 Pleased to open this hearing to receive comments on the commission's proposal the proposed Safety standard for residential gas furnaces and boilers the commission's work in this area has been going on for many years Here at the time CPSC staff have been involved in multiple voluntary standards working groups published a request for information hosted a forum in 2014 to gather information about the availability and feasibility carbon-oxide sensors for use in gas furnaces and boilers and Developed a proposed rule that the Commission published for comment in October 23 Today we're going to hear oral Comments from 18 witnesses This will not be the last opportunity for for public comment as well on this proposed rule the coming months CPSC plans to make Available additional information regarding CO poisoning incident cited in the NPR And I'm heartened to see that there is significant public interest involvement in this work This is an important rule and it's vital that we get it right Carbon-oxide poisoning from furnaces and boilers kills an average of 21 people per year in this country the proposed rule aims to improve the safety of these products and protect consumers from that harm I Appreciate there's so many people signed up to provide their perspective on this proposal Because of the number of participants who signed up to speak we've asked each of you to be flexible and limit your Oral statements to five minutes. We thank you for all agreeing to that change After each panel of witnesses provides their statements, there will be opportunity for commissioners to ask questions I'll call on them by seniority and each commissioner will be given ten minutes And the panelists I see this really as your opportunity to make a presentation. So For me personally, I'm largely getting me in listening mode, but I may ask questions along the way that stay goes on So the first panel I'm going to introduce Most of whom are in person Sharon McNabb with the National Carbon-oxide Awareness Association is appearing web extra wasn't able to make it today We also have Louise Lang with Calron detection instruments limited we have Maria Carpezo and I apologize if I Deeply ruined anybody's name. I live that on throughout my life. So With the air conditioning heating and refrigeration Institute will Wallace consumer reports Paul Scholler with burning and holdings incorporated and Kenneth building with Empire Convert Systems. Thank you all for being here today Miss McNabb, I believe is remote and we're gonna start with you. Thank you and hello Chairman Hoh and Sarek and commissioners Thelma and Trump got and Boyle, thank you for inviting me to speak today on this extremely important topic My name is Sharon McNabb, and I'm president and founder of the National Carbon Monoxide Awareness Association. I Speak today in support of the notice of proposed rulemaking to add carbon monoxide monitoring to furnaces and boilers Please allow me to share a personal story with you and why I founded NCOAA I Was a high functioning engineer single mother of teenage girls and running marathons and triathlons Just before my eldest daughter entered high school I found what I thought was my dream home the woman who lived in the home from before me died of Parkinson's I Now know that they call Parkinson's or they call carbon monoxide poisoning Parkinsonism because the symptoms look identical Shortly after moving into this home. I began developing strange health issues that aligned with carbon monoxide poisoning However, the building inspector who checked my home before I bought it Never caught the carbon monoxide None of the HVAC professionals that I hired to service my furnaces caught the carbon monoxide None of my doctors caught it as a matter of fact my doctor misdiagnosed the poisoning as early onset Alzheimer's these health issues led to loss of jobs By walking with a cane and on oxygen 24 seven The damage that carbon monoxide causes is due in part to oxygen displacement or suffocation less well known is the tissue damage carbon monoxide causes to every system in the body cardiac nerve brain digestive Even if a person survives a poisoning They may not even recognize that carbon monoxide was the invisible culprit During the time I was poisoned my medical bills totaled well over a million dollars That staggering figure Does not even include my lost income or quality of life How is it possible that the carbon monoxide was missed by all of these professionals? No one should have to ever be poisoned by carbon monoxide. It is 100% preventable a Safety risk similar to carbon monoxide is electrical current Electrical current is odorless colorless invisible and designed to flow in a very specific pathway Within that pathway current is safe outside that path It can result in electrocution or fire Over time we recognize the safety risks and Adopted rules like electrical panels groundfall interruption outlets GFI's Voltage ratings and arc fault protection Thus I strongly support adoption of this rulemaking as it is the perfect common sense Low-cost solution to mitigating carbon monoxide poisoning Additionally I'd ask you to strengthen the rule with three simple enhancements first Align the threshold with the established health guidelines for carbon monoxide poisoning prevention second Add a tamper resistance Requirement similar to that in the generator standards of for carbon monoxide monitoring and lastly Integrate the use of the home's temperature Into the design ensuring a minimal safe temperature is maintained in the home While also safe guarding carbon monoxide levels should a leak occur While the device is unable to monitor Carbon monoxide poisoning is a very serious public health crisis and this issue is so important that I I Tried all night to get there today But I apologize that I'm doing it virtually but thank you so much for accommodating the change in the schedule Had this monitoring device been available 20 years ago. I probably wouldn't be testifying before you today So I urge the Commission to implement this common sense Rulemaking as quickly as possible. Thank you so much for your hard work on this important issue and for allowing me to speak today Thank You miss big tab So and I actually are part of the national then CEO a work very closely with Sharon But introducing myself. I'm Louise. I'm the vice president of sales at croc on detection instruments Who's a company who specialise in gas detection for many industries including tools for the HVCR? Industry and thank you for the opportunity to share my experience. I have over 15 years experience in the HVCR industry In the UK and in the USA Seven years in the UK and eight years in the USA My experience working in the HVC industry is with contractors Distributors and training including combustion analysers and personal gas detection products Firstly, I noticed a difference between the UK and the USA regarding gas safety So my experience in the UK With heating engineers have to be gas safe registered to be legally allowed to install and work on gas appliances This is a significant training much like the driving test in the UK, but for heating engineers It is illegal to do work without being registered My experience in the USA But people are required to register there is different requirements in each state and also in some you may only need to have one person in the organisation registered not all the heating engineers in the UK are also To condemn or fix an appliance they find either during work or during personal time So if they're visiting your home and find it they have a duty legally to fix it or condemn it when I lived in the UK and it was normal for people to have a yearly check on appliances and the check concluded Combustion analysis and also seal seal leak testing in the USA. I've observed a very different approach to gas safety In general to become a qualified plumber in the USA. It's much more stringent than a heating contractor. I'm not sure why so personal experience in 2018 I purchased a vacation home and prior to using the property I called the local HVC company to come and check my glass appliances I did have function in CEO alarms in the home and when the contractor arrived he was actually wearing a very small CEO monitor and He observed that I had 15 ppm of CEO in the home This would not have triggered my CEO alarms in my home on Investigation it was a small crack in the heat exchanger in the furnace and I had the furnace replaced and contracted the company to carry out yearly inspections. I John Crocon in 2020 and this is where I learned more about combustion Analyzers and noted that my high efficiency furnace I purchased in 2018 was not set up using this tool therefore the equipment could be over burning and detrimental to the life of the product and could in turn cause damage and seal leakage On my yearly inspections No contractor has been wearing a personal CEO monitor nor a combustion analyzer And so one question in the company they explained that the own it's only plumbers that use combustion analyzers I then did call other contractors and being told the same thing The concern is that not all contractors are using personal CEO monitors nor using combustion analyzers It is also concerning that that you if you do have faulty equipment Then CEO could be leaking and the consumer will have no idea until a CEO alarm is activated Which would only be at higher ppm levels assuming they actually have one I've also witnessed my own personal CEO alarm hitting Levels over 9 ppm while traveling and mainly in Distributors with gas forklift trucks and CEO bleeding through the warehouse to the main counter locations and also in restaurants I also had a report from a manufacturing rep who had a personal monitor And he called as a unit was an alarm in his office and it was a faulty furnace They would have had no idea If he did not have that personal monitor It would make sense to minimize risk by having all equipment shut off if CEO is leaking and enable the consumer to contact the HVAC Contractor to fix the issue. This would have many benefits. It would prevent call-outs to emergency departments The HVAC contractor can fix the issue at the earliest opportunity and ultimately protect the health and safety of the consumer To finish I want to share that one of my UK colleagues has dedicated his working career in gas detection as he suffered a major CEO exposure in the workplace because of a furnace He also had we also had a more recent event where one of her field engineers entered a plant room And the boiler was leaking CEO at very high level. She only knew this when her personal arm went off We just don't know when CEO is present. So without detecting CEO and shutting down the source We are at risk of chronic and acute CEO poisoning. So I'd like to thank everyone for listening to me today Thank you, Miss Lang Miss Carpezo Good morning Chairman Hoh and Sarah Commissioner Boyle Feldman and Trumka Thank you for the opportunity to speak today on this rulemaking My name is Marie Carpezo general counsel for the air conditioning heating and refrigeration Institute HRI HRI is the trade association representing more than 330 manufacturers of heating ventilation air conditioning commercial refrigeration and water heating equipment HRI is an internationally recognized advocate for the industry HRI developed standards for and certifies the performance of the products manufactured by our members in the United States alone The HVAC are in water heating industry supports 1.3 million jobs and 256 billion in annual economic activity HRI represents furnace and boiler manufacturers impacted by this rulemaking on behalf of a HRI members HRI opposes the proposed safety standard for residential furnaces and boilers in CPSC's no per HRI members support CPSC's goal to reduce injuries and deaths associated with carbon monoxide exposure Related to leakage from improperly installed or improperly operating residential gas furnaces boilers wall and floor furnaces However, the CPSC's proposal mandating the installation of a CO sensor in the combustion chamber or flu way of Residential gas furnaces and boilers to measure elevated levels of CO emissions is an ineffective way to address this issue HRI members encourage the CPSC to terminate proposed rule and collaborate with residential boiler and furnace manufacturers to explore alternatives to minimize consumer injuries and deaths associated with CO exposure For example, HRI believes that CO alarms installed within a residence provide a safe economical means to protect consumers from exposures to elevated levels of CO from any source State and local governments have underscored the importance of CO alarms and have adopted safety laws to increase the number of detectors required in homes in 2011 most states adopted new building codes requiring CO detectors for all one and two-story family homes Today 48 US states have adopted legislation that requires CO detectors in homes CPSC should consult with states and localities on the effectiveness of these laws before proceeding with regulations That may yield little additional benefit, but it could increase consumer cost significantly HRI and its members identify technical and legal issues with CPC's Proposal that warrants termination of the proposed safety standards as written CPSC failed to provide relevant data and information to stakeholders to analyze and provide meaningful comments in response to the proposed safety standard Recently the DC circuit held that failure to disclose technical studies and data to the public during the notice and comment period violated the administrative procedures act The 18 month effective date is unrealistic Arbitrary and fails to consider major stages of product development for CO sensors and controls before installation can occur This CPSC assembled a series of tasks to support the proposed effective date without any input from furnace and boiler manufacturers CPSC's 18 month effective date is impossible to meet CO sensors must be designed tested and certified while addressing several technical challenges Costs in time for development of new sensor technology and control boards needs to be estimated which may be considerable for both CO sensor manufacturers will have to overcome significant technical issues While control boards will have added variable costs and need additional time for product development and consideration of the supply chain Certification of these new sensors and controls will be needed and will require manufacturers to devote resources and time to design and develop safety certification procedures for all affected appliances Their capacity to carry out the timely testing and certification required if the proposed rule is implemented also needs to be assessed The CPSC's proposed safety standard is not technically feasible for a number of reasons The CPSC relied on a projected number of compliant furnaces and boilers that is inaccurate Which skewed CPSC's calculation of costs and benefits The CPSC has proposed one single safety standard that applies to residential burn Boilers furnaces wall and floor furnaces alike despite considerable differences among the products a one-sides fits all regulatory approach Fails to appreciate the considerable differences among these products CPSC's risk assessment lacks historical and annual data on CO related injuries from gas furnaces and boilers and does not adequately explain its methodology Calculations or assumptions regarding the use of niece incidents and injury cost model CPSC is not adequately considered and made appropriate findings with respect to the Consumer Product Safety Act nor has this Analysis met accepted standards for regulatory analysis as set forth in OMB circular A4 or the computer consumer product safety act Cost estimates based on the guidehouse report need to be revised to reflect current US furnaces and boiler technology and current CO sensor technology CPSC's current cost estimates are understated by at least 250% for furnaces and 325% for boilers HRI and HRI members respectfully request the CPSC and commissioners to terminate this rulemaking on the proposed safety standard Rely on the US voluntary standard process and work with manufacturers to update existing US voluntary standards to address CEO production and leakage into the living space with a reasonable timeline for compliance. Thank you. Thank you, Ms. Carpezo. Mr. Wallace. Thank you very much, Mr. Chair and commissioners. I'm really glad to be here on behalf of consumer reports, the independent, non-profit, non-partisan member organization. And we welcome the opportunity to comment to the CPSC regarding the notice of proposed rulemaking to reduce the risk of carbon monoxide poisoning associated with residential gas furnaces and boilers. CR strongly supports the CPSC's proposed safety standard and urges the commission to expeditiously finalize the strongest feasible version of the rule. I'll make a few points today in our spoken testimony. First, residential gas furnaces and boilers help consumers heat their homes, but they can also pose a risk of carbon monoxide poisoning. According to the incident data included in the CPSC's NPR, residential gas furnaces and boilers are associated with a risk of carbon monoxide poisoning. These data are compelling and they represent people and families lives changed forever, as you heard from Ms. McNabb. Importantly, these products can produce significant amounts of carbon monoxide when installed and operating properly, and that should be addressed. Consumer reports has long worked to reduce the risk of carbon monoxide poisoning to consumers, including through testing of carbon monoxide detectors and CO safety systems on portable generators. As well as through our stories, helping consumers be aware of CO risks and the steps they can take to protect their family. Our experts have significant experience with furnaces and boilers and HVAC systems, and while CR does not currently rate residential gas furnaces or boilers, in other words, we don't test them, we don't conduct comparative testing of them, we do evaluate brands' reliability on the basis of our CR member surveys. Second point is that a CPSC safety standard for residential gas furnaces and boilers is necessary. The justification for the proposed safety standard is clear. Descent injuries linked to CO poisoning have not meaningfully declined, despite the existence of voluntary standards as well as education and information campaigns. We agree with the CPSC's assessment that applicable voluntary standards for residential gas furnaces and boilers are inadequate because they do not contain requirements that protect against known conditions that cause or contribute to CO exposure, and they don't contain requirements for the appliance to monitor and manage CO production to prevent the introduction of hazardous levels of CO in the appliance's exhaust fence system. Look, we recognize that furnaces, boilers, and related systems can be set up in many different ways, but there should be a strong standard to protect consumers, a minimum standard for safety. That's simply not the case today, and I find it baffling to think that the voluntary standard process is going to get us out of this unless some significant changes occur from what we've seen over the last 20 years. The CPSC has assessed that deaths and injuries associated with residential gas furnaces and boilers can and do occur from CO poisoning even when products within the scope of the proposed rule comply with applicable US voluntary standards. While CPSC staff has for years encouraged the industry to adopt a voluntary standard that adequately addresses the known hazards, they have not done so, and so it's clear that a mandatory standard is needed that will better reduce the risk to consumers. Third, the CPSC should finalize the strongest feasible version of the rule. To protect the public from the risk of carbon monoxide poisoning in their homes, we urge the CPSC to finalize the strongest feasible version of this rule. One option is for the agency to require that all manufacturers use the single point method outlined in the NPR, under which shutdown or modulation of the appliance shall begin immediately after average CO concentration in the exhaust fluid was determined to be 150 parts per million or higher for 15 minutes. This strikes us as a strong straightforward and reasonable approach that serves both consumers and industry. It would compare favorably to the strongest existing standards, namely those existing internationally. It's a performance standard and industry can choose to comply the way that works best for them. Of course, if there are stronger limits that are feasible for both the CPSC and industry to implement, we would encourage the CPSC to pursue them in the final rule. Under no circumstances should the rule permit CO concentrations in the exhaust fluid greater than 400 parts per million. Provisions already exist in the applicable voluntary standards that demand that appliances that these appliances not produce CO in excess of 400 ppm under prescribed laboratory test conditions. Same with the national fuel gas code. Any allowance by the CPSC for CO concentrations greater than 400 ppm would represent a step backward from the already inadequate status quo under the voluntary standards and be counterproductive to what the agency is trying to achieve with this rulemaking. In conclusion, thank you for the opportunity to comment on this NPR. We urge the CPSC to finalize the strongest feasible version of the rule. And in our estimation, the NPR single point method for meeting the rules for performance requirements is strong straightforward and reasonable. Thank you. Thank you, Mr. Wallace. Mr. Solar. Yes, my name is Paul Solar and I represent Burnham Holdings Inc. This rule is flawed in both its substance and manner of promulgation. In the interest of time, I will focus on the technical problems with this rule, which seems based on three propositions. First, the best way to eliminate CO poisoning caused by a given appliance is to monitor CO exhaust in that appliance. Second, that this rule is essentially the same as requirements in Europe and Japan. And third, that practical technology to monitor CO levels and exhaust gases exist and is suitable for all appliances under this rule. The second two propositions are false. Either European or Japanese standards require monitoring of CO directly or indirectly in the exhaust. Instead, they limit CO when the appliance is subjected to particular conditions just like the US standards. In many cases, the foreign standards are actually less stringent. For example, the US boiler standard requires direct vent boilers to shut off when a progressive blockage is applied to the vent before the CO level reaches 400 ppm. The EU standard places a limit on CO production under the same conditions at 2000 ppm and the Japanese standard does not even include this test. Where the Japanese standard prescribed CO limits, they are specified in the room, not in the exhaust gases, meaning that the effective Japanese CO limits are far higher than in the US. EU requirements could be met using a CO sensor, but it is telling that few, if any European manufacturers actually do so. CPSC identified one sensor on a European boiler and our research indicates the sensor is no longer used. The Japanese requirement for an oxygen depletion safety shut off device, which there is, this technology is unlikely to comply with your proposed rule for reasons detailed in our written comments. We need to only look at your briefing package for an independent assessment of the third proposition to quote guide house. We did not find any CO sensors or combustion control strategies on the market that have been demonstrated in atmospherically vented systems as the systems identified in Japan and Europe that utilizes CO sensor also incorporate a power burner. This fits with other CPSC data and our own research of the three CO sensors identified by CPSC only one is known to be currently used in an exhaust gas application. ANSYS testing showed a three and a half year equivalent field life for the sensor under less than works case conditions. The maximum temperature rating for the sensor is 392 F, which is too low for many applications. Finally, the manufacturer of the sensors informed us that it is not designed for detection at levels below 500 parts per million. The indirect methods of monitoring CO are equally problematic. CO2 and O2 cannot reliably infer CO because neither varies consistently with CO. At air fuel ratios over one CO generally varies directly with CO2. At air fuel ratios below 1.0 as when someone operates a natural gas appliance on propane CO2 and CO very inversely. Monitoring air fuel ratio is a proxy for CO only works when the burner system is uncompromised. A fouled or a deteriorated burner may cause elevated CO despite the air fuel ratio being acceptable. And that the same is true for oxygen monitoring. We also doubt that the flame rectification can be used to infer CO levels on Bunsen burners or even most premixed burners at the levels prescribed by this rule. Finally, the test procedure is flawed. It will not show that an indirect means limits CO under any condition other than the one imposed during the test. It is even possible to imagine systems that pass or fail depending on which test option is applied. Another problem is this rule silence on appliance behavior after shutting down or modulating due to elevated CO. If the appliance shuts down as required and is allowed to immediately restart and clearly no benefit is provided. CPSC's efforts would be better spent promoting the use of CO alarms that are feasible covered by a voluntary standard and worn independently of source. Barring that if CPSC were to meet its statutory obligations for promulgation of a rule requiring a response from response to CO in room air while also imperfect would offer many advantages over this rule. Thank you. Thank you, Mr. Solar. Mr. Belding. Thank you. Good morning. My name is Ken Belding, Director of Government Affairs for Empire Comfort Systems. Empire's a small business as defined by the Small Business Administration. Empire's been in business since 1932 and it was started and still owned by the same family four generations later. Empire supports about 300 families directly and is a contributor to Belleville, Illinois where it is located. ECS supports CPSC's goal to reduce CO poisoning deaths. His concern that a sensor in the combustion chamber flue way is an ineffective way to address this issue. CPSC's proposed safety standards are not supported by CPSC's own data and is not technically feasible. Refer to comments submissions by AHRI please. Over the years, ECS has participated in and supported two safety improvement efforts at great expense to our company. Both efforts were very successful. ECS believes that having CO detectors installed at the time of a new gas appliance installation or at the time a unit is serviced in a space with no CO detector would provide a safe and economic means to protect consumers from excessive CO level exposure. Wall furnaces and floor furnaces are powered by a millivolt system of between 0.5 volts and 1.5 volts. That's what we manufacture. This power supply is generated by the pilot flame and the thermo-pile thermocouple. We do not believe that the current strategy by CPSC of controlling CO levels can be accomplished in a millivolt wall furnace. To our knowledge, there is no low millivolt burner system available that can power a sensor and variable burn level. By CPSC... Oh, burn level. The current design allows the gravity wall and floor furnaces to heat spaces with no electricity available. The living space has no electricity available, is off the grid or has a power outage in most cases due to weather. Texas suffered a regional power outage a few winters ago and people died. A gravity wall or floor furnace would have stayed running and kept people warm. People in Alaska, Canada and Northern states use this type of heating every winter. In 2016, DO declared in a final determination that more stringent energy conservation standards for direct heating equipment, which includes wall and floor furnaces, are not economically justified and is therefore not amending its energy conservation standards. DOE also found shipments of direct heating equipment were low, therefore energy savings potential was low. Low shipments meant manufacturers would have a difficult time recouping expenditures related to complying with an amended standard. Product offerings may be reduced, which they were. Manufacturers may leave the market entirely, which the industry went from four manufacturers to two floor furnace manufacturers. And employment may be negatively impacted, it is less now. The industry has gone through consolidation with only two wall furnace manufacturers and only one floor furnace manufacturer. ECS has dropped the floor furnace line of products and this is after DOE did not go through with their ruling. ECS experience with CO poisoning deaths. Most importantly, ECS has had zero CO poisoning deaths due to wall furnaces in the last seven years. I know this because I manage our product liability claims and have done this for the last 36 years. I do not recall the previous almost 30 years, but the last seven have been free of CO poison deaths. ECS is willing to work with the CPSC and requiring owner's manual language mandating CO detectors be installed with every wall furnace installation. We request that our small and safe industry be removed from this NOPER or at least have a consideration for a modified course with owner's manual language requiring CO detectors be installed at the time of a unit installation. Thank you. Thank you, Mr. Belling. At this point in time, we're going to turn to questions from the commissioners. Each commissioner is going to have 10 minutes to ask questions. I appreciate everybody taking the time to come and testify. Do you want to hear from my other colleagues? So at this point in time, I'm going to turn to them. Commissioner Feldman. Thank you, Mr. Chairman. Good morning, and I'm pleased to see so many of our presenters here and on our schedule this morning. Today marks an important step as we gather information about the proposed rule. I want to thank you all for sharing your perspectives and testimonies as the commission continues to work through this process. Should CPSC finalize a mandatory consumer products safety standard for residential gas furnaces and boilers? Such a standard should be technically feasible, effective in reducing the risks of harm to consumers and supported by evidence and analysis to withstand legal challenge. There's more work to be done, including the sharing of the agency's incident information for public review and comment, which I look forward to. Mr. Chairman, I don't have any questions at this time, but I would yield back the balance of my time. Thank you, Commissioner. Commissioner. Thank you. Many of the witnesses here today are here to help protect the public health. And I thank you for being here for that purpose. Others are here out of self interest to protect their own bottom line. Ms. Carpizzo, you're not here for the public health. You represent the industry that makes the products we're here to talk about. And I'll read what your group told the IRS about its business to maintain its tax free status. You said that you quote, serve the industry by promoting confidence in the performance of industries products. Products that you say are quote, coming under increasing scrutiny. And it's your job to quote, work with decision makers to develop policies that recognize the benefits of air conditioning, heating and refrigeration products. Mission accomplished. I see the benefits of your products. I like to be warm in the winter and cool in the summer. But you're going beyond that because we're here talking about a hazard tied to your products and you're telling us not to fix it. I see groups like yours with every problem, problem we try to solve. So before I read your testimony, I made a prediction. And I predicted you were going to claim that the proposed rule is not feasible too expensive and impossible to comply with on any reasonable timeline. Three for three. No points for originality, Ms. Carpizzo. And, you know, we hear those same tired excuses with every single rulemaking and I've yet to see them be true. But here's where you veer from tired argument to insulting. You say that this regulation will provide quote, little additional benefit. And to be clear, you're saying that about a proposed rule that would save 27 lives every year. But I think I shouldn't be surprised there because your industry has made clear over the last two decades there really doesn't see the additional benefit in saving 27 lives a year. You certainly haven't pursued it. You've been talking about voluntary industry standards for 22 years. And according to CPSC expert staff, you've made exactly zero progress. And I have never heard them say that about any industry. If your members cared about saving lives, that kind of delay wouldn't be possible. So I ask you, is 22 years enough time for consumers to wait for safe appliances? Commissioner Trunca, thank you for their question and the opportunity to speak here on behalf of the HRI manufacturers. I want to say it up front that for our HRI manufacturers, safety is paramount to our manufacturers and ensuring that our products are safe, their products are safe for consumers and residents alike. In terms of the ability to address this particular issue. It is very an important issue for it. When my question is it was 22 years enough time for consumers to wait for safe appliances? Well, in that, in that instance, I think in terms of time, manufacturers need to be involved in the process. You need more time. But I'll give you this chance. What do you have to say to the hundreds of families who lost loved ones to CO poisoning from your products in those last two decades? Are you ready to apologize? Commissioner Trunca, safety is paramount to our members. Don't talk to me. I'm asking you to address those families. Are you ready to apologize? I'm not in position to address that. No apologies. Mr. Belly, I want to make sure I understand one of the statements that you made in your testimony. You referenced your 37 years of experience as a product claim manager for Empire comfort systems. And you said, quote, I don't remember about the 30 years prior to. But over the last seven years, Empire comfort systems has not had any CO poisoning deaths related to our gravity wall furnaces. I'm not sure that was the comforting statement you may have intended there. It leaves me with at least two questions. One, do you have any deaths in the last seven years with products other than your gravity wall furnaces? And two, how do you account for the 30 year gap in memory? I'm sorry. Can you turn on your mic? I don't think that's actually the reason I discard them is more for legal reasons than anything else. I don't want to be caught in a trap or have someone suing me for information that wasn't valid. Do you may have discarded records of deaths over those 30 years for legal reasons? Yes, we have a we have a policy. It's normal for industry to have policies of record keeping and mine is for product liability claims and I discard them. Discard information about deaths for litigation risk reasons. That's a new one for me, but I'd like to learn more at some point in the future. Well, the point is, is that many of these cases are not the fault of the appliance and I would submit that all of them have not been the fault of the appliance. I think that's part of my other comment in here about the data that CPSC has. I'm wondering how many of those cases were not the fault of the appliance itself, but the installation of the venting or the operation by the consumer where they modified something. Mr. Wallace, I'm not going to address that. Mr. Wallace, CPSC's economic analysis suggested that the rule would only add $22 or $26 in manufacturing costs per unit. Companies could swallow that cost and personally, I don't think a responsible company should pass along any cost just to make their product safe. Yet the economic analysis in the proposed rule predicts an increase in retail costs of $70 or $87. That's $50 or $60 worth of price gouging baked in beyond passing on all of the increased manufacturing costs. So Mr. Wallace, should we endorse price gouging or should we remove those assumptions from final rule? Yeah, those estimates that that estimate on top of the added cost to the to the product made little sense to us. And certainly I would expect the CPSC to to endorse only those estimates that can be directly linked to what you're talking about with the product changes. Thank you. Ms. McNabb, can you expand, you were touching on two things that I wanted to give you an opportunity to talk a little bit more about. One, that you believe we need lower shutdown or modulation thresholds and two, that we should extend the time period before restart. Yes, the thresholds are extremely high. And they do not follow health guidelines. And so my question is, I understand that this is an absolute great step in the right direction. However, why are we not working towards aligning with health guidelines? Secondly, the shut off, I'm sorry, the, the, sorry. The time before restart was the other part of my question. Thank you. Yeah, the time before restart. We don't believe is adequate enough. And if you were able, and I understand the, the idea of having the opportunity to keep the home periodically throughout the time. But furnaces and boilers are based on a temperature setting in the home. Why don't we use that temperature setting to define what is a minimum level of safe temperature and use that to also balance out how much carbon monoxide would be leaking into the home. Should it leak occur while the device is not monitoring. Thank you. Mr. Wallace, I'll give you an opportunity if you have any further thoughts on, on either of those two issues with, with the thresholds or the time before restart or. I would just underscore that, that Ms. McNabb raises really important points related to, to tamper resistance and also to time of restart. I would just say that, you know, these, these points being made about, you know, the idea that that furnaces and boilers themselves are somehow not related to the CO incidents that we see. It's, it doesn't make any sense. It doesn't. I mean, like, certainly, these are systems that involve multiple parts. Certainly there's ventilation. Certainly there are a lot of houses in this in this country that don't have the ventilation they should, but at the same time, you know, these are the products that are producing the carbon monoxide. And so, you know, it's, it's reasonable to expect them to minimize carbon monoxide production and leakage to the greatest extent possible. Thank you. And Mr. Belding. And last question, it sounded like you were saying that you are blaming installers or consumers themselves for all the deaths you've seen in your company's products. Is that right? I didn't say that. Okay. So there were deaths. Let me clarify just a little bit. First of all, I don't, I don't know of a remember. I, when I say I don't remember, I don't want to tell you for a fact that there weren't any because my brain doesn't go back 37 years. Okay. It's very important to me to make sure I try to remember so we don't make mistakes again if there were any made. As far as I know, and can remember, we didn't have had not had any deaths with gravity wall furnaces or furnaces there were. And those were. I also did inspections and the ones I saw mostly were as an example when I went crawled under a house for it were for a floor furnace where three or four people had passed away due to CEO. I found a hole in the vent pipe this big. The gas company had been there supposedly to do an inspection. The worker they had doing it was fired a week or two later or month later because they found out he didn't do his job and then nobody went back to check. But so I, I don't necessarily consider that an issue for us because where are you going to put the sensor is that you're going to work on a floor furnace. The idea is is the gas company was trying to do their job their employee didn't do his job. I don't want to get into that's not my issue. I'm just telling you that floor furnaces, which we don't manufacture anymore because our industry is shrinking and that one is shrinking the most and there's one manufacturer left wall furnaces are shrinking. And for us to invest money in something that I don't think can work because we use low voltage thermopiles for power. Maybe it will, but we, we don't know of any at the moment. I think the situation you described of those math desk is what we're all here trying to prevent. So thank you for the context. Mr. Boyle. Thank you, Mr. Chair and thank you to all the panelists for being here. I really appreciate the opportunity to hear your views. Just, I have a couple of quick questions from you, Mr. Solar. You recommend that in addition in lieu of the rule CPSC should promote the use of CO alarms. And I just want to clarify that. Is it your view that we should be looking at CO alarms exclusively rather than any mandatory standards for these products. I think right now, putting a flu, you know, flue gas sensor in these products is not feasible. And therefore the question becomes, okay. There is a problem here. What do we do to address it? You know, CO alarms readily available. I would refer you, if you go and look at A O Smith's written testimony, they actually have some pretty striking data from some incident reports that they looked at showing the effectiveness of CO alarms and eliminating, you know, serious deaths and serious injuries from CO. And I think once we do finally get to see the ID eyes, you know, that that'll be borne out. So, yeah, I think the approach needs to be looking at ambient air because it's technically feasible to look at the CO there. Now, you know, I think the best way to do that is with an off the shelf CO alarm. So, just to be clear, for the products themselves, you don't think we should be looking at any kind of safety mandatory safety. I wouldn't say I would say that is something that perhaps voluntary standards should look at. I wouldn't take it off the table. Okay, thank you. Mr walls. Would you care to comment on the argument that CBSC should be focusing almost exclusively on CO alarms. Right. So, I mean, a focus exclusively on on CO alarms is like saying, it's enough for for cars to have, you know, seat belts and airbags and you don't need to make sure that the car runs safely. You know, like that it doesn't matter if there's a safe driver or power steering or anything like that. Like we need to address both of these. We need to address the fact that too much CO is being produced by these units, and we need carbon monoxide detector use throughout homes. It's both. Okay. Thank you very much. I don't have additional questions. Mr. Sheriff. Thank you to all the panelists. I really do appreciate you're taking the time to share your views with us today. Thank you. Was there a press room on the round hearing none. I'm going to excuse the first panel and invite the second panel to come up. Or actually the second panel is all appearing virtually. So, let me introduce them while the first panel is sitting down. First, we have Chief Butch Browning with the National Association of State File Marshals. Brittany Meyer with the American Lung Association. And at least with build fun with the pressure testing solutions. Don Johnson with the Lauren project. Apes car with Perg energy and utilities and Kelly. Rand still with the fire protection association. Thank you for all being here. Chief Brown. If you are ready, you can begin. Browning looks like he is muted. Chief Browning is not ready. We can move to. Miss Meyer with the American Lung Association. We'll come back to Chief Browning. Can you hear me? Yes. Okay. Hi. It's not expecting to go right exactly now. So, here we go. Hello, my name is Brittany Meyer and I represent the American Lung Association, the oldest voluntary public health association in the United States. And I'm here mostly to support the victims, medical professionals and others with personal experiences with this preventable cause of health harm. According to statistics about 550 people died unintentionally from non fire related carbon monoxide exposure in 2021. Which is up about 150 from about 400 in 2015, which is the sharpest increase in more than 40 years. Carbon monoxide exposure is a leading cause of poisoning in the United States public health crisis affecting as many as 1 in 6 homes. Carbon monoxide is in a colorless orderless and tasteless gas that can you accumulate indoors at harmful concentrations and is mostly undetected except for if you have a sensor. Carbon monoxide is admitted at any time that a fossil fuel is burned and deaths are most likely to occur in the colder months from heating systems like gas furnaces and generators, similar to what we're talking about today. But I'm also here to briefly mentioned the low level chronic exposure poisonings, which are non fatal and represent a lot of this issue. Symptoms of this range from very mild and to less mild and can mimic the flu or other more common ailments. Chronic carbon monoxide exposures at low levels can result in serious long term health consequences such as heart failure stroke, cognitive and memory impairments. Sensory motor deficits, emotional changes, cognitive continual defects and low birth weight, a lot of stuff. Carbon monoxide poisoning disproportionately impacts marginalized communities. So we're, we are here to ask you to support to those folks as well. CPSC has encouraged industry to develop safety standards for a long time. But as far as I am aware, this has not happened at least adequately. And technology currently exists to prevent this poisoning and these deaths. The proposed rule suggests using sensors to detect leaks in gas furnaces and boilers and emergency shutoffs that will detect leaks and shut off the appliances before they can cause harm. And we are very supportive of this recommendation, mostly because it does not involve the person acting having something shut off immediately is more helpful than if an alarm going off. You may ignore it or unplug your machine or not leave the way that you need to be acting. However, it is critical that CPSC ensures residential furnaces and boilers sold in the US are as safe as possible. And so we're suggesting that you implement a rule that not only prevents death as per gas boilers and furnaces, which would include incorporating lower shutdown threshold to account for the established US guidance from the CDC, which states that an elevated level of two carbon monoxide HB for non smokers is strongly supportive of carbon monoxide poisoning. In addition, we suggest CPSC add requirements to prevent tampering with or disabling the carbon monoxide shut off device and also to extend the time period before restart is allowed during a failure. So that it's at least 30 minutes. Thank you for your time and happy to answer any questions specifically on the impact of carbon monoxide on the body. As it is. You cut out when we got to the last 30 minutes if you could back up your testimony. 30 seconds. You extend the period of time before restart is allowed during a sense of failure to at least 30 minutes because the current time is not protective enough. If a carbon monoxide incident occurs, the current lead time before restart is allowed is not protective enough of health. And then I just said, we are hopeful that this will help prevent unnecessary death and injury in the future. And I'm happy to answer questions about the impact of carbon monoxide on the body as it enters the body through the lungs and then kind of goes out throughout the entire body system. So thank you for your time. Thank you, Miss Meyer. Thank you for being flexible with your time your testimony. Don't know if Chief Browning is on at this point. Yes, I'm here. Please start then. Thank you so much commissioners it's an honor for me to be before you all my name is but Browning I'm the executive director of the National Association of state fire marshals I represent the senior fire officially each state the state fire marshal. First off, I want to thank you all for what you do as a as a young firefighter in the late 80s I came to know the CPSC. When we had some devastating fires in the Baton Rouge area started by vents and heater vents in bathrooms I come to learn the important work of what you do and protecting the consumers in general but more importantly families and children and neighbors so I look forward to provide some information to you today and hopefully bring safety along in this arena. In my 35 years of public work from being a firefighter fire chief in the fire marshal for the state of Louisiana. I've certainly witnessed the progress on preventing some of the CO poisons dangers injuries and deaths. Certainly I commend you all's work on the generator safety you know when hurricane Laura devastated Louisiana we had a record number of CO desk dealing with CO that was coming from portable generators and some fixed generators so the work is phenomenal. But I stand before you today to tell you that the national fire marshal support. This regulation on boilers and furnaces to create a layer of fire protection. You see, we can put smoke alarms, CO alarms and detectors in many occupancies, but without having a layer of protection without having products that have its own protection its own ability to stop producing CO is very important so I think as we move forward we've got to find the technologies we've got to embrace the things that they can bring about safety of not only the product but also in the world of detection and many states have embraced the single station CO detectors which do a phenomenal job, but it's a minimal level of protection. So as we move forward we want to work with with the industries and the groups out there to find solutions to prevent these things you know I've always said as a as a as a fire chief and farm marshal that one death is too and I hear that theme as as I hear some of the testimony and certainly safety is paramount you can't put a price on life. So as we move forward, we want to work with the industries and support and the state fire marshals are have a very keen eye on getting some solutions on this we realize it may take some time, but we want to get it right and we want to get it right quickly so we can save lives. I'll end with also commending the commission for your work on supporting the CO grant program that nasim has partnered with you all. It's going to save many lives as we get valuable detection out and across the country to protect people's lives. I'll end with that. I'll stand clear to answering questions that you may have and look forward to this process. Thank you chief Browning thank you and your colleagues for the work that you do as well. Turning now to Mr Johnson. Are you on. Can you hear me. Yes, you can please begin. Great. Don Johnson representing the Lauren project and myself as the father of Lauren Johnson who was killed by carbon monoxide. On January 5 2009, I live in Windsor, Colorado, but I speak to you from Tucson, Arizona. So Lauren was a graduate student in international human rights. When she was killed by carbon monoxide. She had gone back to her apartment early during Christmas break. In order to do some preparation she'd been chosen to lead a group of graduate students to Israel. Leaving in five days. She didn't get to make that trip. She was in her apartment doing preparation started to feel ill went to her bedroom to lay down realize something was seriously wrong. And this brilliant woman. Only wanted to make the world a better place. That was her goal in life. Couldn't even function well enough to call for help we could see that she tried to use her phone to call for help. But she couldn't even put together the numbers. 911. So she was in an apartment building a quadrangle design. About 40 or 50 units. With hot water heat. How in the hell did she die from carbon monoxide boy. The unit the board was three stories below her. The vent pipes ran through the walls of her apartment and vented out the roof just above her third floor apartment in the three story building. The roof vent receptacle had blown off in the windstorm. The landlord asked a painter that happened to be there working to put it back on the painter didn't realize didn't have the training to know that it was damaged. So the roof vent became a roof cap. It forced the exhaust. From the malfunctioning boiler which had no sensor. Into that space between the roof and the ceiling above her apartment. The level of carbon monoxide in her apartment was 1500 parts per million. As most of you know 300 parts per million can be fatal over time. Just a few days after Lawrence death and memorial service. I was invited to testify before the Colorado state legislature about her death. A bill had been reintroduced that had not been passed that did not have that had failed a year before. It was reintroduced when the Lofgren family of four was killed in a multi million dollar home in Aspen Colorado. Once again by a boiler that was improperly vented. No sensor in that one either. All four family members died. The boiler's purpose was to heat the driveway to keep snow and ice clear on the driveway. We testified before that committee I wish I had more time to detail what went on. But what I can tell you is that it passed with a bipartisan support overwhelmingly. And that the law which became known as the Lofgren and Johnson family's carbon monoxide safety act. Requires seal alarms in homes when they are built and homes when they're building. And an apartment whenever there's exposure to carbon on site. The law has has what the law has done in Colorado is require thousands of seal alarms every year be installed that otherwise would not be possible. Probably would have ended my time with carbon monoxide there had some of Lauren's friends not come to her mother and I and asked if they could start an organization. That remembered her passion. Lauren was very passionate about making the world a better place to live. So we said yes didn't know if they would happen. But in six months, the Lauren project was created. What the Lauren project has done in the past 15 years is provide thousands of seal alarms and carbon monoxide alarms free of charge to lower income communities in many cases in most cases where landlords, even though the law says they should have them didn't. Or other homeowners who couldn't afford them because they had to pay for it. So we said yes didn't know if they would happen. But in six months Lauren project was created. What the Lauren project has done in the past 15 years is provide thousands. Or other homeowners who couldn't afford them because they had to choose between seal alarms and food on the table. And so the result has been many lives have been saved and injuries prevented because of that law. I've also had the privilege of testifying in Nebraska, Iowa and North Dakota about about bills that strengthen carbon monoxide safety. All three states passed those bills. I will mention that the governor of North Dakota vetoed the bill. He recently was running for president. I'm happy to say that he had that people had no interest in seeing him run at least the people I know. In any case, bills continue to be strengthened as one of the presenters mentioned earlier. Laws are existing apparently in 48 states. However, what I can tell you is that the range of those laws is great and some of them are very minimal in the protection that they require. Lauren project has also in addition to doing carbon monoxide safety advocacy also provides grants to young adults ages 21 to 35 to do international volunteer service. We've sent 175 volunteers to 38 38 different countries to do all manner of good working at orphanages, medical clinic schools, hospitals, community organizing environmental groups, animal rights groups you name it we've sent somebody somewhere in the world to make a difference to make the world better. Make the world a better place, which was all Lauren wanted and work for. So I thank you for this opportunity to share a little bit of Lauren story and about the Lauren project. Thank you. Thank you Mr Johnson. I'm very sorry for your loss and thank you for all your efforts to prevent future carbon monoxide tragedies from happening. At this point in time, we're going to go to miss. Are you there. This is not available. We're going to move to Mr scar scar you available. Can you hear me. Yes, we can please begin. Good morning. My name is Abraham scar and the energy and utilities program director at us. I want to thank the chairperson and commissioners for the opportunity to make an oral presentation today in support of the proposed rule and in support of strengthening rule. Perg is an advocate for the public interest. We speak out for the public and stand up to special interests on problems that affect the public's health safety and well being. We have a long history of working on product safety and supporting the mission of the consumer product safety commission. Our consumer watchdog team has worked for decades to make sure the products you bring into your home won't put your health safety or well being at risk with a particular focus on toys and other children's products. We've uncovered dangers that have led to more than 150 recalls and other regulatory actions over the last four decades. In my role with Perg, I helped write a written comment on this proposed rule and collected sign on from over 50 health consumer community and environmental justice organizations. It's critical to the commission fulfill its mission to save lives and keep families safe by reducing the unreasonable risks of injuries and deaths associated with consumer products. Even the most diligent consumer cannot identify hidden hazards and risks found in some products. And this is of course particularly true for carbon monoxide pollution, which is undetectable by human senses. I'm not a carbon monoxide expert nor am I an appliance expert and I appreciate the testimony of the survivors, flyer and HVAC professionals who are. I do have significant experience in consumer protection and public education and I'm motivated to act on this issue because there is a significant gap between the unambiguous health risks of chronic low level carbon monoxide pollution from residential gas appliances on the one hand. And the consumer protections and public awareness necessary to mitigate those risks on the other. I also own a gas boiler in my basement, not far from where I'm standing right now. This is where I work when I work from home. This is also a frequent play area for my two young children. And we tend to play down here in the basement during the cold winter months in Chicago when it's less comfortable to play outside and when our gas boiler is frequently running to keep our house warm. Like any parent, I want to ensure the environment in which they play and grow is healthy and safe. As I'm relatively new, the issue I was quite taken aback when I learned that carbon monoxide alarms. I do not alert residents of carbon monoxide pollution levels that are not life threatening, but still pose severe health risks. Having learned this, I plan to purchase a more sensitive sensor to better monitor carbon monoxide levels where I work and my children play. And that will better protect my family, but to fulfill the commission's mission more must be done to systematically address the unreasonable risk of injury posed by carbon monoxide pollution from residential gas boilers and furnaces. Like many have said today, we believe the rule is a great start and I can encourage the commission to at a minimum adopt it as proposed. And I further recommend incorporating as Sharon McNabb said earlier, a lower shut down modulation thresholds to account for established US health guidance from the centers for disease control prevention. Add requirements to prevent tampering with or deactivating the carbon monoxide shut off devices and to extend the time period before restart is allowed during a sensor failure event to at least 30 minutes. And finally, I encourage the commission to continue its examination of residential gas appliances and consider rulemaking to address their negative impacts on indoor air quality. Again, thank you for the opportunity to make a presentation today. I appreciate the opportunity to do so remotely. And I'd be happy to take any questions from the commission. Thank you, Mr. Scar. We're going to try again. Miss build phone. Is there? If not, then we're going to go to miss Randall. Good morning and thank you for the opportunity to speak with you at this important hearing. My name is Kelly Randall. I just flew in actually from North Carolina to Tennessee where there is a national vision 2020 conference on community risk reduction. I've worked in fire safety and injury prevention for about 24 years and an emergency services since 1994. And I can tell you that carbon monoxide education has become a passion for me. Since I've seen firsthand the dangers of it in so many situations. I even travel with my own CO alarm, but personally and professionally because I know just how dangerous carbon monoxide can be. I'm one of the latest encounters that occurred in my life involved one of the most precious people I have. That's my mother. She's 76 years old. She's a widow. She is hearing impaired and has to cochlear implants. So of course we have smoke alarms. We have CO alarms throughout our house. We have a bed shaker and a strobe for nighttime. About three years ago, she had to replace her dual fuel heating and air unit where we live at the current time there was only propane fuel. We are seeing some natural gas lines now, but primarily propane is what we use for heat. And in that case, it is electrical and to the point that it hits about 30 degrees and then it switches to the gas fuel furnace. That is the most common heating method we have and what we call our subtropic North Carolina where it can be 71 day and 30 the next and all of that in the same week. The unit was installed by a licensed HVAC contractor working in the industry and being a safety advocate, we always make sure that we use licensed companies and it had operated in North Carolina for a long time. The unit was installed in the spring. So right at the end of the heating system. So it wasn't in a lot of usage until later that fall. My mom has a full basement. We also install seal alarms in there. And in the fall when her heating system kicked on the carbon monoxide alarm in her basement went off. Since she didn't want to bother me, she purchased another one and installed it within hours. This was actually a plugin type with a battery backup when she did that her new alarm sounded and also she went upstairs, but none of those alarms were going off. She then went and grabbed an additional alarm because she still did not want to bother me and thought maybe there was a malfunction. At that time she called the HVAC company and they sent a technician out. When the gentleman came in, he opened the doors to the garage and then proceeded to tell her that there was no problem. It must just be from her vehicle, which actually had not been running in the garage or something else and dismissed her. As you know, fresh air delutes the ability to detect CO. So there was no way he could get a reading. He told her that he was sure maybe it was from her tankless water heater, which is actually on the exterior of her home. Trying not to be a problem. She went along with this and she called the company that installed her tankless water heater. They came and checked it out and they assured her that actually there was no CO being generated from it as it was on the exterior of her home and not inside it. A few days later, the CO alarm went off again on a cold morning and she called me and she said, this is what's going on. I said, Mama, something is wrong. CO alarms don't go off, especially multiple ones on faults or nuisance alarms. So she went ahead, she opened the garage door, the alarm stopped and we started to get a plan together on what exactly was going on. In the meantime, because I'm in this industry and of course it was my mother, so I didn't want to overreact. I called the fire code specialist with the state fire marshal's office in North Carolina and I asked his opinion about whether this was concerning. He said, yes, of course it is and you should call the fire department. So I called the fire department, they placed a note in the system so that if her alarm went off again, we could do everything right, that they would go in, do a reading to see exactly what the source of this was. And of course they were happy to help. In the meantime, we worked with several people in the gas industry to see what was going on. We got lots of mixed opinions and about a week later, the system quit working altogether. So she called the HVAC company again. This time they sent a new technician, they sent a supervisor out and since the system was less than one year old, the manager started looking at the system. At that time he realized that the orifice had been left in natural gas mode and not in propane mode, which means it was over fueling the system. The whole system had to be replaced due to this huge mistake. I'm thankful that my mom had working CEO alarms and that the CEO never went into the living quarters of her home. But unfortunately, I know too many people that that is not the case. It could have turned out so different. And I work in this field and I know how dangerous CEO could be. The average citizen has no idea the dangers of this. And if they don't have CEO alarms, we know that it can be fatal. We know contractors are human. In North Carolina, we did pass legislation that when they put a new system in they put CEO alarms them. But yet they have no concept of why it is so important that just a human error could be fatal for someone. So we are asking that you please help by passing this standard so that the actual equipment will have safeguards in place. This could save so many lives and make people safer with this engineering fix. So thank you for the opportunity to speak with you. And I appreciate so much the consideration of CPSC to really make a difference. Thank you. Thank you, Mr. Anstel. We're going to try Ms. Villefong again. Are you there, Ms. Villefong? Not hearing her. We're going to turn this point in time to questions from the commission. Questions from the commissioners. I'm going to start with myself. And again, I appreciate all those who have come to testify before us and provide information in the course of this rulemaking proceeding. Chief Browning, you talked about the need for layers of protection. In connection with that, I was wondering if in your experience, experience of your colleagues, have you found times when people have had fire or carbon monoxide alarm detectors that have either failed or have maybe not run out of batteries and not provided the notice and gone off for families? During the time of fire or carbon monoxide? Yeah, I'll just tell you specifically on carbon monoxide, the technology has come a long way in the detection. And again, I can remember in my street days, my fire chief days, we'd respond to a lot of CO alarms that when we get there, we can't determine any levels of CO. And in many cases, we felt like the alarm might not have functioned properly. We're seeing a little less of that. I think the alarms have gotten a lot better. And the longer lasting batteries and things, but it still doesn't replace the second means of protection and that is that device. And simply speaking, if that mechanical unit shuts itself off before it would put dangerous levels in a building, in a home, in a sleeping room before that CO alarm has to do its job, those layers of protection are going to save lives, going to reduce the injuries and keep people in a safe environment. Thank you, Chief. I'm concerned to my colleagues now. Commissioner Feldman, did you have questions? Thank you, Mr. Chairman. I want to thank all the witnesses for joining us today, especially those of you who shared experiences involving personal loss. Your testimonies were very touching and helpful to the commission. As I said in the previous panel, I appreciate your perspectives and the commission's going to continue to work through this process on this proposed rule, Mr. Chairman. I don't have any questions. So I would yield back the remainder of my time. Thank you, Commissioner Tomka. Thank you. Mr. Scar question for you in our cost benefit analysis in our proposed rule, the largest share of the costs come from increased need for maintenance of these products over time. I think we forgot the flip side of that coin, that the rule is a job creator. You know, maintenance workers are obviously a vital part of the American economy. Should we work as we move forward in this rule to quantify how many new maintenance jobs this rule would create? How much business this would drive for them and how that would benefit the economy. Thank you, Commissioner for the question. I think I'd have to think about that a little bit before I give you a yes, a certain yes. You should calculate that. Let me provide a different response. However, that may get to this. I would think a benefit of a rule like this would be additional maintenance on boilers and equipment and furnaces equipment that may catch other problems and prevent health risk and make sure that the devices are properly functioning down the road, which will have health benefits and I would assume energy efficiency benefits to ensure that these appliances are working well. I don't understand the commission's, you know, exact charge enough to say that the job creation and economic benefits would be to make that recommendation to you, but certainly I imagine you would find that there would be positive impact. Appreciate that. And as you continue to think through that issue, let us know what you come up with as well. Chief Browning, one of the ask you a question, you know, CO poisoning from gas furnaces and boilers. It's been alluded to multiple times today, but it can kill entire families in one incident. And that is reflected in our data and when people have talked about here today. Have you or your colleagues ever come on a scene like that? And is there anything that you can share about that experience? Certainly, you know, I referred to in my testimony, Hurricane Laura, which was devastated Southwest Louisiana. We had nine CO deaths to Hurricane Laura, though they were contributed to the operation of generators. In one case, we had four members of one family that died. So the CO poisoning and the CO deaths are certainly prevalent. And of course, you know, we see it, you know, more in the winter times when those type of mechanical units are more in operation. And it's just, we never knew that the crazy thing was we never really knew what the answers were. And we've embraced, you know, single station detection, which in my mind is an aftermarket way of monitoring. It's a good way to retrofit to some point, but I'm just excited about the discussions of moving forward and creating an automatic means of detection that works in unison with those mechanical units. Very similar to other type of safety that we have in our codes of standards that we work hard every day to do. You know, and when we work on a rule like this, you know, we, we definitely try to measure all the good that it'll do and quantify that and we try to reflect the benefits of saving lives. And I think we should reflect that saving entire groups of people entire families like like you were talking about losing the hurricane is something different and avoiding those types of tragedies should be given additional weight. It got me thinking about the movie Saving Private Ryan, which was based on true events, four brothers go to war, three are killed, and the Department of War Spared no expense bringing that fourth son home. Because if they lost him, if he died, that'd be a tragedy in itself. But they recognize that losing entire generation of that family would have been something immeasurably more harmful. And so Chief Browning, I'll just ask, I mean, do you think we should take a similar position? Should we place increased value on avoiding those types of tragedies? Sure. I mean, every lab matters. Everybody on this on this call in that meeting know that every lab matters, but certainly the these incidences have more multiple effects. And, you know, it's the same concept that we have with smoke alarms in residential properties. Just just yesterday, we had two children and a father that died in a home fire in the Baton Rouge area. And we don't believe there was any detection. There certainly wasn't any residential sprinklers in those homes. So these are the layers of protection that detect and provide a safe, a safe egress path for people, whether it be from a CO emergency or very similar, a fire that produces CO is very, very important. So yeah, you know, and look, the optics of safety are very hard. If you don't understand, if you've never seen, you know, people who have died, people who have suffered, you know, from the effects specifically CO, but many other things, you know, you have to have many different means to protect people. There is no one way. Some people think, well, you know, if we eliminate ARC, if we put the ARC fault, you know, receptacles in and eliminate, we limit electrical fires, we no longer have a home problem no more. There are hundreds of reasons why home fires are hundreds of reasons why CO can enter someone's home. So again, I keep saying the layer of protection I implore you to look at this as several different ways to protect. Don't just pick one way. I appreciate that. Thank you, Chief. Miss Randall, thank you for sharing your story. And I'm glad to hear you hope your mom get to the bottom of things and that she's all right. She must be grateful to have your help. Your story got me thinking. You said that she's that she's hearing impaired and has special alarms to shake her bed and to strobe. But it got me thinking about people who might be mobility impaired and even people recovering from surgery and for them getting an alert after there's already a problem still might not save them. And so when when this agency does its cost benefit analysis we're going to do in our in our rules, we have to think about things that are difficult to quantify like providing the dignity of equal safety to people in all situations. Do you think that's the kind of thing that we ought to consider here? We always think that we should consider the most high risk in this of course. One of the things we know is that technology is advancing. Today I learned that the new bed shaker and strobe alarms will have CO alarms in them, because that was formally avoid that occurred, but that technology is coming. So we see that because it has to be a constant state of evolution to provide resources to the most at risk. So I would tell you that technology is advancing and we have to be open to that. But there is a huge need for both the mobility impaired but as you see the industry is already stepping in to do good work to help with that. So yes, I think that should be right now. I think it's kind of like the starfish making this move will help so many when we look at the different as she Brown and said the layers of protection or what we advocate for having an engineering fix that stops it. Having a CO alarm that if that doesn't function or if you had a heating unit that did not have that on it. If we move forward, you know, those are the layers we want to see. So thank you for that consideration and caring about those folks. Well, thank you. And thank you for sharing your story. Mr Johnson. Thank you as well for sharing your story and for sharing Lauren's story. She lived an inspiring life cut far too short. And I think I'd be very proud of my children develop anything near her levels of empathy and fearlessness that that you've described. It's wondering wonderful that you're honoring her as well in such a meaningful way through the Lauren project. And Miss Johnson, I wanted to ask you this. You heard the testimony of industry today. You heard that they don't want to pay a few extra dollars to save lives. You heard them say that saving 27 people a year provides little additional benefit in their opinion. And I wanted to give you the opportunity to respond. Thank you. I would greatly appreciate that. Well, first of all, so we're talking about 27 deaths a year, which honestly sounds quite low to me, but let's use that. At the same time, let's talk about the thousands of people who make visits to emergency room every year. Fairly reliable number is 50,000 because of CO poisoning. Now is all that because of boilers and furnaces? No, it's not. It's not what percentage of it is. I suspect it's substantial. So it's not just those 27 lives, but it's all the others that are injured by carbon monoxide during the course of the year, some of whom will have life long injuries because of it. Well, let's go back and look about one of those. Her name is Lauren. Lauren was asked by her teacher of the class was asked to do something for someone else and come back in a month and record. Lauren and two of her friends learned about a woman who had been recently diagnosed with breast cancer. Two young children father had just lost his job. So they decided they do a fundraiser for this family and spent the next three weeks going to every business and concern they could think of to get donations for a silent auction and a benefit dinner. They raised $27,000 back in 2002. For that family. Lauren and her friends mattered. Lauren learned a lesson, a life lesson in that moment that she didn't have to wait to make a difference. And she was like a piece of dynamite lit on fire. She went off to college. She was she was an exceptional student. But when I would talk to her double major at University of Portland prestigious university with very high standards. She'd never talk about her grades. She didn't honestly care. What she would talk about is what she was doing outside of class. Like the battered woman shelter where was she went twice a month to play with children so the moms could have some time on their own. Lauren mattered to those mothers are the homeless shelter where she worked during her senior year. The same community that her grandmother had worked in for over 20 years, trying to provide services to homeless people in the Portland area. To that organization Lauren mattered. Going back to the university the last two years that she was there she ran the clothing drive at the end of each semester that invited students faculty staff to donate unused clothing. She would stay two or three days longer after every after all the other students have left and gone home to sort through that closing and deliver it to organizations in the Portland area to those organizations. Lauren mattered. American Cancer Society she recruited she was working for the volunteer organization at the school. She would pay fellow students to walk in the walk for the cure, which raised money for the American Cancer Society to the American Cancer Society. Lauren mattered. She also helped recruit volunteers for the Oregon State annual beach cleanup, in which volunteers would go out to the beach and clean up litter to the people of Oregon, Lauren mattered. Back to Colorado. And those hearings that I told you about in front of the legislature. When I testified the last thing I said to them was I've got a picture here of Lauren and I'm sorry I don't have one here to show you today. A beautiful, sedentary, intelligent, gifted woman with incredible leadership skills. Said here's a picture of this vivacious woman. Over in this hand I have something else. It's her ashes. Her remains. Do you know what the difference is between this woman and her remains. Her remains are still. That's the difference. A carbon monoxide alarm in that home in that apartment would have saved her life but there was no law. Now even with the laws, lives are still lost. Because not everyone follows the laws it turns out. And people still die children. And so I would say to the manufacturers, you'd get a hell of a lot more support and people would actually buy your product. If you came to them saying by the way we've got the newest technology. If, if a furnace vent starts to or a boiler starts to produce more CO than is safe. It's going to automatically turn off. Wow, what a concept. And lives will be saved and injuries prevented. So yes, I speak in support of changes in the law and the regulation. They've had 20 years it sounds like to do it on their own. I guess they need some help. I'd appreciate it. If your commission could do that. Thank you. Thank you, Mr Johnson. Thank you, Mr Trump or time. Commissioner Boyle. Thank you, Mr chair and thank you to all the witnesses for your powerful testimony. I don't have questions, but I would also say to you, Mr Johnson, thank you for sharing your story. You've turned your pain into action to help others. And that makes a difference and I appreciate that very much. I don't have further questions. Thank you again to everybody who was on the second panel at this point in time. Can I interject quick. I'm so sorry. I'm on a list. Yes, miss. We'll thank we're actually going to add you to the third panel. So let us. Let me introduce the third panel and you can start the panel. We're going to have a third panel on, which is also appearing remotely. We'll start with miss Viltong, but then we're also going to have Kimberly. Pashkowski who is with the Bureau of fire services. John Kane, the national fallen firefighters foundation. Larry Gill with IPEX, Neil zipser with Knox company. Carl. Sotowski. And Kevin Selmaier, who is the state fire marshal of Michigan and a member of the board on the national carbon oxide awareness. Association. Thank you all for being here. And we are going to start with this. Thank you. Sorry, I was having some troubles with my connection there, but so my name is on a list will bang. I'm on behalf of pressure testing solutions. We are a pre revenue company that's been pitching to LP companies for five years. On ways that we can enhance and improve current voluntary standards that can target preventative measures. Measures at the interruption of service standards specifically. To help with incomplete combustion issues and underlying issues that cause CO leakage to. Leak from appliances on behalf of PTSD. I'll see. I speak on behalf of Scott, who has 25 years of experience in the industry. And has also served as a tenured proctor for the Iowa propane gas association. PTS raises concerns about the 1st. Thank you Don and others who have shared stories. I lost my dad in a residential. Fire, but it was related to a truck. So it's kind of unrelated, but it does get me really emotional. In thinking about lives is a little worried about the 18 month delay and implementation. That goes without provisions and we are here to prevent or to propose our solutions to help with preventative measures during this 18 month delay period. Specifically, our concerns related to interruption of service standards. We are aware of current LP industry. Players LP's specifically pencil whipping gas leak checks. There's also lack of communication between necessary industry players like H back and LP companies related to interruption of services. Lack of coordination between regulatory bodies since they're separate. It kind of also provides a bottleneck that allows miscommunication or no communication. And the lack of tech in LP companies specifically probably H back to I can't speak for them. There are things on paper so there's really no proof of compliance for these critical safety measures. We have concerns specifically and related to the interruption of service. Increasing the number of installations on H back increasing maintenance calls in response to CEO shutdown of appliances and concerns related to the CEO shutdown reply of the appliance. That's being considered an interruption of service as well as all the installations and maintenance. And then specifically we are worried about the increase of fire department and EMS services. But hearing butch speak on behalf of promoting this actually almost makes me want to not bring this up but we. Remember the fire department resources are already overwhelmed and that because we're not addressing current issues that could prevent the CEO leakage. That it may cause CEO fire departments to have to respond to the CEO alarms without resolution. And then the increased interruption of service response calls on LP companies currently and their inability to follow current safety measures. So PTS we think of that a targeted solution like holistic and industry wide safety processes checks and communications are what needed or what's needed sorry I'm really nervous. To truly eliminate and reduce the failure modes and industry latent errors that lead to CEO production and leakage into residential homes. There are many players and factors that can lead to incomplete combustion that where you can't really point fingers at. Well you can in some cases you really can. But what's needed is. There's many players and factors that can lead to incomplete combustion by multiple industry players responsible for servicing and maintenance scene of in home gas appliances and the suppliers of gas to the LP tanks. Of residential homes safety communications and records regarding residential home conditions like the appliance and tank health and safety concerns should be kept record of just as a doctor needs the health history and exam before diagnosing and operating on a human in home maintenance and service personnel of gas and gas appliances when even unrelated industry players are performing maintenance and service and residential homes who that are presenting the safety risks. Could also be affected. So PTS's goal and we already have everything set up we've actually spent quite a bit of money and insurance premiums with LP companies that have said they were going to sign and they haven't yet. So our goal is to kind of come in as and put in some of these preventative measures on top of in in being support of the CEO sensor and just trying to help really target the failure modes and improve safety communications proof of compliance and also valuable intermediary data to the CPSC I have my masters in health care administration and I'm very good at looking at systems and using systems thinking and I identify many concerns of being able to evaluate the or manage the many things that will go down and I think PTS is data on top of what has been proposed here would be valuable to improving and increasing the number of lives that are saved. So that's all I have. Thank you, Mr. Fang. I believe Pashkowsky is not ready yet. So I'm going to go to Mr. Cain. Good afternoon. Can you hear me? Yes, we can. I appreciate the opportunity to speak to you today on behalf of the National Fallen Firefighters Foundation. My name is John Cain. I'm a retired deputy chief from Syracuse, New York. I retired from Syracuse Fire Department in 2022. In my final role, I oversaw the special operations and EMS divisions. I serve on two NFPA committees that are tasked with setting national standards for firefighter and fire officer training. And I've also been involved with the development of two fire service publications through IFSTA. Today, I'm the deputy coordinator of education and outreach for the National Fallen Firefighters. And one major part of the mission of the foundation is to reduce preventable firefighter death and injury, which is why I'm speaking today. The NEEF has partnered with the National Carbon Monoxide Awareness Association to develop training programs for firefighters to raise awareness of the acute and long-term effects of CO exposure, including the associated cardiac and neurological symptoms. We believe this partnership will help improve the health, safety, and well-being of firefighters in this country. Repeated exposures to CO at emergency scenes is a major concern in the fire service. And the reason all firefighters should wear SCBA when investigating any CO alarm or potential leak. We've heard a lot today about CO alarms, and they are important. Unfortunately, the reality is that many private dwellings do not have CO alarms. In fact, only about 14% of homes in the United States have properly functioning CO alarms. And unfortunately, some fire departments lack substantial CO metering equipment due to budgetary constraints or other issues. Malfunctioning gas furnaces or boilers can harm or kill civilians and firefighters alike. According to data from the CDC, each year over 400 Americans die from unintentional CO poisoning not linked to house fires. Also every year, more than 100,000 Americans visit an emergency room for CO-related issues, and of those, about 14,000 are hospitalized. Fire departments in this country respond to approximately 80,000 carbon monoxide incidents annually. And those numbers do not include the 91,000 CO alarm malfunctions or the 70,000 unintentional CO alarms. So in addition to the obvious health and safety concerns, this significant number of alarms tax the already limited resources of many fire departments. In December of 2021, a family of seven, including three young children, were found dead inside a Northwest Minnesota home as a result of accidental CO poisoning caused by malfunctioning home heating equipment. Another incident occurred in Buffalo, New York, not far from me, just three months ago. A malfunctioning furnace in an ice hockey rink filled the building with carbon oxide. Over 90 people required medical attention. When the local utility company took readings of the facility, they found CO levels of approximately 4,000 parts per million. An automatic shut off or modulation device could have prevented this incident. And while that did not occur in a residential occupancy, I think it underscores the danger of malfunctioning heating equipment. And just earlier this month, the Philadelphia family of three was found dead inside their home due to CO poisoning from malfunctioning home heating equipment. Several years ago, right in my own backyard, Syracuse firefighters were sent to an apartment building for an alarm activation. Within just a few minutes of arriving on scene, three firefighters were rendered unconscious by high CO levels in the building. All three had to be extracted from the building unconscious by other crews on scene and ended up in hyperbaric chambers later that evening. One individual actually remained hospitalized for nearly a week. All three are lucky to be alive today. So the technology already exists. That's obviously why we're talking today to make furnaces and boilers safer. CO is very dangerous and we have the ability to prevent equipment malfunction from turning into a tragedy. The national fallen firefighters fully supports this proposed safety standard and ask that you even go further by first lowering the shutdown or modulation threshold to account for established acceptable carboxy hemoglobin levels from the CDC of 2%. And second, adding requirements to prevent tampering with or deactivation of CO monitoring devices. And third, extending the time period before restart during a sensor failure event and perhaps adding in a temperature gauge to manage the reset time. I would like to end with a quote from Dr. Joan Dolanak, who's actually the chief burn surgeon at upstate medical university here in Syracuse, New York. She deals with CO poison patients frequently, probably on a daily basis. And what she said was that once a severely CO poison patient makes their way to us in the hospital, it may be too late. We may be able to restore their body, but not their mind. So while they may get discharged from the hospital, they may spend the rest of their lives in some type of assisted living facility. So thank you all for your consideration and attention in mitigating this very important health and safety risk for our firefighters and the citizens they serve. Thank you, Mr. Kane. We're going to turn back to Ms. Pashkowski. Are you available? I am. Thank you. Kimberly Pashkowski, the community risk reduction chief for the state of Michigan under the state fire marshals office. I spent 28 years as a firefighter and have come across multiple situations with carbon monoxide. And then, and since in the last 5 years have worked under the state fire marshals office as a community risk reduction chief. Executing community risk reduction across the state teaching people how to utilize community partnerships. Today, I've been asked to share a community risk reduction, what that is, and then also to specific stories in my career. And they're actually recent ones and personal ones. The community risk reduction is. Pretty much a topic that everybody should consider it is it falls in every category. If you consider even in your family members, if you consider carbon monoxide poisoning. It's not just your home. It's every family member in your home. And so that is community risk reduction. It's your neighbors. It's your any community partner people that you go to church with. It's their homes. And if you. If you've not experienced, I hope you don't ever experience it, but if you come across a seal fatality, I hope it's not in your inner circle, because that's where that community risk reduction affects people. I'm from Michigan in Kent County just in December of 22, 2 days or 3 days before Christmas. We had a home that had a husband wife and a son. The husband wife were in their 80s and the son was in their 60s. He actually moved in with his parents to take care of his parents and they had a carbon monoxide poisoning and everyone died on the 22nd of December. What's more prevalent on that story on my side was that may not have been my fire department. However. It was tragic for the state of Michigan and then 2 days later, I received a phone call from a neighboring fire department stating that there was a specific person, a man in those 50s that was requesting carbon monoxide detectors. But he was in a rental unit and we normally do not provide alarms for rental units that's required by the landlords to provide that. However, once we got more of the story and learned more from the 50 year old. That was his entire family in Alpine township that died. So he just lost his mother is lost his father and lost his brother and he's the only family member surviving. At all, and so he was frantic and looking for carbon monoxide detectors. We said, yes to the rental said, yeah, absolutely give him as many as he needs. I want him to feel safe tonight when he is in his home sleeping. And so we provided that the 2nd story is also very recent as well. This was in November 23, 23. And this one's actually really close to me as I've been a firefighter for 28 years on my friends and family. I've tried to take care of all of them with smoke alarms and CO detectors. And my girlfriend moved into an older home. She reached out to me right away. I put in CO detectors in her home. And then 2 days later, they have an old home that they were going to renovate and they have a Michigan basement. If you don't know on a Michigan basement, it is. It's not a livable basement concrete. Sometimes after so, you don't necessarily go down there often that morning they're getting ready for work in school. They had, they have a 17 year old daughter and the cats came upstairs from the Michigan basement. And their paw prints were black suit and, but it was questioning, but they didn't have time. So they all went to school and work when the 17 year old daughter came back home. All the CO detectors were going off in the home. And she called her mother and her mother said, listen, Kimberly told us if those go off, just get out of the house. Don't investigate it. Get out of the home and then call 911. So that's what they did. And the fire department came read over 300 parts per million in the home and said there was, if they would have all came back in, they would have not survived that night in their home. So that is, she called me crying and said, Kimberly just saved my whole family. You saved my whole family's live. And as a firefighter for 28 years, it's nice to have a good token to put in that mental health wellness box that there was an actual save, and especially someone that I personally have known my whole life. So, CO detectors are extremely important in Michigan since 2019. We've installed over 14,814 co detectors. And as of the reporting ones, because only fire departments that fill out my form, let me know, but we've had already 75 saves CO saves in the state of Michigan from those 14,000 co detectors. So it's a need and it's not going away and that my girlfriend had no clue that CO poisoning was happening in her home. Thank you. Thank you, Miss Peshkowski. Turning to Mr. Gill now. Good morning, everybody. Morning, we can hear you. Please. Thank you. My name is Larry Gill. I'm manager codes and standards at IPEX USA LLC. IPEX is a plastic pipe and fittings manufacturer. We manufacture pipe and fittings for various applications, including venting of flue gases. I am also a licensed engineer and as such have a responsibility to protect the public. And I decided to make a presentation today for two reasons. First, based on what I've heard in preparation for the meeting and in the testimony, I support the use of CO detectors as part of the appliance. Second, I wanted to advise the committee and the attendees of an additional safety option for gas appliances. And that option is a certified venting system. Full disclosure, of course, I work for IPEX. It was a manufacturer of flue gas venting pipe and fittings. But I did notice that in some of the background information, there was the missing information or information missing on the venting of gas appliances. I'm aware of the valuable time and the meeting attendees. And I also understand that the topic at hand is CO detectors, but certainly the overriding concern is safety. So, without a mind, I'll just provide a brief background on venting of appliances in the United States and Canada. So, the CPSC report discusses flue gas venting in several seconds. It makes note of Japan and Europe. And we've heard a bit of testimony on that today. But it's not covering very well what the regulations are in Canada and the United States for flue gas venting products. So, I'm going to cover a little bit of that now. Canada uses the same appliances as the US. However, the venting requirements in Canada are quite different. Canada experienced vent failures prior to 2007. Affairs in Canada included various plumbing products which were being used for venting of appliances, including ABS, drain, waste and vent pipe and fittings. The failures resulted in a new Canadian code requirement stating that only certified flue gas venting products are permitted to be installed on gas-fired appliances. And this law became effective January the 1st, 2007 through the National Gas Code in Canada's VSA B149.1, which mandated the following in Clause 8.9.6, which says vents constructed using plastic piping shall be certified to ULCS 636. In the United States, UL1738 is a standard specifically for flue gas venting products. UL636 and UL1738 are similar, but they are not exactly the same. Both standards do, however, contain over 40 tests specific for flue gas vent products. UL1738 and UL636 also mandate that the manufacturer provide an installation manual, and those standards also mandate that a system of pipe fittings and cements be provided from one manufacturer. These requirements provide for a system designed specifically for venting of appliances. The current United States FPA, IAPO and ICC codes permit the use of 1738 products, but they also permit drain waste and vent and water pipe products selected by the appliance manufacturer. UL1738 venting products are mandated in some jurisdictions, such as Massachusetts, but in most jurisdictions drain waste vent or DWV plumbing products are used for venting of appliances. Examples of permitted product standards would be ASTM D266-5 for PVC, ASTM D2846 for CPVC, as well as ASTM D266-1 for ABS. All of these products are for plumbing products only. There is a note contained in each of these standards that reads as follows. Note two, this specification does not include requirements for pipe fittings intended to be used for venting of combustion gases. Clearly these plumbing DWV products are not intended to be used to vent combustion gases. And it does not permit them to be used, however they are permitted in the United States. This is the information I wanted to provide today, and I'd like to thank you for your time. Thank you, Mr. Gill. I'm going to turn now to Mr. Zipser. Good afternoon. I'm Neil Zipser, Industry Affairs Manager of the Knox Company. And today I'm speaking on behalf of the National Carbon Oxide Awareness Association, which I'm a board member of. Before joining Knox, I was the Industry Affairs Manager of KIDA for seven years. KIDA is the largest manufacturer of smoke and carbon oxide alarms in the U.S. Part of my job there was to educate fire departments and consumers about the dangers of fire and carbon oxide. When it comes to CO alarms, manufacturers develop the alarms based on UL standards. The current UL standards require CO alarms to alert at 70 parts per million between one and four hours. So basically the alarms go off when there's a catastrophic amount of CO in the air. This does nothing to prevent injuries from lower level CO poisoning. Another issue is the glut of outdated or expired alarms. Due to sensor technology, smoke alarms and CO alarms typically have different life cycles. Smoke alarms are recommended to be replaced every 10 years, but CO alarms can be as short as five years depending on the manufacturer and the year they were built. So there's a lot of confusion out there. CO alarms are also required to have end-of-life alerts, but again, most consumers do not know it when they hear an end-of-life beep. We all know that people do not keep the instructions or owner's manuals once they put up an alarm. Speaking of beeps, a 2021 Qualtrics survey revealed that most consumers do not understand what beeps mean coming from the alarm. Three beeps mean the smoke alarm is going off. Four beeps would mean the dangerous level of COs in the air. Again, most people do not understand that. When presented with an audible CO alarm beep in this survey, only 34% of Spanish-speaking respondents and only 47% of English-speaking respondents were able to identify the beep emitted from a CO alarm. Most respondents were also unable to distinguish the difference between the beeps from a CO alarm, smoke alarm, or microwave oven. And the lack of understanding of the beeps is critical with all the noises being heard today in the home from appliances like microwaves to the alerts coming from your phones and smart devices. We also know that most consumers rarely change the batteries in their smoke and CO alarms, typically the low battery level beep will result in the homeowner taking down the alarm and disabling it. So a CO alarm by itself that complies with the current UL standards is not the complete answer. Equipping furnaces and boilers with shut-off devices takes the guesswork and human factor out of this critical issue. It's such a simple solution to one of the major causes of CO poisoning. Manufacturers sell shut-off devices at a layer of protection for consumers, first responders, as well as trade professionals alike. Furnaces and boilers will perform better with improved energy efficiency with the CO monitoring feature as well. The CPSC should consider expanding rulemaking to include all CO producing, to include all CO producing consumer appliances. And one final point I'd like to make another issue regarding CO incidents is that they are grossly under reported, which is a problem because we severely underestimate the burden of society. There are many reasons why CO is under reported as well, one being that once a low level CO poisoning victim leaves their home and is in fresh air for a while, the symptoms calmly go away. This results in people mistakenly believing they are no longer sick or misdiagnosis from a medical professional. Good reliable data does not currently exist, but we do know that acute and specifically chronic CO poisonings are much worse than we believe. I want to thank you for your time and thank you to the CPSC for everything you do. Thank you. Thank you, Mr. Zipzer. Turn now to Mr. Excuse me. Suchosky. You got it right the first time. You did it. Thanks for bearing with me. Please begin. No problem. Thank you for having me. I would first like to say I've been in the gas appliance industry for 60 years working for the testing agencies. And as a consultant to the manufacturers and as an expert witness going out into the field and looking at carbon monoxide accidents and other types of accidents involving gas appliances or their installation. So I've been doing this, as I said, for 60 years. I also sit on the committees that write the standards for most of the major gas appliances. Plus I sit on what's called the parent committee. I would like to offer this possible approach to what you've been looking for. The suggestion offered below is an optional approach that looks at ambient CO, but addresses the CPSC's concerns about current standalone ambient monitoring CO devices. I believe that if the CPSC proceeds with the current CPSC a proposal. There should be or could be an equally safe alternate approach that the gas appliance manufacturers could take that would provide the same safety for the consumer. As you're probably aware, the technology mentioned in 16 CFR part 1408 to accomplish the requirements laid out in sections 14 08.3 are not off the shelf items that have been proven in North American appliances, ie CO detectors. The required accuracy of activation does not appear to be available yet, or does anyone have a good grasp on the issues of real life contamination and the life expectancy of the proposed technology. As the gas appliance industry has pointed out over the last few years, they believe that monitoring air quality in the whole structure would sufficiently address your basic concerns to save lives. The conventional ambient CO detectors sold by many companies have proven to be life savers as has been pointed out many times during this meeting. They have proven to be reliable and new versions generally provide a reasonable life expectancy, but CPSC's concerns about the shortcoming of CO detectors is recognized. Failure of the consumer to replace batteries of devices or replace the whole detector when has failed to work due to its life expectancy. A question that I would like to pose is whether the incorporation of an ambient CO sensor would be a viable option for those appliances that heat air for comfort such as forced air furnaces, wall furnaces, floor furnaces. As envisioned, the sensor would be an integral part of the air handling portion of the appliance and would interrupt gas flow when the air stream, not the source, not the flu products but the actual air stream passing over the heat exchanger, exceeds a limit as adopted by the interested parties, i.e., all the participants here. The system could contain circuitry and intelligence that could, one, not permit appliance operation unless the CO detector is operational, be a smart device that prevents someone from attempting to bypass its function, provide for 100% shutdown of the gas appliance, or our appliances with modulating or multiple stage controls allow the product to reduce input for some period of time and continue to monitor the air quality. And if the ambient CO levels continue to climb, shut down the appliance and keep the circulating air system operating, if so equipped with one. Number five, send an audible signal to the occupants and possibly a message to a cell phone if Wi-Fi or Bluetooth equipped. When the ambient CO levels drop below a predetermined level, allow the appliance to restart but continue to signal the occupants. If the CO then climbs to the predetermined threshold again, shut down or go into a time pulse operation of the appliance to cut down on the mass flow of the flu products. Number seven, it may be possible to design smart circuitry that could determine that the appliance has not been called upon to operate for some expected period of time, yet the CO is rising in the ambient air of the home. Therefore something is wrong and is not the appliance in question. The appliance then could be used like a conventional CO detector and send an audible signal and possibly if near a Wi-Fi hub, a message to a cell phone signaling that something is wrong in the house. The obvious disadvantage to the end user is that if the appliance in question is not responsible for the increased CO levels, the user has reduced or no heat in their home. But they do have a warning that something in the house is causing elevated CO levels. Since most ambient air CO detectors now function for close to, I'm going to say 10 years because I've, I heard five years a few minutes ago, but I think that number has increased before needing replacement. This should help address the issue of unknown life expectancy of source, i.e. monitoring the flu products, source CO detectors whose life expectancy will most likely be shortened due to exposure to all the moisture and contaminants in the flu gas products, especially when flu products are mixed with indoor air contaminants. Those flu products are acidic. They will eat things up. This approach would also look at ambient air quality rather than source CO production. Second approach I would like to address as a possibility is to incorporate an ambient air CO monitor in the wall thermostat of each of these heating appliances that each of these heating appliances requires in order to operate. As envisioned, the appliance and the wall thermostat would be a match team and would provide the following features. The special thermostat would be designed as would the appliance circuitry such that the appliance could not function with the amount without the matched or smart circuit thermostat. To eliminate the requirements to run new wiring for the new style thermostat, the new thermostat could communicate over existing wires used for the old and now removed thermostat. Digital communication, if needed, used could flow over existing wire. The CO detector would function, as mentioned in the preceding discussion, plus it can now be used on a boiler. This also has the possibility that CO sensing module in its own package could be installed next to an existing thermostat and send communication down existing wires on their already installed thermostat. Again, if the CO detector was not operational or not installed, the appliance would not operate. This approach may make it possible to retrofit existing appliances should the home be so inclined without the need to route new low voltage wiring in the house. Since both source and ambient CO monitoring address the concerns of the CPSC, I believe the above two approaches would address the concerns of the CPSC. All of the issues of standalone CO detectors are addressed once the CO detector can communicate with the appliance. Possibly if the future, in the future, if the range of Bluetooth products can be expanded and above approach would allow all the household appliances to communicate with each other and with the ambient CO detector to provide extra protection for the end user. I believe that in addition to the requirements proposed for source monitoring by 1408.3 that some form of ambient CO detection with smart circuitry and intelligence should be permitted as an optional approach to the requirements of 1408.3. That's all I have gentlemen. Thank you very much. Mr. Selmaier, are you on and available to. I am on and I am available. All right, I'll turn to you next. Okay, thank you for the opportunity to be here today to provide testimony during this here. I am the kept my name is Kevin Selmaier. I'm the Michigan State Fire Marshal. I am also a member of the National Government Excite Awareness Association Board of Directors. I have been the State Fire Marshal in the state of Michigan for almost 7 years now. And 1 of the things that I continue to see is the State Fire Marshal and in an effort to reduce death across our state from fire and carbon monoxide. Is that fire departments that are encountering carbon monoxide emergencies on a regular basis. Many of these are would be prevented if there was a CO limiting device that was on these heating products so that when they did go into this trouble motor when it was sensed that it would stop the production of the CO. And it also would then, you know, would be a method for the consumer to know that they have a problem with the heating item that is causing the CO emergency. I further believe that this also is something that needs to be looked at by the appliance industry. As a method to by putting this device or this technology that we can almost eliminate carbon monoxide poisoning coming from heating devices. This would be very important. As our fire service is, you know, getting busier and busier across the state of Michigan also with some of the recruiting retention issues that we have with getting firefighters that are available to respond to these incidents. Many of these carbon monoxide calls that fire departments run on could actually be reduced to with the equipment changes that they could be taking care of what some of us would say a 2nd responder that would be the folks who do the maintenance. And the work on heating equipment so that we could fix the problems so that we didn't see the carbon monoxide poisonings. I believe that this device also has the ability to reduce stress and mental health, not only to the consumers, their families, but also the first responders. I can share with you personal accounts of since I've been the state fire marshal of firefighters who have responded to carbon monoxide poisonings that are coming from heating equipment. Where, in some cases, 3 generations have died from carbon monoxide poisoning at these calls. This puts a burden of stress on our first responders that because of the, you know, many times somebody will find somebody who has either succumbed from carbon monoxide poisoning and that's when the 911 call or folks don't feel right and they're reaching out with the 911 call. And they're saying that, hey, we're sick. Don't know the cause don't know why. Fortunately, with the technology we have available to our firefighters when they're arriving with seal monitors and such we're capturing, you know, that it is a CEO event. But I also will share with you that many times responders themselves have been become victim to the carbon monoxide is generated by these devices. I ask that you very much consider that the seal limiting devices are crucial as we move forward with heating equipment. Not only to protect the consumers to protect our families across the country, but also to protect our first responders. Thank you for this opportunity to give testimony. Thank you, Mr. Selmaier. At this point in time we're going to turn to questions from the commission. Yeah, starting. I think I'm having the same troubles as Don. I couldn't hear anything that was said after Kevin was done talking. Correct. Can you hear me now? Yeah. Yes. Yes. Great. Excellent. I'm saying we're moving to questions to the commissioner at this point in time. And so I was going to start with myself and. Chief Browning had talked about layers of protection, the need for layers of protection of which alarms are one of them. But I want to ask Mr. Cain. If you wanted to discuss or comment on the ideas of layers of protection as it applies in terms of these, what we're talking about with purposes and boilers as well. Absolutely. Thank you. Mr. I agree with the chief's assessment that. Should be a multi tiered approach, right? The equipment that we're discussing today is a very, very important. Part of the equation standalone co detectors in private dwellings. It's also extremely important and the problem we're going to in the fire service, especially in. Poverished areas, you know, which a lot of our American cities have very, very high levels of poverty. If the landlord is not compelled to do the right thing, or they choose not to do the right thing, for example, and install co detectors. A lot of these people have to make that decision. Do I go to Home Depot or Lowe's and buy a detector for myself? Or do I spend money on food this week? So that that is a problem. As I mentioned. Only about 16% of private dwellings in this country have functioning. So without the inherent prevention aspect in the heating equipment. A lot of these folks are left with. With a lot of the fatalities that I encountered over the course of my career. Really started out as a status check, right? So a child doesn't show up for school. A parent doesn't show up for work. So people call. The local police or fire department to see if everything's okay. And then I even find an entire family that was rendered unconscious. Or deceased because of malfunctioning heating equipment. You know, overnight that produced a very, very high levels deadly seal levels in the home. You know, and I think. To Mr Johnson's points, I mean, I believe. Mr Johnson's testimony is, is it sums up why we're all here today. Why most of us are here today. Right? I mean, if we can. Implement the equipment we're discussing today and also some, you know, standalone. CO detection requirements in homes. If we can save 1 life. We've made the world a better place, right? And I think that's really the goal of, of almost everybody in this meeting today. Thank you, Mr. Cain, Miss Pashowski or Mr. Selma or really the comment on layers protection as well. I'll go next. You know, we talk about layers protection. And as Mr. Cain brought up, you know, 1 of the things that we start to see in areas that even with just basic carbon monoxide detectors is. Whether or not they are working at the time, whether or not they have batteries and is definitely part of the equation. But, you know, Mr zips are testified earlier when we talk about, you know, 70 parts per million being the threshold where these alarms are going off by that point. You already have high levels of carbon monoxide in there before you get in the alarm. That's where I believe that, you know, by putting this seal limiting detection on the heating appliances itself, we're taking care of it at the root cause. Well, we still want to have a carbon monoxide detector to as a different form of warning. Absolutely. I mean, the more layers of protection that you can have to warn you of something. But fundamentally, I think if we can get this put on the equipment as we move forward, we start to address that. We'll still have other sources of carbon monoxide in the home where we'll still need the detectors. But it's also having our first responders available with the carbon monoxide detection as they're coming in also. So it is a multi-tier approach that definitely all working together. I believe has the ability to save lives and prevent injury to folks from carbon monoxide in the future. Thank you, Mr. Salmeir. At this point in time, I'm going to turn to my colleagues. Commissioner Feldman, do you have questions? Thank you, Mr. Chairman. I'll be brief and just say a word of thank you to all of us joining us today for sharing your perspectives and testimonies on the proposed rule. To those witnesses from the fire services, I wanted to acknowledge and offer word of gratitude for your commitment to our shared safety mission. Mr. Chairman, I also want to thank you and your staff in particular and our staff from OGC and OCM for their work putting together today's public hearing, which was no small task. Mr. Chairman, I yield back the balance of my time. Commissioner Stromka. Thank you. So we've got three firefighters on our panel and I want to see if we can learn from your expertise here and your experience. And one of the things that I think would be helpful and Deputy Chief Kane, let me start by asking you, so you served 21 years as a firefighter in Syracuse. Can you attempt to explain to us who have never been on one of these scenes what it's like to come across as a firefighter to come across the victims of CO poisoning? I mean, it's horrible. You know, speaking for Syracuse, Syracuse, especially this time of year probably responds to an average of five or six CO type alarms per day. Right. The vast majority of those are just detector activations where the amount of CO in the home is not lethal. But again, we do have a few of those. We probably average one or so a year where. Again, it comes in as a status check. We arrive, you know, in the morning. People are wondering why somebody in show up for school or for work. You'll find in 1 instance, we found a deceased mother and 3 children. This was a single mom who is trying to do the right thing didn't have a lot of money. Did not have any type of CO detection in the home. Heating equipment malfunction and there was obviously no. Built in protection there as well and you know. These are very, very difficult calls to respond to and I think they certainly make a. Very significant impact on the 1st responders who have to arrive and see this, you know, we're all. In emergency services, we're all fixers, right? We want to show up and make things better. But in this situation, we're strictly reactive. We're called to a home because something's wrong. And it's been hours that these folks have been deceased and that there's nothing that we can do. And I think the psychological impact on 1st responders, whether it's police, fire, is fairly profound. You know, and I think this is we can do better, right? And I keep coming back to Mr. Johnson's testimony and, you know, if we can impact. 1 life, right? We've done our jobs. And again, the psychological damage, the emotional baggage that will these 1st responders will carry for the rest of their lives. It's very significant. So there's a lot of people that are impacted by events like this. And it's, it's not unique to Syracuse. It's every fire department everywhere. You know, we all wish we could have solved this problem before as a problem. And I think that's probably the best way I can describe it. Well, thank you, deputy chief. I mean, it's a good reminder that, you know, you do this, you're a professional, you know, you might encounter these types of things, but nobody. Checks that kind of kind of baggage at the door when they go home and clock out, you take that home with you. Miss Peshkowski, I mean, I'll ask you a similar question. You have 28 years as a firefighter. What can you tell us anything to add about firefighters coming on to the scene of the victims of CO poisoning? Well, Mr. Cain really summarized it really well. And, you know, the mental aspect of. Coming to a scene where you, there's nothing that you can that can be done for something that is 100% preventable. Is very heartbreaking. And then, especially when you have families generations of families or children. You know, to when you approach to a scene. It's an investigation process. So you're, you kind of have an idea of what you're coming across. But not always. And so really, sometimes it's, I haven't heard from Mr. and Mrs. Smith for a few days or, you know, 12 hours. And so you're not, you get the police to help you through the door. You're walking through the door and remember this home is filled with carbon monoxide. So, but you're unaware of that. Remember carbon monoxide there is. You can't see it. You can't smell it. You can't feel it. So, as you're walking through, you are yourself being exposed to it. As you're trying to maneuver and figure out and investigate what is happening when you come across the bodies. Evaluate that they are no longer responsive and they have been gone for some time. That's usually our first response and then we immediately get out of the home to make our next decisions. And again, when you come across families, children, several generations over something that is so preventable. It's heartbreaking. And then you go back to your families, you go back to your home. I am a mother of 5 children and you have those conversations and you. It's hard not to come back and bring it to your family. And when I say it, bring it back to your family that I guarantee you that night after that call. I went to my dinner table with my family and we tested co detectors as a family just to have that conversation again. And hey, tell your friends and they all think I'm crazy. But, you know, all my mom's the prevention lady, but it's real. We see it all the time. And now as I do it as a state, I'm seeing higher levels of it. It's not just in my community, but it's in the entire state and we're seeing multiple events fatalities and saves. We're just grateful when we see the saves and the mental health aspect is imperative. Thank you. I mean, thank you for sharing that. And it's very evident. You talked about yourself as being a problem solver and so many firefighters being problem solvers. So where you were able to intervene with your friend and prevent a tragedy there, how much that meant. But on the other end of the ledger, how many of these kind of situations we can't help in. And it's really important to think about. So thank you for sharing that with us. Marshall Selmaier, I wanted to ask you a similar question as well. And your dad was a firefighter. You're a firefighter. Your son's a firefighter. So thank you for your family's tradition of service. And I'll just ask you that same thing. Can you add any insights to what a firefighter experiences coming on to see all poisoning victims. Yeah, absolutely. I was reflecting here. You're asking yours of service. Last week was 40 years ago that I raised my hand to join the United States Air Force and begin my firefighting career. Congratulations and thank you. Thank you. You know, and being retrospective, you know, some of the worst calls that I've run out and I was, I was a firefighter all the way up through deputy chief and the Grand Rapids fire department second largest city in Michigan. And, you know, going to these events and as Kimberly talks about coming in and, and, you know, finding people unconscious and then the worst days finding them deceased, right, that you couldn't, you couldn't do anything about this. I will share this and I'll reflect this had a fire department in just outside of Detroit. Back in the fall. A couple had reached retirement age they went on their dream trip to Europe and came home. And on their first night that they were home. The carbon monoxide detector was going off. It was, you know, in Michigan, we're a, we're a cold weather state. And predominantly, our citizens heat with either natural gas or propane so fossil fuels, right. I mean, we're producing carbon monoxide if there's a problem with that, with that device. The husband actually got out of bed went down to the basement and said, well, it's got to be a CEO, or it's got to be the co detectors malfunctioning. Actually, we know from the first responders took the batteries out of it and actually went back to bed. Only to find out that their family, you know, checks in on them the next day, the fire department arrives and I have talked with folks from that fire department. The, you know, every time we go to a then there's something that firefighters and we take on a little bit of stress. I call it we put a rock in a backpack and, you know, over 40 years you accumulate a lot of these things that you see in that rock goes in that backpack and, and hopefully we're getting the mental health for our members so that I can unload some of those rocks to lighten the load a little bit as we go along. But this is clearly, you know, a sad event and I was talking with Sharon McNabb, who's president carbon dioxide awareness association. This is so preventable. This is folks living in nice middle income home in the Detroit area. They've been on the really their trip of their lifetime they come home. And they die because the heating device in their home is many large amounts of concentrations of CEO the alarm actually does its job and it goes to show you that when you're being poisoned by CEO. It causes you to be confused. You aren't making good decisions and the bad decision that gentleman made that day was to take the batteries out and then go back to bed thinking that we'll deal with that in the morning. There's a lot of families that don't get to deal with anything more than death the next morning after a CEO event, and this is a preventable event. And that's where I ask again for the for the mental health of our members are 25,000 firefighters across the state of Michigan are 1.3 million across the United States. If we get this equipment put in place. It's another layer of protection, and hopefully my son who's, you know, 22 years old on the job that he doesn't. How about this, if he never had to go to one of these events and see what Kimberly and Mr. All right with that as good as a dad as good as the state fire marshal and that's good as a, you know, a leader in the fire service. These are preventable. Accidents that are occurring from these heat from boilers inferences that are preventable with technology layered in with manufacturing that we could reduce these deaths. Well, why I can only hope that coming here and doing the midst of sharing your story, sharing your experiences with us and having us hear them as we solve this problem helps lighten the load of those backpacks full of rocks going forward. So thank you for doing it. You're welcome and thank you. Commissioner ball. Thank you, Mr. Chair. I also want to thank the witnesses and for all the witnesses today. It's an important opportunity for stakeholders to provide their input into our regulatory process. And so I thank everyone for participating in that. It's an important part of the process. I don't have any other questions. Thank you. Thank you. Sure. We had a crest for another brief, another round. Sure. Feldman. Did you have anything? I do not. You're sure. Trump. Sure. Just just very briefly to follow up on on that discussion with our three firefighters on the panel. You know, I mentioned earlier that when we work on a rule, we try to measure all the good that it'll do. And we try to reflect the benefits of saving lives. And one of the things that you talked about is something else that that we might want to try to quantify and try to make sure we take into account here. Should we also assign value as we think through this rulemaking of the benefit of firefighters not having to encounter these kind of scenes, not having to come on entire families who who have died from one of these mishaps. Should we assign value to avoiding that trauma for our firefighters and first responders. And I'll start with Mr. Cain and then miss Peshkosky and. Thank you, sir. Yeah, I mean, there's a very. It's hard, but specific value on that other than to say. The resources that are taxed by fire departments throughout the United States is it's pretty profound 80,000 calls for service per year. For seal related incidents and as somebody else that alluded to. This type of technology if implemented can. Turn a potential crisis into nothing more than a routine visit from the utility company or a furnace or boiler repair man. So, in addition to, you know, taxing the precious resources that a lot of fire departments are struggling, especially the volunteer side. With manpower, you know, they have limited ability to respond to alarms. And this is kind of piling on as I mentioned, some departments lack proper metering equipment so they're not necessarily well equipped to deal with these. The psychological impact, which I think is equally as important, if not more so. As fire marshal alluded to. I really like that analogy, you know, the bag full of rocks. I mean, if we can prevent just 1 or 2 of these additional rocks being added to somebody's load. That's another win. I mean, firefighters, police officers, paramedics are all fixers and they do care about the communities that they serve. So when you are put into a situation where a tragedy has occurred over something as simple as a relatively inexpensive device or multiple layers of prevention. This is something that they will carry with them for the rest of their life knowing that this could have been prevented. If they had only been called sooner, they could have done something about it. But there is absolutely nothing worse than arriving to a scene where, again, parents and children. Especially school age children have passed away due to CO poisoning. You know, another really important statistic is that the vast majority of CO poisoning does occur in the home. 64%, something like that. And children are the hardest hit, you know, and no one wants to see that in any shape or form. So, yeah, I think this is creating a significant burden on our firefighters psychologically. And it's creating a very significant burden on fire departments that are struggling to keep up with increasing call volume and everything else. And not to say that we don't go when we're called. But again, if we can stop short of a tragedy, right? If we can make it known that there's a CO emergency in this residence before it costs someone their lives. I mean, that that's that's a win in my book. Thank you, Deputy Chief, Miss Peshkowski. Yes, I'd like to give a community risk assessment on this. So, I'm not sure if everyone understands the fire service and the aspect that. 75% of firefighters are volunteers. So if you think of bigger cities like Detroit and Grand Rapids, and I'm just speaking of Michigan ones. They are career full time firefighters and it's their job. They sign up for, they get paid for it. If you think about across the country, 75% of our fire fighters are actually volunteer. So that means really every one of you on the panel could be a firefighter in your community. And so you work a full time job and you have a pager and that pager goes up when you're sitting at the dinner table with your family. And you go to a CO, you know, an investigation, a CO call, and you get to your fire. You leave your dinner table with your family continuing to eat. You go to the fire station, you get into the engine, you go to the house and you come across a CO poisoning fatality. And now you got to go back to you. You clean up the truck. You bring come back to station and do all the parts of the job that you have to do. And now you go back to your family. It's not just, it's, yes, it's affecting firefighters, but it's affecting communities because you are responding to the members in your community. Another thing with career firefighters, they go to a city usually and most generally live outside of the city. They go to the city and work amongst. That community, but they don't necessarily know the people, but when you just got, when you are actually focusing on volunteers. They, what they live with all those people, they know those peoples that could have been their neighbors or people they ran into the grocery store, the kids. I did had this a lot with in my career with suicides where those are the kids my kids went to school with the same thing that happened with CO poisoning. So, please consider that as well for mental health and a community aspect for firefighters. Thank you for your time. That's an incredibly helpful perspective. Thank you. Um, Marshall. You know, I think we've talked a lot about the mental health. And that is really one of the biggest when you really look at. You know, I'll go back to the backpack and I would, I would ask each one of you today, you probably carried in a briefcase today to come to the hearing. Imagine if you can go out and you can take a couple of things out of that as you carry it for the rest of the week, you're going, man, that's a whole lot lighter. That's a whole lot better. Well, that's what these events are doing to the mental health of our folks. They're just adding more, they're adding more weight to it. And that is, you know, one of the things that we look at, you know, Chief Pashkowski from my prevention. She talks about, you know, one of the things that we have is firefighter suicide, right? You know, I can share with you that there's first responders that go to when you continue to see death over and over again. And it comes in a lot of different ways. We're talking about CO today, but it has a cumulative effect. And that is what we're really trying to do is that how many, if what we're really using here is we're using technology. So, you know, if I go out and educate somebody, I hope that they remember the message, but the reality is if they forget the message or they get on in life and they don't. But if the technology is their CO detector is a form of technology, let me know there's an issue in my house, but it doesn't alarm until the very high rate of CO and you have folks that are potentially living in that. Now, when you get to the other spectrum where they succumb to their injuries from the CO and there's death involved, it's very high levels of CO. But, you know, those are, those are things that when we talk about heating equipment, it just, you know, it's, I want to know that, you know, I want to meet the energy code now, right? And I want to have the most efficient and I want to do all the different things. It just, it makes sense to think about the first responders and I appreciate you asking these questions because that's what you're really asking about. Does it, you know, hopefully you're putting names and faces through the video here and not, you know, a few firefighters and that's what we're asking. And there's 1.3 million of us across the United States that are, that are, we'd be fine would never go in another CO. I can guarantee you on that. I can guarantee you we can agree on that. So, thanks for the opportunity again. Thank you. Make our world a little safer. Appreciate y'all. Thank you. We appreciate you as well. Last question is to Mr. Zipser. And, and you mentioned a little bit of about under reporting of carbon dioxide poisonings, and that we're underestimating the burden on society. I wanted to just give you the chance to elaborate on that. And, and to share any ideas you have on how we might be able to quantify where we're underestimating the burden on society. Mr. Zipser, are you there? There we go. Sorry. Couldn't get unmuted. Sure. You know, the, the data, you know, when I was a kid, when I made presentations, there's this really old number that the CPSC, I think still uses today, which is about 400 people dive. Carbon dioxide each year that number's got to be over 20 years old. And we're not really sure how it even got reports more of a guess, I think, than anything else. Plus, we. Even guess on the low level CO injuries that occur out there. So when I present on CO, I don't even use statistics because I don't know how reliable they are without good data. It's really hard to make, you know, relevant significant changes in our industry. Knowing that it's an important you could hear from the stories that Sharon tells and a lot of the other victims of CO that they went to hospitals. They said they weren't feeling well. However, when they get to the hospital, their symptoms might have gone away. And the medical community just doesn't know how to diagnose it. So we do know that, you know, when people get out, get that fresh air. A lot of times those symptoms go away. So we know it's severely unreported. And what happens down the road is, you know, they eventually get very sick, which puts burden on a course of medical community, as well as the victims of CO poisoning who now have to pay for the increased medical bills and all that. And we know as the society, we know for fact that people are getting older now. There's already increased burden on the medical community as well as first responders to take care of the aging senior citizens out there that now you've got CO, which oftentimes is overlooked. So that's what I was meaning when I was talking about just data doesn't exist out there and it's a burden on society first responders in the medical community. I would like to just add that PTS services. First of all, thank you to the fire departments who were where many hats. I know you guys are also for my research. You guys do gas leak tests, which is insane. So that's kind of what PTS is trying to come in and help with. And also our data. I know Delaware. Specifically, the fire department has started collecting tank data similar to kind of what PTS is. Tech would be we actually, the software developer. We had to put on hold, but he created the 1 of the 1st systems. So really our whole plan is to kind of get the communications going with the between fire departments, HVAC. LP companies, CPSC for recalls. We would be taking documentation of the LP tank serial numbers, photos and images. As well as the inside in home appliance pictures, serial numbers. Makes models. All that stuff. So. You got my name. Quickly, if I could say 1 more thing, we were talking about layers of protection and before I was in the fire service industry, I was with the auto industry. And, you know, they're everything from seatbelts to airbags, analogue breaks, lane changing warnings, and you could go on and on with all these safety devices. They're there to take that human factor and guesswork out of it. And I think that's all we're asking for as a fire service industry is to take some of that human factor out of it, let the technology. Perform the value added benefits that they can provide. Thank you. Commissioner. Well, did you have anything additional? No, thank you. Hearing none. Again, I want to thank all the witnesses for coming, testifying before us. You provided very useful information. I'm sure will be helpful to staff as it developed the final rulemaking package. And as the commissioners consider this matter further. With that, this hearing is adjourned. Thank you everyone. Have a good day.