 Good morning, and welcome to this public meeting of the United States Consumer Product Safety Commission We have one item on the agenda this morning a hearing to give interested members of the public a chance to provide oral comment on the CPSC's notice of proposed rulemaking concerning portable generators as Seen on the slide. I have prepared it. It'll be up on the screen in a minute I'll read from the statute the CPSIA which says quote The Commission shall give interested persons an opportunity for the oral presentation of data views or arguments in addition to an opportunity to make written submissions a Transcript shall be kept of any oral presentations I'm grateful today for all of the presenters who've come here both in this first panel and the second panel and We've really taken a tremendous amount of time and effort to come here and provide us with your insights and your expertise Your input and believe me your input to this commission is extremely valuable to us To begin I just kind of want to give everyone an overview of how today will play out So bear with me. There's a few little details The presenters as you can see on the agenda have been divided into two panels as seen on the agenda Each presenter will have ten minutes to deliver their opening comments our secretary. Mr. Todd Stevenson will keep track of the time And I want to thank mr. Stevenson and Ms. Rocky Hammond and all of the office of the secretary for their assistance today presenters I would ask that you watch in front of you The lights you're the light on your little speaker to to track your remaining time the yellow light indicates that you have one minute left If necessary, mr. Stevens will orally remind people of where they are in their time Commissioners will have five minutes to ask questions and we will have two five minute rounds of questions In the interest of time and out of respect for all of our presenters Especially those who are waiting patiently to present in the second panel mr. Stevenson and I will hold the presenters as well as the commissioners to their time allowance at Noon following the first panel there will be an hour long break for lunch The second panel will begin at 1 o'clock now That will be depending how long the first panel goes that could be open to a little bit of change But we will try to stick very closely to our schedule We are now going to hear from our first panel the first presenter is dr. Lindell weaver who is Participating by phone and I believe he is on the phone this morning Due to other commitments. He is unable to remain on the phone for the duration of this first panel So following dr. Weaver's remarks I will ask if any of my colleagues have questions for him before he departs the phone call if they do that Time that will be deducted from the first round of five minutes Once any questions for dr. Weaver have been completed I will return to the remaining presenters who are here this morning who will give their opening marks remarks as well And then we will turn back to the commissioners for their questions the first panel includes Dr. Lindell weaver who we will hear from shortly who is the medical director and division chief of hyperbaric medicine at LDS hospital Mr. Greg wish dad portable generators manufacturers association Dr. Kevin Dunn from the National Institute for Occupational Safety and Health Miss Kimberly pendo from the truck and engine manufacturers association Mr. William Wallace from the consumer union Mr. Marvin cloak from Briggs and Stratton corporation and mr. Lee so well from tectronic industries Inc Thank you all very much for here perfect being here this morning And with that I will ask dr. Weaver to begin your testimony and thank you again dr. Weaver for participating by phone Yes, thank you mr. Chairman. I appreciate this opportunity. Can you all hear me? Okay? Yes, we can hear you fine everyone can hear dr. Weaver good. They're all nodding. Yes. Thank you Terrific. Thank you And I only have one slide so I don't know if that's loaded yet Can you help me out here? Is it up yet? It is up. Thank you very good. Thank you So let me explain just for a moment who I am basically I'm a Clinician researcher I work for Intermountain Healthcare at both LDS Hospital and Intermountain Medical Center located in the Salt Lake Valley Professor University of Utah adjunct professor Duke University and I've been involved in carbon monoxide treatment for 30 years. I've evaluated and treated over a thousand patients and Very well published in this field. I get asked about carbon monoxide poisoning almost every day and every day I'm involved in either treating a patient Following a patient Thinking about something writing about something or reviewing an article or a manuscript written by someone else often from anywhere in the world Some of the work has included a paper that dr. Hampson and I authored a few years ago in which we Identified there were 50,000 carbon monoxide poison patients across the United States annually Probably more. I mean our numbers undoubtedly underestimate the true number so with that carbon monoxide poisoning is very common and Today of course is focusing on one topic in particular and that caused by portable generators Just a week ago. I treated a patient who was poisoned pretty badly by carbon monoxide from a generator I'm still following him. He got hyperbaric oxygen promptly and I Have a feeling I can't predict yet, but I feel he's likely going to have permanent neurocognitive and neurological damage So this is something that I'm certainly very familiar with is the harm from carbon monoxide so it causes harm and it certainly can cause death and Generators are great devices. Of course, I have one myself But they produce a lot of carbon monoxide I mean all internal combustion engines without catalytic converters and all sorts of emission standards That's required for example of automobiles produce a lot of carbon monoxide, especially at startup when they're cold and There's no question everyone in the room understands that portable generators producing carbon monoxide have harmed people and killed Some and the harm is not only acute harm. It's long-term Permanent damage anyone who has CO poisoning is at risk for permanent long-term damage and that rate is about 30% Maybe 40% of those poisons So it just seems to me as a clinician who may not know all the details about this subject that if there's a way to reduce carbon monoxide emissions from any engine and Specifically from portable generators. It seems sensible to do so Other opportunities might include even having a remote sensor that's linked back to the generator that when a level got to a certain Amount the generator would turn off These are engineering details that the engineers can work through But it seems to me and I have an engineering background by the way, but it seems to me that if we recognize there's Problems caused by some mechanical device They really ought to be engineering solutions that are satisfactory to all to reduce the harm And that's really the bottom line of the few minutes that I'm allowed here to talk about carbon monoxide And from a clinic clinicians perspective Because it causes a lot of hardship I mean I followed patients now for many years of time and their life self-inters completely disrupted family Relationships disrupted not going back to work, etc So the notion that people all have a universally good outcome after CO poisoning is not supported by the evidence So with that I'd be glad to field any questions and I do appreciate the opportunity to talk this morning. Thank you Thank you very much. Dr. Weaver and again. Thank you for joining us by phone I will ask the commissioners now whether they have any questions. I have no questions commissioner Edler I do have one quick question Dr. Weaver your PowerPoint slide raises two possible ways to reduce CO emissions One is to reduce the CO emissions. The other is to turn off generators of CO levels are too high I'm curious if you have a preferred approach and I'm also curious about what you think about doing both as Mr.. Sol from TTI has suggested I Think doing both Because the thing is you're not going to train the public, right? I mean they put generators in all sorts of places where they ought not put them and we know that's the problem So it seems to me the engineering solution is to reduce the emissions and to turn them off both. Why not? Yeah, I get it it costs more money, but if the money is spread across the entire industry I don't know that that's a big issue because everybody on the manufacturing side is going to have to Pony up to cover those costs those engineering costs Thank you no further questions. Thank you commissioner Robinson. Thank you so much, doctor Weaver for taking time today our time for questioning is also very limited, so I will be quick You've talked about the long-term sequelae of non-fatal carbon monoxide poisoning Could you just amplify on that a little bit in terms of the kind of permanent cognitive sequelae or active? Affective changes that you've seen in people whom you've treated sure be glad to Well I'm sure most of people in the room are familiar with post-concussive syndrome There's a lot of traumatic brain injury around football players college football US service members So many of the people with long-term damage from carbon monoxide act just like they have post-concussive syndrome headaches Dizziness instability in balance Irritability can't sleep well at night change in personality change in mood depression anxiety very common and Of course, there's a spectrum some people are really very bad and some people are not so bad But in the people who develop sequelae the themes are neurocognitive balance Sometimes some problems with vision And it's again just like they had any other type of brain injury carbon monoxide brain injury is really not that different than any brain injury Concussion and then about 15% of the patients that have symptoms at one year They actually develop mild heart failure and I've got quite a few people now in my practice that were treating for heart failure I can't share with you how they do over long long periods of time because they don't know that yet But that's another aspect of CO poisoning. That's rather different than blunt force trauma to the brain So neurocognitive problems and they are of consequence. I mean it impacts their life their family relationships Impacts their ability to to work and to carry on True shame One of the things that we have to do as an agency if we're to pass a mandatory Standard with respect to carbon monoxide emissions is we have to do a cost-benefit analysis and in doing that We have to look at the numbers of people who've actually been died or been injured from carbon monoxide And one of our most important ways of looking at that is patients who are medically treated either in emergency departments or in Physicians offices of the thousand patients that you've treated Can you give us any sort of? Estimate as to the numbers of those who might not get counted as those who actually seek treatment for carbon monoxide poisoning Not sure actually Dr. Hampson Neil Hampson a good friend of mine retired now He recently authored a paper about the cost of carbon monoxide to US citizens And I don't have a paper in front of me, but it seems to me it was on the order of a thousand and I'm sorry a Billion dollars or so. Let's see. I think it's right here. Yeah, I've got it. It was in preventive medicine reports just a couple of months ago and It's a lot of money that goes into this He said approximately 6,000 individuals estimated to sustain long-term cognitive sequelae and he puts the Total loss and earnings at just under one billion dollars And then there's some other money for loss of productivity and hospitalization So it all adds up to about 1.4 billion dollars annually. Okay. Thank you. I'm out of time. Thanks Thank you commissioner. Okay. I have no questions. Thank you doctor for your testimony You're very welcome commissioner Mohorovic. No questions. Thank you Thank you. Dr. Weaver unless my colleagues have any additional questions They're all shaking their heads. No, we appreciate your participation this morning and thank you very much for your expertise and We will excuse or you excuse you from this call. Thank you again. Dr. Weaver Appreciate it. Thank you. Bye. Bye Thank you and now we will turn back to our presenters who are here this morning Who will each give their presentations and just a gentle reminder that we will have give you each presenter ten minutes And then the commissioners will ask their questions. Mr. Weesh dad. We will begin with you from portable generators Is your mic answer? There we go. Thank you. Sorry about that I'd like to first begin by thanking acting chairman Burkle and the commissioners for allowing me and Pgma to come here today And and share our thoughts and testimony with the commission My name is Greg wish dad. I serve as president of portable generators manufacturers Association Pgma is a voluntary trade organization which began in 2009 Representing major manufacturers of portable generators Pgma has seven member companies in addition to one associate member company which employ thousands of individuals in the United States Pgma and its members are dedicated to the safe use of power portable generators as such Pgma has developed the first and only ANSI standard for portable generators ANSI Pgma G300 Although the standard was only finalized and approved by ANSI later in 2015 Pgma decided to go a step further by reopening the standard to include requirements to address potential co hazards when generators are used Improperly Pgma is also involved in the voluntary standards process with UL underwriters laboratories Serving on the UL 20 to 1 co task group However, we would note that Pgma is not comfortable with the task groups current direction In addition to our standards activities Pgma members contribute extensive resources to educating consumers on the safe use of portable generators in 2015 Pgma developed the take it outside safety campaign that includes a website fact sheet Video and resources that our members use to promote consistent messaging around the safe use of portable generators and the potential hazards If generators are misused by running them indoors the campaign also includes ongoing press releases That highlight different usage scenarios and provide Information reminding consumers of the importance of properly working co alarms We also track major storms and send media alerts with pertinent information about the safe use of generators when there is a power outage Since its inception our take it outside campaign has garnered nearly 35,000 media placements and over a billion impressions Since inception Pgma has been focused on dangers of carbon monoxide And we have taken numerous steps to focus our attention on a solution these efforts include the following first CPSC's Incidents deaths in-depth investigations associated with non-fire carbon monoxide from engine driven generators and other engine driven tools 2004 2014 report Indicated that the second most common reason for portable generator use was shut off of utilities which accounted for 20% of all of the deaths In that report Pgma has reached out to utility commissioners Commission's excuse me across the country and provided them with the take it outside fact sheet requesting that When they shut power off they include the fact sheet with the shut off notice and post the information on their websites Pgma has also made several requests to CPSC to help in this outreach In addition to in 2013 Pgma worked with Naruk on their adoption of C a dash one resolution Recognizing the importance of educating power consumers on portable generator carbon monoxide safety Unfortunately follow-up attempts to ensure utility sharing safety information on their websites and through consumer notifications has been challenging as Requested previously we would appreciate consumer product safety commission assistance in this matter The same incident report previously noted indicated more than 92% of engine driven carbon monoxide deaths Occurred without properly operating co-alarms Pgma has provided support to the Nicholas and Zachary Burt Memorial carbon monoxide poisoning prevention act s dot 1250 which would make carbon monoxide detectors more readily available Pgma has also requested the CPSC help in requiring co-alarms in residential buildings and past meetings in 2016 Pgma held a technical summit bringing together Pgma members consumer product safety commission staff NIST underwriters laboratories technical experts and others to gather input for how to address the potential carbon monoxide hazards that occur with misuse of portable generators We appreciate the work CPSC has done with the notice of proposed rulemaking This effort combined with the input from technical summit held in 2016 helped Pgma members with their individual research and development efforts on the issue and Pgma to get very close to releasing a revised ANSI Pgma G300 standard for canvas However, as you're aware our freedom of information Request to the National Institute of Standards and Technology has not provided all the necessary data for us to continue with our testing to Ensure that the solution we are recommending is best for consumers NIST is now requesting eight thousand dollars for the rest of the data and Pgma is not guaranteed We will receive all the information requested that we require for our testing also as a nonprofit $8,000 is a high cost that had not been allocated for in Pgma's 2017 operating budget Pgma believes that since CPSC's NPR largely relies upon the NIST modeling It's in the public's interest to have this data released We would ask that CPSC contact NIST and asks them to release this crucial information used to develop your rule This information should not be withheld especially when CPSC itself has an open comment period on the rule Having access to the NIST data is particularly important for our standard revision in addition in addition to being able to respond to the NPR Pgma's newest iteration of the standard will propose a detection methodology with shutoff mechanism to help ensure CO doesn't build up in an enclosed space if the generator is being misused Initial modeling based on FOIA data We did receive from CPSC shows that a shutoff sensor approach will be more effective towards minimizing deaths and Missing data from the NIST is crucial to better understanding the proposed solution in the NPR And in Pgma's work on its standard to address the potential hazards As a whole Pgma members are committed to quickly finalizing revisions to ANSI Pgma G 300 standard To address potential co hazards if generators are used improperly To assist in this effort and to ensure we have all of the relevant information and feedback necessary We have scheduled a second technical summit for april 3rd 2017 Where we have invited Pgma technical committee members consumer product safety commission staff health experts CO experts including those Versed in detection NIST Underwriters laboratories and other interested parties to review the revisions to the standard and ask any questions and prevent feedback This summit will result in a steering committee to help Pgma finalize the standard Once Pgma has this input Pgma's technical committee will make the appropriate updates to the standard and proceed with the ANSI canvas process A majority of the Pgma member manufacturers are in line with Pgma's voluntary standard revisions Which address the potential co hazards and ultimately feel that this method will prevent more incidents than the lower co emission solution That is outlined in the NPR The revised Pgma draft standard that will be shared and published shortly reflects a detection and shutoff strategy To address the co hazard posed by indoor use While Pgma's full comments on the NPR will come closer to april 24 2017 pending release of the data from NIST We do have several initial concerns with the NPR that include The unintended consequences of a low co emission solution Individuals may think generators are safe to take indoors, which with any co emissions. They will never be safe to take indoors Congress has directed the jurisdiction of regulating carbon monoxide emissions to the EPA As a separate federal agency cpsc moving forward with a mandatory standard that regulates emissions is misplaced Job loss a reduction of choice in the marketplace price increases Potential unintended consequences of incidents and deaths with the misunderstanding that generators are safe to bring indoors Are all very real concerns of a mandatory portable generator rulemaking moving forward Given our good faith effort to take all opinions into account and work on a revision to our ANSI standard That addresses the risk of CO poisoning from improper use We urge the commission to halt or delay the NPR and continue to work with industry and the voluntary standards process to address portable generator safety Thank you for your time and consideration today. Thank you very much. Mr. Dunn Hello, thank you, madam chairwoman and the commissioners for allowing me to talk today My name is kevin don. I'm a research mechanical engineer from the national institute for occupational safety and health And i'll be presenting Some research that has been conducted at nyash Is my are my slides up or can I have some slides. I'm not sure if they're sure We have the slides in front of us, but we don't see them on the screen Okay, so um So i'll move Excuse me one second. Mr. Dunn. Is there a way john that they can get up on the screen so everyone can see them? Thank you Thank you You want me to go ahead? Thank you nyash has conducted research to prevent carbon monoxide or co poisonings from small Gasoline powered engines for over 20 years nyash continues to research to research this problem particularly after identification of co poisonings and deaths Associated with marine engines and generators beginning in 2000 The co emission hazard from portable generators continues to be a very serious concern for both workers and the general public In the next slide. Do I have control of this? In august 2000 the national park service to the department of interior Uh requested assistance from nyash and the us coast guard To evaluate visitor employee carbon monoxide exposures from generators and propulsion engines from onhouse boats The this investigation characterized the co poisonings by collecting epidemiologic data And measuring severely hazardous co concentrations on houseboats at lake pal arizona From 1990 to 2008 over 800 boating related poisonings in 35 states have been identified with over 140 of these poisonings resulting in death Over 300 of the poisonings occurred inside or outside of houseboat cabins With more than 200 of these poisonings being attributed to generator exhaust alone This chart provides some references for concentrations of carbon monoxide which can result in acute health effects The nyash ceiling limit is 200 parts per million And is a concentration that is never to be exceeded in a workplace at any time The nyash immediately dangerous to life and health or idlh For for carbon monoxide is 1200 parts per million An idlh condition is defined as follows Any condition that poses an immediate or delayed threat to life or that would cause irreversible adverse health effects Or that would in fear interfere with an individual's ability to escape unaided from a permit space This picture shows the rear of a houseboat the back of the houseboat where the generators exhausted Underneath let's see There we go Underneath the swim platform on the back of the boat our initial evaluations showed air concentrations of carbon monoxide Between 7,000 and 10,000s per per million in open air on the swim platform And concentrations exceeding the level considered to be immediately dangerous to life and health On the back deck of the houseboat We measured a concentration greater than the nyash ceiling for workplaces at a distance of 10 foot from the back of the boat An area that was particularly dangerous was under the swim platform where the generators typically exhausted Because the emissions of these engines and the enclosed environment The concentrations often reached many times Greater than the nyash immediately dangerous to life and health This posed a significant threat to those that entered this area which included children looking to play And boat operation boat operations who needed access to untangle the ropes from the propellers Initially the major obstacle to the safe use of gasoline power generators was the absence of any emissions controls In 2001 nyash researchers began partnering with boat builders And marine engine manufacturers to prevent co-poisonings from gasoline marine engines A prototype emission control and aftermarket catalytic converter Was introduced in 2001 Initial findings show that this technology greatly removed the emissions at the source Reducing concentrations on and around houseboats Following these findings concerning prototype Generating controls two major manufacturers of marine power generation systems Developed low co emission generators Nyash evaluations found that these new technologies for marine engines such as catalytic converters and electronic fuel injection Reduced co emissions by over 99 percent This is a picture of those two large manufacturers westerbeek and kohler and Some details on the family of generators that they now produce for marine engines This is an example this is an example from evaluation of co concentrations on the back deck of the houseboat with only the generator operating And as you can see the low emission generator Resulted in substantially lower co emissions in open air on the back of this boat These measurements were taken where occupants would normally stand or sit Co measurements taken directly in the exhaust pipe of the generators Ranged from 16,800 to 55,300 parts per million In the baseline generator without engineering controls and from 1 to 39 parts per million In the generator with controls such as fuel fuel injection and catalytic converter Due to these efforts to develop emission control technologies Boating exhaust standards and regulations have been implemented which will inevitably reduce boating related co deaths The american boat and yacht council modified their standards for generator Exhaust to include exhaust stacks the epa using using nash engineering control research Developed and promulgated a low co emission standard for all marine generators This level is five grams per kilowatt hour versus the 610 grams per kilowatt hour Which is currently allowed for most portable home generators The addition of catalytic converters has proven to be a lifesaver In preventing motor vehicle related co poisonings This this graph is from an article by mott at all in the journal of american medical association In 1970 congress established the usepa and acted in an act of the clean air act which set emission limits on automobiles Beginning in 1975 automobiles manufacturers began installing catalytic converters on automobiles in the us to meet these standards An analysis of the effect of these technologies and related policies Showed a decline of unintentional vehicle related co deaths of greater than 80 percent from 1975 to 1996 Thank you for the opportunity to talk to you today about this very important issue Thank you, mr. Dunn Miss pendo you make proceed Okay, thank you very much. Good morning. My name is kimberley pendo And I am here today on behalf of the truck and engine manufacturers association or EMA EMA appreciates the opportunity to testify regarding the consumer product safety commissions proposed safety standard for portable generators That seeks to regulate carbon monoxide emissions generated by portable generators EMA represents the world's leading manufacturers of non handheld small spark ignited engines EMA members manufacture the engines used to power the portable generators that are the subject of the proposed rule While cpsc's proposal seeks to regulate portable generators It is the engines that power generators that create co emissions Accordingly EMA and its members have a direct and significant stake in the proposed rule EMA has been actively involved in the commission's rulemaking process from the outset And has participated in the commission's working groups and related activities organized by underwriters laboratory In addition EMA has collaborated with other industry associations Including the portable generator manufacturers association and generally supports pgma's efforts and comments provided this morning EMA remains committed to working with cpsc and other stakeholders to address the safety concerns raised in the proposed rule In a manner that meets applicable legal standards and requirements And results in a feasible realistic and workable means to address safety to address safety concerns Without the imposition of overly burdensome redundant and unnecessary government regulation As the commission is aware industry is actively engaged in the development of an independent antsy standard That would address cpsc's safety concerns through a through cost effective and efficient self regulation Thus avoiding the need for government interference or the imposition of unnecessary regulation Industry self regulation is particularly warranted in this situation Because cpsc lacks the authority to regulate co emissions The proposed rule is based on the promise that cpsc has the authority and capability to regulate the generator manufacturer However, the genuine the generator manufacturer does not and cannot control the co emissions that the proposed rule seeks to regulate The co emissions that are the subject of the proposed standard are produced by the engines that powers the generator And those engines and engine manufacturers are preemptively and exclusively regulated by the united states environmental protection agency Engine manufacturers are required to comply with epa emission regulation And such epa regulatory requirements preclude the generator manufacturer from changing any aspect of the engine that would affect emissions regulated by epa co emissions are regulated by epa under section 213 of the clean air act and the consumer product safety act specifically states that the cpsc Has no authority to regulate quote any risk of injury associated with a consumer product If such risk could be eliminated or reduced to a sufficient extent by actions taken under the clean air act Accordingly epa and not the cpsc has the sole and exclusive authority to regulate engine co emissions associated with portable generators As such cpsc must withdraw the proposed rule and work with industry on the antsy standard development process In addition the standard levels proposed in the proposed rule are not supported by cpsc's technology demonstration Cpsc's two-part prototype low co emission generator technology demonstration program One covered only one of the three classifications for which cpsc has proposed regulations And two showed that the technology required to achieve the demonstrated co levels results in increased exhaust temperatures which itself could create significant safety issues Such increased exhaust temperatures were well documented in work done by epa And the development of the existing epa phase three exhaust emission standards for the type of small spark ignited engines Used in portable generators and where the subject of safety studies included in the environmental protection agency's rule making docket Further the proposed rule improperly proposes to measure co emissions on a grams per hour basis The proper way to measure emissions as used by epa Is to account for the work done by the engine on a grams per kilowatt hour basis And that way small and large engines can be compared and treated fairly based on the amount of work the engine does epa's method results in significantly greater accuracy E.g. less errors the measurement methodology and standard levels proposed in the proposed rule Do not effectively address the implications of different engine sizes or efficiencies EMA and its member companies are committed to continuing to work with the cpsc ANSI underwriters laboratory Pgma and other interested stakeholders to minimize any risks associated with the use of portable generators Thank you for your time. I would be happy to answer any questions Thank you very much. Mr. Wallace, please Good morning Consumers union the policy and mobilization arm of consumer reports welcomes the opportunity to present oral comments to the us consumer product safety commission On the proposed safety standard for portable generators We appreciate the work done by the commissioners and cpsc staff to research the risk of carbon monoxide poisoning And issue the notice of proposed rulemaking to reduce future injuries and deaths associated with portable generators Cpsc has been taking steps to make these products safer The agency has long urged consumers never to operate a portable generator inside or too close to the house A message we at cr and cu have communicated as well through articles videos and public outreach Often time to snow season or hurricane season For example, we published a story featuring this critical advice on cr.org on february 3rd 2017 Additionally, starting 10 years ago, cpsc required a clear label on portable generators that warrants consumers In appropriately descriptive and severe terms about the deadly risks of operating the product in the wrong place We at cr and cu always consider it important for us to urge consumers to heed safety instructions and to be responsible for the safe use of products However, as the incident data make tragically clear Education and warning labels alone are not enough to protect consumers from carbon monoxide poisoning With an average of some 70 deaths and several thousand non-fatal injuries annually We strongly agree with the commission that performance requirements are needed and without any further delay Consumer reports periodically tests and rates generators including portable generators Our overall score is based on power delivery the wattage delivered and how well it handled surges Power quality the ability to deliver power smoothly with consistent voltage noise level ease of use including starting transport and helpful features such as fuel shutoff And runtime range our average of how long a generator ran over various loads The generators we recommend produce smooth steady power for refrigerators well pumps and other home items Without losing voltage under load and most shut off automatically if engine oil is low We also identify cr best buys that blend performance and value In the name of one of our guiding principles safety consumer reports is exploring potential changes to our testing to account for portable generators carbon monoxide emissions Consumers deserve to have the opportunity To have independently evaluated comparative information about this aspect of the product and to know which models perform better within a class of generators While we fully recognize that the risk of poisoning from carbon monoxide depends on many factors Including the generators placement and the local air flow Reducing co emissions can be a feasible and effective way to reduce the risk Consumers who want to know which models have lower co emissions and want to use this information as part of their purchasing decision Should have the ability to do so This would empower individual consumers and help shape the marketplace That is in keeping with our mission and we take our role seriously We also recognize though that effective safety standards are those which apply across the marketplace Substantial compliance is an important component in maximizing the number of injuries and deaths prevented It is also important to promote a level playing field for the businesses that make up an industry So that marketplace competition is fair and leads to safer products that also provide a meaningful value to consumers Accordingly and especially given the inadequacy of current voluntary standards We support the proposed rule And urge the commission to keep moving forward on its development of a mandatory safety standard As it does so we encourage portable generator manufacturers to deliver product changes Expeditiously and with across the board participation That would meaningfully address the risks of carbon monoxide poisoning and would further inform the commission's safety standard development In most scenarios these changes should substantially extend the time consumers have to identify that something is wrong Before being exposed to co levels that seriously injure them Or eliminate the hazard entirely We look forward to working together with both industry and cpsc to achieve these changes that would protect consumers from harm Turning back to the proposed rule We have several preliminary views to share with the commission about various aspects of the mprm Our more detailed comments will be submitted in writing Purpose the purpose of the stated rule to set requirements for carbon carbon monoxide emission rates for category supportable generators Is appropriate for the goal of reducing the unreasonable risk of injury and death associated with these products We also note that another factor in co poisoning and death may be the length of the electric cord that connects the generator to a home's transfer switch Including 10-foot cords with portable generators may suggest to consumers that they can place their generators close to their homes In addition to addressing co levels banning short cords and requiring cords to be at least 30 or 40 feet long Could help reduce that risk to consumers Scope Generally the scope of the proposed rule is appropriately tailored to products that are portable and are typically used by consumers However, we recognize that products outside this scope Especially the products listed under items one through eight in section 1241.1 b that are intended to be used with a vehicle may pose similar risks to consumers who use them We encourage careful monitoring of the marketplace for any consumer product that presents an unreasonable risk of injury or death Compliance states We understand that design modifications may be necessary under the rule and an effective date that is one year after the final rule is issued Therefore may be in the public interest We also understand that design challenges may be more difficult for smaller units However, we urge the commission to set an earlier compliance date for handheld and class one generators Then three years after publication of the final rule No justification is given for why such an extended period of time would be necessary for compliance Or why such a delay would outweigh the benefits to the public of the rule The commission instead should adopt a compliance date for these smaller products. That is at most 18 months from the date of the final rule Findings We appreciate that the proposed rule includes appropriate context on incident data Indicating that the documented fatality and injury reports in cpsc databases including nice Likely represent an underestimate of the true number of fatalities and injuries associated with the risk of generator related carbon monoxide poisoning In addition, we agree with the commission that under the proposed rule There may be noticeable positive changes in the utility of portable generators to consumers in terms of fuel efficiency and other aspects Automatic shutoff systems In previous comments including comments on the advance notice of proposed rulemaking Consumers union suggested that automatic shutoff systems were the most promising way to reduce injuries and deaths from carbon monoxide poisoning This view was based partially on the fact that many generators on the market Have a similar system designed to cut off the equipment when it senses that the machine is low on oil Since many deaths occur from generators running in enclosed spaces Lowering the allowable co levels may simply serve to increase the amount of time before consumers are exposed to lethal co levels This is not trivial. It could save lives and prevent injuries But if automatic shutoff systems adequately address the risks of carbon monoxide poisoning Then that technology might be preferable to the commission if it has superior hazard reduction value In our view, of course, the best of all worlds from a consumer safety perspective Would be if industry can lower generator co emissions and have an automatic safety shutoff voluntary standards Although we would look forward to working with industry and cpsc in any venue that would facilitate Substantial advances for consumer safety We agree with the commission that the voluntary standards ul 22o one and ancp gma g 315 are inadequate because they do not address the risks of carbon monoxide poisoning beyond the mandatory labeling requirement Least burdensome requirement While we recognize that regulatory alternatives can change as previously unknown facts come to light Including for instance the existence of new technologies effective at reducing a hazard We consider the commission's reasoning appropriate that leads it to conclude preliminarily That none of the less burdensome alternatives to this rule would adequately reduce the risk of safe of injury Thank you for your consideration of our comments. We look forward to continuing to work with the commission cpsc staff Manufacturers and other stakeholders to make portable generators safer for consumers nationwide Thank you very much. Mr. Wallace. Mr. Kloak Am I saying that correctly? Kloak. Kloak. That's correct. Thank you I do have a presentation to compliment My comments Okay, thank you Good morning, dear members of the commission and the public. My name is marv. Kloak I am the global vice president of research and development at bricks and stratton located in mohawk, wisconsin Briggs and stratton is a trusted company with a long history of manufacturing safe and reliable products These products make lives better by empowering customers to get work done Portable generators among the products that we produce They provide essential electric power for work recreation and emergency backup The cpsc is seeking to address the risks associated with the production of carbon oxide gas Or co a byproduct of internal combustion engine that powers the portable generator the cpsc's Proposed regulation which we refer to as the low co Would establish lower exhaust emission limits for co from the engine With the intent to reduce fatalities from misuse of portable generator Generators bricks and stratton believes a performance standard which allows for a co shutdown would be a more effective approach We believe that the co shutdown is a more is more effective than the low co for several reasons First of all A low co engine is proposed by cpsc running in an enclosed space Will still produce poisonous levels of co This premise is demonstrated today in the automotive industry Although automotive automobiles produce lower levels of co than this proposal The national highway traffic safety administration has engaged in regulatory development Designed to address the low level exposure to co over long periods of time The n h t s a has expressed concerns over automobiles with keyless start where poisonous levels of co have been produced Another concern is that the co production rates from portable generators will result in longer exposure times for consumers Exposure to low level to low levels of co Over long Periods of time will delay the onset of symptoms and will result in co blood levels to become higher Than if the generator was to have shut down Co will continue to build up with low with a low co generator While co will not continue to build up with a co shutdown generator In comparison a co shutdown system would work quickly and automatically to shut the portable generator enforce a task orientated change and emphasis size a task oriented change in consumer behavior Is cited by the npr The commission recognizes that consumers cannot be relied upon to react Appropriately to any indication of co exposure a co shutdown system Co shutdown systems does not rely on the consumer taking the correct and at an active response Another fact to consider is that a low co generator requires a catalyst Before the catalyst becomes effective. It must warm up This usually takes several minutes during which the co will be produced at a higher rate than when the catalyst is warmed up Finally an inherent characteristic of the catalyst is that is it is that additional heat is generated As such low co systems will result in unintended consequences such as higher operating temperatures Which increase other risks than when using a generator without a catalyst Did the next slide advance It did not it did not. Okay. Thank you Brakes and stradden also believes that co shutdown is substantially more reliable and durable than low co As previously mentioned low co requires a catalyst Catalyst degradation occurs naturally and can be accelerated with exhaust contamination While diagnostics can be added they introduce complexity with an additional o2 sensor and control algorithms On the other hand co sensor technology used for co shutdown Has greatly advanced since the time of the cpsc shutoff device study conducted in 2005, which was subsequently published in 2013 Additional co's are now commercially available with longer and increased longer life and increased durability They are also used in numerous applications including house boats and the automotive industry Additionally co sensor modules now have the provisions for expanded self diagnostic capabilities, which will make them more reliable Finally durability and reliability are closely related a consideration in reliability and long term durability Is the number of components in a given system? co shutdown involves fewer a fewer number of components than low co which reduces the system complexity This results in a higher effectiveness Over the life of the generator Brakes and stradden also wishes to communicate that there are other regulatory considerations The first is that the cpsc has yet to complete the study of the effectiveness of the 2007 mandatory safety label to determine whether additional regulations should be considered Based on the information available the fatality rate is trending downward Another consideration Is that the portable generator manufacturer's association has published a comprehensive ancy safety standard for portable generators And is in the process of updating it to include a c bowl performance requirement the cpsc should defer to the voluntary industry standard Setting procedures Finally the epa has already adopted emissions regulation, which includes co limits occupying the regulatory space Brakes and stradden supports the engine Manufacturers association or ema and pgma's position on this Next actions, which we respectfully request are as follows First of all the cpsc should work with this to fulfill the pgma's outstanding foyer request for modeling information So that pga pgma members can model alternative solutions following the cpsc's methodology We would also like to note that additional detailed written comments will be submitted by brakes and stradden prior to the close of the public comment period Additionally brakes and stradden welcomes the cpsc's support in the pgma's effort to refresh and modernize the current 2007 mandatory safety label Next on behalf of brakes and stradden I would like to form the extent of an invitation to cpsc For a private technology demonstration And discussion at our facility We are becoming more and more confident on a daily basis with our approach to shutting down the generator And finally we respectfully request that the cpsc for goal of the npr activity work with industry And endorse the co performance Based voluntary standard being developed by the pgma Thank you for your time Thank you very much. Mr. Sewell Good morning. My name is league silo and the president of the outdoor product division for tech chronic industries power equipment known as tti We're a major manufacturer of outdoor power equipment including portal generators We sell generators under the rea b brand black max and power stroke to major retailers like home depot and others Though industry data is limited for determining u.s generator market share We estimate we're the fourth largest supply of portable generators in the industry Excuse me. We have a manufacturing facility in anerson, south carolina Where we produce some of our generators and we also produce some overseas in various manufacturing Locations I want to thank the commission and the cpsc staff for their leadership on this important topic We share the cpsc's goal of ensuring the safety of all consumer products sold to us consumers I'd like to point out too that we are one of the founding members of the pgma Interactive on the board of directors and also we chair the pgma technical committee We're here today to publicly support the portable generator mpr Because it promotes a technical standard that will address the ceo hazard associated with portable generators and enclosed Partially enclosed partially enclosed misuse scenarios as well as outdoor use scenarios not just enclosed spaces Data from the cdc Florida 2004 and portable generators for injuries, which we tend to Talk more about deaths versus injuries, but as we've heard today, it's a much higher number 46 of the cases the generator was used outdoors not indoors in an enclosed space From august and september of o5 from katrina and alabama louisiana mississippi 64 of the cases of injuries and fatalities the generator was used Outside not indoors in an enclosed space So we feel it's important not to ignore that piece of the misuse scenarios, sorry if you look on our tti website We list our six core values and the number one is doing the right thing And we believe doing the right thing is providing the safest possible Generator safety standard. I'll talk about that in a minute Um We are for a comment some perspective of finish good manufacturer portable generators Who's a track record of consistently demonstrating is of most importance They'll highlight our support of the proposed rule and how we've spent significant time and resources doing the rnd In testing of low ceo emissions to prove the technical feasibility of the technology We wholeheartedly support the cpsc's mission of product safety Proposed rule to limit the ceo emissions rate of portable generators at the source This is in our opinion the most sure way to directly reduce the chances of injury and fatalities as a result of the misuse of portable generators To illustrate my point. Let me refer to you to an example case that was included in a recent recently submitted comment To the portal generator npr site Ed and christina watson from clarkfield tennessee lost a daughter and her husband and three friends Due to ceo poisoning are operating their generator outside of their camper Like most consumers the wasps despite warning labels provided may not have realized how dangerous generator exhausts can be Resulting from misuse from the wasps perspective. They were operating the generator correctly. It was not inside the camper Rather, it was intentionally placed outside Unfortunately placed in the generator outside was not enough to avoid a tragic accident The scenario and many others like it will most likely not be prevented by shutoff technology alone Rather the most effective way to mitigate the potential for ceo related injury is to first address the hazard at its source By lowering the amount of ceo produced and then focusing on shutoff technology The work the cpsc did in conjunction with the university of alabama to make a working prototype demonstration provided us with a solid foundation of technical understanding And a very helpful framework of reference points that help guide our development teams to achieve ceo emissions results That were otherwise thought to be unachievable for portable generators Our teams have been able to demonstrate low ceo emissions on many different types of engines and engine sizes both class 2 class 1 and handheld Of up to 90 as well as successful demonstrations using multiple fuel types With each passing phase of development our teams are making further discoveries and improvements in helping to push the base of knowledge and understanding And what the technology is capable of achieving And how it perfectly fits as a technical solution to save the ceo that solve the ceo hazard associated with portable generators We've also found that From a durability standpoint, we're actually getting extended life of the engines. We're getting 20 fuel savings And we see less than 10 percent degradation over time of the ceo reduction Emissions from these units. We also are seeing no increase in heat from the generator itself Our like point out that pj and at the pj technical summit march of 2016 We were the only company that publicly presented the results of our reduced ceo emission development efforts Since then we've continued our development been able to incorporate a shutoff technology that does not rely on chemical sensing devices And has the potential to demonstrate much higher reliability The optimal solution for limiting the ceo hazard would be prevention via reduced ceo emissions and detection via shutoff feature Can never market generator is safe We would not in any way reduce our efforts on warning and instructing Users to use it outdoors a minimum 20 feet away from the structure, which we say in all of our manuals And we would continue to do that as we do today certainly We've been working with multiple multiple partners that have Significant technical experience to enable us to replicate the University of Alabama results And make what we feel is a commercially viable reduced ceo emissions technical solution The technology to reliably control ceo emissions on small engines is readily available in the market today from multiple sources Anyone who is serious about addressing this hazard can do so It's becoming more and more commonly used on commercial mowing equipment as an example. You see efi prevalent Coming more prevalent on a lot of commercial mowing equipment and their touting fuel savings as a benefit We have plans to launch multiple generators during the 2017 calendar year using our own reduced ceo emission engines As well as using third-party engines that are readily available in the market Kola announced in 2016 october 2016. They've developed an engine for use on portal generators Which has reduced ceo emissions rate? We're proud to partner with them to resolve the ceo hazard and improve the health and safety of us consumers We're also partnering with another engine manufacturer from japan and we welcome the opportunity to work with others We also have used multiple chinese engine manufacturer partners in this technology works across every supplier that we've worked with T-tavern may strongly committed to working with industry to address the hazards associated with the use of portal generators We do appreciate the opportunity to provide our view on the proposed rule. Thank you. I'll be happy to answer questions Thank you very much and thank you to all of our panelists for your presentations We will now begin the commissioners questions and I will begin my round of five minutes I wanted to talk to miss pendo just briefly about What you said with regards to epa and the jurisdictional issue How would your members be affected if our agency took up ceo emissions along with what the epa has already done with ceo emissions Sorry, thank you Our members would be affected by having to potentially comply with different standards regulating the same emissions In addition It could create a situation especially you know given the the current proposed rule Um, which uses a different basis for for for measurement for the kilowatt per hour on a grams per hour basis As opposed to a kilowatt per hour basis would not be Possible to comply with different regulations and standards. Thank you very much. Mr. Kloak in your testimony You talked about catalyst And the time it takes for that catalyst to warm up before we would see low ceo emissions I wanted to just relate back to something doctor weaver said about the Amount of ceo that is emitted until the engine warms up. Can you explain His comments in light of what you testified As well. Um, and I don't recall his specific comments He said especially at startup when the engine is cold, right? So yeah, so yeah, so with the with the catalyst That's placed on an exhaust system of an engine It takes a certain amount of time for the catalyst to become active or it's commonly called light off Which can take several minutes. So until that point it's going to produce ceo and emissions at a rate Just like the catalyst was not there Okay, so that so if even with a low ceo approach You got to be mindful that you're going to be producing ceo at a high rate Until that catalyst becomes warmed up and effective And can you speak to is it by the engine and by the catalyst how long it takes for that to warm up? It would vary depending on the engine, you know, and it could be it could be several minutes Just to give you a ballpark understanding of it. Thank you very much My next question is for a pgma. Mr. Wisch dad. I wanted to talk to you in your testimony. You mentioned About your concern with the direction that ul is taking with regards to their voluntary standard Could you expound on that a little bit for us? Certainly Excuse me. Certainly. Um, the ul task group was formed And it brought a number of members together and that task group Completed its activity with a test for emissions. It did not complete its activity with an actual performance standard That's currently in ul's hands. Um, it's out for comment that concluded last week Our members have a number of concerns with that test some of the repeatability reproducibility issues as well Just as well as the approach We have pgma has a strong history of developing standards We were able to get the first ansi standard in a very short period of time Whereas ul 20201 has been out for multiple canvases over several years Spanning something close to 15 years So we feel that pgma is in a better position to be able to move forward with the standard To that end we have also been recently notified by underwriters laboratories that if our members or pgma itself Contributes to their standard making activity Anything we contribute becomes the sole and exclusive intellectual property of underwriters laboratories Which is making it really difficult for us to team up in an effort So we've actually invited them to participate in our standards making activities through the upcoming events in the in the april 3rd Technical summit and steering committee that will be forming. Thank you very much. Mr. Dunn in your comments about Reducing the number of deaths with marine engines and co poisoning I'm interested to know was it a low co emission technology that Brought down the number of deaths and the or was it a different technology Such as venting the co well, I think with With regard to the final graph that I had that was about motor vehicles and specifically about the addition of catalytic converters on on engines and motor vehicles And and and the the the study that looked at that Was particularly looking at the the addition of catalytic converters and on on on automobiles in the boating industry the Try there's not a similar tracking of poisonings and deaths Some tracking has been done looking at the u.s. Coast Guard database and news clippings, but one of the issues with tracking poisonings is that Poisonings carbon dioxide poisonings have nonspecific Symptoms like headache and dizziness. And so we think as Mr. Wallace said that they're tremendously under reported because they they mimic other things So in in the boating industry the you know, we we don't have a track on the number of deaths that have Have been prior to or or after the After the the introduction of the loci omission generators. Thank you, mr. Don I have a follow-up question, but I'm out of time and I will now go to commissioner adler Thank you very much and thank you very much to the panel to all of you for participating Mr. Sal you raised some concerns about a shut off only approach to Generator safety and I was wondering if you could expand on what your concerns about Shut off only as an approach would be We have no doubt that it would be or could be effective in an enclosed space scenario where there's no ventilation But the data shows that as I reported as many as 60 percent of the cases are done where the generator is Either in a garage with a door open or outside of a window or under a porch or patio And the exhaust is drawn in through the window And if the shut off device were on the generator it would not detect the co levels that would be inside the home Where the occupants are versus where the generator might be parked. So that's our concern Yeah, and I did note that uh, mr. Dunn was talking about remote sensors But the actual pgma approaches I understand it is to place the sensor on the generator itself Am I correct in saying that correct and the issue with remote sensors is where do you put it? Yes People are mobile within the house and that addresses that we also are concerned some about Uh, if you're only doing detection is the durability and the Chemical sensitivity to those sensors We're doing it through oxygen sensor on the unit, which is we think a better approach Thank you very much. And mr. Kloak In your statement and in response to commissioner burkle, excuse me chairman burkle's question You indicate that catalyst degregate Degradation can occur with a low emission approach Uh, we know this technology has been used in other contexts as mr. Dunn said on automobiles and boats Do you have any Evidence to suggest that although this is a concern that it would be a serious safety risk If it were adopted for portable gas generators Yeah, so um, we the data that we've run with catalyst shows that there is a natural degradation of it Where it loses its effectivity throughout the life of it Several things can influence that there could be oil contamination Anytime you started it's going to run a little richer which will do that So we see varying degrees of degradation depending on the engines that we've run it on You know, so to give a number would be would be difficult, but it does Decreate throughout the life of the you know, I understand that and I could understand that in a laboratory You might see that but my question is when you've seen it actually applied in Context like automobiles in boats. Have you seen serious concerns? Arising because of catalyst degradation. Yeah, I don't know that I'm qualified to speak on behalf of I'm sure not so so I think I'll defer that Okay, and just one last question You're a multi-billion dollar organization. Is that correct? Our sales are just short of two billion. Okay, and you are a member of pgma. That's correct I'm just curious Would it be possible to dip into petty cash and help a pgma come up with the amount of money needed to? Pursuit this for your request. I really have trouble understanding how How an organization that has such rich members can't come up with $8,000 for a foyer request that can certainly be considered Okay, thank you. Thank you very much Mr. Weestat first of all, thank you for your testimony and I hope that pgma and cpsc will continue to work together Jointly and collaboratively. I certainly appreciate that I guess one question I have and this is just something that perplexes me is that you talk very Much about the necessity of co detectors monitors in people's homes And I'm always sad to see that people have not adopted that the same way they have Smoke alarms have any of your members considered including With the sale of a portable generator a co detector To my knowledge nobody does that and I'm curious if you've considered and if you've rejected it why that is We have actually considered that in fact in one of the first meetings that Pgma came to Share some of the efforts and activities that we had with with your commission We were suggesting that as an opportunity to where we could maybe work together to do such a thing But nothing has ever resulted from that activity Well, I hope that you'll continue to investigate that and just a quick question in terms of shutoff technology versus low emission technology Is it pgma's position that it's either or or is there any approach to Adopting both as mr. Sauer was suggesting So right now the pgma group is aligned strongly around a detection only approach A big factor in getting to that position is that Number one that is what we've seen to be the most effective Solution towards indoor space Which the technical group at pgma defines as Anything in a covered space which would include a garage with an open door Or an interior room where the windows have been attempted to ventilate We've seen some initial results from the nist 1782 data that we did receive. Thank you from the foyer request That actually indicate that we would see far more live saved under those conditions Again targeting indoor applications, which I think amounts to 90 some percent as we've As we've defined an indoor application of the deaths in the ideis We also saw some early evidence some of the some of the member participants shared some evidence that suggests That combining the two technologies together may actually be Harmful in terms of the impact on the result that the detection alone might actually save more lives than trying to combine the two Together and this was from some of the nista. I've dragged you into dangerous territory because you've run over my time limit Thank you very much for your answer and i'm sorry, uh, because I could see chairman berkels about to cut you off Thank you commissioner adler commissioner robinson First of all, thank you to all of you for participating in this This is so important that we have people like you coming in and telling us what We should or should not be doing in terms of our rulemaking. Um, mr. Wishad There's been a lot of complaining from pgma as you very well know about the foyer request to nist But my understanding is that um our staff very specifically told you that if you would just request If you do a foyer request initially of what they actually relied on which wasn't all the millions of documents that you've requested But rather what they relied on is the modeling information from nist technical loan 1925 and that's readily available and could have been easily and quickly obtained But my understanding is that you did not follow that recommendation And that you instead requested millions of documents about things that have absolutely nothing to do with what we relied on including Outdoor tests and so my question of you is have you considered limiting it to the information that our staff has told you That they relied upon for their npr? Well, um, I would like to um explain that when we requested the first request that was made to consumer product safety commission We outlined the items that we felt we needed out of the nist data which included The items specifically used by the npr um to our knowledge all of those items were used in the npr Your own organization came back to us and indicated which items they could not fulfill and suggested we go to nist At which time we went to nist with a very specific request around those additional items And what we are looking for help for with regards to fulfilling this foyer request Is right now we're in a state of waiting with nist They've provided us with a letter of course It was the eight thousand dollars i'm just going to interrupt you because i literally have five minutes But my question very specifically is have you tried limiting your request to the technical note 19 25? That's just a yes or no and then i have more questions for you our request is already limited to that Just 19 25 just the documents relating to the activity that would allow us to run the 100 000 simulations in 19 25 You were told that by staff as i understand it that all we relied on Where's the data that had to do with technical note 19 25? Have you tried to get just that specific information that we relied upon? I have personally reached out to kevin don at nist to try and explain that yes Okay, and you still don't have that that's easily obtained. We do not Okay, that's not my understanding of what nist understands you're asking for but let me ask you this That Everybody seems to agree whether you're for against the npr that it would be lovely if we had A strategy of detection and shutoff that actually worked does anybody on the panel know of a prototype of A machine that has been a portable generator that has been tested That actually will not have the nuisance shut off if it's on top if it's on the generator, but will actually Save lives because it's been looked at in real life situations in terms of the co migration Does anybody know of any testing that's been done? I'll take that one on behalf of generac this Generac has tested such a device in indoor and outdoor applications And our test data indicates that you would be able to reliably detect the difference between the two with a co detector Reliably detect a difference between what a nuisance condition where you would not shut off in a condition where you would reliably need to As that been tested in terms of i mean i'm i'm looking at the cpsc study on The safety shut off device that we published in 2013 which i'm sure you're very familiar with Where we looked at various scenarios where the co had migrated to places where people might be and be injured But wasn't near the generator itself so that it wasn't going to save lives Because the switch wasn't going to turn off but people could be killed or injured So we've tested prototype generators in indoor and outdoor situations In outdoor situations where the co the carbon monoxide is dispersing Uh, the generator would not shut off as as desired to do So my question is if you've found one that's successful i mean and the reason i'm asking this is because we know It's technologically feasible to lower co emissions by 90 from portable generators So if we're going to look at another kind of answer to this problem that we're all concerned with Do we have anything close to a machine? A sensor and a shut off device that will work with a portable generator in terms of turning it off appropriately Taking into consideration the migration of the carbon monoxide We believe we have made progress towards that end and have initial test results that suggest that would be the case for that reason we're trying to arrange a Closed meeting with members of cpsc staff to invite them out to participate and actually witness these tests My understanding from staff is that that no data has been has been yet shared. So we look forward to that. Thank you Thank you commissioner k Thank you madam chair. Thank you to the panelists This is a critical issue if you look at our Daily death reports. It's one of the top issues and it's been going on for years I think many of you recognize that there has to be a solution to this and hopefully What will come out of this process is something that conclusively addresses The deaths and injuries associated with these products. Mr. Clark, I'd like to begin with you Please and make sure I understand briggs's position Do I have it correct that briggs believes that if consumers understand that co-reduction occurred from the co reduced technology that they might Mistakenly believe that it's safe to operate one of those units indoors. Is that briggs position? Um, I wouldn't say that's our position, but that's a possibility It's hard to predict All consumers reactions to given situations, but that that definitely is a possibility So maybe then I should turn to mr. Wish that because I think you testified on behalf of pgma that that was Pgma's position at least that consumers would be Likely or might believe that a reduced co producing portable generator safe to operate indoors. Is that correct? We do have that concern as a as a member organization pgma. Yes, okay And so back to you mr. Clark if is that is briggs does briggs share that concern? That's the p is briggs pgma properly representing briggs individually. They are we're concerned with that Okay, and so back to you and thank you mr. Wish that for that if If a consumer believed that a portable generator that was outfitted with an auto shut off Would cut off any type of harmful scenario? Why wouldn't a consumer believe that was safe to operate indoors? Um What's the difference? I guess i'm asking in terms of consumer misunderstanding between an auto shut off and a reduced emission unit Well, I guess the the point is that if they did operate it And I can't speak for all consumers as far as how they would react to things But if they did operate it indoors it would shut off In a very quick period of time and the consumer would be safe So independent of their disposition on what they think could work or what couldn't work The the incident would not occur. Sure. I understand that's the theory behind it But as you just confirmed that one of the concerns that you that briggs has Is that consumer is being aware of the technology that the unit would have an auto shut off capability in the event of Of too much co in that concentrated area that consumers Would uh That there would be a different understanding. I'm trying to understand why consumers would necessarily Miss Use a product that was low co and bring that indoors But they wouldn't Miss use a product that was labeled as having an auto shut off and bring that indoors if that's the core concern And one of the criticisms of the reduced co unit But I guess under those conditions if they did bring the Co the generator with a shutdown system inside it would shut down safely The low co would not By itself But of course it would run at such a reduced level that consumers would have time to recognize the symptoms and get out If they do indeed recognize the symptoms. Okay, but so i'm not hearing anything about a reduced Sorry about an auto shut off that would Avoid consumer misuse correct Yeah, I don't know the hope I don't know that we can prevent all misuse for products that we sell Okay, mr. Wish dad you want to jump in on that one just on behalf of pgma and then maybe generate separately Well a couple points that I would share Comparing the two first of all generators are never going to be safe to operate it indoors at reduced co levels Whether they have shutoffs or not there are a number of hazards related to bringing them indoors Our concern is that in the event that you bring a reduced co generator indoors You will be building co and the the reliance on the consumer To become aware that they are being poisoned by co at some point is a is a very big open human factors question The shutoff provides the advantage that you can provide the consumer with feedback that the environment has become dangerous And carbon monoxide is building and in addition to shutting off the generator. They understand why? And so I think you just gave a ringing endorsement for combining the two technologies from my perspective Do you disagree or does pgma disagree that? Combining the technologies would actually cover more of the incident data than just using one alone Whichever one you choose what I can say is what I was elaborating on earlier that We still are looking for the balance of the NIST data because the data that we do have suggests that it may actually Be less impactful to combine the two technologies As it is to just go with the detection approach And mr. Sal is there anything you've seen that would support mr. Wish that's contention or belief No, it seems uh logical that if you're reduced by 90 percent you're making things safer and then have shutoff as a backup Just in case the consumer does put it in such an enclosed space that the sear levels will get dangerously high Great. Thanks. I'll come back to you in my second round. Thank you madam chair Thank you very much commissioner horovic Thank you madam chairman. I don't have any questions I just wanted to thank the panelists for their contributions to today's activity. Thank you Thank you very much. I will now begin second round of questions Again, we are commissioners will have five minutes per commissioner I wanted to follow up mr. Wish dad with regards to the question you were asking for commissioner adler with regards to And commissioner k brought it up as well the combination of the two technologies with regards to shutoff and low emission Your concern with regards to Whether or not that may not be as impactful as one might intuitively think if you have both technologies And you're saying that the answers to that are in the nist data Based on what we've seen in nist 1782 And the and the analysis we've been able to replicate comparing the two approaches and the combination of the approaches it suggests that if we're able to Expand our analysis from nist 1925 that Yes, we would see a reduced impact from both combining both technologies. Thank you We've heard quite a bit this morning about the revised ansi standard and maybe you could tell us a little bit Any of the details that you feel free to share with us this morning about the revisions to the to the standard Well, as of this point, um, the pgma technical committee has completed a draft standard Um Since pgma we're last visiting the commission that the technical committee has addressed some of the reliability concerns that have been presented Um, as you have already heard today That standard will be published For members to participate in a steering committee That will take place starting later this week We are having our first in-person meeting with that steering committee on april 3rd. Thank you very much for hosting that here um, we have as an organization set a Uh deadline for the steering committee of 60 days to address the reliability concerns based on input from manufacturers that feel we can get there in that time frame And so if all goes as planned and we get to our 60 days We could be In as early as june ready to take a final version of our standard out for canvass and full public comment Thank you very much I just wanted to ask mr. Dunn and mr. Wallace because it came up in commissioner k's questions With regards to this Unintended consequence if you just have a low c o emissions Do you either one of you and I start with mr. Dunn and then go to mr. Wallace have any concerns that the consumer would Thinking that now this is a low emission technology It's safer to bring indoors and that may be one of the unintended consequences I think there there is a possibility that that generators will be misused even low emission generators However, I think our our our understanding and experience from cars are that there are still deaths due to carbon dioxide from cars It's just that they're dramatically lower. They're they're 80 lower So they can also people can also be poisoned and die From emissions from cars. So I think the um the concept of lower emissions is it's by itself and More inherently safe design than a than a system with higher emissions Thank you. Um, mr. Wallace I agree with the the final part of the statement that inherently a product with lower emissions is going to be helpful for preventing the risk Preventing the injuries and deaths that could occur here. Um, I would say also that You know, we don't We don't think we don't have a We don't think one way or the other that that's necessarily the case that consumers would respond in that way. Um, we Certainly don't think it justifies taking a detection only approach Thank you. Uh, mr. Kloak. I just want to get back to the questions for mr. K with regards to the shutoff So essentially, are you saying that the shutoff technology takes the consumer out of the decision making? Correct Yeah, it basically it a lot it gives them a feedback that they're that they're operating the generator in a not safe manner With a warning and that their behavior needs to be changed to alleviate that and if they continue to do it It'll continue to shut off by the way Thank you That's all those are all the questions I have. Commissioner Adler. Thank you very much, madam chairman Ms. Pender I just have a quick question about your point with respect to cpsc lacking explicit statutory authority To regulate air pollutants or set emission limits You did quote from section 31 of cpsc and i'm impressed And one way of reading that is the way you read or another way of reading it is to say that it permits the cpsc to regulate Where epa has not eliminated or sufficiently reduced the risk of injury under the clean air act Now you've been listening to the testimony today about the severe issues with respect to portable gas generators So my question is to your knowledge and belief has epa solved the problem of the acute Risk of poisoning to consumers as opposed to the risk arising from concentrations in the ambient air Thank you for your question You know, I will again assert that epa has preemptive jurisdiction under the clean air act epa has taken action to regulate marine portable generators To a sufficient level and I would urge cpsc to work with epa as epa is the authority That has the ability and the obligation to regulate in the area So I think an appropriate approach would be for cpsc to ask epa to further introduce regulations That would appropriately address them. I would take strong issue with your notion that they have preemptive authority We have a statute similar to the clean air act our statute is every bit is Strong and valid and our statute was written after the clean air act was written So congress clearly knew what epa's authority was and yet they in effect said That where epa has not acted to sufficiently reduce or eliminate the risk of injury cpsc would have Authority and so my question is Based on what you know about epa regulations. Have they solved the problem of acute poisoning from portable gas generators? Let's say they have not solved the problem. However, I would Take a different approach or I have a different viewpoint with respect to the commission's authority And that it's not that epa has not taken action. It's that there is sufficient Has not been eliminated or reduced to a sufficient extent by actions taken under this daa So they do have that authority. They can take that action. They do regulate ceo missions And I would suggest that it's up to the commission to ask epa to go further Thank you very much for that answer. Mr. Wallace, you raised an intriguing recommendation that I hadn't thought about And that is about limiting the length which is done now of the cords to 10 feet And that does seem to send an implicit message to consumers that 10 feet is good And so one of the recommendations I never thought about and I will certainly contemplate Is to increase the length of generator cords to 30 to 40 feet But you heard mr. Weestat's comments, which I think are quite accurate that A significant number of deaths are resulting from people who've had their utilities cut off They don't want their neighbors to know that they're using a generator And then there are certain neighborhoods where people don't want to put a generator 30 or 40 feet away I love the idea of including that but it is not your suggestion that that would be sufficient to solve the problem That's correct. It wouldn't be sufficient to solve the problem It's a suggestion we're making based on what you discussed As as being possibly consumers getting the misapprehension that they could use it that close to their house If the cord's only 10 feet, but but again, it's not sufficient And so I gather that cus engineers have looked at the feasibility of automatic shutoff technologies And if I read your testimony correctly, it sounded me like you were saying they have not concluded that the technology is there Now have they guessed how long it would take for such technologies to be developed? I'm not asking you as an engineer, but some of you know our you know our work in our analysis is continuing Okay, um Mr. Dunn, uh, one of the things that you uh I'm out of town But it's going to be it would have been a great question. Thank you Thank you commissioner robinson probably the best one today, right? Um, mr. Wallace you make the made the statement that the fatality and injury reports in the cpsc databases including nice Probably are an underestimate of the injuries and deaths. Could you tell us why? Sure. Well, you one reason has been raised already, which is that um Potential generated related injuries may be mischaracterized. Um when treated at medical facilities um another reason Is uh, it can come from Um can come from those occasions when people do not People aren't treated. Um people You know suffer Suffer an injury that that they may not realize is um as long lasting or permanent as they may think Thank you. Mr. Cloak In your testimony, you said that carbon monoxide sensor technology has greatly advanced since the cpsc's Shut off device study and what you mentioned are that the advancements are longer life and increased durability Um, can you tell us? I mean you you mentioned house boats, but they have lower emission standards now And cars which also have lower emission standards So could you tell us what you mean by the sensor technology is greatly advanced? Yeah, so we've been running tests at our facility and that's one of the reasons why we're inviting the cpsc commissioners to come and Witness some of those tests. We've used a couple of sensor technologies that seem reliable To date we've had extension discussions with manufacturers who Are quite confident that they're reliable. So the whole industry has progressed Quite rapidly in the direction of making them more reliable to the point where we're getting comfortable That this is a solution that we can we can Be confident will give us a safe shutdown Okay, I I need something a little more specific than that when you say it's more reliable Are you testing it in situations where you're looking at air in other rooms of a house or Where occupants might actually be or more More reliable in terms of shutting it down at the If the carbon monoxide's around the generator or what do you mean by that? So we're doing I think the the word nuisance was used earlier in some of the some of the commentary So we're doing a variety of tests to make sure that it doesn't get tricked or Shuts down prematurely in in the event that it's outside. I think that was a lot of the earlier discussions from the cpsc findings that the Before I remember from reading that they weren't confident that it that it would reliably Shut it down and that there wouldn't be these nuisance shutdowns and and consumers would get annoyed with it So we've done a variety of tests Some enclosed enclosed areas completely some with Semi-enclosed areas and some outside And we're getting more confident as time goes on that that we can reliably design a system to shut down reliably I wish I had more time because i'm not sure that I understand that and I am I out of time You are out of time. Yes, okay Now it's going out. We will continue with commissioner k. Mission commissioner roverovic But if the commissioners agree to a three minute round of questions, we will have a hard stop at noon. So everyone can have a break Thank you Mr. Wish that just picking back up with you, please Why how is pgma able to move forward with a voluntary standard? If you haven't yet received the nist data and analyze the nist data to understand What the interplay might be between low co and shut off technology We're moving forward based on what we've seen with the foyer request that was fulfilled We're hopeful that we will have that nist data here within this 60 day period of time So that we'll be able to take that into account with our standard as well If it turns out that based on your analysis The your concerns are not valid that combining the two technologies might be less effective But in fact more effective is pgma willing to include in the standard a low co methodology I'm confident that the pgma technical group with the input from others in the steering committee will reach the best decision for all And when you say the best decision for all what is safety going to be the number one concern safety is always the number one concern Okay, so I have your commitment that if there is a safer option Then the shut off technology alone pgma will pursue that robustly I can't make that commitment for all of the members here today. Sorry. Can you do that on behalf of generac? Generac is committed to finding the safest solution to this problem period safety over any other factor It has to be reliable as well So there are multiple factors that have to be inclusive in that you can't simply rely on just the one aspect of safety sure but assuming that what mr Sal at tti and what coler have demonstrated are reliable if we take that As a as a given just for the sake of this argument Do I have generac's commitment at least or do we have generac's commitment? At least that safety will be the number one driver for whatever you pursue with pgma through pgma Safety is an important driver in this and yes, but I will contend that we still need to look at all the aspects of making a reliable solution that lasts for consumers and Is is going to work over long periods of time and work in all conditions that we can possibly come up with And again, then if if you're concerned about long-term reliability How do you push through a standard very quickly if you haven't yet assessed the long-term validity of the sensor technology? The the sensor technology that we've seen you've heard breaks and stratton talk about it here today based on some of their testing I know that other manufacturers on pgma have done similar testing And are seeing similar results And we're confident that the detection methodologies that are available today are reliable and in and of themselves Not only would be far faster to market in terms of The ability to get this solution deployed But also might bring the advantages of retro activity where a device could be Manufactured that a consumer could choose to add to their existing generator We all know that generator lifespan in consumer hands is is 10 to 15 years and even more in some cases And in that case any any rule that contemplates significant design changes without a retroactive perspective would Would take years and years and years to actually have the impact we'd all like to see happen tomorrow And I don't want to and i'm talking to you now in your general capacity, by the way not pgma I don't want to get into Clearly the proprietary information that you shared and you're kind to share with us during our trip in 2013 I think it was 2013 But safe to say that or is it safe to say that generac had at that time an open mind of pursuing whatever technologies And researching whatever technologies Would be most likely to yield the best safety results including reliability and performance blah blah blah Um generac has an open mind towards that of course We were at the very beginning stages of Understanding of this problem at that point. So I would say that It would make a lot of sense for you to come out and let us share with you what we've done since Yeah, and I guess that's the the problem that i'm having reconciling is The generac visit that we had I'm not feeling as consistent with the Direction and limited approach that pgma is taking and that's something you and I might have to discuss privately as to Why I have that misunderstanding and what if there is any disconnect between what generac has been pursuing The robust and broad way generac had been looking at it and in my mind narrow way the pgma and your role in pgma The way that's proceeding, but we can talk offline about that. Happy to do that in my remaining time. Mr. Clark I do want to Tell you right here. I'll take you up on your offer to come out When I did make my visit to mr Sal knows as well because we visited them as well as honda in 2013 At that time Briggs declined to have us visit. That was very disappointing considering your market presence But it's heartening to know at this point that you feel you've developed something that's sufficient enough to share with us And we will be eager to have that visit. Thank you. Thank you commissioner k commissioner moor over Thank you, madam chairman I should have objected to your offer the commission for another round of questioning because I thought maybe I could sell Yielding some of my time to some of my colleagues. I was thinking maybe for the consideration of support for ex ante retrospective review embedded into the rule, but I think it makes it less valuable now no questions Thank you commission rovick. I wanted to talk. I'll we now Mr. Stevens and we're going to have a round of three minute questions. Okay. Thank you Um I wanted to just talk about because it was referred to the study that had been done on shut off technology by cpsc um Between now between then and now has the technology improved on shut off technology I guess I'll ask mr. Kloak and then mr Weesh dead yes based on based on working with suppliers and as well as surveying what's going on in industry that the technology has improved Thank you mr. Weesh dead. Yeah, we've we've seen significant advancements In the technology since the staff looked at the shut off technology, which I believe was over 10 years ago now um at that time The detection technology that was employed was one Had algorithms that were specifically tuned to 2034's requirements Which are longer term sort of periods of time that it takes for the shut off to respond Those devices are not tuned to the situation that is presented by a generator Running in a in a space where co is accumulating And so we've seen algorithms themselves who have advanced great quite significantly We've also seen advances in the technology itself both from reliability manufacturability survivability of Contamination to co or other hazardous chemicals has improved greatly Mechanical robustness has also improved significantly since the time of the initial studies. Yes. Thank you very much Mr. Dunn I wanted to just talk to you a little bit about And and also for mr. Wallace with regards to co And of course it's it's very insidious Effects on the on the consumer If if someone is exposed to low levels of co Which would happen in if you lower the emissions, but then there's a misuse of the product. I'm interested to know Does the low even though the co emission is much lower? Will that have an effect on the consumer? As an engineer not as a physician. I struggle with some of these questions There have been some studies looking at low co exposure And health effects and and unfortunately dr. Weaver could probably help us answer those But I I don't have a good read on that. Thank you. Mr. Wallace. Do you have anything to add to that? No, nothing to add on that. Um, it's outside my area of expertise. Thank you I miss um, pen do I wanted to go back to the jurisdictional issue because that's Of concern to me and I raised it when we had our public hearing And our briefing I should say about portable generators with regards to What you're saying to us with regards to EPA's jurisdiction over emission controls You're not saying we can't Regulate the shut off technology. You're saying that the low emission piece of of this in our npr is what is of concern to you Oh, correct. Okay. All right. Thank you. I am almost out of time. So I will Yield to commissioner adler. Thank you Now I'm put to my proof of asking a great question. It wasn't that great But again, thank you all for enduring three rounds of question. We really do appreciate it So, uh, my my question to you is that it's one of the statistics you cited. Mr. Dunn was it's excuse me. It's dr. Dunn, isn't it? Dr. Dunn since 1975 when automakers began installing Cadillac converters on their cars. There was a greater than 80 percent decline in unintentional vehicle related co desks And uh, I know cars are different from portable gas generators But have you seen any estimates about the likelihood of low emission? Generators with this catalytic technology and in the likely effectiveness of that it's All right, it is it's hard to say On that But I would say With cars it's a it's the best example we have And so we look at that and look at because as I've mentioned to madam chairwoman that As the emissions have come down And that graph you can see the trends follow very closely that There are still deaths related to motor vehicle exhaust. It's just The the emissions came down by about 75 percent and the unintentional deaths also came down about 80 percent So they tracked very well And so I think that That's the example that we have to look at now and I don't have You know any other insight beyond you know that that example and we try to look at it because I think That we're talking about engine and engine exhausts and misuse So many of the characteristics may be similar across both examples. Thank you very much for that. Mr. Sal You indicate that tti will be able to incorporate a shutoff technology that does not rely on chemical sensing devices And that has the potential to have a higher reliability Can you explain in a little bit more detail how your shutoff technology would work and why you think it's superior? Yes Well when you're in enclosed space and the carbon monoxide levels increase the oxygen Oxygen levels will decrease And through an oxygen sensor which is readily used in the automotive industry Located in the engine you can shut off using that So if oxygen gets below the ambient of around 19 percent then in the 17 percent realm the engine can shut off Be lovely if it were also less costly, but I won't ask you about the cost I did want to ask mr. Weestat about cost. I love the idea About a retrofit to portable gas generators and I was curious has anybody done any Pricing of that versus just mailing out carbon monoxide detectors. I love the idea of doing both But has anybody done any cost estimates for the retrofit? I honestly don't know. Thank you Thank you commissioner ravinson Yes, um, there are several witnesses who are going to who are appearing and will appear Before us who are saying that the shutoff sensor and shutoff technology Are superior and more reliable and a lot of statements that I hope are true But I know that our staff has been very frustrated at having no data whatsoever presented to them to Support that and I don't have any question in my mind at all that We are very much trying to get it right and we're trying to find the the Technology that's going to save the most lives and we want to get started quickly So I am glad mr. Weestat that you are going to share the data that I understand is going to show why a shutoff mechanism And sensor today is going to shut off appropriately even if the carbon monoxide has migrated Mr. Kloak, I also will take you up on your invitation and I and I have not asked you But I assume you will share any data you have with respect to the sensor and shutoff Technology, yeah Okay, great. Mr. So why have why have you determined that you really need both? I mean you guys are obviously working on the sensor and the shutoff technology But why have you decided you need both that and the lower emissions? well the Lower emission seems to be pretty obvious to us that it would reduce Desk and some of the NIST simulations over a hundred thousand of them showed that to be the case The shutoff is there more Or less as a Failsafe measure for some reason someone does misuse of putting the garage. They're in the garage with it There's no harm in providing a shutoff as well and with the o2 sensor It's a relatively inexpensive and effective way to do it. We believe And we believe also we can shut off at a much lower Level of parts per million than is necessary somewhere around the 200 range So why not provide an additional what we feel is a safe measure when it's there and able to be done technologically And why is it that you've decided that's not sufficient in and of itself without the lower emissions? Our concern back to my earlier comments is when the generators are used outdoors um, and I've read cases where they're used on a porch near a window air conditioner and people inside Pass away It's also more prevalent from the injury side where if you're in the room with it your deaths are more likely to occur when you have a Scenario where the generator is further away, maybe underneath a mobile home There's lots of cases of that campus horse trails, etc. Where the concentrations may not be as high and you get injuries instead We feel confident it would prevent those as well Let me ask the entire panel has ever there's been a lot of talk about the cold start and that there are more Emissions at the beginning does anyone know of a single incident injury or death that occurred While the generators being started during the cold start because I don't know of any bodies we've found in those circumstances Nobody um That that detail is generally not present in the idei database that we received through the foyer request So you don't know of any that have happened at the very beginning when it's first started No, because the data wouldn't substantiate one way or the other. I'm out of time again chairman It's hard The dr. Weaver's on the phone again. And just in case you have any other questions for him Thank you very much. Mr. Stevenson Commissioner k Thank you, madam chair Ms. Pendo If I can go back to something I think you said earlier and maybe you can reiterate it, please That it would be well If you could please explain your concerns about measuring in both grams per kilowatt hour as required by epa and grams per Hour as would be required by the staff's proposal or by the commission's proposal What are those concerns? Sure the concerns are that the The technique to measure emissions that's proposed by the proposed rule Is is is not a methodology that will accurately represent The difference between emissions produced by small and large engines because it doesn't take into account The amount of work that the engine does So this the the measurement that epa uses and its its regulations account for the work down by the engine on a grams per Kilowatt hour basis and in that way both small and large engines can be compared to each other And treated fairly by the standards based on the amount of work that the engine does and you know EPA is demonstrated and we've demonstrated that they're that epa's method results in greater accuracy So as commissioner morova was whispering to me the same question. I'm about to ask you now Why is that relevant meaning it and I am not An engineer that is probably very evident to anybody that ever has spoken with me But I have worked on this issue for a number of years and I've never heard that before what I have heard is That if you measure in grams per kilowatt hour, of course larger machines produce more co And it would not be an equal comparison meaning a smaller machine In a grams per kilowatt hour measurement Would produce less co than a larger machine in a grams per kilowatt hour measurement But what the grams per hour measurement does it equalizes it across machines? And so first of all, is that accurate whether or not you agree with the technical Validity behind that is is it accurate to say that if you measure by grams per hour you are Measuring objectively the co That comes from a machine regardless of its engine size. Is that accurate? I apologize. I am not an engineer either So I don't have the expertise to definitively answer your question. Mr. Wish that is that accurate Grams per hour is an absolute measurement of emissions. Yes, so it doesn't matter regarding the engine size You still would get an absolute measurement of the co that comes out of that unit. Is that correct? By a grams per hour measurement as opposed to grams per kilowatt hour measurement Under the conditions of the test. Yes And so Ultimately, aren't we concerned about miss pendo aren't we mostly concerned about consumers meaning for a consumer Doesn't it matter objectively what that absolute number that absolute co emission is meaning? They don't know Under the grams per kilowatt hour that they might actually be putting themselves in a riskier riskier scenario And I notice my time is is expiring which is very unfortunate Riskier scenario if they buy a bigger machine than if they have a small machine, is that correct? Okay, I'm out of time I would I would just mention madam chair that Well, I certainly appreciate having run meetings and the time of the panelists There was no time in the last few years where we ever cut off questions I believe other commissioners might still have questions and my hope is that unless and if panelists have to leave We've done that to let them leave that we would consider accommodating another round. Thank you To meet two commissioner k's point This was discussed with Executive director, and I think we have a plan in place if there are other questions. I'm sure the Panelists would be willing to take something into in writing to them, but I would say that We're going to stick to the schedule. I apologize if you feel you've been cut off But that's our schedule and so I apologize to anyone if you feel you have something more to say Especially to my colleagues, but the schedule has been set. We will reconvene at one o'clock Thank you very much to all of the panelists here today I want to thank you for taking the time to come here time and treasure and we do appreciate your input very very much Thank you