Unvented Gas Heater Standards: Proposed Amendments
Apr 09 '02 (Updated Nov 19 '07)
The Bottom Line Please feel free to copy and paste my last review on unvented heaters and these Proposed Amendments to national standards and send them to your government representatives or newspapers.
These Proposed Amendments to national standards are an effort to, at the very least, force the Gas Appliance Manufacturer's Association (GAMA) into a dialogue and hopefully, to take responsible action on behalf of the health and safety of millions of American families. If these products can not be banned altogether, the standards that govern them can be improved.
AFFECTED ANSI STANDARD: ANSI Z21.11.2
BACKGROUND:
In view of growing health and safety concerns, surrounding the installation and use of unvented gas space heaters, in the homes of millions of American families and the gas appliance industry's failure to address them, the following sets out key areas of concern and proposed amendments to the current ANSI standards that govern them.
The ideal solution to these health and safety issues would be a national ban on the sale of such products and the promotion of safety warnings to consumers who currently use them. In addition to a national advertising campaign describing the dangers involved with their continued use and encouraging consumers to convert to vented gas space heaters.
Realistically, such drastic remedial actions are not going to be easily accepted by the gas appliance industry. Therefore, the following outlines some minimum necessary amendments to the existing standards in an effort to;
A) warn consumers "before" purchasing these products of the intrinsic dangers of using them.
B) increase awareness of consumers who currently use these products.
C) force installation contractors to be aware of and to follow the American Gas Association Research Institute (AGAR) sizing guidelines, published several years ago.
D) force installation contractors to become better educated and equipped to install these products.
E) improve safety and construction requirements for all unvented gas heaters.
F) minimize the risks to consumers who insist on purchasing them.
The first step towards improving consumer awareness about health and safety issues involving unvented gas appliances, is to eliminate advertisements, websites, sales brochures and other marketing materials, which flatly deny any hazards are attached to the normal use of these products. The second step is to implement responsible and wide sweeping changes to existing standards which will minimize the risks to consumers.
If one simply looks to the warnings that tobacco manufacturer's have been forced to print prominently on their products, manufacturer's of unvented gas products should see these proposed amendments as fairly reasonable.
This document should be viewed as a work in progress rather than the final requirements. While these proposed amendments are being put forth on behalf of a consuming public's health and welfare, there will be a number of manufacturer's who will want to reject them, without thinking or reading about them, due to the suggested elimination of certain product features and the additional test procedures in certification. To those manufacturers I suggest, these proposed changes will save more than the lives of consumers, they may save an industry.
I fully understand and appreciate, that the following proposed amendments for many manufacturers, if they were adopted, will mean the elimination of many models on the market today. It will also mean added costs in the certification of unvented gas appliances and some added costs in the redevelopment of some products. However, it will also mean that greater safety measures have been taken and the liability costs to some companies will be much lower than it is at the present time.
Many of these proposed amendments and addendums are my preliminary thoughts towards changes that would satisfy the need for a minimum safety margin for consumers. The author of these proposals reserves the right to make additional suggestions and welcomes any input that others may have about increased safety measures for unvented gas space heating appliances. Refer to it as the writer's wish list.
To those who read these suggested amendments and consider their merits seriously, I thank you for your time and your consideration.
Please feel free to contact me via email if you have any questions, comments or would like me to clarify the intent behind some of these proposed changes. Some, I am sure, are self evident to those who have been in the research and development side of this industry for any length of time.
Regards,
The Gasman
April 9, 2002
Prepared By: The Gasman
the_gas_man@hotmail.com
SCOPE:
Many of the following proposed amendments may apply to all unvented gas space heaters. However, the authorized testing agency may find that some products, by design, are already in compliance with the intent of these proposed amendments. For example, some low Btu/h infra-red or plaque type room heaters of a type and brand that have been in production for many years, may be found to be exempt from these proposed amendments.
These proposed amendments are of particular importance to, so-called, yellow flame, unvented gas fireplaces, with rated inputs above 20,000 Btu/H and up to 39,000 Btu/h, whether they are designated as gas log sets, zero clearance, freestanding or inserts.
The intent of many of these proposed amendments is reduce dangerous emission levels and to anticipate some abnormal operating conditions which will take place over time and useage. Further, it is to force installation contractors or service technicians to be responsible for their installations and to be properly equipped to do the job safely.
INSTRUCTIONS: (Addendums To Existing Safety Warnings)
1. Cover Page: All installation, operating and maintenance instruction manuals shall carry prominent warnings, in bold 12 point face type, on the cover page to the effect that:
A) This appliance, MUST be installed by a certified gasfitter trained in the installation of Unvented Gas Appliances.
B) Prior to installation, the installing contractor must certify in writing that he has assessed the room in which this appliance is being installed against recommendations made by the American Gas Association Research Institute. Including specific calculations regarding available ventilation air, the Btu/H input of the appliance and the region of the country in which it is installed. A copy of these calculations shall be left with the consumer.
C) i) This appliance can produce high and deadly levels of carbon monoxide if these installation, operating and maintenance instructions are not followed closely or if this appliance is modified in any way, not recommended by the manufacturer.
ii) This appliance may produce low levels of carbon monoxide continuously when it is operating normally, these carbon monoxide levels are considered to be within tolerable safety levels by health authorities, however, even low levels of carbon monoxide can be hazardous to the health of some people and small pets. (Children, elderly, pregnant women, and those with weight, heart or pre-existing lung disorders.)
iii) This appliance will produce higher levels of carbon monoxide each time it is turned on or off. These levels of carbon monoxide can accumulate in a tightly sealed home and become a serious health threat to the occupants.
For more information about the harmful effects of carbon monoxide and specific danger levels please turn to the information provided on the inside cover of this manual.
D) This appliance will produce high levels of water vapor into the house when it is operating. The excess water vapor may condense on the walls and windows of the home. This water vapor is mildly acidic and may cause property damage over time.
E) This appliance will produce low levels of nitrogen dioxide, which can be detrimental to your health over prolonged periods of continued exposure. People who already suffer with heart and lung disorders may be more susceptible to the effects of low levels of nitrogen dioxide.
F) This appliance will emit low levels of unburnt fuel gas, each time this appliance is started or stopped. These small particles can attach to other pollutants, such as radon, in the air and become ingested deep into the lungs which may lead to cancer.
G) Other unknown products of combustion may be formed and delivered into the room by this appliance, depending upon the indoor pollutants already present in the household air.
H) This appliance uses the air from within the room for combustion. After the installation of this appliance, under no circumstances should you attempt to alter the available ventilation air to the room in which this appliance has been installed. Reducing the amount of ventilation air to the room will affect the oxygen levels in the room and can cause high levels of deadly carbon monoxide to be produced.
2. Inside Cover Page: Shall include the chart showing the harmful effects of carbon monoxide poisoning at various levels over time periods of exposure, in addition to a detailed description of the symptoms and recommended treatments for CO poisoning.
Following this chart there shall follow a vivid description of a healthy flame and signs of poor combustion which will aid the consumer so that they will be able to visually check for, I.E. Ghosting, lazy flames, sooting carbon deposits, flame lifting, etc.,
3. Page 2: To Be Read By The Installing Contractor Prior To Installation.
A) Failure to follow these instructions exactly can result in the injury or deaths of consumers. If you have not read or do not understand the Sizing Guidelines established by the American Gas Association Research Institute, for the safe installation and operation, do not continue with this installation until you have read and understand them.
In order to complete the installation requirements of this installation, you must be equipped with a "calibrated" combustion analyzer, checked and certified accurate at least once per year. You must also be equipped with a working, accurate manometer for checking and recording both supply and manifold gas pressures.
B) After installation of this appliance, the installing contractor shall;
* check and record the gas supply pressure and the manifold pressure on the form provided within this manual.
* check the primary air opening(s) on the burner for conformance with the specifications shown within the installation instructions.
* check the burner ports are all clear of paint or other obstructions and with the appliance operating, check for smooth, fast ignition to all ports, within four (4) seconds of turning the valve on.
* visually check the flame characteristics for signs of incomplete combustion and flame impingement.
* check the gas input rate by timing the gas meter after the appliance has been operating for fifteen minutes (15) from a cold start. The input rate shall be in conformance with the manufacturer's certified input rate as shown on the name/rating plate, within the allowable tolerances of +/- 5 %.
The results of these tests and checks shall be recorded on the Performance Form, included within these instructions and provided to the consumer for future reference.
C) After the installation is completed, the installing contractor shall also conduct a combustion test on this appliance and record these combustion test results on the Performance Form, provided within these instructions leaving a copy with the consumer.
D) Under no circumstances shall the installing contractor or a licensed service technician adjust or in any way modify the primary air settings, the orifice size or the gas pressures in a manner which deviates from the manufacturer's certified and printed specifications within this manual.
E) Upon completion of this installation, the installing contractor shall instruct the consumers as to the safe use of this appliance, including ignition, shutting down, daily operation, procedures and safety features such as the oxygen depletion system (ODS), how it works, how to tell if it is being activated and highlight the need to maintain ventilation air to the room. If the appliance is equipped with a catalytic combustor the installing contractor shall instruct the consumer(s) how to check it and recommended maintenance instructions relating to it.
F) Under no circumstances shall the installing contractor or a service technician add more or different materials to the combustion chamber including ember materials, fiber brick panels, or logs, other than those provided with the appliance and as certified by the manufacturer.
4. Last Page, The Performance Form: On the last page of the instructions manual an appliance Performance Form shall be added, specifying the optimum combustion test results expected by the manufacturer for the model involved, including the expected percentage of carbon dioxide and parts per million of carbon monoxide, with readings taken at a point on the appliance specified by the manufacturer and certified by the testing agency. A tolerance in these test results shall not be greater than a reasonable limit set for that particular appliance by the testing agency, as a percentage of the direct readings given by the analyzer. (Any variance shall not exceed safety levels specified in the existing standard.) These instructions for measurements shall include instructions for burn curing time for logs, brick panels, embers, paint and solvents used in production, prior to conducting the combustion test.
Once the appliance is deemed to be cured it shall be allowed to cool down to ambient room temperature and the combustion test shall be conducted after the appliance has been allowed to operate for exactly fifteen (15) minutes and the results recorded on the included Performance Form.
As noted this Performance Form, shall include the manufacturer's certified specifications for gas input rate in Btu/h and supply and manifold gas pressures, with a space for them to be recorded as tested by the installing contractor.
The Performance Form shall include provisions for recording visual checks conducted by the installing contractor with regards to primary air, burner and pilot operating characteristics.
The Performance Form within these instructions shall include minimum annual required planned maintenance and safety checks by a licensed gas technician. Provisions shall be made to allow the consumer to keep a written record of annual maintenance and test results.
The installing contractor shall sign off on this form, verifying the installation is complete and operating within the manufacturer's specifications and keep a copy for their own records
MARKINGS:
A prominent label shall be permanently attached or added to the lighting instructions and readily visible when the consumer is about to ignite the appliance. A warning to the consumer shall state;
WARNING: BEFORE LIGHTING THIS APPLIANCE CAREFULLY READ THE OPERATING INSTRUCTIONS CONCERNING CARBON MONOXIDE.
CHECK THE FORM IN THE INSTRUCTIONS TO SEE IF THIS APPLIANCE IS DUE FOR REQUIRED ANNUAL MAINTENANCE AND SAFETY TESTS.
CONSTRUCTION: (Addendums To Existing Construction Requirements)
1. The primary air shutter on all burners within an unvented gas appliance shall be permanently fixed with a minimum opening as determined during certification testing, and shall not be adjustable for use with either natural gas or propane, so as to be field convertible. The burner shall be manufactured as either a dedicated natural gas or propane burner. A screw or other such mechanical devices do not constitute a permanent fixed position of the primary air shutter, if one is employed.
2. Logs shall be permanently pinned in the certified position for optimum combustion. Holes used in Fiber logs shall be protected from wear with the use of metal inserts or sleeves, to prevent the logs from becoming loose fitting in relation to the burner ports over time. The means of removing or replacing these logs for service or installation shall be such that they can not be placed incorrectly. The instructions will also ensure there are clear diagrams or pictures to prevent anyone from misplacing the logs in relationship to the burner ports.
3. The addition of ember materials to burners, such as ceramic fiber coals or mineral wool or any other non-combustible material is prohibited. Manufacturer's shall warn their customers not to add any materials (which are commercially available at hearth shops) to unvented gas space heaters. The rationale for this change is that the quantity is too often exceeded, the placement of ember materials can not be duplicated with any precision in test agency laboratories and there are too many variations as to how they may be applied by either the installing contractor, a service technician or even the consumer.
4. Gas valves shall not have a turn down capacity of more than 30% of the maximum rated input of the appliance. Carbon monoxide levels are generated at much higher levels with an appliance that is turned down by 50% or more.
5. The maximum rated input for an unvented, yellow flame type space heater shall not exceed 20 mbh. (20,000 Btu/h) Therefore the maximum reduction in the input rate shall not be less than 14mbh (14,000 Btu/h).
6. A mechanical timer or some form of electronic timer shall be interlocked with the operating control of the appliance to allow for up to two (2) hours operating time. The appliance shall automatically shut down after two (2) hours of operation, requiring the consumer to manually turn the timer back on for another two (2) hours of operation. The rationale behind this clause is to prevent consumers from accidentally leaving the appliance on when they leave the room, the house or simply go to bed.
PERFORMANCE: (Addendums To Existing Certification Test Requirements)
1. No unvented gas heater shall produce in excess of 250 parts per million of cumulative carbon monoxide in the 1000 cubic foot closed room test enclosure, before the ODS system has activated to close the gas control. These tests shall be repeated with the appliance set up for; reduced, normal, increased and overfire/high altitude input rate conditions as prescribed in the existing test methodology of the standard. All tests shall be conducted on both test gases.
2. Normal combustion tests shall be conducted and repeated with samples taken and recorded within five (5), ten (10) and fifteen (15) minutes from a cold start. The average of the results obtained will not exceed .02 % air free carbon monoxide (AFCO). These tests will be repeated with the appliance at; reduced, normal, increased and high altitude input rate conditions as prescribed in the existing test methodology of the standard. All tests shall be conducted on both test gases.
3. Combustion tests as described above under item #2 will be repeated with a typical room ceiling fan operating 6 feet above the appliance and four feet in front of the appliance, with no appreciable affect or change to the combustion results recorded previously. At no time shall the flames lift off of the burners or create carbon deposits.
4. The input rate shall be checked after fifteen (15) minutes of operation from a cold start and shall not decrease by more than 10% over the following thirty minutes of continuous operation.
5. Designed flame impingement on logs shall not create carbon deposits under normal operating conditions throughout the test program. Formation of carbon deposits on logs or on the interior of the firebox under normal operating conditions shall be deemed a test failure. A new sample of the appliance shall be burn cured of any paints or solvents used in production, wiped clean, and set up as per the manufacturer's installation instructions and specifications and cycled under normal operating conditions, continuously for 72 hours. The test agency will then carefully inspect the test sample for indications of carbon deposits. This test will be repeated on both test gases.
6. Abnormal Performance Tests. With the manufacturer's specified primary air shutter setting 50% closed the appliance will pass normal combustion tests after 15 minutes of operation from a cold start.
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