Energy and Climate Change CommitteeWritten evidence submitted by CO-Gas Safety (SMR121)


Smart meters are a once in a lifetime opportunity to visit every property.

Due to the numbers of households exposed to carbon monoxide (CO) we consider that all gas appliances should be tested before change of meter (to find out if people have already been exposed and if so, how many parts per million of CO, which helps people with medical treatment and, if necessary, litigation) and also after the change of the meter, to ensure their future safety.

About Carbon Monoxide (CO)

CO is a poisonous deadly gas which can be emitted from faulty cooking and heating appliances powered by any carbon based fuel that burns (coal, gas, oil, petrol, wood etc.).

CO cannot be sensed using human senses.

Less than 2% of CO can kill in between one and three minutes, see HSE website

See Para 74 table 23 page 26

Numbers Exposed to CO.

There is no automatic testing of dead bodies for CO even in cases of unexplained death. New Scientist 4th December 2004, 3,500 people in the UK between the ages of 16 and 64 die of unexplained death.

CO quickly leaves a live body so by the time it is tested for by a GP or A & E, it has usually left the body.

Therefore, CO is vastly under recognized and reported:

The All-Party Parliamentary Carbon Monoxide Group strongly supports the inclusion of carbon monoxide poisoning as a high risk. The All-Party Parliamentary Carbon Monoxide Group’s recent inquiry, “Preventing Carbon Monoxide Poisoning”, heard evidence that carbon monoxide poisoning causes 50* deaths a year (revised to 40 in the latest report by the Cross Government Group on Gas Safety and Carbon Monoxide Awareness), 200* serious injuries, and 4000* minor injuries—which costs the Department for Health in England and Wales approximately £178 million a year in medical and care costs, as well as creating immeasurable human suffering.

NOTE: The figures above for deaths, serious injuries and minor injuries are in the opinion of CO GAS SAFETY and the CO+SAVi group a tiny percentage of the scale of the poisoning as evidenced below.

Furthermore, it is thought that the number affected by CO poisoning is considerably higher—a recent study conducted by Liverpool John Moores University in 2011 measured CO levels in 109 homes over a number of weeks: it found that 24 homes had CO levels greater than 50 ppm (parts per million)—a level in which symptoms of poisoning, such as headaches, tiredness, and drowsiness can be experienced. A further 53 homes contained CO levels between 10 and 50 ppm.

CO-Gas Safety states:

This then shows about 22% of homes with CO levels exceeding 50 ppm and 49% of homes with CO levels between 10–50 ppm. This equates very well with other research done over the last 10 years. If one was to extrapolate these figures across the whole of the UK, then we would arrive at a number close to 15 million UK citizens being poisoned by CO in levels greater than 50 ppm and around 34 million being poisoned by levels between 10 and 50 ppm. In total this is 49 million people in the UK being exposed to CO in levels greater than those recommended by the World Health Organisation and as a consequence significant numbers, running into millions will as a result of this exposure eventually suffer chronic ill health and eventual death many years after their poisoning, which would not be recorded as deaths from CO incidents.

NOTE: In WHO Guidelines for Indoor Air Quality 2010 (attached) at page 70 Walker (130) states that the incidence of chronic carbon monoxide exposure in Great Britain is officially 200 per year, while at the same time “250 000 gas appliances are condemned annually”. He speculates that if only 10% of these appliances give off significant amounts of carbon monoxide that reach the breathing space of residents, as many as 25 000 people every year may be exposed to carbon monoxide in their homes. The carbon monoxide support study (89) found that “only one case out of 77 was correctly identified (ie diagnosed) on the basis of symptoms alone” and that medical professionals were the least likely group to “discover” the fact of the carbon monoxide poisoning.

NOTE It is important to understand that Carbon Monoxide is not the only toxin released into the home environment from faulty appliances and flues. There are far more dangerous toxins found within the products of combustion of Gas, Oil, Coal and other fossil fuels that whilst in smaller quantities (PPM) than CO nevertheless pose an even greater threat to health from low level long-term exposure and which results in those exposed developing chronic, disabling ill health and early death.

Dr. Andrew Shaw of John Moores University in Liverpool would like to add the following:

“Although 53 of the data loggers showed levels of CO between 10 and 50ppm, which is below what could potentially trigger a CO alarm, this could potentially indicate an imminent failure of an appliance and lead to a serious CO poisoning event.”

“Through the 1st phase of the study undertaken in 2011 with the Merseyside and West Midlands fire and rescue services, 22180 homes where visited in Merseyside and 5147 in Coventry. For the first time this allowed us to undertake an extensive study via the fire and rescue services “Home Fire Safety Check”, to physically identify if the properties had an audible CO alarm installed and measure the CO level at the time of the visit. Previous studies had relied on questionnaires alone and had estimated that the CO alarm ownership was approximately 30–40%, from our study the actual figure in the 2 areas was 10% in Merseyside and only 3% in Coventry. Also the properties in Liverpool were across the whole demographic of the city and showed that the problem with CO safety and awareness crosses all social boundaries and that the potential risk to CO poisoning is far greater than what was previously thought.”

Research by Dr. Croxford at UCL 2006

23% of homes had one or more defective gas appliance;

8% of homes were judged to be at risk of dangerous levels of CO;

45% of homes had received no information on the dangers of CO; and

A higher prevalence of problem appliances was found in the homes of vulnerable people (young, old, those in receipt of benefits).

NOTE: This research was carried out during the summer months when many appliances are off or little used, if this research had been carried out during the winter months then it is probable that these results would be significantly higher. Please find research document attached and note mention of “summer” on pages, 1 (Executive Summary), 3 and 28.

Amendment suggested to the Energy Bill going through Parliament at the moment.

Note. This has been professionally drafted by Bircham, Dyson, Bell Solicitors.


Installation and replacement of meters to provide for CO safety

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To move the following Clause:

“(1) The Secretary of State, after consultation with the Health and Safety Executive, shall make regulations to provide as follows

(a)no person shall replace or install a meter or a smart meter in any premises unless he is equipped with a personal alarm monitor for detecting carbon monoxide gas;

(b)where a person replaces or installs a meter or a smart meter he shall ensure that

(i)all gas appliances in the premises are adequately tested for emissions of carbon monoxide gas using equipment suitable for detecting and recording parts per million of carbon monoxide; Where appliances cannot be tested using a flue gas analyser, the occupier and any person who could have been exposed, should be made aware of the dangers of using that appliance and a spillage test must be carried out and a test of the ambient air after use for 30 minutes which should not exceed the WHO guidelines for 24 hour exposure.

(ii)a record of these tests is provided firstly to the occupier and any person who could have been exposed and secondly to the person responsible in writing including the parts per million of carbon monoxide found if any, the date of the test, the name of the First Call Operative and their Gas Safe Register number or relevant OFTEC/HETAS equivalent and the postal address of the property;

(iii)before any changes are made to an appliance etc or any appliance is removed, an opportunity must be afforded to those potentially exposed to carbon monoxide gas to consider their rights of redress including legal redress;

(iv)immediately following installation the appliances are adequately tested to verify that there are no dangerous emissions of carbon monoxide gas;

(v)the manufacturer’s instructions are provided to the occupier and any person responsible; and

(vi)the occupier and any person responsible are advised to fit an audible alarm system certified to EN 50291 standard or its equivalent successor certification and of the importance of proper and regular maintenance;

(c)regulation 26(10) of the Gas Safety (Installation and Use) Regulations 1998 (which removes safeguards in circumstances of disconnection or purging of gas or air from an appliance) is hereby repealed;

(d)all registered gas installers are required to take out and maintain public liability insurance with an authorised insurer.”.

(e) Installers of oil and solid fuel appliances are required to take out and maintain public liability insurance with an authorised insurer.

May 2013

Prepared 26th July 2013