. We are asking for CPSC's support of these efforts. 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. 

 

Sincerely, 

 

 JOSEPH HARDING 

 Technical Director 

 PGMA 

JH/jlb 

pgma 

cc: Colin Church, CPSC Voluntary Standards Coordinator, cchurch@cpsc.gov

 Angela Heggs, CSPC Office of the Secretary, Docket Manager, aheggs@cpsc.gov