Regulatory Impact Assessment (RIA) Part J (Heating Producing Appliances) of the Building Regulations

Transcription

1 Regulatory Impact Assessment (RIA) Part J (Heating Producing Appliances) of the Building Regulations July 2012

2 SECTION 1: CONTEXT 1.1 Policy Context The Departments Statement of Strategy in its mission and mandate states that Our Mission is to pursue sustainable development. Some of the goals in pursuing this mission are to ensure good quality housing in sustainable communities; protect and improve water resources and the quality of drinking water; achieve a high quality environment with effective environmental protection. The Statement of Strategy also state s that - In the housing sector, the Government s Housing Policy Statement (June 2011) is strongly committed to a vision of better quality housing in sustainable communities. The High Level Objective in respect of housing policy is To enable all households access good quality housing appropriate to household circumstances and in their particular community of choice. The appropriate and timely revision of Building Regulations and their relevant Technical Guidance Documents (TGD) is a prerequisite to achieving good quality housing. Part J / TGD J contributes to good quality housing by providing guidance on the safe design and installation of heat producing appliances. In Part J / TGD J, the protection of water resources and the environment is also achieved by the prevention of pollution due to spillage from fuel storage tanks and provision of information to ensure the efficient operation of the building s heating system. 1.2 Regulatory Context Part J (Heat Producing Appliances) of the Building Regulations 1997 sets out the legal requirements for the use of heat producing appliances and the disposal of the products of combustion in a manner that protects the health and safety of the occupants and reduces to a reasonable level the risk of the building catching fire in consequence of their use. TGD J provides guidance on the air / ventilation required for proper combustion, the location of appliances and the protection of combustible material from radiant heat, the size of flue pipes and termination positions, depending on the type of fuel being used. Guidance on the protection of oil storage tanks from fire both from the building being served or the boundary is also given as well as protection of the ground in sensitive areas from contamination due to spillages. As a general rule, Building Regulations only apply to the construction of new buildings and extensions and construction works relating to material alterations to existing buildings. In addition, certain parts of the Regulations apply to existing buildings where a material change of use takes place. Notwithstanding any material 2

3 alterations or material changes of use, requirements under the Building Regulations do not apply to buildings constructed prior to 1 June Statement of objectives General objectives: Protection of occupiers from the harmful effects of carbon monoxide that may arise in dwellings. Protection of occupiers and buildings from fire. Proper and efficient combustion and discharge of combustion gases. Compliance with, and reference to, European Standards adopted by Ireland. Protection of sensitive areas from pollution due to fuel spillage. Provision of information to ensure the efficient operation of the installed system. General update of guidance and references. Immediate objectives: Ensure that all new dwellings have detection and alarm protection with regard to carbon monoxide (CO) while reducing the potential for CO production by the provision of adequate ventilation. SECTION 2: COST BENEFIT ANALYSIS 2.1 Identification & Description of Options The Department has considered four options for the purpose of this assessment. Option (a) Do nothing. Option (b) Introduce amendments as proposed in draft Part J / TGD J to update existing, and give new, guidance on: the provision of detection and warning of CO in new dwellings and in existing dwellings where the replacement of certain heat producing appliances is proposed. (see Appendix A for background information on this provision). a notice giving information on the type of appliance suitable for the hearth, fireplace, flue or chimney. protect against pollution from liquid fuel storage. 3

4 provision of air for combustion in increasingly airtight houses. information to be provided to the owner on the heating system installed and any continuing maintenance required to ensure its safe and effective operation and to avoid risk to health. Option (c) Introduce amendments as described in option (b) but recommend the provision of CO detectors on a voluntary basis. Under this option, those involved in the design and construction of dwellings would have the information necessary to provide for CO detection and alarm facilities. Option (d) Introduce amendments as described in option (b) except for the provision for detection and warning of CO and rely on other organisations, such as the Registered Gas Installers of Ireland (RGII), to protect the consumer from CO through voluntary schemes. 2.2 Impact Analysis Option (a) This will have no positive impact and no benefits are expected. TGD J will not reflect current construction techniques, product development or European Standards adopted by the National Standards Authority of Ireland (NSAI). Failure to update Part J / TGD J may result in a devaluation of the Building Regulations, as many of the 55 standards referenced in the current TGD J have been withdrawn or superseded by EN standards. Option (b) This will ensure that new buildings and the products installed in them, including, combustion appliances, flues and systems, meet adequate standards to operate safely and efficiently and give adequate warning in the event of a CO incident. The Carbon Monoxide Report attached at Appendix A gives the reasoning behind the recommendation for the provision of detectors. It also outlines the need for the scale of provision as specified in the proposed TGD J. Option (c) This will ensure that new buildings and the products installed in them, including combustion appliances, flues and systems, meet adequate standards to operate safely and efficiently. However, the protection of occupants in dwellings from the harmful effects of CO would only be on a voluntary basis and would not guarantee the standard of detector nor its proper installation, factors which are crucial to the effective operation of a detector system. Continuation of current publicity campaigns would be the driving force for this option s implementation and success. Option (d) This will ensure that new buildings and the products installed in them, including combustion appliances, flues and systems, meet adequate standards to operate safely and efficiently. Similar to option (c), the protection of occupants in dwellings from the harmful effects of CO would be on a voluntary basis. The effectiveness of this proposal would depend, to a large degree, on the type of fuel being used and the 4

5 organisations supplying the fuels. Currently, gas is the only fuel where the end use is regulated and monitored / serviced. This would result in the consumer being protected in specific circumstances only. In addition, there would be no consistency in the standard applying to the detectors, the number installed and their location(s) given the dependence on individual installers or organisations. 2.3 Cost Option (a) There is no cost associated with this option. Options (b), (c) and (d) have the same basic minimal cost in respect of the provision of information and, in specific circumstances, for the provision of a bunded tank for the prevention of pollution. Thus the only real difference in cost is the provision of a CO detection system as a requirement or voluntary basis. Installation advice is given by the manufacturer in accordance with the EN standard. Option (b) The additional cost associated with this option relates to the provision of CO detectors with end-of-life alarms. Typically, this will mean 2 detectors per dwelling. The proposed provision allows for sealed battery detectors, requiring no specific competency and given location knowledge is provided with the unit as well as in TGD J and EN 50292, no specific training is required for the purposes of installation. It should be noted that the EN Electrical Apparatus for the detection of carbon Monoxide in domestic premises - Test methods and performance requirements standard has been adopted by the NSAI. The Building Regulations will refer to this I.S. EN standard with the result that all units will have to comply with this standard and in addition have an end-of-life indicator. The average cost of a CO detector complying with the EN standard and having an end-of-life indicator is 30-40, with more sophisticated radio link devices costing 60. This is minimal in the overall build cost of a dwelling which is currently in the order of 150 per square foot. Replacement costs every 5-6 years will be born by the householder. Option (c) The current promotional costs by various sectors, including Government, would have to be maintained or increased to have an equivalent impact with no guarantee of success. Possible education of professionals involved in construction may be needed in order to convert them and the industry to the voluntary use of detectors. Option (d) The current promotional costs by various sectors would have to be maintained and the cost of the provision of detectors currently being provided indirectly by the State would also have to be maintained and applied to new build as well as existing. 5

6 2.4 Benefits Option (a) No benefits are expected. Option (b) The economic consultants DKM in their report The Irish Construction Industry in 2012 estimated that the number of dwellings to be built this year would be in the order of 5,000 and that the main prospects for the residential construction sector are expected in the emerging Green Economy with its associated opportunities for the retrofitting of homes. As Part J / TGD J applies to the retrofit of heat producing appliances, as well as new build, any benefits will have a major impact in the current construction environment. The main benefits of the proposed amendments to Part J are that they will ensure that all new installations meet the improved standards applying to heat producing appliances and that information for the proper and efficient operation of these appliances will be provided to the home owner. The immediate effect is that: The householder has detection and warning of CO in high risk areas within the dwelling. There is a reduced risk of a CO incident affecting the occupant s health by early detection. The operation of new heating appliances will be more efficient and effective. Local drinking water sources will be protected from potential pollution. Longer term benefits will include: There is a reduced risk of fatalities from CO incidents in dwellings. The risk of a house fire due to the use of an inappropriate flue will be much reduced. The potential to contaminate the groundwater due to spillage will be reduced. The risk of damage or explosion due to the storage of gas or bio-fuel will be reduced. The environment will benefit from the proper operation of the heating system and will aid compliance with Directive 2002/91/EC on the energy performance of buildings (i.e. the EPBD). 6

7 Option (c) The extent of benefits relies heavily on the willingness of designers, consultants and builders involved in industry to participate. Without resources to sustain public awareness and the continual promotion and education of professionals, the possible benefits secured under this option would be significantly less than other options. Option (d) Benefits under this option would be of the same magnitude as those of option (b) for the gas sector but without the establishment of similar organisations in the oil and solid fuel industries the impact would be minimal and reliant on public awareness. The householder would ultimately be responsible for any success. 2.5 Other Impacts Competition assessment The proposed recommendations will create a demand for properly tested and certified products and potentially reduce the number of non compliant products currently being sold to consumers and reduce the burden of product surveillance. Fully compliant products currently on the market will be able to compete in an open market without any extra cost. It is not expected that the costs of the regulation will have a disproportionate affect on any one manufacturer, nor affect the market structure. Consultation The draft proposals for Part J and TGD J will be subject to a three month public consultation in the latter half of Regulatory burden Building designers will have a period of time to adapt to the proposed revisions. It is generally accepted in the industry that Building Standards and codes of practice evolve over time. This should not have any impact on design and supervision fees. Enforcement and compliance Under the 1990 Building Control Act, enforcement of the Building Regulations is primarily the responsibility of the 37 local Building Control Authorities, each of whom has appointed a Building Control Officer. Responsibility for compliance with the Building Regulations is primarily a matter for the owner and builder of a building. 2.6 Summary and recommendations Option (a) While this option imposes no additional costs, it does not provide any benefits over and above existing requirements. Furthermore, Part J is now viewed as being outdated having regard to current construction techniques, product development, European Standards and requirements in neighbouring jurisdictions. Option (b) This is the preferred option as it provides the following: 7

8 It reinforces current actions being undertaken by other State agencies, like RGII, and neighbouring jurisdictions such as Northern Ireland and England. It ensures Ireland s Building Regulations with regard to heat producing appliances will be more comparable with international best practice. Its estimated benefits to the homeowner and the public far outweigh the extra cost. It is in accordance with other public sector recommendations from the Commission for Energy Regulation (CER) and the NSAI and gives due recognition to public concerns raised on the CO issue. It will aid in bringing CO detection products on the market in line with the EN standards and apply end-of-life criteria crucial to the long term protection of the consumer. Option (c) This option will continue to impose ongoing costs on Government / State agencies due to media campaigns and may yield little additional benefit compared with Option (a). Option (d) Option (d) would continue to impose ongoing costs on Government / State agencies for public awareness and supply of detectors. The selection of this option could also be viewed as supporting one fuel sector while providing limited consumer protection. In conclusion, Option (b) is the recommended course of action. 8

9 APPENDIX A Carbon Monoxide Report 1. Introduction 2. History and reliability of CO detectors 3. Developments in relation to CO detectors 4. Current International Practices 5. Incidents 6. Recommendation

10 1. Introduction Carbon Monoxide (CO) is a colourless, odourless poisonous gas. It is a non-irritant gas that is lighter than air and is very slightly soluble in water. When CO is inhaled into the body it combines with the blood preventing it from absorbing oxygen. If a person is exposed to CO over a period, it can cause illness and possible death. In the case of buildings, CO can arise from heat producing appliances if there is a lack of air for the combustion process, or if the heat producing appliance is faulty. In such circumstances, incomplete combustion can occur resulting in the production and potential build up of CO in the building concerned. This report comprises a desk top study of the available information with regard to CO in dwellings and its purpose is to seek to establish the reliability of current alarm technology, the lifespan of such technology, the practical application of the available systems and their potential to reduce the adverse outcomes that may arise from CO incidents. The study reviews current standards, has regard to the current recommendations of major stakeholders and takes into account international best practice. 2 History and reliability of CO detectors The CO detectors available in the nineties raised many questions with regard to - 1. Sensor accuracy, 2. Sensor lifespan, 3. Battery life, and 4. Method of alarm. As a result, the UK Government initiated research to establish the reliability of CO devices. The HSE Contract Research Report 360/2001 entitled Joint industry project on carbon monoxide issues: Long-term reliability of domestic CO alarms was further supplemented by a continued two year study reporting in 2003 on the performance of the sensors. Failure rates of 33% were observed after 1 year, 24% after 2 years, and 40% after 3 years. The majority of failures were attributed to excessive loss in sensor sensitivity. These reports also highlighted the potential limitations in the periodic button testing of alarms, as such tests were suggested to be unable to test the continued reliability of the alarm sensor to detect CO. Two of the main conclusions from this report noted that - A number of specimens have been withdrawn, mostly for exhibiting sensor drift of a fail-to-danger type, and 10

11 Domestic CO alarms need output signals that are clear and unambiguous, and other design features require careful consideration, to reduce the possibility of unnecessary emergency callouts. The devices showed either late triggering of the alarm based on that required by the standard for a certain level of CO (see diagram below) or nuisance triggering due to the early triggering with low levels after 2 years. Test with 350 ppm CO Test 150 ppm CO It is in this context that any recommendations regarding CO alarms were felt to be inappropriate and that the key actions that are required to prevent CO incidences are: - 11

12 1. Proper installation and commissioning of heat producing appliances and flues/chimneys; 2. Ensuring proper air supply is maintained to combustion devices. 3. Proper maintenance and inspection of combustion appliances on a regular basis. This is born out by the fact that in the introduction to EN 50292: 2001 Electrical apparatus for the detection of Carbon Monoxide in domestic premises - Guide on the selection, installation, use and maintenance it is stated that Apparatus for the detection of carbon monoxide are not a substitute for good installation and regular servicing of fuel burning appliances or regular cleaning of chimneys, although they may provide an added margin of reassurance for users. Even the development of a product standard for CO alarms EN 50291: 2001 Electrical apparatus for the detection of Carbon Monoxide in domestic premises - Test methods and performance requirements while setting down performance criteria regarding alarm times for certain levels of CO, more stringent than those required by BS 7860(see table below), did not specify the need for an end-of-life warning, resulting again in uncertainty regarding the true protection being given by the apparatus. The introduction also called into question the ability of the existing sensors to be as discerning as the test required resulting in the HSE Contract Research Report commenting that it seems unlikely that this level of discrimination can be achieved reliably by existing metal oxide semiconductor sensors. It should be noted here also that, unlike a smoke alarm where the test button confirms the serviceability of the device, the push button test on the CO alarm only tests the electronics of the apparatus not the sensor device and so the electronics may be working but no protection is given as the sensor may be defunct. 3. Developments in relation to CO detectors. EN 50291: 2001 Electrical apparatus for the detection of Carbon Monoxide in domestic premises - Test methods and performance requirements has been revised and is now designated by EN 50291: 2010 Electrical apparatus for the detection of Carbon Monoxide in domestic premises - Part 1 Test methods and performance requirements. 12

13 The standard EN Electrical apparatus for the detection of Carbon Monoxide in domestic premises - Guide to the selection, installation, use and maintenance is also being revised and is currently out for comment. The National Standards Authority of Ireland (NSAI) in conjunction with the Gas Standards Technical Committee and this Department further strengthened the quality of detectors to be used in Ireland by developing a Standard Workshop agreement, SWiFT 8, requiring the detector s end-of-life to be displayed on the product and an audible and visual alarm to be fitted. Product surveillance in Ireland has resulted in at least 5 detectors not complying with the EN standard being withdrawn from the market here. The EU rapid alert system for dangerous consumer products (known as RAPEX), which allows for the rapid exchange of information between Member States and the Commission of measures taken to prevent or restrict the marketing or use of products posing a serious risk to the health and safety of consumers, shows that other countries are also having detectors withdrawn that are not meeting the standard. In 2011 the UK Health & Safety Executive initiated a study on the long term reliability and use of domestic CO alarms. Two of the objectives of the study were: - 1. To estimate the reliability of domestic CO alarms, which have been in normal service in consumers homes, based on the 330 ppm CO test, for those certified to the British standard BS EN 50291, or the 400 ppm CO test, for those certified to the US standard UL To derive information on the domestic use of CO alarms, from data obtained from householders by questionnaire, and relate such data to the recommendations contained in the guidance standard BS EN Effectively, two aspects of CO alarm use were investigated as part of this study: the reliability of alarm sensors to detect CO according to specific requirements set out in BS EN or UL 2034, and whether the alarms were appropriately used and deployed in homes by householders, e.g. according to BS EN guidelines. The conclusions of this study with regard to reliability are that: - The reliability of the most common models of CO alarms available in the UK, particularly over their first four years of life, as judged by conformance to the British standard BS EN and the broadly equivalent US standard UL 2034, appear to have improved significantly since the last study of this kind in The headline failure rate observed in this study, suggests that significant improvements in alarm reliability have been made over the last 7 years. It should be noted that the average manufacturer recommended lifespan of the alarms tested was 6 years while 59% (55/93) of those gas tested were between 2-6years. 13

14 Key stakeholders The Minister for Communications, Energy and Natural Resources and the Commission for Energy Regulation (CER) are both required under the Gas (Interim) (Regulation) Act 2002 to have regard to the need to promote safety and efficiency on the part of natural gas undertakings. While CER historically were not in favour of a mandatory requirement for CO alarms, their current position has changed given recent technological advances in alarm accuracy and reliability development. CER are now supportive of such installations when in accordance with SWiFT 8: 2011 or equivalent EN. The Minister for the Environment, Community and Local Government addresses the technical considerations in relation to the installation and commissioning of heat producing appliances under Part J of the Building Regulations (see below). NSAI, and its Gas Technical Standards Committee (GTSC), have a role in the development of standards relating to gas appliances and their installation. In the light of the provisions of SWiFT 8, both the NSAI and the GTSC are now supportive of the use of CO detectors in dwellings incorporating fuel burning appliances. The Health and Safety Authority promotes awareness and regulates the risks of carbon monoxide in the workplace. The Department of Health and the Health Services Executive have specific responsibilities in relation to health promotion and environmental health. The Environmental Protection Agency monitors the level of atmospheric pollutants, including carbon monoxide; and the Central Statistics Office publishes statistics relating to incidents of carbon monoxide poisoning. Other measures in place to address CO risks (i) The Registered Gas Installers of Ireland (RGII) scheme run by CER. This scheme imposes a statutory obligation that only competent persons may install and maintain gas installations, thus providing an important level of safety in the industry. The RGII in conjunction with CER have contracted for 30,000 CO alarms to be distributed free to RGI members once they have done the specified CO training course. (ii) Bord Gáis, NSAI and ILPGA operate and frequently revitalise their radio and television advertising campaign to raise public awareness about the risk of carbon monoxide poisoning. They also support a very informative website (iii) NSAI, acting through the GTSC, convened a group of gas industry and Government technical experts, including the Department of Environment, Community and Local Government, to provide information in the absence of sufficient provision in the European standard (EN 50291) to ensure that the user can identify battery or sensor failure when it occurs or satisfactorily address the required level of competence for installing such alarms). This work resulted in the publication on 29 July 2011 of SWiFT 8: 2011 Specific Requirements for 14

15 Electrical Apparatus for the Detection of Carbon Monoxide (CO) in Domestic Premises. (iv) The CER has extended the Natural Gas Safety Regulatory Framework to include the Liquid Petroleum Gas (LPG) sector which would extend the coverage of the CERS gas safety responsibilities. (v) Building Regulations Part L Conservation of Fuel and Energy has required all new and replacement boilers in dwellings to have an efficiency of 86% since 31 March 2008 and an efficiency of 90% since 1 December This promotes the installation of room sealed boilers, which have a lower risk of the escape of carbon monoxide due to balanced flues. (vi) There has also been an awareness campaign for General Practitioners / family doctors to increase awareness of carbon monoxide risks amongst health professionals. 4. Current International Practices In 2009, Colorado state passed a bill that requires homeowners and owners of rental property to install carbon monoxide alarms near the bedrooms (or other room lawfully used for sleeping purposes) in every home that is heated with fossil fuel, has a fuel-fired appliance, has a fireplace, or has an attached garage. This requirement applies to every home that is sold, remodeled, repaired, or leased to a new tenant after July 1, A requirement on CO alarms exists in 24 states in the USA. In Canada, the national building code recommends that CO alarms be provided in each bedroom or hallway within 5m of the bedroom door where a combustion appliance is fitted or a garage is attached. Many of the territories have adopted the recommendation including Winnipeg where the alarm must be hardwired. The Australian Government is currently working with each state and territory in Australia to pass legislation that would regulate the installation of CO alarms and the testing of gas appliances in rental properties. The UK s Regulation J, which came into effect on 1 October 2010, requires that where a fixed combustion appliance is provided, appropriate provision shall be made to detect and give warning of the release of Carbon monoxide. The Approved Document J - Heating Appliances deems compliance is achieved by the provision of a CO alarm in dwellings with solid fuel burning appliances. In Northern Ireland, the Housing Executive last year undertook to install 40,000 CO detectors in its homes. The Northern Ireland standards authority in their recent public consultation on heat producing appliance regulations propose Where a combustion appliance is installed in a dwelling, reasonable provision shall be made to detect and give warning of the release of carbon monoxide at levels harmful to people. 15

16 Their Guidance document states Where a new or replacement combustion appliance, not designed solely for cooking purposes, is installed in a dwelling, a carbon monoxide detector/alarm should be provided in the room where the appliance is located. However, if the combustion appliance is installed in a room or space not normally used e.g. a boiler room/cupboard, the detector/alarm should be located just outside the room or space. This will allow the alarm to be heard more easily. This is to come in operation in October Building Regulations Part J Heat producing appliance Part J of the Building Regulations 1997 sets out the minimum legal standards of safety and quality in relation to the installation of heat producing appliances in new buildings and in relation to the replacement of heat producing appliances in existing buildings. Technical Guidance Document (TGD) J provides guidance on how to comply with the requirements of Part J. The maximum rated outputs of the burning appliances addressed in TGD J would normally apply to dwellings and small commercial premises but not large bespoke systems. Mobile heat producing appliances do not come under the requirements of Part J. The Building Regulations have not previously required the provision of CO alarms due to concerns about the reliability of such alarms, their lifespan and the lack of research-based consensus on optimum location and installation arrangements (see history section above). However, developments have taken place within the industry since Part J of the Building Regulations (Heat Producing Appliances) was last reviewed which would suggest that these concerns may have been addressed or at least lessened. 5. Incidents Ireland has very little statistical evidence with regard to CO incidents and most of the statistics relate to gas incidents. However, the department of public health within the Health Service Executive has analysed Hospital Inpatient Enquiry Data (HIPE) on all Irish acute hospital discharges; and Central Statistics Office (CSO) data on deaths in Ireland. The HSE s analysis shows that over the 11 year period of 2000 to 2010 inclusive there were 307 deaths registered in Ireland in which the toxic effect of carbon monoxide was the natural cause of death. Seventy three of these cases were due to accidental poisoning following exposure to carbon monoxide. This represents an average of over 6 carbon monoxide deaths per annum in Ireland potentially preventable*. The study found a national average of 24 acute hospital discharges per annum with a diagnosis of toxic effects of carbon monoxide. 16

17 *By preventable it is assumed that no carbon monoxide monitor was installed; and the assumption is made that the presence of a functioning carbon monoxide monitor could have provided the alarm, resulting in appropriate action to prevent exposure to toxic effect of carbon monoxide. Other causes of death from carbon monoxide include fire, suicide or poisoning. Unfortunately, no information on where the fatalities happened, the type of fuel or appliance involved, or whether an alarm was in place and functioning, is available and so inferences must be made from statistics in other jurisdictions especially the UK. From analysis of incidents that have occurred in the UK, the predominant area for CO fatalities is in dwellings (see diagram below) privately owned. This analysis would appear to suggest that non-domestic buildings would not be considered high risk category having regard to the number of CO incidences that have arisen over the period of the study. Location of deaths arising from CO in 2007 (Study on the Provision of Carbon Monoxide Detectors Under The Building Regulations BD 2754) 17

18 6. Recommendation Possible Options The proposed Part J / TGD J have the following options available: 1 Give guidance on the voluntary provision of CO alarms including product standards, installation and scale with warning on the continued servicing and maintenance of combustion products. 2 Require the provision of CO alarms meeting certain standards in new dwellings where there is a combustion appliance and possibly in existing dwellings where combustion appliances are being replaced. The location and level of provision is crucial in assessing the practical provision of CO alarms. The considerations are: a) CO alarm for some fuels (like UK) or for all fuels; b) CO alarm for open flue or flue-less appliances or for all appliances including room sealed / balanced flues; c) CO alarm for main heat producing appliance or all appliances (including open fires) in dwellings; d) CO alarm for all combustion appliances and / or in bedrooms; e) CO alarm for all combustion appliances and where system flues pass through / over bedrooms / other rooms; and f) CO alarms in high risk areas. Analysis of options (a) From the evidence of CO incidents, the majority appear to occur with solid fuel with gas and oil being the safest. This is also the conclusion of the UK study (See Figure A1 & A2) but gas was excluded in the UK as the new appliances have an oxygen depletion cut out device fitted. No other country has taken this approach. (b) Open flue or flueless appliances, because they take the combustion air from the room, have a potentially greater risk than a balanced flue scenario. The draft pren states if there is a fuel burning appliance in more than one room and the number of apparatus is limited, the following points should be considered when deciding where best to position the apparatus: locate the apparatus in a room containing a flueless or open-flued appliance, and locate apparatus in a room where the occupant(s) spend most time. 18

19 Modern room-sealed / balanced flued appliances are not considered a high risk when installed, commissioned and serviced properly. The CO incidents recorded involving these flues mainly relate to older systems from the late sixties and early seventies where the fan draught system was fitted on the exhaust side and was prone to failure due to the effects of heat and combustion gases. An exception to this is the room sealed appliance with an extended balanced flue due to the travel distance of the air and potential dislodgement of the flues resulting in the escape of CO at the appliance or along the flue length (see Figure A3). (c) (d) The limiting of CO alarms to the main heating appliance would exclude some of the main causes of incidents, the open fire or the fixed gas room heater. It could also mean that some dwellings would not have a CO alarm as the appliance could be sited externally. The draft pren states Ideally, an apparatus should be installed in every room containing a fuel burning appliance. Additional apparatus may be installed to ensure that adequate warning is given for occupants in other rooms, by locating apparatus in: remote rooms in which the occupant(s) spend considerable time whilst awake and from which they may not be able hear an alarm from apparatus in another part of the premises, and every sleeping room. Currently some countries require detectors at the appliance while others require them at, or adjacent to, the bedrooms but no country requires them in both places. In Canada, if the appliance is in the basement then a detector is required at the appliance and the bedrooms. The provision of detectors in bedrooms alone would not have prevented some of the fatalities associated with CO particularly in the cases of solid fuel in Ireland. (e) (f) There is merit in considering the specific circumstances where a flue from a combustion appliance travels through or over bedrooms. From Figure A4 it can be seen the High Risk areas are the living room, bedroom and hall / landing and this would concur with the anecdotal evidence from known incidents across all fuels in Ireland. Thus any solution should potentially cover all these areas. Preferred option An analysis of all the available information leads to the conclusion that the use of CO detectors to the proper standard and with adequate in-built visual and audible warning systems would give added protection. The predominance of CO incidences in dwellings either owner occupied, or private rented, leads to the conclusion that the provision of an alarm in dwellings would be the most advantageous. 19

20 Combining the High Risk areas with the high risk flue types and the recommendations of EN where limited number of apparatus are to be used, it would appear appropriate, in the context of the Building Regulations and related guidance, that in general : - CO detectors / alarms should be required in new dwellings and in existing dwellings where certain heat producing appliances are replaced. In such cases they should be in or near bedrooms and where open-flued or flueless appliances including fireplaces are used. 20

21 Appendix Figure A1: Deaths from CO in 2007 shown by fuel type [CO-gas safety, 2009] Study on the Provision of Carbon Monoxide Detectors Under The Building Regulations BD 2754 Figure A2 CO-Gas Safety

22 Figure A3: Incidents by Flue type Gas Safety Trust Carbon Monoxide Incident Report 2011 Figure A 4 Gas Safety Trust Carbon Monoxide Incident Report