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The Manager 16 April 2012
SCER Secretariat
Department of Resources, Energy and Tourism
GPO Box 1564
Canberra ACT 2601
The risk of carbon monoxide poisoning from domestic gas appliances
Consultation Regulatory Impact Statement
Dear Sir / Madam,
GWA Group Limited is Australia’s leading supplier of building fixtures and fittings to households and commercial premises; the Company has approximately 2200 employees with manufacturing and distribution facilities located across Australia.
GWA Group comprises GWA Bathroom and Kitchens, GWA Heating and Cooling and GWA Door and Access Systems.
GWA Heating and Cooling [GWAHC] manufactures and distributes through a national network gas space heating appliances under the Brivis brand as well as solar, gas and electric water heating products under DUX brand for the residential market.
Consultations
Has the problem been accurately represented in this RIS?
GWAHC’s comments are restricted to the category of internal space heating by gas appliances and aim to clarify the different types of gas heating; namely:
1. Whole of house ducted gas heaters
2. Single room non ducted gas heaters
Whole of house ducted gas heaters are generally located external to the living space and are always flued and subjected to a variety of existing regulations.
These products are also supported by a qualified service network that inspects and maintains the appliance in its operating environment.
Single room non ducted gas heaters are usually located within the living space being heated, not always flued and as with portable heaters, often subjected to packing and unpacking at start and end of heating season.
It would seem with the lack of control over the operation, maintenance and handling of portable flue-less gas heaters, Western Australia’s lead of mandating an approved oxygen depletion sensing system is a good example of applying available technology to improve safety and provide additional peace of mind.
GWAHC’s recommendation would be to apply the Western Australian example nationally.
Review of options
Option 1: Status quo
No comment
Option 2: Consumer education and public awareness
GWAHC supports the implementation of Option 2
With one in four dwellings tenanted and residential market churn rate reported as every six to seven years, there is a sizable amount of housing stock where the occupants of the dwelling have little knowledge or history of the gas appliance’s operating or service regime.
A targeted campaign aimed at increasing the awareness of the risk of CO poisoning from gas appliances and the importance of regular twice yearly servicing by qualified service technicians would not only aid in self mitigation of the risk but also lead to improved efficiency and running costs for the consumer.
Option 3: CO Alarms
GWAHC supports the implementation of Option 3 subject to appropriate standards being adopted for the device.
Option 4a: Permanent ventilation
GWAHC supports the implementation of Option 4a.
However, it is noteworthy that a number of State and Federal government initiatives aimed at improving the energy efficiency of dwellings provide financial support to households to reduce draughts and therefore lower energy costs.
A balance on adequate ventilation needs to be reached to prevent unintended consequences.
Option 4b: Mechanical ventilation mechanisms
GWAHC does not support option 4b.
As with 4a, maintaining adequate ventilation is very important however mechanical ventilation mechanisms have played a part in past tragic events.
In addition, they are prone to breakdown or reduction in operating efficiency that could lead to a false sense of security.
Option 5: Future improvements to natural draught open flued appliances
GWAHC supports Option 5.
Finally, as there has not been a preferred option put forward by the Consultation RIS, it is strongly recommended that Industry is consulted prior to a Decision RIS being published.
Thank you for the opportunity of responding to the Consultation RIS and we look forward to our continuing involvement with the development of improved safety outcomes for gas appliances in the Australian market.
Yours sincerely,
Len Place
Corporate Affairs Manager