STNN36 co poisoning- NON-generators engine powered tools

INCIDENT INVESTIGATION ASSIGNMENT INSTRUCTIONS
Carbon Monoxide Poisoning from NON-GENERATOR Engine-Powered Consumer Products
DOCUMENT NUMBER:
DATE OF INCIDENT:
FOLLOW-UP REQUESTED

CATID: STNN36 2020
HAZARD ANALYSIS

SECT 15

PRIMARY CONTACT: Matthew Hnatov, EPHA, 301-504-7403, [email protected]
BACK-UP CONTACT: Han Lim, ESFS, 301-987-2327, [email protected]
Only if it is found that a generator is involved, also include:
COMPLIANCE CONTACTS: Blake Rose, CDI, 301-504-7613, [email protected]

ASSIGNMENT MESSAGE: Use guideline Appendix 16 - All Carbon Monoxide Poisoning-Related
Incidents and Data Recording Sheet (revised September 2007) and complete the data record sheets related
to General Information, Injured Persons and CO Alarms.
If the involved product was used indoors (this includes the basement, crawlspace, attached carport and
garage, or shed), please be sure to ask the consumer the reasons why they chose to operate it there.
Be sure to obtain:
1. Pre-incident, incident, and post-incident information
2. Product Description, including age of the product, manufacturer, horsepower (HP) of engine, and
kilowatts of output (continuous/rated watts). List names and address of outlet where product was
purchased or rented. Specify if borrowed or obtained as used product.
3. Product Description of any CO alarms, including age of the product and manufacturer.
4. Specify the type of fuel used by the product, the size of the fuel tank, how much fuel was left in
the tank when the injury/fatality was first discovered, if the product was running when the victims
were discovered, and if not running, the state of the ignition or on/off switch.
5. Square footage and layout of room or partially enclosed area where product and victims were
located during the incident. If incident occurred in a house, apartment, condo, mobile home, etc.,
obtain square footage of the living area of the structure. If victim or generator was located in
basement or attached garage, obtain square footage of basement or garage and report separately.
Mark locations of any CO alarms, fans, doors, and windows. Indicate whether fans were
operating and which doors or windows were open during the incident. Indicate the degree in
which windows or doors were open.
6. Find out if product was operating near a central heating or cooling unit or other appliance that
circulates air throughout the home.
7. If incident occurred while product was operating outdoors, describe how exhaust reached the
victim(s). Were there any open doors, open windows, vents, or air intakes to the home near where
the product was operating? If so, how close was the product to any of these? If there was an
open window or door, describe how far it was opened. What were the wind conditions?

CPSC FORM 324A

8. All CO measurements taken (in ppm) by emergency response personnel, fire dept. and/or utilities,
and any steps taken immediately after the incident to ventilate the premises.
9. Document fatalities and injuries. Obtain toxicology or autopsy reports to obtain the COHb level
in each deceased victim (usually expressed as a percentage). Obtain death certificates for all
fatalities. For victims not fatally injured, document what, if any, treatments were received, both
at the scene and/or at the hospital. If COHB blood levels were taken, please try to obtain from
the victims or thru medical records (with medical release).
10. Photograph product, if possible, including standards markings and warnings. Also document any
standards markings and warnings, including the year of the standard.
11. Obtain copy of owner’s manual or instructions.
12. If a CO alarm or combined CO/smoke alarm is present, obtain location of alarm.
a) Obtain manufacturer name, model number, copy of instruction, photo of front and back
of alarm.
b) Obtain information about previous experience with the alarm:
1) Has it alarmed before?
2) Has it gone into trouble signal in the past?
3) When was it installed?
4) If it is a battery operated unit, when were the batteries changed last?
5) Does the consumer routinely use spray deodorizers, air fresheners, or ammoniacontaining cleaners near the alarm?
OBTAIN COPY OF FIRE REPORT, EMERGENCY RESPONSE REPORT, OR ANY OTHER
OFFICIAL REPORTS.
Complete the relevant portion(s) of Appendix 16 required for this IDI as fully as possible. Due to
the lag in state reporting of death certificates and contract restrictions placed on investigations
initiated from death certificates, we recognize that some information may be difficult to obtain to
complete the required portion(s) of the Appendix 16 Data Record Sheets. However, we request
that the investigator provide as much information as possible in the Data Record Sheets.
Additional requirements for this IDI ONLY IF A GENERATOR IS INVOLVED:
Request for additional information for IDI’s assigned for deaths related to portable generators.
The Office of Compliance and Field Operations would like to review the CO poisoning hazard
labels on the generators involved with fatalities for compliance with the labeling requirements of
16 C.F.R. § 1407. Compliance will follow-up with the manufacturers of any products found to be
non-compliant.
Copies of the mandated on-product and on-package CO poisoning hazard labels are shown below.
If you suspect that the labeling on a generator does not meet the requirements, please photograph
the top and each side of the generator. Inquire if the consumer has retained the outer packaging of
the generator, if so, evaluate the hazard labels on the packaging for compliance.
Requirements for placement of the labels:

CPSC FORM 324A

On-product hazard labels:
The on-product hazard label must be permanently affixed and located:
A) On a part of the portable generator that cannot be removed without the use of tools, and
B) On a location that is prominent and conspicuous to an operator while performing at least
two of the following actions: Filling the fuel tank, accessing the receptacle panel, and
starting the engine.
On-package hazard labels:
The on-package hazard label must be located on the principal display panel(s) of the package AND
the surface containing the top flaps of the package. The principal display panel(s) of the package is
the portion(s) of the outer packaging that is designed to be most prominently displayed, shown,
presented, or examined under conditions of retail sale.

Generator On-Product Label

Generator On-Package Label

Please include all primary and all backup contacts in the distribution of the completed IDI.
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ Area below will be completed in Data Systems _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
Person(s) to Contact:
Guidelines: Appendix 16 – All Carbon Monoxide Poisoning-Related Incidents,
including relevant portion(s) of Data Recording Sheet
Task Number:
Assigned to:

CPSC FORM 324A

Date:
Processed by: lew