CO Experts’ George Kerr Weighs In On The Flaws He Sees In U.L. Standard 2034.
By George Kerr
For The NEWS ..... Published in the March 27, 2006 Edition, pages 38 & 39
At issue is the revised Underwriters Laboratories (UL) standard 2034, setting forth requirements that cover electrically operated single and multiple station carbon monoxide (CO) detectors intended for protection in ordinary indoor locations of dwelling units, including recreational vehicles, mobile homes, and recreational boats with enclosed accommodation spaces and cockpit areas.
If you have ever spent time on my web site (www.coexperts.com) or attended any of my presentations or seminars, you are very much aware of my severe criticism of UL-2034 and the flawed retail quality CO detectors manufactured to the various editions of that standard since its first publication on April 30,1992 and continuing through the present version.
Since the very first version of UL-2034, I have been calling on industry professionals to:
1. Use the right sensors
2. Monitor the sensors
3. Have "end of life" warnings
4. Improve digital display accuracy
5. Reduce false alarms
In order to understand my concerns for the poor quality of the UL-2034 listed CO detectors, you simply need to understand the purpose of, and the wording in, UL-2034. The purpose is clearly defined in the "foreward" on the previous editions of UL-2034. Consider Item 1.2.1 of the Scope statement of UL-2034:
"Carbon monoxide alarms [detectors] covered by this standard are not intended to alarm when exposed to long term, low level carbon monoxide exposures or slightly higher short term transient carbon monoxide exposures, possibly caused by air pollution and/or properly installed/maintained fuel-fired appliances and fireplaces. See Table 38.1, Part B, False alarm resistance specifications."
[Table 38.1.B indicates the "NO ALARM" or "Ignore" Levels: 30 PPM for 30 days, 60 minutes @ 70 PPM, 10 minutes @ 150 PPM, and 4 minutes @ 400 PPM.]
What is left unsaid in that foreword statement is the extremely wide "time tolerance" permitted between the DO NOT Alarm, and the MUST alarm levels. This is especially troublesome to me since the same manufactures make CO detectors that meet the new EN-50291 Standard in Europe that requires all alarms must activate between 60 minutes and 90 minutes at 50 PPM.
Here are some conclusions I have drawn, based on the wording of the standard:
· At 30 PPM, a UL-2034 CO detector never has to alarm.
· At 70 PPM, it does not have to alarm until four hours of 70 PPM or higher.
· At 150 PPM, it does not have to alarm until 50 minutes of 150 PPM, or higher.
· At 400 PPM, it does not have to alarm until 15 minutes of 400 PPM, or higher exposure.
In my opinion the worst part about UL-2034, is that the standard would "permit" exposure to 65 to 69 PPM without alarming –– forever.
Fortunately, in March 1999, the Consumer Products Safety Commission (CPSC) took action and announced a recall of CO detectors that failed to comply to the standard to which they were manufactured. It was a step in the right direction.
The overwhelming negative publicity on the poor quality of the available retail grade CO detectors caused a virtual standstill in the sales for CO detectors manufactured throughout North America. At that time, manufactures were not using the right sensors and neither of the recalled CO detectors had an "end of life"" warning indicating product sensor failure. Today, both manufacturers are using good electrochemical sensors and do have end of life warnings. One of them now makes the best UL-listed CO detector on the market.
And Progress Is Being Made
Thanks to additional studies and testing, as well as product recalls and new laws mandating the installation of CO detectors in residential buildings, people are becoming aware of the dangers of low-level CO poisoning and the need for stringent guidelines for the manufacturer of CO detectors. Canada has played a major role.
Interest in CO detectors was greatly increased in Canada when Toronto decided to follow the lead of a few U.S. cities that had already written mandatory CO detector installation by-laws. This increased interest was further advanced when Canadian Standards Association (CSA) acquired control of IAS Laboratories, established previously by the merging of American Gas Association Laboratories and Canadian Gas Association Laboratories, and the fact that IAS had written a greatly improved CO detector standard.
The original IAS-96 Standard was the best CO standard ever written, thereby resulting in an extremely active competition between CSA and UL/ULC. This increasing media attention prompted CTV (television news station) to contact Jim Mackie, president of Fuels Safety Consultants and one of the world’s leading experts, to do a series of professional, fully data logged, CO detector activation tests to verify compliance to the existing UL/ULC-2034 test requirements. These test results were alarming, revealing an extremely high percentage of failures to comply with the performance requirements of the standard to which they had been manufactured.
In December 2004, I received a call from CBS News of New York, N.Y., about the new mandatory CO requirements for homes in New York, and the quality of the UL listed CO detectors being required by the wording in the new ordinance. CBS indicated that they wanted to conduct their own tests on the CO detectors available in retail stores.
I told them I recommended they contact Paul Clifford of Mosaic Industries, or Jim Mackie to perform the actual testing since they were both professionals with a lot of CO testing experience, and no vested interest, stock, etc. in any CO manufacturer. They chose to have it done by Jim Mackie in the week before Christmas, 2004. I was requested to be a witness to the procedures.
Three days later the tests were completed, and I was happy to report that other than one CO detector that failed to alarm within the proper timeline, all of the CO detectors tested responded at the required levels of CO, within the required timelines.
So it appears that the CO detector manufacturers have gotten the message that the media, lawyers, and consumers are watching, and are expecting the CO detectors –– as well as all of the detectors they purchase –– to do exactly what they say will do, nothing less. In previous testing of UL-2034 listed CO detectors, failure to meet the required activations at the levels and time frames listed in the standard was 36 percent, 48 percent, or more. So I will applaud most of the CO detector manufactures for finally meeting the UL requirements, as flawed as they are.
Let’s Work On The Standard
I want to make it very clear that I still do not endorse UL-2034. It is flawed. And like the other positive changes occurring in the CO detector industry, these improvements are a direct result of the passion and dedication of a few "life safety" professionals, media attention (especially in Canada), and large, successful liability lawsuits.
Now we need to get U.L. and CSA to make the needed changes to their standards to provide even greater protection for the consumer, and protection for everyone in the home. The technology is available, the medical requirements are better understood, and the time for change is now.
George E. Kerr, is president and founder of CO - Experts, a division of G. E. Kerr Companies, Inc.. Kerr has been in the early warning detection industry since April 13, 1953.