CO Alarm Mandates in Model Codes as Public Policy

Presented at ICC Code Technology Committee on CO Alarms

Ted A. Williams, Director, Codes, Standards & Technical Support American Gas Association Washington, DC* July 25-26, 2005 Schiller Park, IL *With technical contributions from Dr. Irwin Billick, WEC Consulting 1

Issue Before ICC:

Is the mandating of CO alarms in residential buildings through model codes or other mechanisms an effective mechanism for reducing the incidence of CO poisoning death or serious injury? 2

AGA’s Interest in the Issue

• Consumer Safety • Customer Satisfaction • Long History of CO Response and Understanding of Appliances as Sources • Estimated Gas Utility Response Cost of $78-$90 Million Annually for CO Alarm Response, Based on Early CO Alarm Performance and Protocols in Place at the Time* • Gas Industry Response: Published studies on laboratory alarm performance (four of them), field data gathering from first responders and gas utilities, analyses of mortality and morbidity data, and policy analyses (e.g., benefit/cost analysis and consumer response analysis).

*Cost-Effectiveness Analysis – Residential Carbon Monoxide Detectors: Final Report,” Science Applications International Corporation, GRI-96/0054, August, 1996.

3

Some Current Views of the Federal Government on CO Alarms and Mandates

“CPSC will eventually go back to that [making proposals to model codes for CO alarm requirements], but we are concerned about the long term durability of CO alarms.”

Don Switzer, Directorate of Engineering Sciences, CPSC, responded to questions at the UL Gas Products Council Meeting, Itasca, IL, May 3, 2005

“CPSC would not support mandatory requirements for CO alarms while long term reliability is still at issue.”

Richard Stern, Compliance Division, CPSC, responding to questions at the ASHRAE 62.2 Indoor Air Quality Subcommittee Meeting, Orlando, FL, February 4, 2005.

“Carbon Monoxide Detectors are widely available in stores and you may want to consider buying one as a back-up - Carbon Monoxide Poisoning,”

BUT NOT AS A REPLACEMENT

use and maintenance of your fuel-burning appliances. However, it is important for you to know that the technology of CO detectors is still developing, that there are several types on the market, and that they are not generally considered to be as reliable as the smoke detectors found in homes today. Some CO detectors have been laboratory-tested, and their performance varied. Some performed well, others failed to alarm even at very high CO levels, and still others alarmed even at very low levels that don’t pose any immediate health risk. And unlike a smoke detector, where you can easily confirm the cause of the alarm, CO is invisible and odorless, so it’s harder to tell if an alarm is false or a real emergency.” U. S. EPA Fact Sheet, “Protect Your Family and Yourself from http://www.epa.gov/pubs.coftsht.html

. for proper 4

Non-Federal Mandates, Passed or Considered

•States •Enacted •Alaska; New Jersey; New York; Rhode Island; Utah (bldg. code provision); West Virginia; Texas (day care centers and group homes) •

Rejected

•Maryland •Pending •Massachusetts 5

•Local Governments Muscle Shoals, AL Anchorage, AK Wilmington, DE Illinois: Chicago, Frankfort, Gurnee, Lake Forest, Lincolnwood Linn County, IA Massachusetts: Abington, Marshfield, and Mashpee, Pontiac, MI St. Louis, MO New York State: Albany, Greenburgh, Kingston, New York City and Rockland and Suffolk Mecklenburg County, NC NJ: Fort Lee and the Village of South Orange Ohio: Brooklyn, Eastlake, Lakewood, Macedonia, Maple Heights, Northfield,Parma, Richmond Heights, Westfield Center, and Willowick.

Bellaire, TX Brown Deer, WI 6

No contemporary formal or documented analyses has been identified that evaluates the effectiveness of mandating CO alarms in terms of potential number of lives saved or serious adverse health impacts avoided and direct or indirect costs to the public affected.

7

Elements to Consider in Evaluating the Potential Effectiveness of CO Alarms

•Size of the Problem •Mortality •Morbidity •Housing Population Covered •Compliance •Alarm Reliability •Response to Alarm •By Individuals •By Municipal Services •By Utilities 8

Size of the Problem

Mortality Analysis Data •Alarm Manufacturers and Advocates •National Center for Health Statistics •Consumer Product Safety Commission Mortality is a function of: •Time •Season •Location •Geography •Demographics •Source of CO 9

•How many unintentional, non-fire CO deaths are there per year that would be covered under the terms of the proposed mandate?

•Is this number stable, or is it changing with time?

•If changing with time, what is the estimated future number of deaths?

10

Unintentional Non-Fire Related Carbon Monoxide Deaths (NCHS, 1943-1998)

2000 1800 1600 1400 1200 1000 800 600 400 200 0 1940 1950 1960 1970 Year 1980 1990 2000 TOTALCO Pipeline Motor Ve Other 11

Location of Unintentional CO Fatality All Sources 1979-96

Total Cases 14579 NOT SPEC 15% OTHER 12% INSTITUTION 0% PUB BLDG 3% STREET 5% REC CTR 2% INDUSTRIAL 8% MINE 0% FARM 1% HOME 54% 12

800

Unintentional Non-Fire CO Fatalities in the Home 1979-2019 (NCHS Morbity Data 1979-98)

Other Sources Obs Other Sources Pred Motor Vehicle Motor Vehicles Pred Total Total Pred 700 600 500 400 300 200 100 0 1975 1980 1985 1990 1995

Year

2000 2005 2010 2015 2020 13

The number of CO deaths in the home from automobiles and most consumer products sources has been steadily decreasing for over fifty years and is expected to continue to decrease at the same rate for the foreseeable future with

one major exception

:

portable generators

, for which incidents are increasing.

14

Unintentional Non-Fire CO Fatalities in the Home Associated with Consumer Products 1990-2019 ( CPSC Data 1990-2001)

250 200 Home,Obs Home, Pred.

150 100 50 0 1985 1990 1995 2000

Year

2005 2010 2015 2020 15

CO Deaths Associated with Engine-Driven Tools (CPSC Data 1990-2003)

45 40 35 30 25 20 15 10 5 Generators All Other Engine -Driven Tools 0 1990 1991 1992 1993 1994 1995 1996

Year

1997 1998 1999 2000 2001 2002 16 2003

The rate of CO deaths per million homes is decreasing about 5% per year. By the year 2005 there will be two deaths per million homes and by 2019, this is projected to drop to one death per million homes.

If two million houses were built in 2005 and one CO alarm was placed in each house, the maximum number of CO deaths that could be prevented would be 4. If the average cost of an alarm is $10 per year, the cost per life saved would be $5 million. The cost per life saved would rise to $10 million by 2019 due to decreasing incidents.

17

Unintentional Non-Fire CO Fatalities per Million Homes (NCHS Data ,1979-2019)

9.00

8.00

7.00

6.00

5.00

4.00

3.00

2.00

1.00

0.00

1975 1980 1985 1990 1995

Year

2000 Deaths/Milliion Homes Obs Deaths/Million Homes Pred.

2005 2010 2015 2020 18

CO incidences that lead to carbon monoxide fatalities or serious injuries are random and highly case dependent. In order to be effective, carbon monoxide alarms must be in all homes and must be 100% reliable, and consumers must respond appropriately.

Limiting the housing population covered by a mandatory code requirement will reduce prevention effectiveness. Some of these limitations on coverage include: •Housing stock covered (e.g., new vs. existing houses) •Type of garages •Types of installed appliances vs. portable appliances •Types of fuels used.

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Examples of Mandate Limitations

•

Albany NY

Every building of residential or mixed occupancy, relying on combustion of fossil fuel for heat, ventilation or hot water or sufficiently close to any ventilated source of carbon monoxide to receive carbon monoxide from that source, and having more than one residential unit must have carbon monoxide detectors installed. [

Missing

: All electric homes with attached garages.]

Chicago, IL

. Dwellings that do not rely on combustion of fossil fuel for heat, ventilation or hot water, and are not sufficiently close to any ventilated source of CO, and units heated by steam, hot water or electric heat and not connected by ductwork or ventilation shafts to any room containing a fossil fuel-burning boiler or heater and not sufficiently close to any ventilated source of CO, are exempted. [

Missing

: All electric homes with attached garages.]

Maryland State (As Proposed)

Any new residential unit for which an initial building permit is issued on or after October 1, 2000, for a residence to be constructed with a gas heating system, fuel burning appliances, or an attached garage. [

Missing:

Existing homes.] 20

New Homes Dwelling Units Without Garage Dwelling Units With Fossil Fuel Appliances Dwelling Units With Garage Existing Homes Dwelling Units Without Fossil Fuel Appliances 21

Enforcement Complexity May Inhibit Alarm Effectiveness

.

Initial Compliance. New York City example

: Building owners' responsibilities •Provide and install at least one approved carbon monoxide alarm each dwelling unit. •File a "

Certificate of Satisfactory Installation

in the borough in which the dwelling is located. •Post

a notice in a form approved by HPD

in a common area inform occupants of Local Law # 7 requirements. •Provide

a notice in a form approved by HPD

informing occupants •Provide written information regarding the testing and maintenance carbon monoxide alarms, including general information concerning carbon monoxide poisoning and what to do if a carbon monoxide alarm activates to at least one adult occupant of each dwelling unit. •Keep all records relating to the installation and maintenance of carbon monoxide alarms and make them available upon request to the Department of Housing Preservation and Development (HPD), the Department of Buildings (DOB), the Fire Department and the Department of Health and Mental Hygiene (DOHMH). Keep and maintain the carbon monoxide alarms or systems in good 22

Non-Compliance With Code Will Reduce Effectiveness

Market Penetration of CO Alarms in Cities with Legal Mandate July 1999*

100% Alarm No Alarm 80% 50% 60% 60% 75% Ordinance Cities 40% 50% 20% 40% 25% 0% Effective Date of Ordinance Albany Jan 97 Chicago Oct 94 Toronto

*RESIDENTIAL CARBON MONOXIDE ALARM POPULATION: SIX CITIES STUDY

J. Kramer and S. Tikalsky GRI-00/0144 August 2000 Nov 98 23

Failure of Consumer to Respond Appropriately to an Alarm Will Reduce Effectiveness

Consumer Response to CO Alarm *

Friend/Familyily 5% Contractor 2% Other 6% Fire Department 14% No Call 63% Utility 10%

*RESIDENTIAL CARBON MONOXIDE ALARM POPULATION: SIX CITIES STUDY

J. Kramer and S. Tikalsky GRI-00/0144 August 2000 24

Alarm Performance Deficiencies Will Reduce Effectiveness

•Studies on CO alarms showed unacceptable performance.

•Gas Industry: ETL, GARD Analytics, Mosaic Industries •Consumer Product Safety Commission •There is inadequate data about the long term CO alarm reliability.

•False positives (“false alarms”) negatively influence installation/replacement and consumer response to activations.

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GARD Analytics: Alarm Failure by Brand and Failure Mode at 100 ppm.* 1 6 1 4 1 2 1 0 8 6 4 2 0 1 6 1 4 1 2 1 0 8 6 4 2 0 A 1 A 1 Fai l Low A 2 A 3 No Al ar m A 4 1 6 - 4 A 2 A 3 M o n t h 0 A 4 A 2 M o n t h 3 Fai l Hi gh 1 6 1 4 1 2 1 0 4 2 0 8 6 1 6 1 4 1 2 1 0 8 6 4 2 0 A 3 M o n t h 6 A 1 A 2 A 3 A 4 Tot al Num ber of Fai l ur es A 1 A 4 M o n t h 9 A 2 Br and A 3 M o n t h 1 2 A 4 *

CHAMBER TESTS OF RESIDENTIAL CO ALARMS, R. L. Hedrick, GRI-97/0082.3 April 1998 26

Mosiac Industries: Overall Findings*

• 109 CO alarms tested: 81 commercial alarms of 10 brands manufactured from 1997 to 1999 and 28 alarms under development at the time • 3 of 10 commercial brands alarmed within all UL 2034 performance specifications but with 15% supervised failures • 6 brands failed one or more UL performance specifications: 8% of alarms false alarmed, 79% failed to alarm at 5% RH, 47% failed to alarm at 50% RH; 30% alarmed in response to interference gases.

• 4 brands showed poor digital display accuracy (>+/-30% of actual concentration) • Half of brands showed decreasing sensitivity with rising CO concentrations (tested at 50 ppm/hour rise), failing to alarm at 10% COHb.

*“Evaluating the Performance of Residential CO Alarms: Final Report,” Mosaic Industries, GRI-02/0112, 27 June, 2002 .

•

CPSC “Dynamic Testing” CPSC Findings*

– 12 of 40 CO alarms tested failed to alarm at the UL 2034 Standard limit of 10% COHb when presented with CO concentrations rising at 50 ppm/hour used in Mosaic tests.

– Safety margin within UL 2034 would have prevented acute poisoning in all but one alarm test – Poor accuracy of digital displays.

•

Alternative Interpretations

– 50 ppm/hour rise time is far too slow to account for catastrophic CO events (e.g., vitiated combustion, portable generator emission factors, etc.). Faster, more realistic rise times would show far worse results.

– 10% COHb is the only reasonable basis for life safety protection afforded by alarms and has been maintained by CPSC as the appropriate limit for protection of the public. It should be a basis for acceptable performance.

*”Status Report on Carbon Monoxide Alarm Testing,” U. S. Consumer Product Safety Commission Staff Paper, June 2004.

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Fire Responder Data on CO Alarms (NFIRS 4.5-5.1 1999-2002)

• From U. S. Fire Administration, Department of Homeland Security – National Fire Incident Reporting System (NFIRS) • 64,204 CO incident calls • 13.4% of “CO Incidents” where a CO alarm was present and performance reported, the CO alarm “did not alert occupants” –

false negatives/failure to warn

• 94.2% of incidents where a CO alarm activation was reported, “no carbon monoxide detected” or “CO detector malfunction” –

false positives or “false alarms.”

From: “Preliminary Analysis of Fire Department Reported Carbon Monoxide Incidents 1999 2002,” WEC Consulting, January, 2005.

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NEWS from CPSC U.S. Consumer Product Safety Commission

February 2004

CPSC, GE Security, Inc. Announce Recall of Carbon Monoxide Alarms

WASHINGTON, D.C. - The following product safety recall was conducted voluntarily by the firm in cooperation with the CPSC. Consumers should stop using the product immediately unless otherwise instructed.

Name of product:

Carbon Monoxide (CO) Alarms

Units:

About 74,000

Manufacturer:

GE Security, Inc., (GE Security) of Tualatin, Ore.

Hazard:

The recalled units fail to detect carbon monoxide after 1 year of operation due to an internal software error. These CO alarms do not provide an "end of life" signal or other indication of inoperability, even if the test button is depressed.

Incidents/Injuries:

GE Security has received one report that the CO detector did not operate properly in the presence of CO. No injuries have been reported.

Description:

These ESL SafeAir 240-COE Carbon Monoxide alarms are hard-wired and require professional installation. The white, rectangular units are about 6-inches long and 2.75-inches high. "CARBON MONOXIDE ALARM" and "DO NOT PAINT" are written on the front of the units. "240-Coe, "SENTROL," (a former name of the company) and the date code are written on the back. The date code is a four digit number ending with a "T." The four digits denote the week and year of manufacture. For example, the date code "4500T" refers to a unit that was manufactured in the 45th week of 2000. Only units with date codes 4500T (November 2000) through 3502T (August 2002) are included in the recall..

Sold at:

Distributors, dealers and installers of security systems nationwide from November 2000 through October 2003 for about $49.

Manufactured in:

China

Remedy:

Consumers should contact their system installer or service provider to arrange for the free installation of a replacement CO alarm.

Consumer Contact:

Call GE Security, Inc. at (800) 648-7422 between 6 a.m. and 5 p.m. PT Monday through Friday, or go to their Web site at www.ge-interlogix.com

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Impending Proposals for UL 2034 Standard Changes

• Three task groups formed June 2004 to develop product standard changes: – Lifetime requirements for CO alarms – Accuracy requirements for digital displays – Performance testing based on “dynamic tests” used by Mosaic and CPSC • Proposals for changes expected Summer of 2005 • These proposals, whether adopted individually or collectively, will have major changes for manufacture and design certification of CO alarms • Tomorrow’s CO alarms will not be like many of the alarms produced today.

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Summary

•Most, if not all, mandate implementation activities have not carried out any technical analysis on expected effectiveness or cost.

•A number of factors impact mandate effectiveness, including breadth of housing stock covered, performance of alarms, compliance to mandates, and consumer response to activations.

•Only non-fire, unintentional deaths (~ 625 in 1979 decreasing to ~ 325 in 1996) could be avoided by a CO alarm mandate.

•Requiring an alarm in all housing would provide the only potentially efficient means of reducing fatalities.

•The number of deaths/dwelling unit has been dropping by about 5% per year.

•Laboratory and field data continue to demonstrate relatively poor performance of CO alarms across the range of listed products.

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Summary (continued)

•Potential changes in UL 2034 raises questions about current stability of design certification of CO alarms and appropriateness of mandates using current and past editions.

•For an idealized national mandate (one alarm per household, 100% compliance, performance to design certification, appropriate consumer response), about two CO deaths/million homes could be avoided.

•Under these idealized assumptions, the cost to taxpayers of $5 10 million/life saved from the idealized mandate is above the Federal Government life value of $2-6 million/life saved.

•The cost effectiveness of the mandate most certainly is decreased (cost/life saved increased) by realistic factors including: •Limitations on housing stock (I.e., incident base) covered •Incomplete compliance with the mandate •Performance and reliability issues of alarms, including added costs •Inappropriate consumer action in response to an alarm 33

ICC Has It Right for CO and Appliances: Source Control Based on Enforceable Code Provisions

“Sound regulatory practice requires code enforcement agencies to ensure that heating appliance installation and maintenance takes place in accordance with code requirements. The IFGC & IMC cover the entire range of such installations” 34