 Good morning and welcome to this public meeting of Consumer Product Safety Commission. This morning, CPSC staff will brief the commission on its work regarding carbon monoxide sensors and gas appliances. Since I arrived at the commission four months ago, carbon monoxide poisoning from consumer products has been front of mind for me. Carbon monoxide is known as the invisible killer. It's odorless, colorless, and can kill in minutes. Most recently, I've been talking with the public about winter safety and the need to be aware of carbon monoxide risk regarding portable generators. Today we're talking about the same risk, but from a different source. The gas appliances we use inside our homes, especially furnaces and boilers. They're the second leading cause of a non-fire-related carbon monoxide test in the U.S. I look forward to hearing about CPSC's work in this space, the safety solutions that currently exist, and to explore the next steps we can take to prevent carbon monoxide poisoning in homes. Today we have just one briefer, Ron Jordan, Program Manager and the Director for Engineering Sciences and also in attendance are Mary Boyle, Executive Director, Austin Schlick, General Counsel, Alberta Mills, CPSC Secretary. Once Mr. Jordan has completed the briefing, each commissioner will have up to 10 minutes to ask questions with multiple rounds if necessary. I will now turn the gavel over to Mr. Jordan. Welcome. Good morning. Can everybody hear me? Yes, sir. Great. Well, welcome to CPSC. My name is Ronald Jordan and I'm a Mechanical Engineer within CPSC's Directorate for Engineering Sciences. I'm also the Project Manager for CPSC's Gas Appliance CO-Sensor Project. And this morning I'm going to talk to you about what we're trying to accomplish in that project and also the status of those efforts. Next slide. Just to introduce you to what we're talking about, the scope of this project includes central gas furnaces. As you see in the left-hand side of your screen, they're located typically in your basement or your attic in crawl spaces, garages, practically anywhere. And they're probably the most commonly used gas appliance, gas heating appliance, followed by gas boilers. This is an upright gas boiler that you'll typically find in your basement. A newer innovation in the gas appliance industry as the picture in the middle are tankless gas boilers. And essentially they have a much smaller footprint than the traditional upright gas boiler. They heat water just like the gas boilers, but they take up much less of a smaller footprint. And you don't have the storage tank that you would use typically in a gas boiler. They shouldn't be confused with gas water heaters. As gas water heaters or tankless gas water heaters, they use a heat water for hot water, whereas gas boilers heat water to provide comfort heat to the home. The last two products are on your right-hand side of the frame. They include wall furnaces and floor furnaces. And unlike the first three, these are pretty much designed to heat the room that they're located in. And sometimes you may get carry-over heat to an adjacent room, but they don't provide central heating. Next slide, please. So the problem that we have with these products are that they're the second-leading cause of non-fire-related CO poisoning deaths in the United States. And the other part of that problem is that when you look at the U.S. voluntary standards that govern these products, that they don't have provisions that protect consumers from known hazard patterns that cause or contribute to CO poisoning. And that's what we're here to address. Next slide. To understand the problem from an engineering standpoint, it's important to understand the root cause of the problem. At the root of this is whether or not the hydrocarbon fuels are burned completely. With these appliances, we're dealing with natural gas or propane. If you burn the fuel completely, then you'll have complete combustion and you shouldn't produce very much CO. The problem lies when you have incomplete combustion. And when you don't have complete combustion, you're more likely to produce elevated levels of carbon monoxide. The other part of the problem, the other part of the root cause is that when a leakage path or mechanism exists or is created that allows the CO that's created through incomplete combustion to leak from inside of the appliance into the living space of a home, then it comes into contact with consumers. And so when we look at the hazard patterns that we've seen in incidents involving CO and gas appliances, these are the root causes that we see when we look at the incidents that have been reported to us or that we investigated. Next slide. Just to give you a visual of what some of these hazards look like or some of these failure mechanisms or root causes look like. To the left, we have a disconnect event. That's probably the most common occurrence where you have either the vent that's designed to vent products safely to the outside of the house becomes disconnected. That also happens when you have that type of breach or opening in a masonry chimney and other parts of the flu passageways that are designed to convey the combustion products from inside of the appliance to the outside of the home. So anywhere along that path, if you have a disconnect, if you have an opening, if you have a breach, it creates a space for products to leak from inside the appliance into the home and that causes problems. The other very common failure mode that we see are partially block vents or chimneys. And what happens there is, as you can see in this picture, you have a vent, then an appliance that's venting into the masonry chimney. Sometimes, if you don't line the chimney, the water vapor from the hot gases will condense and cause the mortar to decay inside the chimney, causing the bricks to collapse, causing a blockage. You have animals that build nests in chimneys that are caused a blockage. You also have problems with both of these. You can have improper installation, improper maintenance. You can have product failure. We've had a number of incidents where there have been failure of the actual vent material. And so we recognize that there are a lot of different ways for a product to fail, either through conditions that lead to incomplete combustion or conditions that cause, that allow the combustion products to leak from the appliance into the living space. One thing that we'll be talking about is how our approach, regardless of the failure modes that the appliance may come up against, our approach deals with it by addressing the problem at the source of production of CO and that's in the appliance. Next slide. Okay. And just to summarize what we're talking about, the hazard pattern is carbon monoxide poisoning from gas appliances. We're focused on gas furnaces and gas boilers. And the hazard patterns, again, are incomplete combustion, which can be caused by either not having enough combustion air to complete the combustion, having too much fuel or reducing the flame temperature at the burner, the burning of the burner flame. We also just went over the leakage paths. And these are the things that we see when we look at incidents that we investigate. Next slide. Just to give you a feel for the impact of this problem, between 2000 and 2018, there have been a total of 504 estimated CO depths associated with these class or products that we're dealing with that averages out to about 27 deaths per year. And again, that's between 2000 and 2018. Next slide. So what's the purpose? The purpose of this project is to reduce the CO depths and injuries by improving the performance requirements for the appliances. Again, we want to deal with the problem at the source, make the products safer so that when any of these conditions occur, regardless of what the cause, that the product that the appliance can deal with it and perform in a safe manner. Our statutory authority is the Consumer Product Safety Act. And just to give you a glimpse at some of the things that we're currently working on. So we've been working to establish the expected lifespan of CO or combustion sensors or controllers when they're using this harsh environment of a gas appliance. We've also, we've been aware for a number of years of standards in Europe and Japan. And so we've been looking at what's been going on in those parts of the world to see how they deal with the same very similar problems. And then ultimately our ultimate goal is to develop a performance requirement that will help to reduce the CO depths and injuries. Next slide. So the relevant U.S. standards that we're dealing with and that we've dealt with over the years have been the ANZZ-21 set up gas appliance standards. For the products that we're looking at, the specific standards are ANZZ-21.47 for gas-fired central furnaces, ANZZ-21.13 for a gas-fired low-pressure steam and hot water boilers, and ANZZ-21.86 for vented gas-fired space heating appliances. But the caveat there is that we're only focused on gas wall furnaces and gas floor furnaces. There are other types of products addressing that standard that we're not attempting to address because they do have provisions in place. Next slide, please. Just to give you a little bit of background on this project, we've been engaged, actually our engagement with the ANZZ-21 set of standards go back to almost to the beginning of this agency. But in terms of the specific approach that we've used to address this hazard, we've been dealing with the Z-21-83 technical committee and a subordinate technical subcommittees for gas furnaces, boilers, wall furnaces, and floor furnaces. So back in 2000, we developed a proposal that was designed to mitigate this hazard, and the proposal essentially called for, it's important first to understand that there are combustion emissions requirements in each standard that specify how much CO the appliance can safely produce. And for these products, that level is 400 parts per million in an air-free fuel sample. So that is the emission standard for these products. As it stands now, even though that's how they're required to perform, there's no mechanism or there's no means to ensure that once they leave the factory that they will continue to produce within the emission limits of the standard, the 400 parts per million. So our first proposal or the first part of our proposal was to provide a means of limit gas appliance emissions to that standard limit of 400 parts per million. If that couldn't be accomplished, the next option would be to require a means to shut down the appliance if it reach or exceeded the 400 parts per million. I'm going to stop here because I see that my slides went away and I'll wait for those to come back. Here we go. Okay, so I left off at the proposal bill at number two, which was to require a means to shut off the appliance if the CO emissions reach or exceeded 400 parts per million. And then the other option would be to require a means for the appliances operation to be modulated to reduce the CO emissions to below 400 parts per million. The subparts of those two proposals were that in addition to just looking directly at CO emissions, we also allowed for looking at other combustion conditions that cause CO emissions to exceed 400 parts per million. So there are different ways to monitor the combustion process. So we weren't limiting our proposal to just CO monitoring, but there are other parameters in combustion that you can look at and monitor and possibly control that would help to control CO emissions. Next slide. So by way of further background, can you go back one slide please? By way of background, further background. So we made this proposal and as an engineer, I understand that you would need some type of device or a sensor to monitor accomplish what was being done. And so we had done proof of concept testing back in 2001 and 2004. And then some additional testing as the years went by to demonstrate the concept of using a seal sensor or a combustion sensor in the appliance. The Z2183 technical committee questioned the viability of sensors being used in that environment. The major concern launched, this was back in 2005, was that there were no sensors that were commercially available that had the durability to survive in that environment and to last the expected lifespan of the appliance, which is estimated to be about 20 years. Well, part of the efforts of the working group were designed to look into those things, but that's part of the background. We've conducted quite a bit of research to look at these concerns and I talked about some of them earlier. We've contracted with a vendor to conduct the accelerated life testing of seal and combustion sensors in the most severe conditions that they would encounter. They're stressors. We also contracted with another vendor to conduct an impact study of the impact of seal sensors, combustion sensors, and gas appliances in Europe and Japan. Next slide. So for years, we've known that there are international standards that have very similar seal set off provisions that we've proposed back in 2000 and then again in 2015. They are the Japanese industrial standards, GIS, for a gas burning water heaters, hydronic heaters, which are boilers. Those are gas boilers and gas space heaters. Also, the Committee for European Standardization, they have a couple standards for gas boilers, for domestic gas boilers, and also standard for combustion product sensing devices that would be used in those boilers or other appliances. So these international standards demonstrate pretty much what we've been pushing for the last 20 plus years that it can be done. It has been done in Europe and Japan. Next slide. And here are a few examples of gas appliances from Europe and Japan that are equipped with CO and combustion sensing devices. A number of these we've acquired ourselves for examination. So you have tankless gas water heaters, which are very similar to gas boilers. The only difference, the combustion process is the same. It's just what your demand is, which load is, how much water do you want to heat and for what purposes. But in terms of the basic operations of the appliances, these products are all pretty much sustained from a combustion standpoint and from a technology standpoint. It's just how do you decide to use the appliance? Do you want to heat water for hot water or do you want to heat water for comfort heating? So they have units equipped with seal sensors, as well as combustion controllers that accomplish that by monitoring the air fuel ratio of the combustion process. Next slide. I said I was going to provide a status and this is that back in 2018 we were approved to work on the AMPR, which me and my project team did. The AMPR was published in the federal register in August of 2019. The commission approved my project to work on the MPR and the FY22 performance budget request. However, during the operating plan hearings for the FY22 operating plan, the commission changed our MPR deliverable to a data analysis technical review, which we've been working on. We continue our efforts to develop documents through this DATR that would be needed for our MPR and we continue to work with the Z21 set of technical committees and technical subcommittees. We do plan to propose to the commission that an MPR would be pursued in the FY23 operating plan. Next slide. Just want to quickly introduce you to my project team. I'm the project manager, Mr. Brett Griffin from the Director of Economics, Lynn Wang from Health Sciences, Matt Nataw from Epidemiology, Tim Smith also from Engineering Sciences, and then Dave DiMatteo from the Office of General Counsel. We've all been working diligently to get the work done, but thank you for your time and that concludes my presentation. Thank you, Mr. Jordan, and thanks to your team as well. At this point in time, we're going to turn to questions from the commissioners. I mentioned 10 minute rounds with multiple rounds of necessary, 10 minute question with multiple rounds of necessary. I'm going to start with myself, and Mr. Jordan, thank you very much for presenting today and the work that you've been doing. Let's say, as has been said, carbon dioxide is an invisible killer, and sadly, it's one that can kill not just one person when an appliance fails, but entire households. I was recently reading a report about seven members of a household in Moorhead, Minnesota who died of carbon dioxide poisoning from a malfunctioning furnace just days before Christmas. It's an entire family who's gone an instant, and these are the type of horrific events that we as an agency must try and prevent. There have been assertions made that the sensors required to detect carbon dioxide conditions won't work as needed in these systems. It seems like your staff's research contradicts that. Is that consistent with what you were finding? Yeah, that's been our experience. Our research today indicates other ones. We've conducted sensor testing to demonstrate durability and diffusability, and we also know that there are, as I mentioned in my presentation, that there are European and Japanese standards that are dealing with very similar issues. The combustion process isn't that much different. There are some design differences, but they've been able to overcome what I would expect to be the same types of problems encountered here in this country. I don't believe that's the case, that they're unreliable. I think that the evidence in Japan and Europe kind of speak differently to that. Going to that, if I looked at your slide correctly, seems like the first Japanese standard was put in place around 13 years ago. How long has it been in place in Europe? Do you know off the top of your head? I don't know the age of the European standards for boilers. I know that the standard for this sensing device became effective in, I believe it was 2014 to 2016 timeframe. The standards for boilers have been in place for much longer than that, but I don't have the actual timeframe for that. So it's been in the marketplace for quite some time, it sounds like. With respect to the US, do any of the voluntary standards in these products, do they apply to the carbon monoxide sensing that you're talking about in the European? Are you asking whether the European standards can be used in the US? Currently in the US standards of voluntary standards that exist out there, do they address any of the carbon monoxide problems that you're seeing and that we're talking about today? Okay, I'm sorry, I misunderstood you at first. We don't believe that they adequately address the CO issues that we face here in this country. They do address one third mechanism and that's totally block events, but they don't address other things which are very common, such as disconnect events, depressurization of a room, snow blockage of a sidewall vented appliance. Historically back in the early to mid 80s, there was actually disconnect event coverage in the furnace standard and that was removed. So they don't have any effect provisions currently in the standards. And when we look at the incidents that we investigate, we see the consequences of that because we see modern appliances with the modern devices and equipment on it still being involved in CO poisoning incidents. You know, going back to the family I was talking about this mother, father, four kids, all died in one night. This has been going on far too long. I know you talked about FY 23 plan, but would it be possible to accelerate the the NPR done in this fiscal year if the Commission directed so? Yes, I'll defer that. I'll take that one. So yes, if direction to the staff changes, we can submit an NPR to the Commission this fiscal year. The staff continued to work on on this area as directed by the Commission, although some staff resources were shifted given the lack of an NPR deliverable in the current operating plan. But yes, we can submit an NPR this year if that direction changes. Thanks, Jordan. Those are my questions. I'm turning to Commissioner Biacco. Okay, I'm on now. Mr. Jordan, nice to meet you. I don't think we've had a chance to meet along the way. And I appreciate all your introduction and introducing us to your team. And let's start with that very issue. So understand that, you know, one of the reasons I personally supported changing the NPR to a technical analysis is that I came in 2018. It sounds to me like you guys have been working on this for 22 years plus. And I don't have a background. So I do have probably more questions than some people do. And it's not to question what you or your team has been doing. They're just questions that I don't have answers to yet. So if you'll bear with me. And I know you mentioned something, and I guess really proving my point that in the mid 80s, there was one standard. And, you know, now we have made a different standard in 2000. We have a different standard now. And so before we have the NPR out there, I'd like to know what exactly we're dealing with right now. Because in 2000, we're still using typewriters. And I don't know if many things have changed. I just don't know if many things have changed since then. So let's start with one of the things, and I'm going to jump all over the place because I was scribbling here. One of the things that you said, and this is in no particular order, where the hazard pattern are conditions that cause CO poisoning. Conditions, if I understand correctly, are not necessarily the boiler or the furnace, correct? The actual product. No, it runs the gamut. It can include the product and it can also include the vent systems. So the family that the chairman was referring to, I mean, nobody wants CO poisoning for anybody, not one single person. The family he was referring to though, was that those deaths were they caused by the product or the conditions, like a block vent or, you know, maintenance issue? Well, I haven't had a chance to review that incident. So it would be probably inappropriate for me to speak to that one. But I can speak in general that, you know, you don't have a complete installation of a gas appliance that's designed to be vented unless it's properly vented either through a vent pipe or to a masonry chimney to safely remove those products to the outside of the dwelling. So the conditions come along with the products that they're part of the installation environment that the product has to operate in and that have to be in proper order in order for the product installation to be whole and to be appropriate. So if you don't install the vent system properly, in accordance with the manufacturer's instructions and the local building code, you don't have a valid installation. You don't have a safe installation. Okay, I get that. So let's assume we have a safe installation. And then the vent breaks later for something else occurs. I think you see the example you gave us snow piling up on the side of the house and blocking that vent. So you can have a complete proper installation, but there conditions beyond the product and the installation that cause, for example, you know, CO poisoning in the house. Well, that's true. But again, but again, the vent pipe, the furnace installation or the boiler installation is not complete or safe unless it's properly vented to the outdoors through the use of a vent pipe or a chimney. Some of the conditions that lead to these tragedies, some of them are associated with the vent pipe or the chimney, but some of them that the ones that tend to lead to the incomplete combustion are the things going on within the appliance. There's too much here. Okay, I'm sorry. That's what I'm trying to drill down on, trying to get a better understanding because over an 18-year period, we had, you know, about 27 deaths. As Alex pointed out, there were households, so it would be in situations versus individual deaths. I think the one he was talking to was one household with several deaths, so that number would vary. And I'm trying to figure out how many of those were caused by the product itself or something outside of the product, like a blocked air vent, even with an appropriate installation. That's all I'm trying to get a feel for. And I guess I don't have that breakdown in front of me, but I will say this, that we don't disassociate the condition of the vent from the appliance because even though the vent may become disconnected, if you're producing dangerous levels of CO inside the appliance, that's where the problem lies. And also, even if you have a properly operating appliance, when you start leaking combustion products into the atmosphere, you can start depleting the oxygen, which is the foul of the combustion even more. That's exactly what I'm asking about, so that's helpful. I get that. On that issue, and Alex cut me off when my time is up because I have an entire page of questions that maybe somebody else will ask. The CO admissions that you refer to, the 400 parts, was it PPM? I didn't write that down. Okay, admissions themselves, and maybe this is not an appropriate question for you, but isn't that an EPA issue versus a product issue? Or am I wrong about that? No, so there are a number of agencies that have different involvement that have overlapping or cross cutting activities. So for product safety, this is fairly a product issue and it's a CPSC issue because it goes to the health and safety of consumers. And so the operation of that appliance, whether it's producing 400 parts per million or 40 or 4,000, that goes to the appliance and the standards that are designed to make that product perform safely. Okay, got it. And do the other agencies who have overlapping jurisdiction, are they with us on the, are the standards all the same, 400 parts per million? No, we'll see. Or unsafe. Well, this is the 400 parts per million as part of the voluntary standard. They're not government standards. Okay, I missed that. But do we have an idea of what the other agencies say as far as what is a quote unquote safe or not safe number there, the 400 parts per million? Right. No, I think that EPA, I don't want to speak for them. Actually, I'll defer that to somebody from EPA, but I just know that generally speaking, they deal with indoor air quality from a number of sources. And carbon monoxide is just one of multiple things that affect indoor air quality. So they deal with it from a holistic standpoint, they're looking at any pollutants that can be in the indoors. And that's the overlap with us. Whereas work focused on the safety and operation of the appliance. Okay. One of the things that I know I've been, I have a strong feeling about, and some of the other commissioners do as well, is how long it's taken the agency to address issues in front of them. And like in this case, you're talking about, you've been doing this since the 2000, early 2000. Why did the agency, was there a reason why no voluntary standards were put in place to address this? Or the agency hasn't taken any steps in that 22 years? Do you know? Right. So we're, as you know, we're required to work through the voluntary standards process, which we've been doing. We've made two proposals, the first in 2000. And we've supported it with test documentation, incident data, things like that. We worked each time we made a proposal, the technical committee would establish a working group to examine our proposal. And those working groups were in operation for about three to four years. So going back to 2000, they established the working group in 2002. We spent the next three to four years working on our objectives for that working group. Unfortunately, that effort ended with the Z21 technical, the Z2183 technical committee, disbanding that working group. The concern that was raised back then was that, well, they don't have a lifespan of the durability of the appliance. So we conducted some testing in the following years to address that issue. We wrote a report, we shared it with industry. So now we're up into, I think it was 2012, by the time we finally published that report. We continued, we stayed engaged with the industry through the voluntary standards. We weren't seeing anything happening. So we called for a request for information back in 2014. We were trying to get gathered information from all stakeholders that might know anything about this issue, including the gas appliance industry. We held a forum to discuss those concerns in 2014. And then in 2015, because nothing had happened in terms of standard development, we wrote another proposal. We submitted it. The technical committee once again established another working group. We spent about three to four years working on our objectives. In 2019, the technical committee disbanded that working group. And unfortunately, again, without developing a standard, again, without doing work that might be necessary to give them a better comfort level or understanding of the problem or how to address it through sensors. So yeah, when you look at it just from a timeline, it's like, wow, that's a long time. But when you're in trenches, what's going on from the beginning up through the current? I've seen this standard drag for these standards committees drag. What's the big objective? Has it been the same since 2000 to today? Is it the same? And Ms. Turner, if you can answer that quickly, because time has run and I'm sorry. No, no, not at all. I'm happy to go for another round, but I just didn't want to let the other commissioners talk as well. I'm sorry. No, these are great questions. So commissioner, yeah, I appreciate them. Mr. Orr, did you want to answer that one quickly? Or we can come back to it when the next round, if you think it's a longer answer. Right. So when we published the AMPR and we got responses from industry, they did raise a lot more additional concerns beyond what was raised back in 2005 about the lifespan. I think a lot of them, they're very addressable and they have been addressed. But the primary issue has been the lifespan. They want sensors to last the life of the appliance. So that's a major concern and a major obstacle as I see it. Thank you, Mr. Jordan. Thank you, Mr. Biakko. Mr. Feldman. Thank you, Mr. Chairman. And I'm happy to yield some of my time back to Commissioner Biakko if she has additional questions. It'll take a couple rounds. So go ahead, Peter. Maybe you'll have some. Mr. Jordan, thank you for the presentation today. This was comprehensive and frankly, when the commission's engaged in rulemaking, coming forward with the mandatory standard on performance requirements, this is the format and the way forward that we should always engage in. Having an opportunity to hear from you and hear what your staff is doing and to have this kind of public discourse where we've got an opportunity to ask questions. And again, I think this is the first time that you and I are having a chance to sit down in a forum like this. So Mr. Chair, I appreciate you making staff available to answer questions about the work and the research that they've been up to. Taking backing off of questions that I heard Commissioner Biakko ask and the presentation, it sounds like one of the key issues and hurdles historically has been this question of technical feasibility with respect to the sensors. And this is dating back 20 years plus. Going back to those discussions in 2000, 2004 era, do we have documentation that relates to the ANSI committee's questioning of the viability of the sensors to be used to measure appliances exhaust? Yes, they would be found in the meeting minutes and so staff meeting log as well. Okay. Okay. Coming to this issue somewhat fresh, you know, this is sort of, you know, historical context that we're lacking right now. If you guys have those meeting minutes available, is that something, and I see that Duane's on the, Mr. Boniface is on the, is that something that you're able to make available to us? Yes, those are publicly posted on our website, the CPSC meeting logs, so we can pull those together and send them. If you can pull them and share that, that would be helpful. Thank you. Sorry, in the presentation, there were pictures of a disconnected vent and a blocked vent or a chimney. When we track these incidents, do we know how frequently these types of issues are possible? Just setting it inside the actual go-to meeting. You have to change. I'm sorry. I think somebody else is talking. Please mute if you are not speaking, not supposed to be speaking. Thank you. When we're tracking the incidents, how frequently are these types of issues responsible, you know, disconnected or blocked vents, responsible for the injuries that were reported, and are we tracking how many of these, you know, vent issues are the result of, you know, consumer misuse or installer error? I believe I'd have to go back and look at some of the old reports, but I know that we looked at those types of things. I don't know if we were keeping tally as to how many were consumer misuse or how many were product failure, but it wouldn't be too difficult to do that, I don't think. Just to add onto that, if I may, again, what we are looking at trying to do is trying to address the production of unsafe carbon monoxide levels at the source, and so whether or not the leak at the furnace or at the boiler or through the vent or so forth, we're really concerned about the generation of unsafe carbon monoxide levels above that 400 parts per million. I understand that. I think we're trying to take a look at the global picture in which the hazard banner is manifesting itself and trying to, you know, understand the full context of what's going on in these incidents. And to that end, you know, as you're tracking incidents, has staff compiled a list of, you know, IDIs or other, you know, incident reporting where we've taken a look at the vent issue? Yes. Now, we have, we've done a couple reports where we've reviewed incident reports to determine what the failure modes and mechanisms were. And in that case, we would tell you, though, like, okay, this percentage were block vents, this percentage were disconnective vents. We haven't done one of those in a while, but we have a couple of those. And of course, everything that we do. Do technologies change enough that those older incidents would still be valid and paint a useful picture of what's happening? Absolutely. A number of years ago, when we first proposed this industry, took the position that, well, these incidents were only occurring with older appliances. And older is defined as appliances that were built before some of the more modern safety standards went into effect. So that would be products that were built and certified prior to 1990. Okay. But what we found is that when we looked at our incidents, we were seeing a number of cases with new appliances with the new safety equipment in them that were still having been exposed or still experiencing failure and resulting in seal poisoning. Because again, the only provision that's gone in place universally are the block vents, which is for a totally block vents. I don't know, I don't believe they address partially block it, partial blockage of a vent or chimney. I also do work in sections, well, I'll stare away from that. But we are aware of cases in a different, different venues where we see these types of failures with newer appliances. Okay, if we've got that incident data that would be useful again for the commission to take a look at so we can, you know, start tallying what we've seen and how that sort of informs the commission's decision-making going forward. A separate question, are there other standards that deal with exhaust inventing? From the appliance or from the material, the vent products? I suppose both. And absent sort of, you know, industry standards, you know, are there separate local building code provisions that get specifically at, you know, vent installation, you know, how to avoid the snow build-up problem that you cited, you know, with respect to vermit and animal infestation, materials with respect to, you know, brick, mortar, and grout? Right, so there are local building codes. And typically in the manufacturers installation instructions, they'll instruct the installer to install it in accordance with the manufacturer's instructions, and also the local building codes. I mean, I think that's fairly boilerplate and an installation standard. So have we can install local building codes to make sure that those are sufficiently robust to start avoiding, to avoid, you know, some of the issues that you cited with respect to chimney collapse and, you know, blockage from road and infestation? Or, you know, the very apt example that you gave about snow pile-up with the side vent? Right. A year ago, we were involved in the model codes and there may be some staff that are currently involved with it. But the approach for this particular project that we've taken is because I think that the, I'll say the beauty of this proposal is that regardless of what they cause, what the leakage path or mechanism is, what the internal failure mode that causes the appliance to generate dangerous levels of CO, that by, we felt that we can cut through a lot of that and overcome a lot of that by addressing the problem at the source of production. If you can monitor the source of production and provide some type of response, either shut off or modulating to keep the emissions low, it doesn't matter what happens. It's almost like the Dijk's point and the Dijk analogy where the Dijk's was trying to plug the Dijk. But there's one plug, but there are multiple leaks. So our approach addresses it from a multifaceted approach, regardless of where it leaks from or what causes it to produce CO, that if we can address it at the source, we should be able to stop the problem. And that's been our approach and that's been our focus. I appreciate that. Again, it could overview and I appreciate the work in the presentation today. Thank you, Mr. Jordan. Thank you, Commissioner Feldman. And I remind everybody again, if you're not talking, please mute yourselves to avoid feedback. Commissioner Trump. Thank you, Mr. Chair. And Raul, thank you for the presentation and for your persistent work in this area over the years. I think the one thing that I wanted to address, staff's been asking the voluntary standards body to address this through voluntary standards for 22 years. And that hasn't happened. And it seems like the only explanation or the only resistance from the voluntary standards body is that they weren't sure if the sensor can hold up over the 20-year lifespan of a product. So, at the outset, I hate to point this out, but if they had set this thing up and let it run when you first asked, they would have known by now. But aside from that, there's been a lot of evidence that seems to undercut that from the fact that the Japanese and the Europeans have been regulating this for a long time and those sensors have been running and held up. But it also looks like staff addressed this directly and dismissed the concern. And you alluded to this before. And from the briefing materials, it looks like there was a durability for sensors tested from 2007 to 2008. And staff, quote, found that the sensors under test were durable enough to survive within a gas furnace throughout its lifespan. And that was 2007-2008 testing. Can you expand on what you did and how they haven't accepted that decade-plus old finding? Right. And I'll try to be brief. But after the working group was disbanded back in 2005, we set about to find out what individual manufacturers were concerned about and how could we go about testing and establishing the durability of sensors in this application. One of the outcomes of those interactions was that, well, there's a corrosion test that's used to accelerate the life of the metal parts in the appliance, whether it's a heat exchanger or a vent system. Because corrosion of any of metal materials was a problem early on and sometimes it still comes up as a problem. But that was a problem in the gas appliance industry. And so this test was one mechanism to accomplish that. So we did testing where we had sensors in that environment because that was considered probably the most robust harsh environment above and beyond what they would normally experience because we were the test called for burning of the fuel-air mixture along with hydrochloric and hydrofluoric acid being injected into the process to to promote corrosion. The sensors were subjected to that environment. We did pre-testing where we tested sensor performance before that testing in the furnace and we did post-testing where we tested the sensors after that testing in the furnace with all these acids and performance didn't drop off much. We still were able to get reliable proportional signals from the sensors. So that was an indication that they were still working from an environment. We shared that information with the with the technical committee and its various standards groups and they had to go back and look at that report or look at some of the responses. But that kind of led to led into us doing the forum in 2014 because we're still engaging back and forth still participating with the voluntary standards. I don't recall I'd have to go back and look at my notes to see why they didn't move on that but we continued to move and so we didn't really wait for them to say hey we're going to do. We continued to stay engaged with them and then the only way to revive it was to make the new proposal which we did in 2015. Thank you. All of my questions have been addressed perfectly. Thank you very much. You know I think that the only other thing that I would say is that I don't think there can be any complaint that we haven't given the voluntary standards body enough time to address this. So I'll get back to rest of my time. Thanks. Thank you, Commissioner Trumka. I know that Commissioner Biakko has additional questions. I'm going to ask one question for clarification before turning back to Commissioner Biakko. So my understanding from what you're saying about how the CO sensors work and the safety mitigation is as the sensor detects higher levels of carbon monoxide in the atmosphere it will then either turn off the furnace or reduce the amount of the operation of the device. So regardless of why the CO levels are increasing whether it's a block bent from you know snowpack which may be separate from the appliance at all or a problem with the appliance itself it can identify that there's rising levels that could be hazardous and you know lethal and then take preemptive action to stop that from happening. Is that is my understanding of what the sensors and the technology would do and are in Japan and Europe? Yeah that's correct that they either directly detect CO or they detect the combustion conditions and respond to those. So but yeah you're spot on. So it's it's less really an issue of whether it's the vent that's being blocked whether there's like you know the mortar's not going or whether the housing standards are right as opposed to there is safety technology that can be incorporated into these devices that whatever the reason if there is a dangerous level of CO that's in the household or nearby the sensor then then action will be taken to mitigate the amount of CO that's being produced by that device. I think I'm just saying the same thing over again but if I'm if I'm internalizing this correctly can you just confirm that? I can confirm that you are internalizing it correctly. You have a good grasp of it. Thank you I appreciate that in your work Mr. Jordan. That's my questions. Commissioner Bianco did you have more questions? I do just so I understand and I'm following so far. The products in Japan and Europe are I mean I know you've said many times that they are similar. We expect it to perform the same it's pretty much the same. What's really the difference as to why it's working in those countries and we're not using it here and what is the big difference or what is the objection to using this technology and isn't it technology or something has been around? Well the primary issue again is that the gas appliance industry or the standards development group they believe that the sensors should last the life of the appliance. That has been the the biggest and most consistent objection that I've heard over these years. Excuse me. Can't they be replaced I mean if the sensor fails before the furnace does isn't there can they just be replaced? Oh absolutely they can absolutely be replaced. I've heard comments that I'm sorry. No keep going. No that I mean for the sensor. He cut out. He cut out. Okay that there's not there not much different than some of the other common devices that you'll find in appliances that have to look into the bulkhead of say a heat exchanger or some compartment that essentially it's typically two screws and a gasket material and then you have the connection wire that provides the power to the device and then the signal from the device but it's really not complicated at all and very similar to existing devices in terms of replacement. And so what's the cost is that an issue? Well I would have to defer to our economists and we haven't looked at all the costs. I'm sorry I don't want to I don't need an economic analysis I'm trying to get an understanding of is as the are the committee saying it's too expensive in addition to it's taking you know we don't know about the lifespan of the sensors and do we have an understanding of what these sensors cost? I haven't really heard very many cost issues raised at the volunteer standards committees and one thing as a rule they don't discuss cost issues at these meetings. Okay so I just want to be clear on something. You referred to these several times as gas appliances and earlier you mentioned that water boilers don't have this issue. Are we really focused on just gas furnaces and boilers that heat the house and that's it is that little box of products? Right that's correct because we look at the data the incident data and and we attempt to be data driven and when we look at the trends somebody mentioned generators they've overtaken furnaces and space heaters as a leading cause of CO deaths. So we've been focusing on furnaces and boilers because that's where we see most of the deaths. There are other appliances that just anecdotally been at space heaters years ago they were the leading cause along with furnaces of CO poisoning deaths. One thing that they've done that's been very proactive and very a positive approach is that they introduce something known as an oxygen depletion sensor and unvented space heaters and they also use vent safety shutoffs which is which are designed to detect a disconnected vent and some of the vent at space heaters and so whereas those were leading causes of CO deaths years ago they know they barely make it on the radar because they took a positive approach to dealing directly or indirectly with the issue and that is CO poisoning. Okay so I don't research should I I just have a maybe a dumb question doesn't a plug-in CO detector in the home accomplish the same thing that these sensors would? Yes and no. Yes it does monitor CO but it has no impact on the operation of the appliance and so just as I mentioned that the vent at space heaters now you they barely register on our incident tracking as causes of CO deaths because of the the measures that they took through the standards and then through technology that came to the market units that were equipped with either and safety shutoffs which is for oxygen depletion sensors so now they are no longer leading causes of CO poisoning. I feel the same way with furnaces that if we're trying to make the appliance safer and then dealing with that those group of voluntary standards that's the relevant area of coverage. So let me tell I'm sorry go ahead so my question was dumb thank you for pointing that out I get the doubt and let me just say say this and then I'll quit because the rest of my questions are just details. I personally and in this position as a commissioner I am losing patience with the amount of time it's taking and the delays with the voluntary standards. I personally believe that voluntary standards can be very effective if you get them into place but if there is a if there is 22 years that have gone by and there's not a single standard that is going as far as I'm concerned that does not adequately address the problem. Not that there isn't one the fact that there isn't one and that we haven't gotten there it does not adequately address the problem so to those people out there on the committees who might be listening and for what it's worth that's where I am on all of this. Assuming of course that the proposals for a new voluntary standard whether on this product or any other product are technically feasible and and and something that we need to address and it would make the product safer. So that's my little policy comment and I appreciate you taking the time to answer all of my questions. I know they were very tedious. Thank you. Thank you Commissioner Bianco. I'm sorry. Mr. Commissioner Feldman do you have further questions? Thank you. Just to state that I agree with Commissioner Bianco. I too am open to a path forward on this issue. No further questions. I did want to state in my first round I asked for some follow-up information on industries concerns about feasibility that were raised in the early 2000s and then I asked for summation of some of the incident data with respect to you know how chimney and exhaust issues maybe manifesting themselves. When you send those up if I could request that they be sent to all my colleagues I want to get past having information come from staff to the commission in a siloed manner as had been the practice under previous agency leadership. We all need to be operating off the same set of facts and information here in order to make good decisions. Thank you Commissioner. We'll work to get the information the commission needs. Thanks for holding this today. Bye bye. Yes helpful. Commissioner Trump did you have any further questions? No more questions. Just again Duane, Ronald thank you Duane your team for the work on the issue. So with that first I want to thank the staff for this informative briefing and for the work that they've been doing and also I agree with what a number of my colleagues have said that this is a very useful discussion to have and I appreciate the commissioners for actively participating in this. You know as a final note and this goes back to what Commissioner Biacca was saying a clearly this is an issue that we need to move forward with trying to figure out how best to to protect consumers but as we're moving forward I would urge everybody who is viewing to make sure that you have working carbon monoxide detectors in your homes and the homes of your loved ones also think about changing the batteries in your carbon monoxide and smoke alarms when you change your clocks for daylight savings time in a few weeks it really could save you and your entire family. So with that thanks again to everybody and the meeting is adjourned. Thank you.