The NPGA, along with several other appellants, appeared before an American Society of Heating, Refrigeration and Air Conditioning Engineers’ (ASHRAE) appeals panel to deliver arguments on why the actions taken to publish Addendum “A” to the Standard 62.2 Ventilation and Acceptable Indoor Air Quality in Residential Buildings, were in violation of ASHRAE’s own standards development procedures. Due to the severe sizing restriction that this addendum would implement, it would effectively ban the installation and use of gas-fired unvented heaters as a safe and viable supplemental heating option in a 62.2 compliant residential dwelling.
NPGA’s appeal was made in concert with several other organizations that have worked together to defend the use of gas-fired unvented heaters that comply with national safety standards and that are installed in accordance with national fuel gas codes. Recall that this same issue was successfully appealed by NPGA in late 2018. The appeals submitted by NPGA and others were based solely on procedural violations and could not address the technical content of the proposed addendum, although that is certainly a contentious issue as well. NPGA’s appeal raised several instances of clear violations of ASHRAE’s development procedures.
The primary concern from the opponents to the use of these heaters directly relates to the level of products of combustion that may be released into the living space. However, there is little recognition by the 62.2 Standards Committee that the safety standard (ANSI Z21.11.2) already includes limitations on the maximum allowable nitrogen dioxide and carbon monoxide emissions that can be emitted by the heater. In fact, the 62.2 Committee has not produced any evidence that modern heaters that have been properly installed and used are actually creating an unsafe condition. NPGA has maintained that if there are concerns that the current allowable emissions are too high then the proper venue for proposing to reduce those limits is in the safety standard and not by implementing erroneous sizing restrictions in other standards that would ban the product.
The results of NPGA’s appeal and those of the others will be known in the coming weeks. For further information, please contact Bruce Swiecicki.