NF386

Ethanol powered appliances: the French approach to improve their safety

1. F Weil, 2. Y Peter* 1. CorrespondenceGeneral Directorate for Competition Policy, Consumer Affairs and
Fraud Control (DGCCRF), Bureau E2 59, Boulevard Vincent Auriol PARIS, 75703 CEDEX 13, France

Abstract
Ethanol powered appliances (EPA) are usually marketed in a rather up-market position. In France, these products were marketed at low prices from the beginning, and the number of sales grew rapidly, whereas the safety of these devices was a concern. Accordingly, the DGCCRF (French national market surveillance authority) gave an impetus in 20062007 for the professionals to have their appliances certified, and to start a Standardisation Committee within the AFNOR. Several events an accident, a study from the Consumer Safety Commission (CSC) highlighting EPA as hazardous as regards burn, fire and intoxication hazards, and media campaign made the DGCCRF quicken the pace of its actions in order to improve their safety: The professionals were reminded in the Economy Ministry Recommendation published in theFrench Republic Official Journal (November 2008) that their products had to meet the general safety requirement; A survey was launched in order to have a comprehensive overview of operators and their products, and analyse the safety level of each appliance. It was decided to create a Select Committee within the AFNOR Standardisation Committee composed with the DGCCRF, CSC, LNE (national laboratory of conformance-testing) and other Administrations (Health, Housing, Fire Safety). As a result, the French standard NF D 35386 (Ethanol-fired appliances Safety requirements and test methods), whose specificity is to integrate fail-safe devices, has been published in August 2009. France is now willing to promote this standard

internationally. This is an example of the French approach bringing stakeholders together for a common goal.

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RECOMMENDATION ON THE SAFETY OF ETHANOL-POWERED APPLIANCES 12/08 THE CONSUMER SAFETY COMMISSION, HAVING REGARD TO the Consumer Code and specifically Articles L. 224-1, L. 2244, R. 224 4, and R. 224-7 to R. 224-12 HAVING REGARD TO petitions no. 08-023 and 08-080 Whereas, I. THE COMMISSION'S REFERRAL AND THE INQUIRY FOR THE RECOMMANDATION

During the 2007-2008 winter, the Consumer Safety Commission was notified of the growing sale of decorative ethanol-powered fireplaces. The Commission was especially concerned about intoxication, fire, and burn hazards for users, and particularly young children, due to the very high flammability of the fuel. That is why at its 21 February 2008 session, the Commission decided to process a draft recommendation on the safety of ethanol-powered appliances (fireplaces, burners, etc.). On 8 December 2008, the Commission also registered a petition (no. 08-080) wherein a consumer reported that he had had an accident while lighting an ethanol-powered fireplace. The victim had sustained second-degree burns on his hands after the fuel overflowed as he was filling the burner. II. THE PRODUCTS Ethanol-powered appliances comprise a burner, which is sometimes sold as a separate unit, and a decorative body. They are delivered with various decorative and lighting accessories, and the necessary fuel.

A. The Burners

Three types of burners can be found on the market. The first type is a plain metallic container. It is filled with 25 to 50 centilitres of liquid or gel fuel, placed inside the body, and then lit. The flame cannot be adjusted and can be damped with a lid. A variant of this kind of burner is a hollow ramp feeding fuel into several small jars, meaning that a hearth longer than a metre can be fashioned. The second type of burner is more commonplace. It is a metal (stainless steel or anodised aluminium) parallelepiped rectangular container, with a longitudinal opening on top letting out the flame front once the fuel is lit. Some openings have sliding tops to control the inflow of air, thus making it possible to stir, lower, or extinguish the flames. The burner is filled through the flame escape top or a special hatch. The capacity of this type of burner ranges from 1.5 litres to 5 litres, meaning an operating time ranging from 2 to 8 hours for an average consumption of 0.6 litres per hour. The fuel in a can or a measuring jug is hand poured into the burner through a funnel. Alternatively, there is a mechanical filling system using pumps that are filled either by hand, or electrically. The fuel is also hand lit with either a long lighter or a metal rod that has to be dipped in the fuel and then lit. Last, a new generation of safe burners has recently appeared on the market. They have a radically different design with separate compartments for the tank and burner. They also include several built-in electric or electronic safety components, such as fuel supply management, device temperature, stability, and CO2 emission controls. B. The Body

Most burners are inserted into a body that may have different shapes:

- A plain box for burners that are inserted in fireplaces

- A full fireplace in aluminium, wood, or stone, which is sometimes fitted with a glass fire screen: the weight of the transportable fireplace ranges from fewer than 20 kilos to more than 80 kilos - Furniture (living room tables, shelves) - A large basin that can be placed on the floor (or even on the ground outside); or on furniture

C. The Fuel For Ethanol-Powered Appliances 1. The Composition

Burner fuel is a liquid or gel preparation with 95 or 96% of neutral rectified ethyl alcohol [ethanol] and denatured additives to which manufacturers sometimes add colouring agents and perfumes.

2.The Names is fuel has several different commercial names. What most of the fuels have in common is that their names have environmentally friendly sounding prefixes (bio, biol, veg, eco) although they do not come from a production system complying with the charters of organic agriculture.[1] They must not be confused with biofuels for engine-powered vehicles, which mainly contain gasoline and a small proportion of vegetable-based alcohol. The fuels are available in different packaging, ranging from the disposable gel cartridges to one, five and twenty-litre cans. III. THE MARKET

The ethanol-powered appliance design was born in the late 1990s in Germany where 200,000 appliances are installed. In France, imported ethanol-powered appliances came on the market about three years ago. Unlike foreign markets, the French market quickly opted for the mass sale of the appliances, which (in-store and Internet) retailers present

as decorative objects, but also as extra heaters, at prices that have been slashed by a factor of three, or even ten, over the past three years. The booming market has attracted numerous stakeholders : Import companies selling burners and medium-range to top-of-the-line fireplaces have been on the market for several years. The appliances are manufactured in the European Union or abroad. The importers market the fireplaces at trade fairs and through a network of approved dealers, which have received special training in selling this item. Their products cost from 600 to several thousand euros. French or foreign companies designing and manufacturing their ethanol-powered appliances in Europe or abroad: their price range can be from three to ten times lower than the import companies prices. Fireplace professionals seeking to diversify their product range and win new customers who do not have access to standard fuels Recently, grocery retailing operators who reach a large public practice among the lowest prices (from 200 to 400) IV. RISK ASSESSMENT

As they have come onto the market recently, no compendium of the accidentology of burn or intoxication accidents caused by ethanol-powered appliances has yet been published in France. The Commission has no knowledge of any such compendiums abroad. After hearing several experts, the risk assessment drawn up by the Commission is the following.

Ethanol-powered Appliances and Burn Hazards

Generating Event

Origin

Origin

(due to product) No fire screen Contact with the flamesBody has openings on several sides Appliance built with Contact with the hot conducting materials and no insulation on the parts of the appliance outside walls (burner, body, fire No body screen)

(due to use) Installed in an place that is overexposed to draughts Appliance is handled when hot (filling; transport) Installed in an inappropriate location (passageway)

Deflagration and/or explosion

Backfire

Combustion starts up spontaneously after an attempt to extinguish a hot appliance, or after an apparent spontaneous flameout (low tank, draught, and so on)

Burner is sealed closed andHot appliance is relit the ethanol vapours without waiting for the time concentrate inside the required for the burner to appliance cool down, or without refilling with cold fuel No time delay-trip to prevent filling a hot appliance No fuel supply hatch Fuel is poured directly into burning chamber of a hot appliance Tank has no anti-spill Faulty control of filling system operation (from a very large can) Lack visibility of boiling Shape of the burner fuel surface Faulty sealing of system The burning chamber is not closing the burning fully closed or closing chamber system gets stuck Incandescent components Burning chamber is in the burner (very thin reopened immediately after metallic walls, steel an attempt to extinguish a filings, and so on) hot appliance

Burning chamber has no Untrained person lightslock system the appliance

Appliance is turned off with a full tank Unsafe storage of the fuel and lighting accessories

A. 1.

Intoxication Hazards Carbon Dioxide and Carbon Monoxide

Per kW output, ethanol whose heat efficiency is twice as low as hydrocarbon efficiency turns out to be almost as CO2 polluting as the other domestic fuels.

Fuel

Burned unit

Heating power

CO2 emission/ burned unit

CO2 emission/

kW output

Liquefied gas

1 kg

12.9 kWh

3.8 kg

310 g

Kerosene

1 kg

11.8 kWh

3.4 kg

288 g

Ethanol

1 kg

7.8 kWh

1.1 kg

226 g

Kerosene (a)

1l

8.9 kWh

2.56 kg

217 g

Ethanol (b)

1l

6.2 kWh

1.4 kg

178 g

(a): 1 litre of kerosene = 0.755 kg and

(b): litre of ethanol = 0.789 kg

Theoretically, ethanol combustion only produces carbon dioxide and water vapour, but like any other fuel, ethanol is liable to emit carbon monoxide when combustion is said to be incomplete, i.e., if the fuel does not completely react with the oxygen in the air to produce carbon dioxide.

Ethanol-Powered Appliances and Carbon Monoxide Intoxication Hazards

Generating event

Origin (due to product) Large capacity tank

Origin (due to use) Appliance operates in a very small space, or faulty ventilation causing CO2accumulation Flame confined inside burner (deliberately slow rate, or opening blocked by accessories) Appliance is used in an extant fireplace, which is not closed off, but emissions are driven

Flames cool due to Carbon monoxide burner shape output No CO2 detector built into the appliance

back into the room (hazard if a CMV is installed)

2. Nitrogen Oxides

As there is no fuel delivery regulation system, ethanol-powered appliances may emit high rates of nitrogen oxides. When nitrogen and the oxygen in the air combine in the ambient air, the result is nitric oxide (NO) and nitrogen dioxide (NO2), also called nitrogen oxides (NOx). High temperature combustion and oxygen-rich flames produce nitrogen oxides. NOx are irritating gases that penetrate into the tiniest ramifications of the respiratory tract. At very low rates, they may cause respiratory problems and bronchial hyper-reactivity in sensitive persons and tend to increase bronchial sensitivity to infections in children.

Generating Event

Origin (due to product)

Origin (due to use)

Nitrogen oxide output

Width of flame front due to burner shape Insulation of the burner Is operated in a highly in the appliance ventilated environment (burner generates a gradual increase of its wall overheats) temperature

3. Volatile Organic Compounds The compounds may cause irritations and allergies of the respiratory tracts, eyes and skin over the short-term. Over the long-term, some compounds such as formaldehyde and benzene[2] are reputedly carcinogenic. Ethanol-powered appliances produce VOC in several different situations.

Ethanol-powered Appliances and VOC Intoxication Hazards

Generating Event

Origin (due to product)

Origin (due to use)

Poor fuel quality Inappropriate choice of fuel Additives in the fuel produce VOC Volatile organic Component materials of A hot appliance is turned off, compound (VOC) the device are damaged or an appliance is turned off in output a hot atmosphere (> 15), tank is still full, and ethanol vapours disperse in the atmosphere Burner shape Contact with the flames, or products heat and may emit VOC (wall hangings, paints, varnishes, wood panels, and so on) Faulty burner sealing CO2 saturates the air due to faulty ventilation

For the record, there are also intoxication hazards due to fuel ingestion, which is always possible if the fuel is within reach of fragile persons (children, alcohol dependent persons). V. THE TESTS

Working with UFC Que Choisir (a consumer association), the Commission appointed the Laboratoire national de mtrologie et dessais (LNE, the National testing Laboratory) to conduct several tests on, and measurements of four ethanol-powered appliances (EPA): - A fireplace with a stainless steel body without any fire screen, which can be hung or placed on the floor, and that was fitted with jars powered by gel fuel (EPA no. 1) A stand-alone burner for insertion (EPA no. 2) A decorative basin on a stand, with a burner surrounded by shingles, and two glass fire screens on each side (EPA no. 3)

 A plain basin with shingles, without any fire screen; the basin serving as the fuel reservoir (EPA no. 4) Five accident factors were assessed: deflagration, contact burns, the emission of carbon monoxide, nitrogen oxides, and aldehydes.

A. Deflagration

The test served to measure the hazard of deflagration occurring when a hot appliance was relit after total combustion of tank content, and then refilled. Results show that there is an actual hazard. Actually, two of the four appliances produced a deflagration (EPAs no. 2 and no. 4). As a deflagration had been sparked when one of the EPAs had been turned on when cold, the LNE deemed that it was too hazardous to run the test on a hot appliance.

B. Contact Burns

The temperature values selected by the LNE are the reference values found in certification no. 427 Ethanol-powered Domestic Appliances published in November 2007[3], i.e., 105C for the body (front, bottom and sides), and 350C for the fire screen. No value is provided for the burner, the active component in direct contact with the flames. However, it should be underscored that for aesthetic reasons the bodies of a large number of ethanol-powered appliances are bare minimum. Consequently, measurements cannot be taken, but in this case, the burner and the fire screens are often within users reach while the appliance is operating. The measured values correspond to the highest temperature observed after the appliance had been working non-stop at maximum rate for an hour.

EPA Reference EPA no. 1: steel fireplace EPA no. 2: standalone burner EPA no. 3: basin on a base EPA no. 4: basin

Body Front Body Side Body Top Burner Temperature Temperature Temperature Temperature No front 73C 358C 69C (fire screen) 43C 260C - (a) - (a)

- : NA given the configuration of the device (a): burner covered with decorative shingles The studied EPA bodies showed contact temperatures under or near 105C. On the other hand, the easily accessible burner on two appliances exceeded a reasonable temperature threshold. The burner on the other appliances could be accessible and was probably at similar temperatures.

C.

Carbon Monoxide

The LNE measured the carbon monoxide emission of each ethanol-powered appliance in a normally ventilated room (air renewal at 0.4 volume/hour). The reference values are the World Health Organizations Human Toxicity Values (HTV): 9 ppm/hour for eight hours of exposure (10 mg/m3) 26 ppm for one hour of exposure (30 mg/m3) 52 ppm for 30 minutes of exposure (60 mg/m3) 87 ppm for 15 min of exposure (100 mg/m3) Although they are not lethal, the values do trigger the first symptoms of intoxication in high-risk persons (headaches, nausea, and dizziness). The results are as follows: EPA reference Carbon Monoxide Concentration Rate (ppm) 1 hour 2 hour 3rdhour 4thhour 5thhour 6thhour Average Exposure
st nd

and tank combustion time EPA no. 1 (2hr 25min) EPA no. 2 (5hr 15min) EPA no. 3 (2hr 29min) EPA no. 4 (2hr 43min)

CO/hour time over rate 27 ppm

5.8 5.7

20 13.3

43.5 (a) 18

22

18.4 17.7

Yes Yes

26.2 30.6 (a)

4.2 9.3

10.4 20.2

13.2 (a) 25.6 (a)

8.5 17.6

No Upper limit

(a) For the residual combustion duration of the tank

Three out of four EPAs (no. 1, no. 2, and no. 4) sharply exceed carbon monoxide emission reference thresholds. On average, the theoretical hourly output is double the reference value and nears 18 ppm, not to mention that the longer the exposure, the higher the intoxication hazard. In this respect, EPA no. 2 is twice as hazardous as the others are because its operating time is longer. Furthermore, the carbon monoxide rate increases regularly and rapidly during combustion for all the appliances, but varies widely from one to the next, despite air renewal. At combustion end, two appliances produce exposure to carbon monoxide at a rate higher or near 27 ppm. This exposure time is less than an hour, but is substantial for EPA no. 1 (25 min) and EPA no. 4 (43 min).

It should be pointed out that if the devices had been fitted with a CO2 detector, as are oil convectors and gas-fired boilers, with a trip switch at 0.8% or 1% of CO2 in the ambient air, the safety system would have shut down the four appliances before their tanks were empty. In three out of four cases, this precautionary measure is warranted considering the rate of accumulated carbon monoxide.

D.

Nitrogen Oxides

The WHO alert threshold for human exposure is 200 micrograms/hour, i.e., 0.1 ppm/hour. The hourly average of the nitrogen oxide concentrations measured by the LNE while the four ethanol-powered appliances were operating can be found in the table below.

EPA reference and tank combustion time EPA no. 1 (2hr 25min) EPA no. 2 (5hr 15min) EPA no. 3 (2hr 29min) EPA no. 4 (2hr 43min)

1 hour 1.08 0.94 0.75 1.25

st

NO2 Concentration Rate (ppm)[4] 2nd 3rd 4th 5th hour hour hour hour 2.10 1.95 (a) 2.43 1.89 3.25 3 2.2 (a) 3.44 (a) 3.12 3.11

6th hour

2.99 (a)

a) For the residual combustion duration of the tank

The measured values are well over limit thresholds (from 7 to 30 times higher) during the very first operating hour of the appliances. The excess value is particularly high for EPA no. 4.[5] As there is no such thing as a nitrogen oxide detector, it is worth studying the advisability of preventing the hazard of nitrogen oxide accumulation in the ambient air by limiting the tank capacity of the appliances, or the number of times they can be relit in a row (intermittence). E. THE ALDEHYDES

Aldehydes are among the most common volatile organic compounds found in domestic environments, and are the most harmful over the long-term. The LNE used highperformance liquid chromatography to analyse the rate of some ten aldehydes collected

in the atmosphere of a sealed enclosure (39 m3), after combustion of the entire tank, and its spontaneous extinction. For aldehydes, the World Health Organization has issued a recommendation only for formaldehyde, which is a severe eye, nose and throat irritant at very weak concentrations. The WHO has set an average value at 0.1 mg/m3, i.e., 0.08 ppm, for one half hour of exposure. For the other aldehydes, the acceptable limit values for workplaces[6] were selected. Among the values, the value for acrolein (0,1 ppm), a toxic compound when inhaled or ingested, a skin and mucous membrane irritant causing severe eye-tearing, is produced by the decomposition of organic matter and its derivatives (perfumes, fats, and plastics). Most of the limit values for the aldehydes measured by the LNE are well under the selected exposure threshold limits, except for the values for formaldehyde or acrolein. Assuming a linear increase of formaldehyde and acrolein concentration during the entire combustion time, the results of the LNE measurements can be presented as follows.

EPA reference and tank combustion time EPA no. 1 (2hr 25min) EPA no. 2 (5hr 15min) EPA no. 3 (2hr 29min) EPA no. 4 (2hr 43min)

Formaldehyde Concentration Rate Acrolein Concentration (ppm) Rate (ppm) st nd st 1 half 2 half At end of tank 1 half At end of tank hour hour combustion hour combustion 0.647 0.1 0.484 ppm 0.07 0.20 0.622 0.03 0.04 0.07 0.09 0.347 0.10 0.721 0.20 0.005 0.027 ppm 0.003 0.014 ppm 0.003 0.035 ppm

a) For the residual combustion duration of the tank

We can see that the exposure threshold limit for formaldehyde was exceeded upon the second half hour of combustion for the four appliances. For acrolein, only EPA no. 1,

which is powered with ethanol gel, became hazardous past the first half hour of use. Therefore, the LNE has concluded that, prolonged use may lead to sensitive exposure for the relevant appliances. What the tests show is that each of the four ethanol-powered appliances are hazardous on one or several counts of the studied parameters:

Hazards Deflagration EPA Reference EPA no. 1: steel fireplace EPA no. 2: only burner EPA no. 3: basin on base EPA no. 4: basin No Yes No Yes

Contact CO NOx temperatures Emission Emission (a) Yes Yes No No Yes Yes No Yes Yes Yes Yes Yes

VOC emission (b) Yes Yes Yes Yes

(a) Analysis compared to WHO recommended threshold (b) Analysis based on formaldehyde emission

VI. THE REGULATORY BACKGROUND

A. THE APPLIANCES Neither the EU nor France has any current regulations particular to ethanol-powered appliances. Therefore, they are governed exclusively by the general safety requirement defined in Directive 2001/95/EC of 3 December 2001 on general product safety.

Accordingly, as there is no standard, in 2006 the DGCCRF (General Directorate for Competition Policy, Consumer Affairs and Fraud Control) urged professionals to have their appliances certified. For this purpose, it asked the LNE and AFNOR to draw up the appropriate technical references (see Chapter VII). As the DGCCRF was later alerted by the Consumer Safety Commissions test results, it did the following:

 On 22 November, it published a Recommendation to manufacturers, importers, and retailers of ethanol-powered domestic appliances in the Official Journal. The recommendation based on Article L. 221-7 of the Consumer Code reminded the professionals that their products had to meet the general safety requirement. For this purpose, it asked them to design, manufacture, and fit the appliances with devices that could prevent gaseous intoxication, burn, and fire hazards. The Recommendation also reminded professionals of their obligation to provide information and advice about hazards, and product safety instructions (see Appendix no. 1). It scheduled a national survey to have a comprehensive overview of operators and their products, analyse the safety level of each appliance and its fuel, and take the appropriate ministerial measures, if needed.

B. The Fuel For Ethanol-Powered Appliances As it is a hazardous preparation, the fuel for ethanol-powered appliances is governed by the amended Order of 20 April 1994 that lays down the requirements for the declaration to the authorities, the packaging, and labelling of hazardous substances and preparations. In its September 2008 Recommendation on the safety of methylated spirit and liquid and gel lighter products, the Commission had already underscored that it would like to see the said regulation improved in several areas, such as label readability, consumer information on product composition, safer packing materials, and the limitation of the unit amount of packs for products with higher risks. The Commission considers that these recommendations have even greater relevancy for ethanol appliance fuel, as their use entails the regular storage of large amounts of ethanol at retailers premises, and consumers homes. In this respect, packaging fuel in 20-litre cans is a factor increasing burn and fire hazards during handling.

VII. THE BACKGROUND ON STANDARDS

In the European Union, there is no national or harmonised European standard for ethanol-powered appliances. A. THE TEST REPORTS BY FOREIGN LABORATORIES

The Underwriters Laboratories Inc. in the United States and Canada deliver certification based on their respective standards, UL 1370 Factory built unvented liquid or gelled alcohol based fuel burning decorative heating system of April 2006, and ULC/ORD-C627 Unvented Ethyl Alcohol fuel burning decorative appliances of April 2008. Aside from these, none of the test reports reviewed by the Commission guarantees consumers a generally acceptable level of safety. The reports are often limited to the study of a few features of the appliances and come with recommendations that limit their scope: For stand-alone burners, SITAC explicitly says that the system must be installed by an approved fireplace installer, or by any other expert organisation of the profession. TV SD considers ethanol-powered appliances are decorative objects and therefore recommends never extinguishing an ethanol-powered appliance because by damping the flame one confines the boiling alcohol inside the combustion compartment. The emitted vapours upon contact with a hot point may ignite (ethanol flash point is 16C). Last, the alcohol is still within reach of children who may ingest it, or light the appliance when adults are not there.

B. The French Standardisation Approach

In France, certification standard no. 427 Ethanol-powered domestic appliances published by AFNOR Certification[7] in November 2007 lays down the essential requirements for the design and manufacture of ethanol-powered appliances, their operations, marking, and the management system for the quality of their manufacture.

The standard draws heavily on standard NF no. 128 Mobile back-up flame-producing heating appliances operating intermittently, powered by the liquid fuel for mobile heating devices, called liquid fuel powered mobile heating appliances[8] of October 1991, and is based on standard NF D 35-300 Liquid fuel powered mobile heating appliances of December 1992. Since January 2008, standard NF no. 128 has been the basic document for the work of a Standardisation Committee convened at the request of the DGCCRF and several professionals. The Commission has examined a draft version of the standard dated 1 October 2008. The Commission considers that in principle the standard should set the requirements for all types of ethanol-powered appliances, their fuel, and accessories.[9] However, draft standard D 35-586 does not deal with stand-alone burners and their installation rules, fuels and their convenience additives (perfumes and colours), accessories, and how they are set up with regards to the flames, whereas they are prone to promote CO production. As long as there is no regulation on the installation of stand-alone burners, the Commission deems it advisable that standardisation make no distinction between ethanol-powered appliances connected to flues, and the appliances designed to operate without flues. It is reasonably predictable that consumers will use a device specifically designed to be connected to a flue without connecting it, or will install it in a closed-off fireplace, thus finding themselves exposed to an intoxication hazard. The Commission also questions some of the technical choices modelled on texts concerning oil convectors, as said choices do not seem completely appropriate for ethanol-powered appliances: Intermittence comes down to limiting appliance operating-time to eight hours (Article 4.2.9). A priori, the operating time is set based only on tank capacity (5 litres). For the Commission, the said operating time is a strong incentive to use the systems non-stop, during the day and night, whereas it is known that safe oil convectors still cause some fifty serious cases of intoxication per year due to their non-stop use and lack of ventilation. There are also all the fire hazards due to a tank capacity enabling such a long operating time. Furthermore, for the time being limiting operating time seems to be the only feasible preventive measure against the hazard of nitrogen oxide accumulation in the ambient air.

- For a power exceeding 4.65 kWh (i.e., a consumption of about 750 ml of ethanol/hour), the appliance should be connected to a flue (Article 4.2.10). This requirement is the same as the one for oil convectors, without any other technical justification. The Commission is concerned by this; as the threshold-power allowed by standard ULC/ORD-C627 of April 2008 sets the limit at about 3 kWh. The standard allows for the building ethanol gel-powered appliances whereas the emissions of this type of fuel, which may produce carbon monoxide and aldehydes, have not been measured yet. The Commission notes the lack of some specifications that it deems necessary, specifically: The systematic fitting of devices protecting users and the materials near the system from direct contact with the flames and burner Heat and mechanical resistance specifications for the fire screens and specifications for their attachments to the appliance[10] The systematic fitting of a lighting device located far from burning chamber regardless of system size and shape (see Article 4.2.3) More detailed specifications for the body, such as using qualified fire resistant (M0 or M1) building or decorative materials When necessary, the fitting of safe attachment systems for the appliance to prevent it from falling over or down after a small impact Considering the very high fuel hazard, ban any device making it possible to move the appliance while it is operating (wheels, tote handles, and so on). The Commission is also addressing the advisability of drafting or adapting harmonised technical documents for the installation of ethanol burners in building fixtures, especially during renovation works, and specifically detailing the power thresholds that have to be taken into account with regards to the volumes where the appliances will be installed. VIII. THE CONCLUSIONS OF THE COMMISSION

BASED ON THIS DATA Whereas the Consumer Safety Commission set forth recommendations in its Recommendation of 4 September 2008 on the safety of methylated spirit and liquid and gel lighter products, which also apply to the fuel for ethanol-powered appliances; Whereas the ethanol-powered appliance market is growing, particularly in retail networks that are little or not trained in the limits of product use and the operating hazards of the appliances; Whereas there is A risk assessment conducted by the Commission Results of the tests run by the National Testing Laboratory The opinion of the experts at the hearings The measures taken by some retail professionals that, after examining the products available on the market, have forgone selling the appliances due to their consumer hazards Petition no. 08-080 filed with the Commission on 8 December 2008, wherein a consumer reported that he sustained a burn accident when lighting an ethanol-powered appliance; Whereas there is no French or European standard setting down the essential safety requirements for ethanol-powered appliances, but a certification standard NF no. 427 called Ethanol-powered domestic appliances drawn up by the National Testing Laboratory and published by AFNOR Certification, may be used to ensure that the products meet the general safety requirement; Whereas to the Commissions knowledge, the appliances on the market and specifically the ones sold on the Internet do not meet the essential safety requirements set down in the above standard; Whereas in these conditions, it would be hazardous to maintain on the market the ethanol-powered appliances that do not meet the characteristics of a safe product as

defined in Article 2(b) of Directive no. 2001/95/EC of 3 December 2001 on general product safety, that has been transposed into Article L. 221-1 of the Consumer Code; Whereas there are inherent hazards of installing ethanol-powered appliances in establishments open to the public; Whereas Article L. 221-2 of the Consumer Code stipulates that products that do not meet the general safety requirement are banned, or regulated under the terms set forth in Article L. 221-3 of the said Code; Whereas the General Directorate for Competition Policy, Consumer Affairs and Fraud Control (DGCCRF) has already taken measures to make the market safe, specifically the recommendation of 22 November 2008 to manufacturers, importers, and retailers of ethanol-powered domestic appliances; Whereas there is a need to complete, detail, and validate scientifically the requirements of draft standard D 35-586 on Ethanol-based fuel powered domestic appliances operating intermittently; Whereas professionals have the obligation to put only consumer-safe products on the market; Whereas users of ethanol-powered appliances may be exposed to burn, fire and intoxication hazards, and specifically: When using inappropriate fuel with a low flash point such as the gasoline or thanol 85 for cars; When filling the appliance directly from an over 1-litre capacity can, or when filling with a hand or electric pump; When lighting a hot ethanol-powered appliance, or after storing fuel in the extinguished appliance (ethanol vaporisation at 16C) When the appliance is not firmly attached to the floor or walls, and not installed far from any inflammable component When the appliance is handled by persons who are not informed of the hazards and the instructions, particularly children

 When the appliance operates without careful surveillance When appliance is used for extended periods, in poorly ventilated rooms, or, if need be, when using appliances connected to blocked or damaged flues; After having heard a representative of the National Testing Laboratory and a representative of Socit Merchandises & Business International in plenary session, ISSUES THE FOLLOWING RECOMMENDATION : THE COMMISSION RECOMMENDS THAT: 1. The Public Authorities a. The General Directorate for Competition Policy, Consumer Affairs and Fraud Control (DGCCRF) Promptly warn consumers of the hazards of ethanol-powered appliances, on its website among others Establish safety recommendations for the items below, in a regulation based on Article L. 221-3 of the Consumer Code: The marketing, including Internet sales, of all ethanol-powered appliances and their accessories, regardless of their power, use, or installation methods Their fuel (name, composition, packaging, and so on) Consumer information on the hazards, and safety instructions before using ethanolpowered appliances and their fuel Pending this, and after inquiries, take emergency measures to suspend immediately the import and marketing of ethanol-powered appliances that do not meet the general safety requirement, and specifically those appliances that are not fitted with safety devices that can prevent intoxication, burn, and fire hazards Support the Commissions recommendations at the meeting of the AFNOR Standardisation Committee, and ensure that standard recommendations are based on the results of laboratory tests run at the request of the administration or professionals

b. The Ministry of the Interior Explain to the Departmental Safety Commissions the proper implementation for ethanol-powered appliances of the regulation on establishments open to the public, and specifically for the appliances presented as decorative objects Complete the regulation with the required provisions so that only ethanol-powered appliances meeting the general safety requirement will eventually be installed c. The relevant ministries Improve the epidemiological knowledge of the aetiology of burn and intoxication accidents, by compiling a documented collection of the circumstances of the accidents. This will provide a better knowledge of the accidentology on the use of denatured ethanol Set the rules and conditions for installing and maintaining ethanol-powered appliances and burners in private homes, specifically if the appliances are built into the construction, or must be connected to flues.

2. The Authorities in charge of Standardisation Continue the work to draft standard NF D 35-586 on Ethanol-based fuel powered domestic appliances operating intermittently, regardless of power, use, or installation methods; and do so based on laboratory tests Detail and complete the requirements for the future standard, specifically on the following points: Extend the scope to include stand-alone burners, their body, accessories, different types of fuel, and packaging Re-examine the requirements for maximum power of non-connected appliances, and intermittence, so as to prevent carbon monoxide and nitrogen oxide intoxication hazards

 Identify the requirements and testing methods that will prevent formaldehyde and acrolein emissions Add provisions on appliance transportability, attachment system resistance, insulation, and body Once standard NF D 35-586 is published, subject to standardisation work that could be undertaken at the European level, suggest to the European Standardisation Committee the draft of a European standard on ethanol-powered appliances 3. The professionals, designers, manufacturers, importers, and retailers of ethanolpowered appliances, and their professional representatives Immediately suspend the marketing, withdraw, and as appropriate, voluntarily recall the ethanol-powered appliances, their accessories, and fuel that they deem do not meet the general safety obligation, having regard to DGCCRF Recommendation of 22 November 2008 Actively participate (specifically retailers) in the scientific studies and discussions required to draft standard D 35-586, and its prompt publication 4. The mutual societies, complementary health insurance companies, and insurance companies, As part of their activities to prevent everyday accidents, inform their members, customers, and the public in general, of the hazards of ethanol-powered appliances 5. Consumer Organisations Actively participate in the discussions required to draft standard D 35-586, and its prompt publication 6. Consumers Pending the publication and implementation of regulations and standards framing the safety of ethanol-powered appliances, postpone their purchase decision. If not, only buy appliances meeting the requirements of technical standard no. 427 of November 2007, or of any other standard. Compliance with said requirements should be warranted by a

conformity certificate delivered by an accredited independent organisation. This should also apply to Internet purchases. For consumers who already own one, they should not use their ethanol-powered appliance if it is not fitted with safety devices that can prevent intoxication, burn and fire hazards, and specifically a carbon monoxide detector ADOPTED AT THE SESSION OF 11 DECEMBER 2008 BASED ON THE REPORT BY DR. PHILIPPE GERARD Assisted by Mrs. Muriel GRISOT, Commission Technical Advisor, in according with Article R. 224-4 of the Consumer Code.

[1] None of these products qualifies for the ECOCERT label. [2] Because of this, the amount of benzene in several preparations is regulated. [3] The full text of the standard can be accessed on the LNE website (www.lne.fr). [4] Due to fast nitrogen oxidation, the listed emissions represent the overall value of the NO and NO2emissions expressed in nitrogen dioxide equivalent (NO2- equivalent). [5] Nitrogen dioxide (NO2) emissions alone produce the same results in terms of exceeding the standard threshold value. All the appliances exceed emission thresholds. [6] Source: Institut national de recherche en scurit (INRS) File ED 984 [7] AFNOR Certification, an AFNOR Group subsidiary, is an organisation providing the certification and assessment of products, services, systems, and skills [8] More commonly called oil convectors [9] See NF EN 1860 standard for barbecues [10] The Commission does not consider a sliding fire screen on a plain groove in the appliance as a reliable attachment system. +++++++++++

Electronic Burner Safety

Prestigious Fires electronic boethanol burners are the next stage in the development of bioethanol burners. With the latest in built safety features, these burners offer the flexibility of a bioethanol fire with the security of a gas fire. The electronic burners, are compliant with NF D35-386 which is the

french safety standard for ductless fireplaces, which guarantees a high level of safety to the end user including:

Ensuring no hot start re-ignition Room CO2 monitoring Clean burning appliance laboratory tested and certified for CO/CO2 ratio

In addition to the mandatory safety standards to meet NF D35-386 the electronic burners also include:

Monitoring fuel levels to ensure no fuel overflow takes place A removable fuel tank which ensures a clean safe refilling experience Parental control function Lively authetic flames Battery powered using simple available AA batteries Insurance compliance

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http://www.prestigiousfires.co.uk/electronicburners.html

Electronic Burner Safety Explanation

1) Hot Start Ignition Danger Prevention Made compulsory by D35-386 norm, it must not be possible whilst the burner is still hot to:

refill the burner restart the burner

When bioethanol bio ethanol is in contact with hot surfaces, it vapourises quickly. Ethanol vapours; which are heavier than air, have a tendency to remain within the confines of the fireplace. when igniting the liquid in the burner, vapours will also be ignited creating a hot start ignition effect. If there is a high concentration of vapours, ignition becomes dangerous and several accidents have occured with non secure burners. Our electronic burners are equipped with temperature sensors and locking systems controlled by an electronic microprocessor.

2) Clean Combustion
The D35-386 standard requires a high combustion index to limit the amount of CO and volatile organic compounds released. This basically translated means that the CO levels should remain below a certain low level during the combustion process. Because the electronic burners constantly pumps ethanol into the burner, the liquid height in the burner remains relatively constant throughout the whole time the fire is burning. As a consequence the amount of oxygen getting to the burner is the same throughout the whole burn. This can be compared with the "Kleenex" box type metal burners, where as the liquid level within the burner drops as the liquid is consumed. This leads to an increasing distance for the oxygen to travel to meet the flame and therefore the combustion process is not as clean as when the liquid level is high.

The falling liquid level in the (diagramatically indicated o harder for the oxygen to ge be compared with the electr where the liquid level is con levels are constant.

The result is a cleaner more the electronic burners.

3) Risk of Over filling

Caution has to be exercised when refueling bioethanol burners becuase ethanol is volatile. When refilling takes palce directly in the burner, it can be difficult to ensure that the burner does not overflow. Spilled bioethanol needs to be cleaned up before the fire is lit. Using a removable fuel tank ensures that bioethanol is not spilled and that all refilling is done away from the burner; ideally near a sink; ensuring a safe filling process.

4) CO2 Monitoring
Even though the electronic burners have been tested for their natural combustion quality, they still incorporate a built in CO2 detector. This CO2 detector activates an emergency shutdown in case of oxygen depletion. Why do we need it? The main ethanol combustion products are H2O and CO2 (carbon dioxide - normal product of exhaling). It can produce CO(carbon monoxide) which is odourless, colourless and dangerous when in burns with insufficient oxygen. This poor combustion can be due to poor burner design or inadequate airflow. Where the potential for inadequte oxygen for proper combustion is apparent; e.g small confined room; the installation of an quality device monitoring device is essential. At the moment CO2 detectors have been found to be more reliable over time than CO detectors, for this reason CO2 detectors are used on bioethanol fires. In the past, petrol heaters were confronted with the same problems and therefore the same solution they adopted has been adopted for the french norn for bioethanol fires, namely:

Make sure that the CO concentration in the steady state combustion does not exceed 0.01% namely 100ppm. (For this reason the design of Kleenex shaped burners are being adandoned.) Anticipate oxygen depletion in the room by continual CO2 monitoring. Shut the appliance down if and when the CO2 reaches levels of 0.8%.

5) Parental Control
The removable battery holder provides the user with a simple and efficient way of preventing unwanted use by others such as children, guests, teenagers or guests.

6) Insurance Compliance
The removable battery holder provides the user with a simple and efficient way of preventing unwanted use by others such as children, guests, teenagers or guests. In December 2008, CCS, Commission for Consumers Security, (an independent french public authority which includes consumer groups, industry experts & professional organizations) published a very strong warning against a majority of ethanol fireplaces on the market, specifically addressing the models with Kleenex box type burners. This commission recommended a list of security measures necessary for public safety including a CO2 detector and anti-flash features. Significantly, the CCS called for a specific Standard regulating the ethanol burners industry . At the same time, Mr. Luc Chatel, Industry Secretary of State, released an official statement urging ethanol fireplaces manufacturers, importers and distributors, to comply with and implement these security measures in the manufacture of their fireplaces : Appliances must be equipped with the necessary security features to prevent CO poisoning, burns and fire hazard Since the government's announcement, AFNOR published in August 2009 , the French Standard D 35-386 Ethanol Fire Appliances Safety Requirements & Test Methods. SPARXS burners original design and manufacture pioneered in their compliance of these requirements. In june 2010, the norm has been made compulsory for public places. In case of an accident in a private place with a non-conformed fireplace, based on the CSC's recommendations and the government's issuance, insurance companies may

be within their rights to deny coverage, thus increasing the liability of industry distributors or manufacturers.