Dear sir,

The following are my comments on above subject. Fix the problem do not put in a possible 90% effective warning system.

Carbon Monoxide and RV‘s have been a subject of discussion and action for the past 50 plus years which has resulted in the development of modern and safe mobile accommodation and a safe and pleasurable pastime be it in a caravan or motor home. Although stupidity and ignorance can lead to disastrous and even fatal outcomes, ignorance of what has been done and achieved is no reason to recommend or produce stupid legislation or regulation.

After reading the discussion paper I am disgusted at the assumptions and lack of any real attempt to address and understand what has been outlined as the real problems or issue for investigation. In the discussion paper, it is pointed out that there are no statistics available on fatalities or injuries caused by Carbon Monoxide poisoning in RV’s other than by people using gas heaters designed for external not internal use or using gas stoves as heaters. However even with this lack of negative statistics, an adverse determination has been determined.

It is easier to assume that the statistics are wrong and that RV’s, being smaller, must be more prone to Carbon Monoxide poisoning than houses. Nothing could be further from the truth; Caravan designers, Manufacturers and users themselves, have recognised problems, analysed the cause and redesigned the offending process to make them safe. As a simple example LPG fridges now may appear to be inside a RV, but in reality, are in a cabinet which is vented to the outside so that burnt gases etc are flued outside not inside. RV’s are also permanently vented inside both at floor and ceiling to ensure there is not a negative inside pressure, to ensure Carbon Monoxide or other unburnt gases are expelled and not retained inside. The same principles apply to gas hot water services which are external venting. LPG stoves which are in the RV are a source of Carbon Monoxide gas but regulations require specially designed exhaust venting to minimise the chance of problems arising. (Perhaps these improvements that have been implemented over the past decades are the reason that there are not any negative statistics)

RV’s are not the problem. In the past any issue / causes have been recognised and designs and regulations introduced and included at the production (design & manufacture) stage. Why had the working party invented something that is not there or cannot be substantiated.

In RV’s, the only possible issue could be due to Stupidity and or Ignorance in the use of portable LPG or liquid hydro carbon heaters which have been designed for outside use not for enclosed areas such as caravans, motor homes and houses. In RV’s the best way forward is Education and awareness programs or signage on these heating units.

You cannot legislate or regulate to stop stupidity or ignorance. You must not let lack of understanding of RV’s, allow the introduction of stupid legislation or regulation.

In the mean time KEEP YOUR HANDS OUT OF MY BLOODY POCKET and stay focused on the real issue of home safety rather than leaping to RV’s because it would be a simple fix.

Des Hartree

PSI am a retired engineer and have been caravanning for 45 years and have owned Caravans continuously for the past 40 years.