20 Queens Road Melbourne 3004
PO Box 7622 Melbourne 8004 Victoria Australia
T 03 9867 0291 F 03 9867 0199 jonley@aigroup.asn.au www.gamaa.asn.au
ABN 76 660 439 676 REGISTERED No A00 381 33U
April 12 2012
Manager
SCER Secretariat
Department of Resources, Energy and Tourism
GPO Box 1564
Canberra ACT 2601
Dear Sir or Madam,
Re: Consultation RIS on the risk of CO poisoning from domestic gas appliances
GAMAA members have reviewed the Consultation RIS on the risk of CO poisoning
from domestic gas appliances, and would like to provide the following input for
consideration.
GAMAA strongly supports the proposal to form a strategy to mitigate the risks of
carbon monoxide poisoning from domestic gas appliances. The Australian gas
industry has a proud record of leading the world in the voluntary implementation of
health and safety requirements for gas appliances, as well as mandatory standards for
certification and installation. GAMAA members have strong technical backgrounds
and have made, and will continue to make valuable contributions to improving the
safety and efficiency of gas appliances.
We note that a preferred option has not been recommended – Chapter 6 – Findings
for discussion. GAMAA is concerned that there be full and open consultation leading
up to the publication of the Decision RIS to avoid ‘surprises’ when it is published.
We will firstly provide responses to the four aspects of the RIS requested in Chapter 8
– Consultations, and then provide some extra comment based on the RIS and work
done previously with GTRC and other organisations.
Consultations
Has the problem been accurately represented in this RIS?
We believe the figures for CO deaths related to the use of gas appliances for Australia
are reasonable, however, as discussed in Box 2.1, they are confounded by figures
related to appliances that have been misused. The figures for CO deaths from
appliances that have been used normally are probably less than is shown in Table 2.3.
It seems reasonable to base the estimates for acute CO poisoning on the UK research
– Table 2.4, however it is probable that the issue is worse in the UK due to housing
design, climate etc, therefore the figures may be an over estimate.
The assessment of costs and benefits options:

Does the assessment fully reflect all the potential costs and benefits of the
options assessed?
The assessments appear to reflect the costs and benefits as accurately as can be
expected in a document such as this.

Are there costs to industry or Government that have not been accounted
for?
We cannot identify any significant or obvious costs that have not been accounted for.

Are the assumptions underlying the analysis valid/reasonable?
For the most part the assumptions seem to be reasonable, although we have questions
and comments related to detailed aspects of the RIS which are discussed later in this
response.
Identified risks and uncertainties associated with each option.
It is very difficult to know wither all the risks and uncertainties have been addressed,
which the RIS already acknowledges. We cannot identify any significant or obvious
risks and uncertainties that have been missed.
Other comments
Data for households with various appliances (Table 2.1)
We believe that the data for unflued heating is under estimated. According to
manufacturers of unflued heating, based on annual sales and life expectancy of the
appliances, there are estimated to be well over 500,000 unflued heaters in use and
hence the number of households with this type of heating would exceed the 259,429
indicated. As mentioned in 1.2 Consultation, this figure would affect the calculations
of costs for installation of CO alarms in all homes with gas appliances (see comments
below).
Ventilation, Risks (Section 2.5 – Improved energy efficiency in residential
buildings and Section 2.7 – A case for intervention)
GAMAA agrees that an additional issue is the move towards sealing homes more and
more tightly under 5 and 6 star building requirements. This is likely to make
awareness of ventilation issues with all combustion appliances even more vital.
This includes the risks of adverse flow, as mentioned in Box 1.1. This issue not been
fully investigated since the introduction of requirements for buildings with high
energy ratings, and deserves more detailed study.
Unfortunately, as mentioned in Costs of option 4 – changes to ventilation design of
extraction systems, retrofitting modifications to ventilation and extraction systems can
be expensive, and in some cases very difficult
As mentioned in Chapter 4 - Options to achieve Government objective. Natural draft
open flued appliances are exposed to the most risk factors; therefore efforts should
concentrate on reduction of risk with this class of appliances, rather than ‘across the
board’.
GAMAA agrees that gas appliances are not the only household items that can pose
inherent risks, and that some of the risks posed by other items are much greater than
those posed by gas appliances, this should be considered when formulating strategies.
Safety awareness (Section 2.5 – Consumer awareness and Inadequate
maintenance of gas appliances, Section 5.3 – Direct costs)
Promoting public awareness does appear to be one of the feasible options. Safety
awareness is very low amongst appliance users, and unfortunately awareness among
some groups of appliance repair and installation professionals may not be as high as
we would expect. Definite improvements are needed, which leads on to the next point.
Training (Section 2.5 – Lack of awareness of the risks of CO poisoning across
tradespeople)
There is an identified and serious issue with the shortage of qualified gas fitters.
Our Association has initiated several programs to correct this shortage but
marketplace conditions impede finding and training such technicians. There is an
Australian Standard for gas appliance servicing, AS 4575 – 2005 Gas appliances –
Quality of servicing. This standard, among other items, contains guidelines on
checking appliances for spillage. It is unclear how many operatives in the field are
aware of this standard.
CO alarms and monitoring (Option 3)
GAMAA does not support the mandatory installation of CO detectors or alarms in
homes with gas appliances. In particular, there are a number of categories of gas
appliances, some of which have the potential to release products of combustion into
the room under some circumstances, and others which do not (e.g. room sealed
appliances and outdoor appliances). Very careful consideration needs to be given to
which type of appliance might have its safety enhanced by a carbon monoxide
detector. Mandating detectors for ‘all gas appliances’ is unnecessary from both a cost
and safety point of view.
As the RIS describes, domestic carbon monoxide detectors have been available for
many years, and are used in some other jurisdictions, but unfortunately their reliability
in warning about the presence of carbon monoxide gas seems to be unproven. There is
no Australian Standard for domestic carbon monoxide detectors (Costs of Option 3Mandatory CO alarms, Households), and the suitability of European and American
Standards in the Australian context is unknown. GAMAA is very concerned about the
possibility of lower quality, possibly untested, detectors coming on to the market.
This could have the unintended consequence of giving appliance users a false sense of
security and probably adding to the problem rather than improving it. If the use of
carbon monoxide detectors is to be promoted in Australia, an Australian Standard
must be developed, or a suitable overseas standard adopted after appropriate scrutiny
by experts in Australia, preferably a Standards Australia committee. This point is
emphasized in the article entitled “ESV position on carbon monoxide alarms” on page
5 of Issue 23, Summer/Autumn 2011 of “Energy Safe”.
We are also aware that maintenance and checking of carbon monoxide detectors
overseas has been an issue.
In summary, we support the conclusion expressed in the RIS that Option 3 is ‘the
poorest performing option’.
Mitigation of risks other than carbon monoxide
As well as mitigating risks from carbon monoxide, there should be a review of other
risks with gas appliances that could be mitigated. It should be noted that injuries and
fatalities related to gas appliances are statistically very low when compared with
electrical appliances, but that does not mean that we should not strive to improve the
situation even further.
GAMAA has a history of joining Energy Safe Victoria and other safety organizations
to promote awareness regarding gas safety. In fact, we provide our volunteers to
develop the safety standards for the manufacturing, installation and servicing of gas
appliances through Standards Australia.
Gas appliances in rental properties (International regulations – United
Kingdom)
A requirement that residential landlords have any gas appliances inspected by
qualified contractors periodically is something that gas appliance manufacturers have
always supported. The various Australian Standards require that gas appliance
instructions recommend inspection intervals for the various types of gas appliance.
However, customers have a low awareness of the need for service and seem to think
appliances only need service when they break down. This issue is not only limited to
rental properties. We would be happy to join the various governmental agencies and
other groups to try to address this issue.
Option 5 – Future improvements in the control systems of natural draft flued
appliances
Performance requirements for devices to reduce the risk of spillage are contained in
Australian Standard AS 4553 Gas space heaters, however the fitting of the devices is
not mandatory. This is because of the difficulty of designing such devices that operate
reliably for many types of natural draft appliance - (Box 1.1).
In most cases the appliance alone does not directly cause the CO poisoning and there
may be several other factors that need to coincide to produce the conditions that lead
to hazardous levels of CO. The ability to identify these potential combination issues is
an area where technicians in particular should be better trained. The article entitled
“Meet Jeff Balman, a gasfitter who know the right way to test for CO” on page 29 of
Issue 2 “Energy Safe” serves to demonstrate the importance of training and equipment,
and the fact that faulty appliances can be detected much earlier by trained technicians
than by CO detectors.
Comment on 2.3 Requirements for CO poisoning from gas appliances
In bullet point 5, unflued heaters are listed as one of “a number of possible ways that a
flue system can fail…..”
As the name implies unflued heaters do not have flues, so for clarity they should be
under a separate heading that indicates that they are source of combustion products,
which can accumulate internally if not properly ventilated.
In conclusion, GAMAA remains committed to ensure that the general public is able to
benefit from the use of the millions of gas appliances in the Australian market in a
safe and effective manner, and is willing to assist in any way possible with strategies
to reduce the risk of CO poisoning.
Yours sincerely,
Andrew Creek
GAMAA President