DOUBLE ANGEL FOUNDATION ®

Raising the Awareness of the Dangers of Carbon Monoxide Poisoning

 

 

 

August 9, 2005

 

 

Richard Blackman

US Coast Guard Office of Boating Safety

Commandant (G-OPB-3)

2100 Second St. SW

Washington , DC 20593

 

Dear Mr. Blackman:

 

This letter summarizes and condenses information from several reports and presentations in which a shower device used on recreational boats was discussed. We are sending you this information to reemphasize concern about the severe and unnecessary carbon monoxide (CO) poisoning hazard presented by the use of this device. We are asking you to review this information and act to prevent future deaths and injuries related to use of the device.

 

Please determine if the device falls under its regulatory mandate for recreational boats. If the device is not within your jurisdiction, it is likely to be under the jurisdiction of the US Consumer Products Safety Commission (CPSC). If it is not under your jurisdiction, I am asking for your assistance in bringing it to the attention of CPSC.

 

This shower device uses warm water from the operating propulsion engine for its function. This means that the engine is operating when the user stands on the boat to use it. The most likely place for use of the device is on swim step near where it is attached to the boat, or on the transom. Use of it within the boat is unlikely as you would be pumping water into the seating area of the boat. We know that the device has been associated with one death, and four other very severe poisonings (in two separate events).

 

Information about the CO danger associated with use of the shower is in the following documents:

 

•  The National Case Listing that has been forwarded to the US Coast Guard Office of Boating Safety and that can be found on the Department of Interior (DOI) website at the following address http://safetynet.smis.doi.gov/thelistbystate10-19-04.pdf . The specific entries are:

 

 

 

Arizona/Utah - Lake Powell

8 (22) Since 1990, 22 people survived CO poisoning outdoors on pleasure craft (boats other than houseboats) on Lake Powell .. .. The remaining 8 of 22 people poisoned outside of the cabin area of pleasure craft were in the water when they were poisoned, or were dangling from or sitting on a water-level swim platform. The circumstances of these 8 poisonings are described below:

.

Playing for several minutes with a shower hose that was fed hot water by the operating engine while sitting on the swim platform; her arms clenched, she started crying, her eyes rolled to the top of her head and she appeared to stop breathing. She was given rescue breathing and was transported to the hospital. (Source: Review of NPS EMS Records, Glen Canyon National Recreation Area)

 

Utah - Flaming Gorge National Recreation Area

In 1995, 4 children were poisoned inside a cabin cruiser boat powered by an inboard engine. Three of the boys were hospitalized and the fourth boy (aged 14) died. The boys were using a warm-water shower device attached to the boat's propulsion engine. This device drew heated water from the propulsion engine, which meant that the engine had to be operated for the device to work. The boat had been completely covered because of rain. When the boat was occupied, a panel was unzipped and a door to the rear of the boat was opened to allow access to the ski platform. All four boys were discovered unconscious inside the boat. The coroner reported that the boy that died had a COHb of 46.6%. (Source: US Coast Guard Database; Utah Division of Parks and Recreation Incident/Accident Report) Propulsion engine exhaust

 

•  NIOSH's control technology report (EPHB 171-31a) that was funded by the US Coast Guard interagency agreement. This report was provided for the US Coast Guard and is also available at the following internet address: http://safetynet.smis.doi.gov/171-31a%20final%20report.pdf . Data relevant to the shower device is found in Table 15 of the report (on page 52) which has been abstracted for this letter and included in Enclosure 1. The data document average exposures greater than the NIOSH recommended ceiling limit (200 ppm), and peak exposures as high as 4 times the NIOSH ceiling limit are likely when the shower is used.

 

•  NIOSH's final report for Health Hazard Evaluations 2000-0400-2956 and 2002-0325-2956 which was forwarded to the US Coast Guard Office of Boating Safety and that can also be found on the above DOI website.

From the Results section (page 11) :

. Two others lost consciousness while sitting on the platform of a stationary ski boat, either pausing while accessing the boat or playing with a shower device that uses warm water from the operating boat engine.

 

From the Discussion section (page 17):

In addition, during the course of this work, a feature described as a shower that operates using warm water from the operating propulsion engine arose as a serious concern. This device draws heated water from the propulsion engine, meaning that the engine has to be operating for the device to work. In the GCNRA incident, a 4-year-old girl was poisoned. She had been playing with a shower hose that was fed hot water by the engine. While sitting on the swim platform she clenched her arms, started crying, and her eyes rolled to the top of her head. She appeared to stop breathing. She survived. However, in a 1995 incident occurring in Flaming Gorge, Utah , three boys were hospitalized and another died in connection with the use of a similar device. In the Flaming Gorge incident, the boat had been completely covered because of rain. When the boat was occupied, a panel was unzipped and a door to the rear of the boat was opened to allow access to the ski platform. All four boys were discovered unconscious; the COHb of the boy who died was 46.6%.

 

From the Recommendations section (page 19):

7. Portable shower devices that operate using hot water from an operating propulsion engine should be evaluated for potential recall.

 

•  Presentations attended by US Coast Guard representatives (s pecific slides from those presentations are shown in Enclosure 2).

 

2002 International Boating and Water Safety Summit

Interagency Meeting at Lake Powell , June 2002;

2003 annual meeting of the National Association of State Boating Law Administrators;

2004 International Boating and Water Safety Summit .

 

 

To reemphasize the hazard related to the use of this shower device, I am also enclosing video footage in DVD format. Chapter 7 (31 minutes into the DVD video) shows CO air sampling on a ski boat. The occupants of the ski boat indicate that the boat is equipped with this shower device. CO concentrations in excess of the air sampling device's upper limit (thus greater than 1000 parts per million) are measured in the area where the occupants indicate that the shower is used (i.e. on the swim platform and on the rear padded platform) while the boat's engine was idling.

 

In summary:

The combined body of information specific to this device, as well as the overall information about CO poisonings related to occupancy of the swim platform of ski boats, clearly show that use of this device poses an extreme and unacceptable risk of death and injury to boaters. The information also demonstrates that the manufacturer/s and suppliers of the device clearly do not understand the issue of CO poisonings related to occupancy of the rear of the boat concurrent with propulsion engine operation.

 

We are asking that the US Coast Guard Office of Boating Safety address the NIOSH recommendation that portable shower devices that operate using hot water from an operating propulsion engine should be evaluated for potential recall. We are also asking that you immediately contact manufacturers and distributors of the device to inform them of the risk of using such a device in an area that has been documented to be rich in CO.

 

If you determine that this device does not fall within your recall jurisdiction, we are asking that you work in conjunction with the US Consumer Product Safety Commission to accomplish these ends.

 

Sincerely,

 

 

 

 

Jane B. McCammon

Double Angel CO Awareness Committee Chairman

 

Cc: Janet Buyer, Consumer Product Safety Commission, jbuyer@cpsc.gov ,

Telephone: (301)504-7542

 

Double Angel Foundation CO Awareness Committee members
Enclosure 1

Data Relevant to the Shower Device from

NIOSH's control technology report (EPHB 171-31a)

Table 15, Page 52

 

The boat on which the testing was done was a 21' long, 7'9 Malibu Sunsetter, Malibu Boats, Merced, CA 21 ft SV (sport vee) with transom shower. The engine was a carbureted Malibu Vortec 310 hp.

 

Table 15 - Malibu Wakesetter With Transom Shower, Carbon Monoxide (ppm)

 

 

Start Malibu

 

Wakesetter engines

 

(with shower device)

L1

Mean

287

Back Deck Port

Std dev

55

 

Samples

4

 

Peak

316

 

 

 

L2

Mean

522

Back Deck Center

Std dev

240

 

Samples

4

 

Peak

794

 

 

 

L3

Mean

197

Back Deck

Std dev

39

Starboard

Samples

4

 

Peak

240

 

 

 

L4

Mean

11

Interior

Std dev

4

 

Samples

4

 

Peak

15

 

 

 

L5

Mean

7

Front

Std dev

2

 

Samples

4

 

Peak

9

 

 

 

L6

Mean

11

8' Pole

Std dev

4

 

Samples

4

 

Peak

15

 

 

 

L7

Mean

17

10' Pole

Std dev

10

 

Samples

4

 

Peak

29

 

 

 

L8

Mean

27

12' Pole

Std dev

13

 

Samples

4

 

Peak

37

 


Enclosure 2

Slides Relevant to the Shower Device from

Presentations Attended by US Coast Guard Representatives

 

2002 International Boating and Water Safety Summit

 

Interagency Meeting at Lake Powell , June 2002 (same slide presented)

 

 

 


NASBLA Annual Meeting 2003

 

 

 


2004 International Boating and Water Safety Summit :