NFPA Journal - Winter 2021 - 12

Feedback
Carbon monoxide revisited
To the editor:
In your recent article on carbon monoxide
hazards ( " General Negligence, "
spring 2021), based on a report by the
Fire Protection Research Foundation,
you write that " many states in the
US have no rules requiring the use of
carbon monoxide (CO) detectors, even
in hotels, assembly occupancies, and
other public spaces. " This is factually
incorrect, deceptive, and does a disservice
to your readers, especially those
who travel.
Saying that " many states " have no
rules requiring the use of CO detectors
belies the facts. Typically, 44 states
adopt an edition of the International
Fire Code (IFC), either at the state
level or locally (cities, counties, and
fire districts). The 2012 edition of the
IFC first introduced the requirement
for CO detection (alarms) in several
occupancies, including hotels. The
2015 IFC continued those obligations,
modified somewhat. The 2018 and
2021 IFC editions changed those obligations
to require CO detectors in
rooms or spaces with fuel-fired appliances
or fireplaces-detectors typically
monitored by the facility's fire alarm
system-as a means of providing the
earliest warning of a CO leak. All of
the editions of the IFC mentioned
here made those requirements retroactive
to existing hotels, among other
occupancies.
Prior to 2012, states including Massachusetts,
New Jersey, and New York
imposed requirements for CO detection
in new and existing hotels, with some
state regulations dating to 2003. Some
cities, including Chicago and New York
City, had similar CO detection regulations
for hotels prior to their states
acting to require the same. As a result,
the vast majority of the hotels in the
US now have CO detection technology
deployed in some form.
Homes remain the focus of this
problem. " Non-Fire Carbon Monoxide
Deaths Associated with the Use of
Consumer Products: 2017 Annual Estimates, "
a report issued in November
2020 by the US Consumer Products
Safety Commission (cpsc.gov), indicated
that 84 percent of the estimated 190
CO deaths related to consumer products
that occurred in 2017 took place
in homes, including garages, sheds,
camper trailers, and temporary shelters.
Hotels weren't even mentioned.
John Hall, the former head of the
Fire Analysis & Research Division at
NFPA, once said that, when it came to
fire safety, " you are safer sleeping in a
hotel than you are in your own home. "
The same is true today regarding the
risk of an adverse CO exposure.
THOMAS G. DALY, MSc., CSP
Principal and managing member
The Hospitality Security
Consulting Group, LLC
Reno, Nevada
The editor responds:
The writer has a good point: according
to the FPRF report, the vast majority
of states include at least some requirements
for the use of carbon monoxide
detectors-at the moment, only a handful
of states have no such requirements.
In the process of editing our " General
Negligence " story, the scope of that
particular problem was overstated.
As the foundation report indicates,
however, states don't always include
requirements for specific occupancies-
including assembly, daycare, education,
and existing hotels-and they allow
local jurisdictions to change state
codes and remove CO requirements.
Also, while recent editions of codes
and standards have included new CO
requirements, it can take several years
for those codes and standards to be
adopted into law. The foundation report
TELL US WHAT YOU THINK Email your letters to ssutherland@nfpa.org, or mail them to
Editor, NFPA Journal, 1 Batterymarch Park, Quincy, Massachusetts, 02169. Please include your title,
company or organization affiliation, and where you're based. NFPA Journal reserves the right to
edit letters and comments for content and length.
12 | NFPA JOURNAL * WINTER 202 1
underscored the importance of consistent
regulation, along with more robust
public education and improved data
collection on CO poisoning incidents,
as means of addressing this persistent
public safety challenge.
ESS and 70E kudos
To the editor:
I just read your article on the 2019
explosion involving an energy storage
facility owned by Arizona Public
Service and the hazards those kinds
of events pose to first responders
( " Guidance Needed, " fall 2021), and I
was impressed by the factualness and
clarity of Jesse Roman's story. I thought
it was one of the best articles I've ever
seen in any magazine!
In that same issue, I also read Chris
Coache's " In Compliance " blurb on battery
safety and NFPA 70E®
, Standard
for Electrical Safety in the Workplace®
.
I wanted to thank Chris for referring
readers to the standard's Article 320,
Safety Requirements Related to Batteries
and Battery Rooms, as well as
pointing out the arc flash issues inherent
to batteries, since it is very difficult,
if not near impossible, to " make them
dead " in order to " work them cold. "
I also wanted to thank Chris, as well
as Jim Biggins, chair of the technical
committee for NFPA 855, Standard for
the Installation of Stationary Energy
Storage Systems, for their work on that
standard.
CURTIS ASHTON
Director of training
American Power Systems
Littleton, Colorado
Correction
In a recent story on drone research
sponsored by the Fire Protection
Research Foundation ( " Drone Smarts, "
fall 2021), we misidentified a research
foundation partner. The partner should
have been identified as the Unmanned
Systems Research Institute in the
College of Engineering, Architecture,
and Technology at Oklahoma State
University.

http://www.cpsc.gov

NFPA Journal - Winter 2021

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