Multiple Chemical Sensitivity

To: United States' National Highway Traffic Safety Administration (NHTSA) and Transport Canada's Road Safety Directorate (RSD)
Re: Rulemaking Requested to Prevent Illness and Death Caused by Carbon Monoxide from Motor Vehicle Exhaust



To: United States' National Highway Traffic Safety Administration (NHTSA)
and Transport Canada's Road Safety Directorate (RSD)

Rulemaking Requested to Prevent Illness and Death
Caused by Carbon Monoxide from Motor Vehicle Exhaust

Submitted On: 12 January 2001

Submitted To:
Steve Wood, Assistant Chief Counsel for Rulemaking, NHTSA, via fax to 202-366-3820
Nicole Pageot, Director General, Road Safety Directorate, Transport Canada,
via fax to 613-990-2914

Submitted By:
Albert Donnay, MHS, President, MCS Referral & Resources
In USA: 618 Wyndhurst Avenue #2, Baltimore, MD 21210, ph 410-566-3333, fax 889-4944
In Canada: Suite 920, 1130 Sherbrooke St. West, Montreal, Quebec, H3A 2S7

Supported By: (a list of individual and organizational supporters of this petition is being submitted separately)

"Cars can--and must--be modified to reduce the likelihood that fatal doses of CO can reach the occupants.
In the final analysis, the problem is one of changing behavior, not primarily of the motorist--who can't smell an odorless gas--but of those who pick the designs of the vehicles. The death penalty is not appropriate for the unwary owner of a poorly designed car."
Dr. William Haddon, Jr., President, Insurance Institute for Highway Safety, 1973

In memory and honor of Barbara Lighter and the at least 16,000 others who have died of vehicular carbon monoxide poisoning in the United States and Canada since 1991 when NHTSA-funded researchers first reported that all these deaths could be prevented with a carbon monoxide detector then estimated to cost just $11.39 per vehicle.

WHEREAS [summaries only, see full petition for details and references]

  1. NHTSA reported in 1996, and again in 2000, that both suicides and unintentional deaths caused by carbon monoxide (CO) poisoning in motor vehicles are still a significant cause of death--over 1,500 per year--even after the major reductions in CO from vehicle exhaust achieved by the use of catalytic converters first introduced in the 1970s.
  2. NHTSA recognizes a need to warn the public about the "Danger from Carbon Monoxide Poisoning Associated with Motor Vehicles," having issued a press release on this subject on 16 December 1996.
  3. NHTSA has acted on CO-related problems in motor vehicles in the past, having issued CO-related recalls for 4,000 passenger vehicles in 1979 (2 models) and 13,988 recreational vehicles from 1984 to 2000 (12 models, including 4 recalled in 1999 because they were sold with defective CO detectors).
  4. NHTSA has known since at least 1991 that a CO detector--then costing only an estimated $11.39 in parts--could prevent both CO poisoning and CO deaths from motor vehicles if it were installed in the passenger compartment and linked to both a low-level digital display and an engine cut-off switch that would automatically shut off the engine before lethal levels were reached.
  5. NHTSA rejected a petition filed in 1997 that asked NHTSA to require vehicle manufacturers to offer CO detectors as optional original equipment and include information about CO hazards and optional CO detectors in their owners' manuals.
  6. In contrast, NHTSA has required inexpensive vehicle safety modifications to prevent deaths from much less common causes of non-moving fatalities, such as trunk entrapment (fewer than 400 deaths documented since 1970, an average of under 15 per year), and also very expensive modifications, such as air bags, to reduce deaths from moving vehicles, which have saved approximately 5,000 lives since 1990, an average of 500 per year.
  7. NHTSA has not funded any extramural research on CO-related issues since 1991 and, despite publishing two compelling Research Notes and one press release on CO in 1996, it has not included CO in any of its own research programs or policy initiatives since then. CO also has never been studied by NHTSA researchers working on potentially CO-related problems such as drowsy drivers and passenger cabin air quality. And NHTSA has not yet begun to investigate a three-fold increase in vCO-related consumer complaints.
  8. The detrimental effects of CO exposure on driving performance were first reported in 1937.
  9. The US Surgeon General's current "National Suicide Prevention Strategy" includes under the broad category of "Intervention"(Section 2) the need to "Promote efforts to reduce access to lethal means and methods of self harm" (Objective 5) and specifically to "Implement standards for automobile exhaust systems that impede automobile exhaust mediated asphyxiation" (Obj. 5.5)

THEREFORE [summaries only, see full petition for details and references]

On behalf of the at least 16,000 North Americans who have died needlessly from vehicular CO poisoning since NHTSA was first informed in 1991 of the life-saving potential of CO detectors linked to engine cut-off switches, and on behalf of the hundreds more who will die of vehicular CO every year until vehicle manufacturers are required to warn consumers about and protect them from this lethal hazard, I--an environmental health engineer, certified carbon monoxide analyst, president of MCS Referral & Resources, and a dual citizen of the United States and Canada--petition both NHTSA and the Canadian RSD to do the following:

  1. Beginning in 2001, start issuing an annual consumer advisory warning (in the form of a press release and public service announcements) about the dangers of vCO and recommending the use of portable low-level digital CO monitors inside motor vehicles that can warn vehicle occupants about low levels of CO before they become lethal.
  2. Beginning in 2001, start tracking and publicly reporting all vCO-related deaths (in each country), both suicides and unintentional fatalities in stationary and moving vehicles, on an annual basis, using data on these causes already collected by the US NCHS and Health Canada.
  3. Beginning in 2002, start funding intramural and extramural research into the causes, effects, detection and prevention of vCO exposure inside vehicles. All NHTSA-funded researchers studying the impact of human factors such as drowsiness and alcohol consumption on driving performance should be encouraged to study the interaction of such factors with vCO and to at least control for vCO exposure in their study designs.
  4. Beginning in 2003, require vehicle manufacturers to include detailed information in their vehicle owners' manuals about the health dangers of vCO, the life-saving potential of CO detectors, and tips for reducing vCO exposure.
  5. Beginning in 2003 or 2004 at the latest, require vehicle manufacturers to install CO detectors in the passenger compartment of all new motor vehicles--and to offer equivalent devices as optional upgrades for older vehicles--featuring a digital display and some kind of temporarily silenceable audiovisual warning activated instantly by any CO levels above 9ppm.
  6. Beginning in 2003 or 2004 at the latest, require manufacturers of vehicles with gasoline engines (only) to connect the built-in CO detector to an engine cut-off switch designed to instantly shut off the ignition and engine as soon as and as along as the CO level inside the vehicle exceeds 200ppm (the NIOSH evacuation limit), provided for safety reasons that the vehicle is not already moving. If the vehicle is moving when CO levels exceed 200ppm (a most unlikely scenario), the occupants should be directed to open more than one window immediately.

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