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Vent Free Gas Heaters & Fireplace Manufacturers Lost Challenge By Default

Aug 10 '07 (Updated Aug 21 '07)

The Bottom Line Vent-Free gas fireplaces continue to be one of the greatest, avoidable health and safety hazards to over ten million families within the United States and elsewhere in the world.

I updated my review entitled "Challenge to the Manufacturer's of Unvented Gas Heaters", from February 2002 and republished it back in December 2006. I feel it only makes sense to update the second part which highlights why and how such a large and powerful organization lost this challenge.

It is also important to keep these issues current.

The challenge was simply a request for answers to serious safety questions I had been asking for years and I received the most unusual response in March 2002, from Mr. Evan Gaddis then President of the Gas Appliance Manufacturer's Association (GAMA. His response speaks volumes about the nature of their massive organization. Bear in mind, that this was addressed and responded to by the president of the largest gas appliance manufacturing association in North America.

Much of this review is from my review dated April, 2002, with a few necessary updates and added facts that support my case against vent-free gas appliances.

My challenge has been refused. Vent-Free gas products continue to be one of the greatest, avoidable health and safety hazards to over eight million (now estimated at over ten million) families within the United States.

On February 14th (2002) I published a challenge to unvented, ventless and vent-free gas heater manufacturers to come forward and respond, responsibly to my statements that;

"Addressed to GAMA and The Vent Free Products Alliance

Vent-free gas space heaters represent one of the greatest, avoidable health and safety hazards, within the United States of America.

This is an open invitation to either the manufacturers or any one of the organizations who claim to represent them to respond in a technical manner, to specific statements I have made, with specific scientific proof, that any or all of my assertions are unfounded.

Summary of My Assertions

In no particular order of importance:

1. Vent-free gas heaters have an adverse affect on the indoor air quality in a home and therefore, on the health of the occupants of that home. Products of combustion, that are being discharged directly into the homes of men, women and children, include but are not limited to, carbon dioxide, (CO2), carbon monoxide (CO) nitrogen oxides (NOX), sulfer dioxide (SO2), unburnt fuel particles, soot, and a host of other chemicals drawn into the combustion process from cleansing, polishing, air freshening products, new carpets, new furniture and other sources.

The chances of deadly or life threatening levels of carbon monoxide, an odorless, colorless poison, to people living within a house, with a ventless gas heater are infinitely greater than from a vented gas space heater.

2. Suggested savings on installation costs of vent-free heaters, fireplaces and stoves, over vented products are over-estimated for marketing purposes by the Vent Free Gas Products Alliance. Offering false estimated savings to consumers, unsupported by industry statistics on installation costs.

3. Vent-free gas heaters can and do damage the interior of the home with acidic water vapor and soot. Verified by emails I have received over the past several years from all over the United States and by insurance claims paid or denied by home insurance companies and vent-free product manufacturer's themselves.

Those same products of combustion are implicated in several respiratory diseases, and have been shown to cause irritation to eyes, throat and the lining of lungs. The State of California has implied such products are related to lung cancer and birth defects. For more on this, please refer to my review,

http://www.epinions.com/content_5004370052

4. Oxygen Depletion Systems (ODS) pilot systems are not 100% reliable to shut down the gas supply to an appliance when the oxygen levels in the room fall to 18% or less. They are not located high enough in the room to detect the average oxygen content in the room. They are typically low to the floor where cool, fresh, oxygen rich air collects. Hot by-products of combustion, will rise to the ceiling and drop down slowly as they cool. We refer to this as stratification, and it is a given, unless there is a ceiling fan in the same room pushing the hot air and gases down.

The ODS bi-metal strips, which are the heart of the system, are subject to being out of calibration straight from the factory. People's lives should not be gambled on such a weak safety technology.

Actual oxygen depletion is a remote possibility with these products, as it would require a vent-free appliance within an undersized, tightly sealed room, with little or no infiltration air.

The Vent-Free Gas Products Alliance refers to them, wrongly, as Oxygen Detection Safety Pilot systems, rather than oxygen depletion systems. I suppose the correct terminology wasn't sexy enough for the marketing folks. However, it is a more accurate description of what this device does and how it works.

The ODS does not technically "detect" oxygen levels. That requires a much more sophisticated and expensive device. The ODS is only designed "react" to drops in oxygen levels close to the floor, where it may already be too late for the consumers within the room.

5. Performance efficiencies published by the Vent-free Gas Products Alliance are misleading. 99.9% Is the theoretical combustion efficiency of gas. It is not the annual fuel utilization efficiency (AFUE) when one takes into account the amount of ambient air required, to be ducted into the room, for complete combustion and to maintain normal/healthy oxygen levels within the home. No gas appliance fires up or shuts down at 99% combustion efficiency. Therefore, additional pollutants are introduced to the room.

(Most manufacturers, EPA, and the CPSC all recommend opening windows when operating one of these appliances, which would offset potential comfort and efficiency levels. How much more fuel would a consumer use therefore with an open window, as compared to a closed window with a vented heater?)

6. The American Gas Association Research Division (AGAR) did not endorse the use of up to 39,000 Btu/H unvented gas log sets, freestanding stoves or zero clearance fireplaces, which is a two (2) to six (6) times higher Btuh gas input rate than any of the following test samples used in the AGAR report. The Vent-Free Gas Products Alliance is misrepresenting the results of the AGAR study conducted (in 1996) and applying those results to support the sale of products in some cases with more than double the Btu/H input rates tested by AGAR, which were designed and manufactured many years after the AGAR study was published.

There were six (6) test units in the 1996 AGAR test protocol, tested under varying housing conditions of, loose, average and tight, in various regions of the country, within various room sizes (all assume 8 foot ceilings):*

Ex. 1. :11,560 Btuh, cycle tested within 425 sq. ft., loose construction, region 2, Texas, Louisianna, Alabama, Georgia, Northern Florida, etc.

Ex. 2. :16,891 Btuh, cycle tested within 621 sq. ft., loose construction, region 2, as above.

Ex. 3. :5,569 Btuh, cycle tested within 221 sq. ft., tight construction, region 5, North Dakota, Minnesota, Wisconsin, Illinois, Michigan, New York, Vermont, New Hampshire, Maine.

Ex. 4. :9,984 Btuh, cycle tested within 390 sq. ft., average construction, region 5 as above.

Ex. 5. :10,964 Btuh, cycle tested within 740 sq. ft., tight construction, region 5 as above.

Ex. 6. :19,127 Btuh, cycle tested within 621 sq. ft., average construction, region 5 as above.

*(excerpts from AGAR Division of Gas Research Institute (GRI) report: Development of Sizing Guidelines for Vent-Free Supplemental Heating Products, dated March 1996.

NOTE: There were no test models representing the common vent-free fireplaces sold today with input rates of up to 39,000 Btuh, in region 5, with tight construction, which are not cycled on and off but often operated continuously during cold winter months.

Consumers will find very few vent-free fireplaces available, at input rates as low as 10,000 Btuh and none below 10,000 Btuh, as shown above.

Six test cases, conducted more than 10 years ago, under ideal conditions, with test samples set up with gas input rates at 50 to 85% below the input rates of the currently approved, vent-free fireplaces, formed the basis for product approvals across most of the United States. This test program and report were sponsored by Gas Appliance Manufacturers Association and therefore by members of the Vent Free Gas Products Alliance.

7. Despite claims to the contrary by the Vent Free Gas Products Alliance, (VFGPA) there are thousands of reported injuries and hundreds of deaths each year, caused by fires and accidental carbon monoxide poisoning, attributed (by the U.S. CPSC) to the use of vented and unvented gas space heaters. Common sense dictates that the vented space heater will always be safer than an unvented space heater. Statistics were not broken down by product categories of vented or unvented. The VFGPA does not have the right to make such blatant statements as "to date, the industry is not aware of any recorded deaths attributed to a vent-free gas product, that is equipped with an Oxygen Detection Safety Pilot (ODS)."

UPDATE: (More recently, there has been a documented death of a young girl and her dog from CO poisoning, in a room with a relatively new vent-free fireplace, equipped with an ODS. The oxygen levels were normal and not the cause of the deadly levels of CO which were generated.)

The VFGPA simply have no grounds to make such statements about the safety records for all of the products they represent and the Btu/H inputs rates they are sold with, untested by AGAR.

In an effort to be fair to them, I forwarded copies of my review to many of the major manufacturers as well as the Vent-Free Gas Products Alliance.

Over a month later, on March 17th, (2002) I did receive a response from a Ms. Mary Carson, Program Director for the Alliance. It was unfortunately, not the response I had hoped for. The essence of her email was to ask; WHO ARE YOU AND WHERE DO YOU LIVE? There was also an invitation back to me to attend the ANNUAL HEARTH PATIO BARBECUE ASSOCIATION EXPO IN CALIFORNIA, April 10-12th. (At my expense.) Where, Ms. Carson assured me, "WE WILL HAVE OUR TECHNICAL TEAM, RESEARCHERS, AND ENGINEERS AVAILABLE TO RESPOND IN A TECHNICAL MANNER."

Apparently, it is more important for them to know my identity than it is to respond to my public challenge, as her added statement shows; "UNLESS WE KNOW WHO YOU ACTUALLY ARE AND WHAT PUBLICATIONS YOU REPRESENT, WE DO NOT RESPOND TO E-MAILS."

My response to her email was lengthy, but here are a few paragraphs from it.

"I have attended a few in previous years and I find them of little research value. These shows tend to be geared towards the installing contractors, retailers and wholesale distributors. I therefore have no plans to attend this particular show next month."

"Your statement; "we do not respond to emails." is in direct conflict with your web site, where I quote: For more information, contact: The Vent-Free Gas Products Alliance, 2111 Wilson Blvd., Suite 600, Arlington, VA 22201, mscsmitty@cs.com"

"I would just like to be clear about this statement. As the "Program Director" for the Vent-Free Gas Products Alliance, are you refusing to respond to the statements made in my article? May I quote you on that?"

"I would suggest, Ms. Carson, that the most productive next step for your organization, would be to convene your entire "technical team, researchers and engineers" to respond in a technical manner, to all of the points that have been raised, completely, professionally and without selective exclusion of facts."

I was surprised to receive the following brief and most unusual comment via email a few days later.

From: "Evan R. Gaddis"
To: 'The Gas Man' , Mscsmitty@cs.com
Subject: RE: RESPONSE TO " CONTACT " WITHOUT PREJUDICE
Date: Thu, 21 Mar 2002 11:16:25 -0500

Mary, I fully agree with Mark. This fool only gains clout by getting a credible organization like us to respond . Lets let this die.

(Mr. Evan R. Gaddis was President of the Gas Appliance Manufacturers Association -GAMA.)

He is right about at least one thing, GAMA is a very credible organization. It is one of the largest and most respected organizations in the United States, with regards to gas appliance manufacturing. I feel honored that Mr. Gaddis was apparently moved enough by my arguments to call me a fool, thus justifying his refusal to respond.

Where he went wrong is by copying me with his, off the cuff, comments. I can live with his name calling. I've been called worse things, by better people.

"Lets let this die." Sad... Mr. Gaddis, a very sad and inadequate technical response to a number of technical criticisms, which directly affect the health and safety of millions of Americans.

My Response to GAMA: March 28th (2002)

Dear Mr. Gaddis,

Although you were kind enough to forward a copy of your response to Ms. Carson on behalf of GAMA, you still haven't responded to my last two emails. I can understand that in your position, as president of GAMA, you don't have much time for "fools" and their questions. However, there is a proverb that goes; "Answer a fool according to his folly, lest he be wise in his own conceit."

The Vent-Free Gas Products Alliance and GAMA appear to have satisfied themselves that they have responded to my criticisms adequately, however, I can assure you that there are those of us in this industry who do not intend to, "let this die", as you so eloquently put it.

Thanks again for stating GAMA's position on the issues I have raised, very much appreciated.

Kind regards,
The Gasman

(This email of course, went unanswered.)

Closing Comments (Finally!)

The manufacturers and the organizations who purport to represent them were all given an ample opportunity to respond to my challenge and provide answers. I asked them for a technical response and to provide any scientific proof they claim to have. Not one of these manufacturers responded to my review dated February 14th or my emails sent directly to the members of this so-called Alliance. The Vent-Free Gas Products Alliance wanted to keep it between their team of experts and myself in California.

The Gas Appliance Manufacturers Association (GAMA) president, Mr. Evan Gaddis decided not to respond, dismissed my comments after consultation with someone named Mark and says he wants to "let this die." The irony of this is that although he had decided not to respond, he responded. Possibly by accident or else I'm missing the logic behind that one.

Gama's credibility as an organization is apparently much more important than responding to a technical critique on one relatively small, sick segment of their organization. The Vent Free Gas Products Alliance is a tiny division within their membership ranks.

Don't you think that if any one of these organizations had a shred of scientific proof that I was wrong, they would have come forward with it?

I may very well be a fool, Mr. Gaddis, but, I'm not the one hiding behind the ivory towers of GAMA, wishing this would just go away and "die". Incidentally, it isn't going to happen. By emailing me, as president of GAMA, you've delivered the very clout you were hoping to deny me.

Canada, California, Wisconsin, and New York City continue to ban vent-free gas appliances.

We lost the Commonwealth of Mass., to the dark side of the Alliance, just a couple of years ago, with unique caveats that requires special warnings, CO detectors and often the involvement of building inspectors.

I need to remind people who have already purchased CO detectors, that they are not required to accurately sense below 75 parts per million (ppm). The technology for finer sensing is too expensive for consumers to buy. Even at a 75 ppm minimum limit, all manufacturers of CO detectors will warn you not to depend on them for your life. These gadgets are not as effective or time proven as smoke alarms. Besides, CO is only one of the poisons you will be inhaling with a gas vent free heater or fireplace. I believe it is a good idea to have a CO detector in your home, I just don't believe you should rely on it to save your life.

Why don't I feel good about winning this debate, by default?

Thanks for reading, be safe and buy vented gas heaters and particularly, vented gas fireplaces and freestanding stoves.

All the best,
The Gasman

P.S. I apologize for the length of this review and the technical detail. It may seem boring to many, but information is important and I could not find too many things I would cut for the sake brevity. Thanks for persevering to those who took time to read it.

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Still venting after all these years.


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