16 April 2012
Manager, SCER Secretariat
Department of Resources, Energy and Tourism
GPO Box 1564
CANBERRA ACT 2601
RE: Consultation Regulation Impact Statement (RIS) for the Gas Appliances (Carbon Monoxide) Safety Strategy
The Master Plumbers’ and Mechanical Services Association of Australia (MPMSAA) submits the following comments:
The MPMSAA is a National Plumbing Association and a leading stakeholder in the Gas Appliance Services sector and is committed to providing its member companies with up to date information, training and support to ensure that the highest quality of service and safety is provided to consumers.
MPMSAA is more than happy to provide technical assistance to the RIS through the Gas Services Division that comprises of licenced gas appliance fitters who also sit on two Australian Gas Standards committees.
The comments below have been collated from member’s responses. Some individual members’ statements and comments have been included in red.
In regards to Carbon Monoxide safety, the MPMSAA is supportive of a strategy that addresses the importance of appliance maintenance on a regular basis.
MPMSAA strongly supports and is active in providing upskilling of plumbers/gasfitters and educating consumers on the importance of keeping their appliances serviced by competently trained and licenced gasfitters.
The MPMSAA in conjunction with the Plumbing Industry Commission (PIC),Plumbing Industry Climate Action Centre (PICAC) and Energy Safe Victoria (ESV), has been running a free training course to provide plumbers and gas technicians with the skills and knowledge to use carbon monoxide (CO) testing equipment and complete the practical procedure to test appliances for CO emissions.
The course covers the processes plumbers should follow to identify situations that could result in CO spillage within a residence. It references the newly released ESV Gas Information Sheets No. 37 & 38.
Additional courses have been scheduled due to the popularity of the courses which have been delivered throughout Victoria. However we believe that these courses should be available to all gasfitters across Australia.
The following, are further comments regarding the RIS on Carbon Monoxide for Domestic Appliances.
Note: A number of individual’s comments have been highlighted in red. These are personal comments and have been included as additional information that may be of assistance for the Allen Consulting Group to collect the views of gasfitters in the field.
In reviewing the Allen Consulting Group RIS we feel that many cases described could be considered as a knee jerk reaction rather than identifying why as an industry and not just plumbers, are in this situation.
It would appear no method let alone training was done on the subject of testing the fan effect on gas appliances.
We have one big initial problem to contend with in relation to existing installations and only a concerted and honest awareness program will suffice but on the other hand we can see that future installations will be acceptable if the points raised below are taken into consideration.
Energy Efficiency:
Page 13 of the RIS highlights “Improved energy efficiency in residential buildings” is sighted as a factor in reducing the rate of air exchange between the inside of a house and the outside environment and the fitment of better sealing around windows and doors “may not provide sufficient oxygen for combustion resulting in the production of CO.”
Sealing, termed as adventitious openings “i.e. gaps around doors, windows, etc” as described in AS/NZS 5601-2010 and AS 5601-2004 the previous Australian standard for Gas Installations, should not only be addressed with the addition of extra ventilation or public awareness communication of problems it can cause with gas appliances and in particular natural draught heaters as a way to resolve the problem.
How has the building/plumbing/electrical industry got to this situation without proper assessment and investigation as to what the overall effect of sealing up a home will have on gas appliances?
Discussion and consideration on the following points raised is recommended as a long term solution that takes in prevention of such a situation arising again and the development of checks and balances that will continue to question ventilation standards and requirements in future building development.
CO Poisoning Domestic Gas appliances:
Box 1.1 on Page 2 of the RIS “Quantitative Risk Assessment on the risk of CO poisoning from domestic gas appliances” last paragraph states:
“The least effective strategies (from a pure efficacy point of view) included increased appliance standards for existing appliance technologies and increased training. Given the stringency that already applies to appliance safety standards and gasfitter/plumber accreditation it was unlikely that suggested increases would have a material effect.
“In the case of training what is this statement based on? It is outrageous to suggest training will have no effect on the overall scope of the industry. This is a statement made by person/s with NO actual knowledge or background in this industry. As far as the increased appliance standards this can easily be disputed as false and misleading as the AGA is no longer the main governing body. Also there is no real testing of the appliances as was the case originally”.
There is no listing under references relating to what any training programs are conducted on gas installation, servicing and/or pass or failure rates of trades persons and apprentices who attend this training at Registered Training Organizations (RTOs)
To suggest that increased training would not have a material effect on the problem at hand or even the future is a negative and offhand comment without any substance.
“Since the demise of the Old Gas and Fuel we have lost the skill set required to carry out appropriate training and competent trainers. The “bar has been effectively lowered” without thinking about the future. We now have a lower standard of training with influence from other states attempting to mask the importance of servicing of appliances over pushing the manufacturers line of selling new and “supposedly better” appliances”.
The same applies to AS/NZS 5601-2010 and AS 5601-2004 Gas Installation standard which is still presently current in the state of Victoria.
Had these two standards been consulted, the inaccurate claim under
Option 4 Changes to ventilation design of extraction systems on page 26 of the RIS that states “the effect of exhaust fans on the room air pressure is currently not considered in residential premises” would not have been made?
There are a number of anomalies between Parts 1 and 2 of AS/NZS 5601-2010 can cause confusion.
These Australian Standards are not referenced and included or apparently considered in the RIS and therefore leading to some inaccuracies in the report and subsequently a potentially suspect assessment of the problem.
A very good example of the anomalies between Parts 1 and 2 of the standard are described below where in some cases the restrictions on the installation of a gas refrigerator in a home are greater than that in an RV.
Page 6 of the RIS under the heading Recreational Vehicles makes the point that “Gas appliances are also common in Recreational Vehicles (RVs). Gas is often used to fuel cooking appliances, water heaters and refrigeration units. Gas appliance use in these vehicles poses an additional danger due to the small areas within which these appliances are operated.”
The last sentence of this paragraph is quite alarming against what is allowed regarding the operation of gas refrigerators in homes and RVs as detailed in ASNZS 5601-2010 Parts 1 & 2.
AS/NZS 5601-2010 which came into effect around Christmas Eve 2010 has contradictory requirements as to how a gas refrigerator can be installed.
AS/NZS 5601-2010 Part 1, General Installations: (Domestic Residence)
6.10.18 Refrigerator
6.10.18.1 Prohibited locations
A refrigerator shall not be located in a pantry, larder or bedroom unless installed in accordance with Clause 6.10.18.3.
6.10.18.3 Requirements where refrigerator is to be in a sealed recess.
Where a refrigerator is to be installed in a sealed recess, the recess shall have two openings to outside. One opening shall be located at the top of the recess and the other at the bottom.
AS/NZS 5601-2010 Part 2, LP Gas installations in caravans and boats for non-propulsive purposes
6.10.3 Clearances
Refrigerators shall be installed within cabinet work such that the infiltration of combustion products into the compartment is minimized. Minimum clearances, where specified by the manufacturer, shall be maintained.
As underlined above the installation of a refrigerator in a domestic residence when installed in a pantry, larder or bedroom has to be in a sealed compartment other than the free vent area to an external location.
Conversely this requirement is different when it applies to an RV. “Refrigerators shall be installed within cabinet work such that the infiltration of combustion products into the compartment is minimised.”
This situation is compounded further when you have a state gas regulator who has given an exemption to a manufacturer of caravans to have additional fixed ventilation installed at the top of the refrigerator cabinet within the Caravan, RV immediately over the heat exchanger and flue outlet of the refrigerator to expel warm air that effects the operation of the refrigerator. This exemption was granted over ten years ago.
An incident at Porepunkah in Victoria in 2010 involved a gas refrigerator where 11,000 parts per million (ppm) were emitted from the refrigerator and the occupants of the cabin were affected by CO emissions.
Any expelling warm air through a vent over a refrigerator in a caravan may also contain flue products and potentially CO.
Another anomaly between what is required in installing a refrigerator in a home and an RV in regard to the ventilation requirements is that a mesh that restricts the flow of air is allowed to be placed over fresh air ventilation in an RV and not in a home.
“It shows that there is little understanding from the author but they are willing to sacrifice in a home situation for “Green Star Ratings” whereas an RV does not have the same”.
AS/NZS 5601-2010 Part 1 Gas Installations (Domestic Home)
6.4.4.2 Natural ventilation
Two permanent openings shall be provided each with a minimum free ventilation area as calculated using the following formula:
A = F × T where
A = the minimum free ventilation area, in millimetres squared.
F = the factor given in Table 6.1
T = the total gas consumption of all gas appliances, in megajoules per hour.
The minimum vertical dimension of any free ventilation opening shall be 6 mm to minimise linting.
AS/NZS 5601-2010 Part 2 Gas Installations (Caravans, RVs Boats)
7.3.1 Minimum free area
The free area of the total permanent ventilation to be provided shall be at least 4 000 mm2
or the value obtained from the formula below, whichever is the larger:
V = (610 × U) + (650 × P) where
V = the minimum free area (in mm2).
U = the input rating for all gas appliances, including cookers (in MJ/h), refer to rating plate.
P = the number of persons for whom the compartment is designed.
Example calculation
For a compartment designed for 3 people, and having a gas cooker rated at 29 MJ/h (8 kW), the minimum free area for ventilation, V, is (610 × 29) + (650 × 3) = 19 640 mm2.
NOTES:
1 This formula should be applied for any part of the caravan or boat that is normally divided off as a separate compartment or that can be divided temporarily by means of doors, curtains, etc. The calculated ventilation area is strictly the minimum for safety and should be exceeded where possible. It does not in any way replace or reduce the normal adjustable ventilation provided by windows, etc.
2 For appliances with input ratings given in other units the following conversion factors may be used:
1 kW =3.6 MJ/h; 1000 BTU/h =1.055 MJ/h.
3 The use of louvers and/or mesh screens will reduce the free area of an opening. Allowance should be made to ensure free areas are achieved.
The last line in each of the above clauses from Parts 1 & 2 of the standard varies greatly and can be very confusing to the installer.
In a home which is much larger than an RV a clear 6mm of free ventilation is required to prevent linting where as a mesh screen can be placed over the same required free air ventilation in a smaller caravan, RV which is basically a pantry, larder and bedroom on wheels.
To compensate the issue of having a mesh over what is supposed to be clear ventilation in an RV the standard calls for an allowance to be made.
A mesh screen is not equal to 6mm’s of clear ventilation no matter what size the vent perimeter is, it will block up quicker and easier than 6mms of clear ventilation.
“Demonstrates clearly the lack of knowledge in this area by the Author of the RIS”.
The second paragraph last sentence under Recreational Vehicles of the RIS reinforces the need for the author of the RIS to consult with what is written in the gas standards before assuming that reviewing them in making this report will have no effect.
“The GTRC has indicated that issues with gas appliances in RVs mainly result from the incorrect installation of 3-way fridges.”
Once again on Page 13 of the RIS under “Gas Appliance use in Recreational Vehicles it states Recreational vehicles (RVs) containing gas or other fuel burning appliances are potential source of CO poisoning risk in the community. RVs pose an increased risk of CO poisoning due to the small area within which gas appliances operate. As a result, faulty appliances can rapidly increase the CO concentration in RVs to potentially dangerous levels. Gas is commonly used in RVs to fuel space heating, water heating, cooking and refrigeration devices.”
On the basis of what is described above AS/NZS 5601-2010 standard Parts 1 & 2 the reviewing of them would not be the “least effective strategy”.
CO Poisoning and what can cause it:
See Item 2.3 Requirements for CO poisoning from gas appliances and the dot points on Page 9 of the RIS after “Likewise, there are a number of faults that can lead to the production of CO by gas appliances.”
One very important dot point that is not listed is the correct operating pressure of the gas at the appliance plus very importantly the volume of gas to the appliance and the whole installation that may include other appliances when on at the same time.