Severe Carbon Monoxide Poisoning from Portable Electric Generators

We handle all kind of carbon monoxide poisoning cases, but amongst the the most preventable are Severe Carbon Monoxide Poisoning from portable electric generators. The reason severe carbon monoxide poisoning happens from portable electric generators is that these generators have the most deadly the exhaust. We are involved in a case where when we tested the generators, the exhaust spewed out 87,000 ppm. That number was in accordance with manufacturer’s specs. Most emergency responders have meters that only go to 2,000 ppm. (When you see a 2,000 ppm reported, it is almost always because that was as high as the meter went.)

Severe carbon monoxide poisoning from cars

The frequency that car exhaust is the cause of severe carbon monoxide poisoning has been drastically reduced since EPA emissions mandated carbon monoxide reductions.

In contrast, a car exhaust might be as low as 87 ppm, only twice what a properly functioning natural gas furnace might produce. Why one might ask is a small 5KW engine, about the size of what you might put on a lawn mower, producing CO levels hundreds of times more deadly than a car exhaust? It is because the portable electric generator manufacturers have ignored two generations of improved technology in reducing carbon monoxide emissions.

What are the consequences of these severe poisonings carbon monoxide poisonings? We did some research in medical journals and here is what we found. According to Hampson, The Journal of Emergency Medicine, Vol. 49, No. 2, pp. 125–129, 2015:

  • Acute, severe CO poisoning from portable electric generators likely affects an estimated 4000 individuals annually, occurring predominantly in residential settings.
  • Blood carboxyhemoglobin levels averaged 22.7. These are severe levels. Anything over 10% COHb levels come with more than a 40% risk of permanent brain damage.
  • 24% demonstrated evidence of cardiac ischemia.

Thus the risk factors of severe carbon monoxide poisoning from portable electric generators include not just brain damage but heart and other organ damage. When people die from severe carbon monoxide poisoning, they usually die from heart attack. The more vulnerable the person’s cardiovascular system is, the more likely they are to die from severe carbon monoxide poisoning.

If you are curious as to who makes these generators, click here. 

Church of God Carbon Monoxide Poisoning Survivors at Risk of Long Term Brain Damage

In yesterday’s blog about the Iowa church carbon monoxide poisoning, we mentioned that the 20 survivors of carbon monoxide poisoning may have a worse outcome than those who survived the shooting the church shooting in Sutherland Springs, Texas on the same day. The headlines all went to the horrific event in Texas but those who survived the Church of God carbon monoxide poisoning may face worse long term prospects than those who are in surgery for gunshot wounds.

Church of God carbon monoxide poisoning

This warning label on a portable electric generator isn’t sufficient to prevent tragedies such as the Church of God carbon monoxide poisoning.

Statistically, at least 40 per cent of those who survive carbon monoxide poisoning are likely to have ongoing problems, most of which can be directly attributed to brain damage.  The Church of God carbon monoxide poisoning survivors not only have to overcome the direct effects of lack of oxygen to their brains and other vital organs, but they must also fight off the long-term effects of the poisoning.

Double Trouble for Church of God Carbon Monoxide Poisoning Survivors

Hypoxia is the technical term for what happens when the cells in the body are deprived of oxygen. Inhaling carbon monoxide deprives the body of oxygen because carbon monoxide will take the place of oxygen in the hemoglobin. Thus, when blood is circulated to the cells, carboxyhemoglobin instead of oxygen will reach the cells, potentially strangling the cells for oxygen. When the concentration of carbon monoxide in the blood reaches above 40%, the heart will often stop. This is the cause of death in most cases.

But if the heart doesn’t stop from lack of oxygen, the person exposed to carbon monoxide will likely survive. Too often it is thought that this ends the risk factors, but it does not. What is also happening in addition to the hypoxia risk, is the bodies defensive reaction to the poison. Like a bee sting can cause the body to have an over-reaction such as anaphylactic shock, the body can also over-react to this poison and cause more damage than the initial lack of oxygen.

For the 20 Church of God carbon monoxide poisoning survivors, it is not Sunday’s illness that is critical, but the illness that will linger and perhaps get stronger over the next days and weeks. The illness, often referred to as Delay Neurological Syndrome or DNS, happens to in excess of 40% of the people exposed to carbon monoxide. For more on DNS, click here. As the levels in the Marshalltown Church of God were so high, at least 8 of those exposed can be expected to have permanent brain damage.

We have been crusading to force the manufacturers of portable electric generators to reduce the emissions in these dangerous products for this entire year. I testified in front of the federal Consumer Products Safety Commission about the need to reduce the carbon monoxide emissions from portable electric generators in March. Yet, that federal regulations have stalled because of industry pressure. Only lawsuits can force change.

Portable electric generators emit hundreds of times more carbon monoxide than an equivalent car. Cars reduced carbon monoxide emissions by 99% over the last two generations, but portable electric generators have not reduced emissions. Running an electric generator in a basement of the Church of God is equivalent to running several hundred 2017 cars and pumping all that exhaust into the church.

Generator manufacturers have a duty to use modern technology to make these products safe. They refuse to do so, even though they claim to know how to do it. The death of one in the Church of God is a horrible tragedy. But we can’t only focus on that one death or even the death of 751 people over a decade. We must also focus on the 20 who survived because they may face a lifetime of disability and brain damage. Are the portable electric generators manufacturers making a calculation that they can afford the litigation over 75 deaths a year? Perhaps. But what about the 20 Church of God carbon monoxide poisoning survivors? Can they afford that litigation too?

Only lawsuits can change this calculus. Now is the time.

For more on the long term consequences for the survivors of carbon monoxide poisoning from portable electric generators, see this 2005 article. Hampson,  Am J Prev Med. 2005 Jan;28(1):123-5. Yes. That was a 2005 article. Tomorrow’s blog will discuss the 2015 updates to that research by Dr. Hampson.

Attorney Gordon Johnson


On the same day when a killer with a gun stalked a church in Texas, an equally deadly foe sent at least 15 at an Iowa church to the hospital with carbon monoxide poisoning. Sunday November 5, 2017 was the day that 26 people died in Sutherland Springs, Texas, where about 20 additional were injured. In the Iowa church carbon monoxide poisoning, at least 15 were sickened. The Iowa church carbon monoxide poisoning happened at the Church of God in at 305 E. South St., Marshalltown, Iowa, a city of about 27,000, half way between Des Moines and Waterloo, Iowa. Click here for the Iowa Church carbon monoxide poisoning story.

The weapon in Texas was a semi-automatic weapon.  In Iowa, it was a  electric generator, set up in the Church basement. Today, Washington is full of calls for greater regulation of the first weapon. Unfortunately, the call to stop the silent killer is being lost in the administrative shuffle. We have known for as long as I have been alive that electric generators kill almost every month. There were 751 electric generator deaths between 2004 and 2014 according to the U.S. Consumer Product Safety Commission (the “CPSC”.) The CPSC has been trying to put a stop to these killings since 2002, but have been ignored and blocked by the generator industry ever since.

Iowa church carbon monoxide poisoning might have been stopped if this proposed regulation became law.

The Iowa church carbon monoxide poisoning is just one more case of electric generator deaths. Despite this proposed rule from the CPSC, generator carbon monoxide deaths keep happening.

I testified to the CPSC this year about the necessity of these regulations. In that testimony I argued it wasn’t just about the deaths, but the lifetime of disability that could come from these poisonings. Probabilities are that the 20 injured in the Iowa church carbon monoxide poisoning will have worse outcomes than the 20 injured in the Texas church shooting.

Iowa Church Carbon Monoxide Poisoning Preventable

These stories are connected. Both require regulation. Both involve dangerous products that should be banned. The Second Amendment protects the manufacturers of semi-automatic weapons from litigation. But there is no constitutional right to continue to manufacture deadly machines such as portable electric generators.

Iowa church carbon monoxide poisoning is another case like those Gordon Johnson testified about in front of the U.S. Consumer Products Liability Commission with respect to the dangers of portable generators. Attorney Johnson was the only personal injury attorney asked to participate in this public hearing for the new CPSC regulation on carbon monoxide emissions.

This Iowa church carbon monoxide poisoning could be the turning point against portable electric generators. It must be. The only solution is for those who survive and their family members to go after the manufacturer of that generator, the retailer who sold that generator. We know how dangerous these machines are. We know how to make them safe. It is time to fight back and put an end to this death and mayhem.

I called for this to happen last spring after a series of weeks where it seemed that each week there was another generator related death. The industry didn’t hear, because no one sued them over these deaths. I am going to start calling for this to stop again, hopefully louder. The civil justice system is the only solution to a problem that the CPSC has been unable to stop on its own.

For our earlier blogs:

Hurricane season of course has added many events since I compiled this list in June. Who knows how many may have died in Puerto Rico. Check back. I will retell this story in even stronger terms than I did months ago, over the next week. It is time for the portable generator industry to start saving lives. “What industry is demanding is a solution to eliminate deaths.” Those are not my words. Those are the words of a leading manufacturer of portable electric generators. Let the Iowa church carbon monoxide poisoning be the event that forced upon industry to “eliminate deaths.”


Attorney Gordon Johnson



Dozen Hospitalized in Mount Olive Carbon Monoxide Incident

Carbon monoxide strikes in the best neighborhoods, strikes indiscriminately to children, adults or even rescue workers. Even Good Samaritan passer byes who save the day may get poisoned is the levels are high enough. That is how a dozen people got hospitalized in the Mount Olive Carbon Monoxide poisoning on Monday, August 14, 2017. Mount Olive is in New Jersey.

High levels left a dozen hospitalized in Mount Olive Carbon Monoxide Poisoning

A dozen hospitalized after Mount Olive carbon monoxide poisoning. Levels reach 1,600 ppm. Video embedded below.

While unconfirmed, reports are that the carbon monoxide ambient air levels in the beautiful single family home in Mount Olive were as high as 1600 ppm. Even an hour in that poisoned environment could kill. That level was high enough to poison rescue workers. Reports are that at least four occupants of the home were so poisoned that they need hyperbaric oxygen therapy to help push the carbon monoxide out of their system.


According to New York CBS local:

Melanie Milo and her boyfriend Afam Nwande were walking along Finnimore Court at 7:30 p.m. Monday when they heard calls for help coming from a man who had just come home to find his entire family passed out inside. Outside the home, the man’s two young children were laying unconscious on the lawn.

“No smell, no odor, just people,” Milo said.

“He says ‘My wife’s in there, I need help carrying her.’ I ran upstairs, she’s at the top of the stairs, I picked her up brought her out and I laid her next to his kids,” Nwande said.

Two young men were found unresponsive in the basement. One was nude, possibly because he fell unconscious in the shower.

Levels as high as were in the home are often referred to as “drop where you stop” levels.

“The one gentleman was on the floor in the bathroom, he was nude, it appears he may have fallen out of the shower, the other one was asleep in a room,” Milo said.

The family sensed something was wrong, but had no idea what it was until hours later. A pool maintenance man got no response at the front door four hours before when he came to do his work. Efforts to alert the family didn’t trigger an alarm.

If there were carbon monoxide detectors inside of the home they should certainly have gone off by the time the levels got to 100 ppm. Investigations as to the cause of the Mount Olive carbon monoxide poisonings are focused on the hot water heater, which is often the culprit in warm weather poisonings.

TriBeCa carbon monoxide poisoning

Carbon monoxide poisoning can strike almost anywhere, including a grocery store. This is the case with the TriBeCa carbon monoxide poisoning.

A carbon monoxide leak in New York City sickened 32 people. The people who were in the building in the TriBeCa carbon monoxide poisoning made it out with minor injuries, according to the American Press. The poisoning occurred at the start of the workday Tuesday morning in a building three blocks from the World Trade Center. The building was a grocery store, which had extremely high levels of carbon monoxide. The readings were off the charts, with levels as high as 1,000 parts per million. This can render someone unconscious very quickly. At first, someone made the connection between sick people and a package opened in the basement around 8:30 a.m. They felt that it could have contained poison. When they checked, bringing in a bomb squad and the FBI, it was found there was no poison in the package. It was just salad bowls. The source of the leak was a broken boiler pipe in the basement.

Sometimes the most innocuous situation can cause the greatest harm. Nobody might suspect that 32 people are sick from a broken boiler pipe in a public grocery store. Nobody might suspect that what’s making people sick is carbon monoxide poisoning, when it is. We need to raise awareness about the dangers of carbon monoxide poisoning, so people can better be able to recognize when this is the case. This can also be done by installing physical carbon monoxide detectors in buildings, even in businesses. Sometimes people might not think about carbon monoxide poisoning in a public place like a grocery store, even though they might have a detector at home. It is ultimately the responsibility of the store owner or whoever is responsible for maintaining the building to make sure there are carbon monoxide detectors to protect the building’s inhabitants or visitors.

In some states, this is actually the law that people need to have carbon monoxide detectors. The most common law I’ve seen is making sure that carbon monoxide detectors are installed in sleeping areas in residences or anywhere that provides lodging, such as hotels and bed and breakfasts. Also, sometimes they have laws in some places that require carbon monoxide detectors in commercial buildings. Sometimes they require them on boats, too. The problem with most of these laws is that they require carbon monoxide detectors only on new construction and newer buildings, leaving the people in older buildings missing a level of protection. Carbon monoxide poisoning does not discriminate against older and newer buildings and neither should the law. In fact, older buildings or motors might have a greater risk of emitting high, dangerous levels of carbon monoxide than newer buildings with electric stoves or newer boat motors with low carbon monoxide emissions.

In New York, carbon monoxide protection is required in commercial buildings where a carbon monoxide source is present or if there is an attached garage or vehicle. The law applies to all buildings no matter if it is new construction or an existing building.

Generator Carbon Monoxide Events Keep Happening

The list of generator carbon monoxide events keeps getting longer. When we started keeping track of these events on June 5, 2017, there were four incidents in the previous five weeks. Since then the list of generator carbon monoxide events now has 9 entries. That means five more generator carbon monoxide events in 15 days.

The latest involved the death of a 3-year old boy in San Antonio, Texas where the small structure he was living in with his family was overtaken by fumes from a generator that was outside the structure. Each one of these stories is sad, but this one rings a particularly note. Not only that it is a 3-year old victim, but that this family was obviously living in such poverty that normal electrical service was not an option for them. In fact, inability to get utility service is one of the leading causes of generator carbon monoxide events.

Generator carbon monoxide events

Inability to get electricity from a utility company is a major part of the problem leading to generator carbon monoxide events. In San Antonio, Texas poisoning, the makeshift home the victims were living in was without other power.

The epidemiology of generator carbon monoxide events is about one a week with the worst time being in the winter. But the second worst time is storm season and that is what we are in the middle of. Often before I am done writing about one of these tragedies, another shows up in the news.

Listing of Generator Carbon Monoxide Events

Here is our updated list of these events over the

I know I have missed one or two. They have been happening so fast this month that I am having a hard time keeping them straight. Some are so closed together I don’t get the chance to blog about them separately. There was a followup TV story to the Olathe, Kansas poisoning on todays news wire. It may be that the generator was run in the garage although yesterdays picture appeared to show differently. But the important takeaway from that followup was two things:

  • First, the reporter wanted to end the story on the upbeat note that say “they’re all feeling much better.” The story ends with the statement that the “family is fortunate to be alive and well.” We know, however, that just surviving doesn’t mean that all will be well. The kind of carbon monoxide poisoning involved in a generator carbon monoxide event is sudden and serious. Just surviving doesn’t mean that everyone will be well. There is a 40% chance of permanent brain damage in this case and a 24% chance of permanent heart damage.
  • Second, the reporter strikes the tone of everyone needs to learn about the dangers of running generators indoors. Yet, the reporter ends his story with referencing the dangers of carbon dioxide poisoning. Is there a better illustration as to how common the lack of knowledge is about carbon monoxide poisoning?

Attorney Gordon Johnson


Even outside, portable generator danger is beyond imagination.

Portable generator danger was greater than imagined in Olathe, Kansas where four were hospitalized Saturday June 17, 2017 with carbon monoxide poisoning. Since we started blogging on this topic, not a day goes by that someone doesn’t say to us that the solution to the portable generator mayhem is for people to simply take the generators outside. Each time we state our position that the generator manufacturers must be sued in these cases, someone blames it on the victims.

Based on photo evidence from the scene of the latest poisoning event over the weekend in suburban Kansas City, the generator that poisoned these four individuals was being run outside the dwelling. See for the photo.

Portable generator danger extends to operation outside home.

The unpredictable nature of portable generator danger is shown by this graphic where only 29% of the fatalities occur inside the home. Like the 10% shown above, the generator appears to have been outside in the Olathe, Kansas poisoning. The above graph is from the Portable Generator Manufacturers 2016 Technical Summit, a summit which has yet to find a solution.

How can a generator be so dangerous that it can poison from outside a dwelling? The answer is 85,000 ppm. That is how much carbon monoxide poison a generator has in its exhaust, when operating properly. This is nearly 20 times the amount a carbon monoxide detector can read. Not a residential carbon monoxide detector, but the professional detectors used to measure the carbon monoxide in the exhaust of furnaces and other household gas burning appliances.

It is hard to explain to people who have not had a carbon monoxide detector near a portable generator to imagine how dangerous they are. Walk within five feet of a portable generator running outside, and levels will begin to climb. I recently saw a detector go off within five seconds.

How can these generators still be so dangerous? Because generators were not considered a significant contributor to air pollution at the time the EPA mandated cleaner cars in 1970. Thus, they have had little regulation.

Why Portable Generator Danger Continues?

Does the generator industry understand how dangerous their product is? Are they fully aware of the 751 deaths and 25,000 cases of medical treatment between 2004 and 2014 related to their product? I will let the Portable Generator Manufacturer’s Association answer that question. A timeline of the industry’s presumptive knowledge of this danger is in the PGMA’s 2016 Technical Summit. My comments are in parenthesis and italicized:

  • 2009 – Generator manufacturers join forces as PGMA to create and promote safety standards for portable generators and began work on safety standard. (Create and promote means lobbying.)
  • 2012 – Education Awareness Subcommittee Formed (Why three years to form an education awareness subcommittee?)
  • 2012 – Support adoption of CO monitor as part of building code
  • 2013 – Support NARUC CA-1 Resolution Recognizing the Importance of Educating Consumers on Portable Generator Carbon Monoxide Safety (All the focus is on the consumer not the industry.)
  • 2013 – Communications Subcommittee Formed
  • 2013 – Safety First Program Begins
  • 2013 – PGMA contracts consultant to study deaths related to portable generators to identify trends that could be used to formulate potential solution options. (CPSC has been providing this information for a decade at this point.)
  • 2014 – PGMA Public Relations Campaign Begins (PR not solutions.)
  • 2014 – PGMA actively participates and works collaboratively in the UL CO Task Group
  • June 2015 – PGMA G300 Safety and Performance of Portable Generators Standard obtained recognition as an ANSI standard.(Does this standard lower emissions? Not.)
  • October 2015 – PGMA Launches “Take it OutsideTM” Safety Awareness Campaign

The PGMA addressed everything at its technical summit that they could think of to point the finger at the consumer for misusing the generator. They talk about how consumer’s need to know how dangerous their machines are, not how to make them less dangerous. Unless you have actually tested one of these machines, you can’t fathom how dangerous they are.  Even professional engineers who work in this industry don’t perceive how dangerous these machines are until they strap on a carbon monoxide detector and go near a portable generator’s exhaust.

Even after PGMA began extensive testing of solutions in 2016 (seven years after being formed for this purpose) the PGMA is still arguing that such reduction would not save people from carbon monoxide poisoning. Reducing these emissions is feasible. The marine industry had reduced CO emissions by 99% by 2006. One PGMA member in fact has a reduced emission generator reading to mass produce. Yet the balance of the generator industry seems intent on making dangerous generators until they are forced to make generators safer.

One PGMA tactic is to argue that because their are more generators in use than the government estimated, that makes their machines safer than claimed.

Safer than claimed still means deaths averaged 75 per year with 4,000 poisoned annually according to Hampson’s 2015 study. Hampson said there:

Acute, severe CO poisoning from portable electric generators is common in the United States, likely affecting an estimated 4000 individuals annually, occurring predominantly in residential settings.

Time for change or more denials and delay? Justice says litigation is needed now.

Attorney Gordon Johnson


Generator carbon monoxide poisonings

Boats are just one place where carbon monoxide poisoning can occur. In the Georgia case, it was a houseboat powered by a generator that sickened two young girls.

Two young girls were poisoned by carbon monoxide in Cobb County, GA, rushed to the hospital after inhaling toxic fumes from a houseboat, according to WBSTV. The source of the poisoning was a generator powering the houseboat, possibly an older model. In 2005, marine generators were manufactured that reduced 99 percent of carbon monoxide emissions. This is just one incident of many cases we have seen of generator carbon monoxide poisonings. From the Georgia incident, the parents were traumatized by experiencing such a close call.

From the children’s mother:

“Emalynne was just laying there. I was holding her. Her eyes were rolling back,” Britni Thomas said. “It’s very hard to describe holding your lifeless child in your arms.”

The doctor in the case said that they may use hyperbaric oxygen therapy, which is the most effective treatment for severe carbon monoxide poisoning. It has been demonstrated that hyperbaric oxygen therapy reduces the chance of cognitive sequelae significantly. The two girls were just having fun on Memorial Day weekend on their grandma’s houseboat, and this call was too close for comfort.

From the children’s father:

“You never want to see your kids with oxygen being given to them, stuck with a lot of needles and IVs,” Marcus Thomas said.

As we have seen with other carbon monoxide poisonings on boats, the back of the boat is the most dangerous part where people can be overcome by fumes. This case is eerily similar to the case of Raven Little-White, who died from a boat carbon monoxide poisoning. The back of the boat, where she was poisoned, is called the “kill zone.” Most people think it is dangerous because of the propeller. In fact, the fumes are dangerous too. It’s estimated that as many as 250 people die each year from drowning due to carbon monoxide poisoning.

Another carbon monoxide poisoning that is called to mind is one earlier this month in the Morgan Park area of Chicago. In this case, as with Raven Little-White, someone died. One woman died, and two other people were injured and taken to hospitals. If they had not been rescued, the fumes were strong enough to have killed them overnight. The source of the fumes was a gas generator being operated indoors. It’s such a shame when we hear about people dying of carbon monoxide poisoning, because it is an entirely preventable tragedy.

The parents of the two girls in Georgia said they are taking extra safety precautions now, staying away from the back of the boat from now on. The Chicago Fire Department issued a reminder on Twitter after the Morgan Park poisoning that nobody should ever operate a gas generator indoors. Hopefully the cases we have mentioned and others will help raise awareness about the dangers of carbon monoxide poisoning and tips to prevent it. Gas generators operated indoors can become dangerous in a matter of minutes. It is time that the generator manufacturers began producing low carbon monoxide emission generators, because, as we have stated in our previous blog, this kind of equipment is feasible. Marine generators have gotten there years ago, so it is time for the rest of the industry to adapt to these consumer needs. Enough is enough with these generator carbon monoxide poisonings.

Low Carbon Monoxide Generators are being made now

In testimony before the U.S. ‘Consumer Products Safety Commission, the head of one of the United States leading portable generator manufacturers said that low carbon monoxide generators are not only necessary, but feasible. On March 8, 2017, Lee Sowell with TTi testified to the CPSC that the agencies initiative was important, necessary and could be done affordably. He also testified that TTi was currently manufacturing generators that complied with the CPSC proposed standard.


Low carbon monoxide generators are feasible according to the head of a major generator manufacturer, TTi. One wonders why if the marine generators got there in 2004/2005, the rest of the portable generators industry is still making excuses.

Among the highlights of Sowell’s testimony were his whole hearted support of the CPSC Proposed Rule and announcing that TTi was prepared to launch multiple low carbon monoxide generators in 2017. One wonders why if TTi can be making these generators now, why the rest of the industry is fighting the clear safety advantages of low carbon monoxide generators. Said Sowell: “I would like to point out that at the PGMA Technical summit in March 2016, we were the only company that publicly presented the results of our reduced CO emission development efforts.” The rest of PGMA has been denying the value of the CPSC’s proposed rule and making excuses why low carbon monoxide generators can’t be done after 15 years of the CPSC pushing this issue.

Mr. Sowell’s prepared remarks on low carbon monoxide generators are posted below in full.

Oral Testimony of Mr. Lee Sowell:

President, Outdoor Products Division, Techtronic Industries Power Equipment.

Before the U.S. Consumer Product Safety Commission Portable Generator NPR March 08, 2017

Good morning. My name is Lee Sowell and I’m the President of the Outdoor Products Division for Techtronic Industries Power Equipment, known as TTi. As a major manufacturer of outdoor power equipment including portable generators, TTi sells product under the Ryobi, Blackmax and Powerstroke brands to major retailers like The Home Depot and others. Though industry data is limited for determining US generator market share, I estimate that we are the 41 h largest supplier of portable generators in the industry. We have a manufacturing facility in Anderson, South Carolina where we produce a portion of our generators. We also have overseas manufacturing capabilities.

I want to thank the Commission and CPSC staff for their leadership in this important topic. We share the CPSC’s goal of ensuring the safety of all consumer products sold to U.S. consumers. I’d also like to point out that we are one of the founding members of the PGMA and we are active on the Board of Directors and also Chair the PGMA Technical Committee.

TTi is here today to publicly support the Portable Generator NPR because it promotes a technical standard that will address the CO hazard associated with portable generator in enclosed, partially enclosed mis-use scenarios and as well as outdoor use scenarios. We offer our comments from the perspective of a finished goods manufacturer of portable generators, who has a track record of consistently demonstrating that product safety is of the utmost importance to our company. Today, I will highlight our support with the proposed rule; and how TTi has spent significant time and resources doing the R&D and testing of low CO emissions to prove the technical feasibility of the technology.

TTi wholeheartedly supports the CPSC’s mission of product safety and the proposed rule to limit the CO emissions rate of portable generators at the source. This is, in our opinion, the most sure way to directly reduce the chances of injuries and fatalities as a result of the mis-use of portable generators. To illustrate my point let me refer you to an example case that was included in a recently submitted comment to the Portable Generator NPR site. Ed & Cristine Watson, from Clarksville TN , lost a daughter, a husband and three friends due to carbon monoxide poisoning after operating their generator outside of their camper. Like most consumers, the Watsons, despite warning labels provided, may not have realized how dangerous generator exhaust can be resulting in mis-use. From the Watson’s perspective they were operating the generator correctly -it was not inside the camper. Rather, it was intentionally placed outside. Unfortunately, placing the generator outside was not enough to avoid a tragic accident. This scenario and many others like it will most likely not be prevented by shut off technology alone. Rather, the most effective way to mitigate the potential for CO related injury is to first address the hazard at its source -by lowering the amount of CO produced -and then focusing on shut off technology.

The work that the CPSC did in conjunction with the University of Alabama to make a working prototype demonstration provided us a solid foundation of technical understanding and a very helpful framework of reference points that helped guide our development teams to achieve CO emission results that were otherwise thought to be unachievable for portable generators. My teams have been able to demonstrate low CO emissions on many different engines and engine sizes, as well as successful demonstrations using multiple fuel types. With each passing phase of development, my teams are making further discoveries, improvements and helping to push the base on knowledge and understanding of what the technology is capable of achieving, and how it fits perfectly as a technical solution to solve the CO hazard associated with portable generators.

I would like to point out that at the PGMA Technical summit in March 2016, we were the only company that publicly presented the results of our reduced CO emission development efforts. Since then, we have continued our development and have been able to incorporate a shut-off technology that does not rely on chemical sensing devices and has the potential to demonstrate higher reliability. The optimal solution for limiting the CO hazard would be prevention via reduced CO emissions and detection via a shut-off feature. We have been working with multiple partners that combined have significant technical experience to enable us to replicate the University of Alabama results and make it commercially viable reduced CO emissions technical solution. The technology to reliably control CO emissions on small engines is readily available on the market today from multiple sources. Anyone who is serious about addressing this hazard can do so today.

We have plans to launch multiple generators during the 2017 calendar year using our own reduced CO emissions engines, and also using other third party engines that are readily available on the market. Kohler announced in October 2016 that they have developed an engine for use on portable generators which has a reduced CO emissions rate and we are proud to partner with them to resolve this CO hazard and improve the health and safety of US consumers. We ~e also partnering with another engine manufacturer from Japan and we welcome the opportunity to work with others. TTi remains strongly committed to working with industry to address the hazards associated with the use of portable generators. We do appreciate the opportunity to provide our view on the proposed rule. Thank you. I am happy to answer any questions you may have.



Portable Generator Comments on Facebook

Since we started posting on this issue this week, there have been a number of people on Facebook who have disagreed with our position that the generator manufacturers need to be held accountable for ignoring this foreseeable misuse of their product.

For our story on the Chicago poisoning click here.

For our story on the Kingsport Tennessee poisoning, click here.

Pasted below are some of those comments and our responses to them.

Portable Generator Comments:

Would you leave your gas lawn mower or gas weed eater running in your basement or anywhere inside your home?
The Brain Injury Law Group:
You might work on either in your garage with the door open. But lawn products are being designed to run outside. A gas generator is not weatherized to be run outside and it is a risk of being stolen. It is designed to be left unattended, so where is it you are supposed to use it?

Portable Generator Comments:

Family has many power outages and use a generator as backup but is used on the outside of the home. Busses have generators but all the fumes are with the mufflers going completely to the outside of the bus so the fumes don’t cause carbon monoxide poisoning. Some have built sheds to store their backup power generators away from the home to lock them up and keep them safe and to provide safe and proper use of the equipment and proper adequate ventilation.
So chicago brain injury you’re suggesting that a gas powered generator is meant to be used indoors?? Thats ridiculous! They have gas engines…same as a lawnmower. Theyre definitely not meant for use inside. Theyre made to run tools…or for camping…small power requirements. Not to run a breaker panel
I went to school with the Kingsport victim. He was a great guy growing up. I remember him always sticking up for the underdog, calming bullies, and sharing his lunch and snacks with friends in need. God rest his soul.
Sad. This happened on my street.
The Brain Injury Law Group:

We are sorry for your communities loss. But justice should be sought to stop these deaths and help provided for the survivors. To give a relative sense of how much the generator manufacturers knew about the relative magnitude of this “foreseeable misuse” of their product, see this chart comparing generator deaths to other well known product liability crisis.

No automatic alt text available.

Portable generator comments include these who think that manufacturers should not be sued because of operator error.

Portable Generator Comments:

I hate to hear this but why did they have it the basement and if you plan on doing something like this you need to make some type of hose system like you see at the dealership garages that will slide over the exhaust pipe and route it outside
I swear ppl will sue over any damn thing anymore. Im not trying to sugar coat ehat happened. It sux what happened to this guy…but sumtimes you just have to use your head. A butcher knife made for cutting meat can be used to stab and kill somebody, or yourself. But when that happens should ths knife manufacturer be held accountable??? I guess your against guns too…and think guns kill ppl…not ppl killing ppl WITH guns huh
The Brain Injury Law Group:
From the CPSC:
Additionally, some portable generator manufacturers recommended (and continue to recommend) using extension cords that are preferably less than 15 feet long, to prevent voltage drop and possible overheating wires. Other generator manufacturers also recommended (and continue to recommend) that portable generators be placed under cover when it is wet outside because, although these products are intended for outdoor use only, they are not weatherized for safe use in wet conditions posing a risk of shock or electrocution. Staff believes these manufacturer recommendations conflict with the need to avoid the CO poisoning hazard because the recommendations may encourage generator operation in close proximity to a residence or in an enclosed or semi-enclosed environment. Proper placement of the unit is especially significant because demand for portable generators to power home appliances increases dramatically during storms with wet or icy conditions that cause power outages.

Portable Generator Comments:

Really blame the manufacturer why not the moron running the generator inside.
Portable Generator Comments:
They care about a couple of carbon monoxide deaths cause money is involved but the shootings in chicago go unattended shows where priorities are
Outdoor use only duh!!
Not one word in the article to caution running the gas powered generators OUTSIDE ONLY. Pretty damned irresponsible for a position paper on safety.
Only use outside
The Brain Injury Law Group:
Yes of course, only use outside. But the only prevention angle that hasn’t been tried is for the generator manufacturers to make these internal combustion engines as safe as cars and the generators on boats.
Portable Generator Comments:
Sue the gas co for making fuel sue the parents for raising
Stupid sue Egypt
Sure cars are safe to go 80 or maybe even 90. But using an internal combustion engine indoors is like driving 100MPH OR FASTER.
TWO POINTS: first your article should point out that generators are to be place outdoors.
Second, that there are no combustion engines made to run indoors.
There are warning labels on coffee cups for a reason! There are also an abundance of safety warnings included with the generator that clearly tell the user not to use it indoors and to place it a certain distance away. I hope that your firm is trying to get a new warning label on the box that reads “WARNING! NOT TO BE USED BY MORONS, STUPID PEOPLE, OR THOSE SELECTED BY DARWIN!”.
I am certain that technology does not exist to allow the indoor operation of gasoline engines.
And listen, your answer is not just about how many are injured.
I am a Speech Language Pathologist with many years working in the rehab setting where most of my patients are brain injured.
Sympathy does not make engines run clean.
The Brain Injury Law Group:
The technology exists to make these products safe enough that they give people warning before they succumb to the fumes. TTI is already making these generators. See
Portable Generator Comment:
You can only make so many excuses for people’s stupidity… I know it pays your bills, but don’t expect the rest of us to go along with this ridiculous premise. What are you going to do? Designate a company representative to come over every time they use it?
The Brain Injury Law Group:
The generator manufacturers can only blame their bad product on misuse for so long. Children are dying. Do you want to blame them, too?
Portable Generator Comments:
When u buy a port. generator the instructions say outside use only!
This has got to be one of the most ridiculous articles I’ve ever read. So I’m assuming that we need to tell people not to run their cars in the garage with the doors closed for hours? Maybe we should tell everyone not to bring your grill in the house and cook for 100 people on it? Seriously, why are we protecting the stupid? If you are not smart enough to realize you DO NOT run an internal combustion engine indoors……….well then I guess that’s just survival of the fittest.
Brain Injury Law Group:
Modern cars aren’t nearly as deadly as a portable generator.
Portable Generator Comments:

And I’m just gonna leave this right here ……….

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Reader points out in Portable Generator Comments that there are warnings on generators not to use indoors. Such warnings are only in English.

Brain Injury Law Group:
500 people have died since this warning label was put on the generators. 
Well this is exactly why I am bothering to post here.
You just shifted your initial position opposing the use of gas powered generators because of injury and death while using generators indoors to the use of generators outside of buildings.
This leads to suspicion of your unspoken motive.
They make heavy gauge extension cables to minimize voltage drop…
The Brain Injury Law Group: You sound like a knowledgable consumer. The generator manufacturers know that they will be selling these machines to people who are not, who are making emergency decisions because of loss of power. The consumer’s motivation is to get the power restored in an emergency. Most people don’t know about CO.
The Brain Injury Law Group: Many of those die from generators put the generators in open garages, outside near an open window, with fans and other makeshift exhaust mechanisms. None of this is new. The generator manufacturers have been making excuses not to to what marine generator manufacturers did in 2005/2006 and what auto manufacturers did in the 1970s’ Use catalytic converters and Electronic Fuel Injection to cut down the number of deaths.
The extension cord problem is because people go to Walmart and buy the cheapest cord they can find. No, you should be buying heavy duty cords to use with generators.
2. Under cover does not mean inside your house. 
Please tell me what deaths have been cut down by using catalytic converters and fuel injection?
The Brain Injury Law Group:
Automotive related carbon monoxide deaths are down 80% since catalytic converters and EFI has been put on cars. Even car related suicides are down by a similar percentage.
So what are you saying? Ban generators?
The Brain Injury Law Group:
What we are saying is that emissions should be limited like they have been in cars for two generations and that there should also be an automatic shut down mechanism so that if carbon monoxide exceeds 100 ppm, that the generators will shut off.
I think it’s more financially feasible to let natural selection take its course. That would add a lot to the cost of a generator. For the markup that would add to them, people could just pay the power company to turn their power back on. Like I said, I know these idiots are your bread and butter, but… ?
Brain Injury Law Group:
The cost of the shut down system is nominal. The catalytic converter adds perhaps 10-20% to the cost. This is a reasonable expenditure considering that these products kill at such a predictable rate. We require seat belts, airbags and safety devices all through our society. What is it about portable electric generators that should make them exempt to the safety principles that apply to products?

Attorney Gordon Johnson