CPSC should run a computer simulation on its 2016 NPR on portable generators to assess its potential to mitigate carbon monoxide (CO) if it does so with UL 2201 and PGMA G300, the agency heard. This suggestion came in detailed comments from the Portable Generator Manufacturer's Association (PGMA) on CPSC's plans with NIST (PSL, 7/8/19).
Overall, the group made 41 comments, many on the fine details of the plan. Last month (PSL, 8/12/19), the agency spent a few hours explaining those details to aid commenters' input.
Broadly, PGMA's advice addressed outdoor use and real-world assumptions; air handling systems; door/window positions/sizes; various scenarios involving issues like generator placement, exhaust generation, and user reaction; weather conditions; shutoff criteria; generator characteristics; simulation methodology; and effectiveness estimates.
Comments (bit.ly/2pCSjoK) by others included:
- Generac urged better occurrence weighting for outdoors scenarios because 95% of incidents occurring with generators in enclosed spaces. It also asked for CPSC and NIST to do a sensitivity analysis on changes to the CONTAM model, and it said a human factors study ought to address dependence on user interaction. It noted its help in creating and supporting the PGMA input, which included a similar suggestion about the outdoors.
- TTI (Techtronic Industries Power Equipment) suggested that CO-linked shutoffs might lead users who place units indoors to place them outdoors but still too close to buildings, causing incidents. This "gap" is not addressed by shutoff, it warned. TTI additionally urged more focus on the elderly and children, noting they combine for about 20% of deaths. It also said that some models adhering to PGMA G300 might produce more CO than assumed.
- Missouri Department of Health and Senior Services wrote that its incident data support a "need for engineering controls, standards, safety training, and education" and that the study would aid in those efforts.