Listed below are some of the solutions we favor for resolving CO conundra, and the results of our efforts to date to achieve them.
Please let us know if you can think of any better or if you have pursued any solutions yourself and we'll post them here.
ATSDR , the Agency for Toxic Substance and Disease Registry, should
- finish its Toxicological Profile on CO
We formally requested that ATSDR prepare a Tox Profile for CO in 2001. ATSDR finally began the process in 2008, hiring SRI to draft it. Drafts were released for peer review and then public comment in 2009, and the comment period closed in February 2010. A year later, ATSDR blames the delay in releasing a final version on the expiration of SRI's contract, even though it received no comments on the draft and thus has nothing to revise. [Had we known, we'd have commented!]
CDC , the Centers for Disease Control and Prevention, should
- publish information on chronic CO poisoning, and specifically on its screening, testing, diagnosis and treatment.
This is still on our to-do list.
CPSC , the Consumer Product Safety Commission, should
- require home CO detectors to display from zero and alarm instantly at low levels, before people are poisoned, instead of requiring that they wait until estimated COHb levels are over 10ppm.
We have repeatedly asked CPSC staff for more than a decade to abandon theses COHb-based specifications, given that the presumptions upon which they are based are inadequate to prevent CO poisoning, but CPSC refuses to reconsider.
- require all gas ovens to be directly vented to the outdoors, as they were before the introduction of natural gas in the 1950s-1970s.
We asked CPSC staff to consider this but were told that unvented ovens and ranges are not considered defective so long as their CO emissions are below those established in a voluntary industry standard (ANSI Z21) which allow them to release up to 800ppm. But this standard dates from 1925, when all ovens had flues, which except for AGA and Rayburn cookers made in UK, they no long do!
DOD , the Department of Defense, should
- study the level of CO exposures to which US personnel around the world are exposue in their living, working, traveling and fighting conditions (exposures inside gun turrets on vehicles and ships are particularly high)
We asked the Army Industrial Hygiene Command to do this and were told "Why would we want to bother studying CO? Everyone knows that CO exposures on battlefields are high."
- start screening, testing, and treating veterans of all wars and particularly those with Gulf War Syndrome for chronic CO poisoning since this syndrome may persist for years and even decades after CO poisoning stops unless and until properly treated.
We have asked both uniformed and civilian clinicians and researchers at both DOD and the Department of Affairs to do this but cannot find any doctor who believes chronic CO poisoning is a problem for active duty or retired military
DOE , the Department of Energy, should
- require residential energy conservation and weatherization programs to test all unvented as well as unvented CO appliances in the homes in which they work, and to install exhaust ventilation as needed.
We have recommended this to DOE in formal comments regarding its weatherization guidelines, but to date DOE has only accepted our recommendations to require that exhaust ventilation be installed in attached garages, for which we are very grateful. Thank you DOE!
EPA , the Environmental Protection Agency, should
- lower the NAAQS for CO to levels that would protect the health of susceptible populations (1ppm for 8 hours and 5ppm for 1 hour)
We have submitted formal comments to EPA requesting this and have appealed to over 40 medical associations and 50 national environmental and public health advocacy organizations to submit their own comments or sign on to ours. EPA is under court order to issue a final rule by August 2011. Individuals and organizations can submit comments directly by email through April 12, 2001. If you do comment (and we urge you to), specify Docket # EPA-HQ-OAR-2008-0015 in the subject line.
- publish information on EPA CO and asthma webpages about the role of CO in asthma attacks.
We have been both privately and publicly asking EPA staff to do this since 2000. They have consistently refused, claiming CO plays no role in asthma.
FAA , the Federal Aviation Administration, should
- ban the use of "CO Spot" detectors and require all planes, both private and commercial, to install CO detectors in their cockpits. These should display the CO level and alarm promptly
This is still on our to-do list.
FDA , Food and Drug Administration, should
- regulate the CO used in DLCO devices as a drug since it meets FDA's definition of a drug.
We requested this but FDA told us the CO involved is only a "device accessory" and therefore does not need to be regulated by FDA. FDA has since reclassified DLCO devices as combination devices (combining device and drug), but still has not required the CO component to be considered or approved as a drug.
- require DLCO device manufacturers to conduct safety studies and submit safety data.
We requested this but FDA told us it is not required since the devices have been in use without any complaints since the 1950s.
until such data are available, FDA should allow the use of DLCO devices only with the informed consent of patients. We requested this but FDA told us that clinical guidelines for DLCO testing were the responsibility of the American Thoracic Society and the American Association of Respiratory Care. Both ATS and AARC also refused our recommendations that respiratory therapists obtain patients' informed consent before DLCO testing. They even refused our request to ban DLCO testing of asthmatics (due to their well documented high sensitivity to even a few ppm of CO) and pregnant women (due to the higher risk of CO poisoning their fetuses).
HUD , Housing and Urban Development, should
- require all homes with HUD mortgages to have at least one working CO detector
We have proposed this to HUD's Healthy Homes staff but gotten no reply.
- require all homes with HUD mortgages to install continuous exhaust ventilation in attached garages. Per the requirements of Section 403.3 of the the International Mechanical Code, HUD should require at least 100 cfm of exhaust per vehicle bay.
We have proposed this to HUD's Healthy Homes staff but gotten no reply.
NHTSA , the National Highway Traffic Safety Administration,
- should
require all motor vehicles to be fitted with CO detectors. These should give audio-visual warnings to drivers at low levels of exposure and automatically shut off the engine at high levels (but of course only when the vehicle is not moving).
We submitted a petition requesting this in 2001, which NHTSA rejected in 2006, claiming that if people wanted to know the CO level in their vehicles, they could purchase home CO detectors to keep in them.
NIDCD , the National Institute on Deafness and Other Communication Disorders, should
- call for and fund more research into sensory hypersensitivity disorders.
We asked the head of NIDCD's Chemical Senses Branch to do this, but were told that NIDCD cannot tell researchers what to study. It can only consider whatever funding requests researchers submit.
NIEHS , the National Institute of Environmental Health Sciences, should
- start publishing articles in EHP about the role of CO in asthma
This is still on our to-do list.
- start requiring epidemiological studies of the role of air pollution in asthma and other disorders to include and control for exposures to CO
We asked, but like NIDCD above, were told that NIEHS does not tell researchers what to study.
NIOSH , the National Institute of Occupational Safety and Health, should
- start investigating CO poisonings from motor vehicles. These are at least as "occupational" as the CO poisonings NIOSH investigated on houseboats.
We asked but were told that anything automobile related is NHTSA's responsibility.
NPS , the National Park Service, should
- warn all visitors to national parks about the risks of CO poisoning. The risks are not just from the use of unventilated heating appliances inside vehicles, campers, tents, etc, but also from the use as directed of jet-skis, snow-mobiles and other off-road vehicles that are not equipped with catalytic converters. The risk of CO poisoning is particularly high when these types of devices are driven or idled in large packs.
This is still on our to-do list.
OSHA , the Occupational Safety and Health Administration, should
- initiate rulemaking to lower the occupational limit for CO exposure from an 8-hour average of 50ppm to no more than 1ppm. There is no reason that workers should be any less protected from CO than the rest of the population.
This is still on our to-do list.
SSA , the Social Security Administration, should
- change Medicare and Medicaid guidelines to pay for home oxygen therapy in cases of chronic CO poisoning, even if COHb and arterial oxygen levels are normal, provided that patient has low VO2 max or other evidence of chronic tissue hypoxia.
This is still on our to-do list
