This recommendation has reference to

the appeal no. 95-071
1 - The Direction Générale de la Santé (General Directorate for Health at the State Secretariat for Health) brought before the Committee on 5 July 1995 the problem caused by some systems redistributing hot air produced by inserts, by open hearths, or by closed hearths. Consumers most frequently use the insert system (see definitions in the appendix) strongly recommended by installers given its greater efficiency in terms of heat production. Insert systems generally operate on wood or coal but some use gas. Whatever type of hearth and fuel is used, the problems likely to arise are the same however.

2 - The referral was drafted precisely as follows:

‘I wish to inform you that the last meeting of the ‘Prevention of carbon monoxide poisoning’ working group of the Conseil Supérieur d'Hygiène Publique de France (Higher Council for Public Hygiene in France), held on 15 June 1995, addressed inter alia the problem caused by the appearance on the market of systems mechanically extracting hot air from closed hearths.

These systems draw in the hot air under the cowl of inserts or closed hearths installed in decorative fireplaces, then redistribute it to other rooms in the house. This creates a negatively pressurised zone surrounding the connection of the closed hearth to the smoke flue (under the cowl) which can cause flue smoke to be partially drawn in and redistributed in the other rooms. This polluted air is likely to present abnormally high levels of carbon monoxide placing home occupants at risk. Given the potential risks this type of system appears to present, would you please examine this matter and determine whether it is opportune to give an opinion on the subject’.

3 - Heat generators (inserts, for instance), whatever fuel is used, are not concerned by the referral, which concerns exclusively systems redistributing hot air. 4 - Such systems comprise an electric fan, conduits carying hot air around the house and hot air openings. They are designed to blow into bedrooms or other secondary rooms air heated, in general, in the main room, the living room.

5 - Systems redistributing hot air appeared on the market approximately 15 years ago, around 1985. Out of a global number of 2.5 million installations, 10% to 20% (inserts or closed hearths) are thought to be equipped with a system redistributing hot air, i.e. 250 000 to 500 000 units.

6 - Some systems can be bought at DIY stores at varying public prices: the price of the ventilation kit is approximately FF500 to FF4 000; with conduits and gratings the installation price may reach FF5 000 to FF10 000.

7 - Gas hearths represent a market share of approximately 1%, just like coal hearths or mixed hearths. As for inserts and closed hearths using wood as the fuel, about 180 000 are sold each year, making them the main items sold.

8 - The Committee questioned by mail the professionals concerned, namely:

Absence of inappropriate air (non airtight doors to the outside, existence of low air vents, etc.)’.

18 – In the light of these texts, the CSC feels that the rules on systems redistributing hot air should be based on the same principles.

19 - Pending the implementation of the necessary texts, the Committee points out that professionals are not freed however of the general safety obligation, which is mandatory even without a legal text. The equipment available on the market must therefore at least meet these general health and safety requirements pending the implementation of adapted and specific legal rules.

20 - Similarly, the rules of the trade relating to installations must be such that they guarantee their correct operation.

C - Solutions proposed pending specific legal rules

21 - Pending the drafting of specific legal rules, the CSC invites professionals to base themselves on close legal rules relative to gas-fired and fuel-fired generators and to controlled mechanical ventilation.

22 – Also, the Committee had already given on 6 January 1993 an opinion on fireplace inserts, which were also sold freely to consumers without them being informed of the serious dangers that can arise from an installation breaching the general safety rules. In the wake of this opinion the public authorities enacted a regulation, the decree no. 93-1185 of 22 October 1993 on consumer safety with respect to fireplace closed hearths and inserts using solid fuels. A similar type of approach should therefore be used since this case showed that a regulatory type decision could be taken rapidly. This decree provides for a specific information procedure for buyers-installers defined in articles 4,5,6 and 7 (see appendix).

23 – The Committee feels however that the mere application by analogy of texts of a legislative character applying to similar equipment does not offer a sufficient safety guarantee, particularly regarding old installations or ones made directly by the user.

24 - Indeed these installations may not have received regular maintenance of all their components and no correct operation guarantee can be given, even if they were built according to the rules of the trade.

25 - Similarly, an installation not designed according to these rules (case of a private individual having done the job himself) may not meet the guarantees laid down. This may be the case for heat generators whose burnt gas exhaust system is disturbed by a ventilation system installed in breach of the rules of the trade: insufficient air vents, interior doors that have not been planed enough, flows of air too high on occasions...

26 - The CSC therefore recommends—for want of a specific legislative framework serving as a basis for certification—the implementation of a technical opinion procedure to characterise, from a ventilation viewpoint, systems redistributing hot air (fan curb, flow and pressure characteristic of the blown air network), and to specify their use conditions (on the basis of the existing ventilation system specifications, the fresh air supply to the house, transit passages and the ‘permeability’ of the house).

27 – Lastly, it should be noted that systems redistributing hot air come within the scope of directive 89/106/EEC on construction products. France's representatives at the European bodies should therefore ask for these systems to be the subject of a mandate given by the Commission to the European Committee for Standardization (CEN) with a view to the drafting of specific legislation.

The CSC notes that combating deaths and poisoning due to carbon monoxide is a public health priority. And this risk is likely to be exacerbated by the new equipment recently placed on the market—particularly aimed at the general public—such as the kits or discrete components to build systems redistributing hot air.

The CSC therefore recommends that the government and the bodies concerned should adopt in the shortest possible time the necessary regulations for systems redistributing hot air, by referring to the existing rules. In addition it is necessary to: