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Recommendation (summary) on the safety of type c200 piercable gas canisters and the appliances they power 04/06


THE CONSUMER SAFETY COMMISSION
(27th April 2006)
 
HAVING REGARD TO the Consumer Code and specifically Articles L. 224-1, L. 224-4, R. 224 ‑ 4 and R. 224-7 to R. 224-12,
 
HAVING REGARD TO referral no. 04-078,
 
WHEREAS:
 
 
THE REFERRAL
 
The Marseilles Regional Trauma Burn Centre petitioned (referral no. 04-078) the hazard of pre-filled so-called “piercable” or “puncture” liquefied gas canisters of the Campingaz and IdéalGaz brands to the Commission:
 
“Every year many casualties are admitted to trauma burn centres in France after the explosion of pre-filled liquefied gas canisters (model C206, Campingaz brand; IdéalGaz brand). The accidents usually occur when the canisters are being used in a closed space near a flame. The arrival on the market of canisters with leak-preventive valves (model CV 270 of Campingaz brand) has not caused the old canisters to disappear. On the contrary, European standard EN 417, updated in October 2003, validates the use of valveless canisters. Considering the seriousness of the burns and quite high accident frequency, we felt that it was necessary to alert the CSC.” 

THE ISSUE
 
The canisters are made by several manufacturers and sold by the hundreds of thousands worldwide. They power backpacking gas stoves, camping lanterns and soldering lamps. The lightweight easy-to-pack canisters are practical for travelling purposes.
 
The canisters are very simple to make since they are just closed containers with a thinner area on top that can be pierced (or punctured) by a special device that is built into the appliance.
 
The entire system has sealing rings to ensure that it stays fully leakproof when punctured.
 
However, a number of users are unable to puncture the canister as required, causing comparatively big gas leaks that quickly empty the canister. Another, albeit seldom occurrence, fortunately, is when users want to change a gas canister even though the one mounted on the appliance is not completely empty.
 
The gas in the cartridge is liquid and turns into gas the minute the canister is opened (volumic expansion), thus causing intense cold (refrigerator principle). The cold causes burns (cold burns) whose effects are similar to those of hot burns and whose consequences may be very serious (although they usually only affect a fairly small area of the body).
 
The gas escaping from the open canister may also catch fire.[1] Virtually unstoppable, inflammation continues until gas runs out and may lead to an explosion in certain (fortunately uncommon) conditions.
 
Actually, far from limiting the analysis to the canisters, the investigation has to be broadened to include the ‘components-canister’ pair and the connection system on the appliance; the entire set-up must be perfectly safe.
 
Details provided by manufacturer ‘A’ show that handling and fitting the canisters onto the appliance may be difficult and certain less skilful consumers may fall victims to an “accident”.
 
Company ‘B’ recognises that proper use by consumer assumes that he or she strictly complies with several requirements, viz.,
 
-                     Canisters should be changed according to the instructions in the directions for use supplied with the appliance although on hiking and camping trips the instructions are not usually taken along with the appliance, which may also be handed down over several generations.
-                     Canister change should be done in an open space, therefore precluding apartments, workshops or tents.
-                     It should be done far from any ignition source as specified in the directions for use of the appliances, and on C206 canisters. The instructions are listed in two different ways on B gas canisters, e.g.,
 
·                                            A written explanation in 1.5-millimetre high white letters against a blue background in a 6 x 6 centimetre box (roughly 134 words on general safety conditions, 77 on changing the canister) in several languages
·                                            Six pictograms (total area 2.8 x 5.6 cm) depict (for two different types of appliances) the three steps required to change the canister, i.e., unscrew the valve, mount the new canister, screw the valve back on.
 
Nevertheless, consumers may hole the canister before it is properly mounted onto the puncture device (faulty centring) or well secured in the canister housing (gas pressure may “push out” the canister and trigger a gas leak). Among other things, this may cause accidents when user attempts to replace the empty canister without unscrewing the appliance with its puncture device.
 
 
THE HEARINGS
 
The rapporteur held several hearings. The statements brought to light several major issues.
 
- The total number of piercable gas canister appliances worldwide may be assessed at about 35 million units. The main manufacturers are Coleman, Campingaz, and Kemper (Guilbert Express). According to certain attendees, Japan has made the leakproof safety device mandatory.
 
- The comparatively simple and sturdy appliances have a long life cycle. They are handed down from one user to the next (especially within families), most often without the directions for use.
 
- Numerous incidents, specifically gas leaks without ignition, are not reported even though they could have caused a serious accident (users are not always to blame for the ignition source that may have been triggered by another person or an outside event, such as an electric spark).
 
- Both ‘A’ and ‘B’ manufacturers, who were auditioned, have safe canister models although manufacturer ‘B’ does not market them. Coleman, which mainly does business on the US market, has a safe canister model.
 
- A gas leak may cause:
 
-                                             Cold burns when the leaking gas is reduced in pressure,
-                                             Burns after gas ignites (inevitably if there is an ignition source) producing a fire-ball with a diameter of about two metres (a video illustrates the occurrence), at a temperature of about 1,000°C,
-                                             Explosions if the canister, which has a low explosibility threshold, empties out into an unventilated room.
 
- The cost of a leak preventive device amounts to about 25% of the price of a canister that is not equipped with. Mass-production would incur a sharp drop of the extra cost.
 
- Company ‘B’ manufactures about 500,000 gas appliances (backpacking stoves, lanterns, and so on) per year in Europe and about 50 million containers (canisters, cartridges, and so on) designed to power them.
 
- The canisters that seem to be the source of incidents are mostly type C 206 canisters with or without valves because they are the most widely sold. The incidents usually occur while replacing the empty canister with a new one.
 
- Most accidents are due to non-compliance with directions for use (that are on each canister in about 1.5-millimetre high white letters against a blue background for Campingaz canisters, for example).
 
- Consumers do not always know how to install the replacement canister properly, especially as some systems do not make it easy to mount the canister properly. A canister that is mounted slightly askew will cause a leak when punctured and possibly when withdrawn. Actually, replacement should be done after the valve has been unscrewed. Once the new canister is properly placed and locked into position in the appliance, the valve is screwed down to ensure that canister is properly punctured.
 
- A 2002 study by Delft University of Technology, Holland, confirmed these problems and the frequent non-compliance with directions for use. 
 
One may justifiably ask whether the product (appliance and canister) was designed with consumers’ reasonable foreseeable behaviour in mind as they are drawn by the apparent simplicity of the object and its servicing.
 
 
STANDARDISATION
 
A – The Canisters
 
In the European Union, the canisters are governed by Directive 99/36/EC of 29 April 1999 on transportable pressure equipment. The Directive was incorporated into national law by Decree no. 2001-386 of 3 May 2001 transposing Directive 1999/36/EC. The Decree refers indirectly to standard NF EN 417 (October 2003) for the assessment of gas canister compliance with the relevant general safety recommendations applied to canisters.
 
B – The Appliances
 
Standard NF EN 521 defines the characteristics of piercable-canister stoves. The standard applies to gas-powered appliances using piercable canisters compliant with standard EN 417. The standard is under the responsibility of CNE/TC 181 and in France, it is monitored by Standardisation Commission BNG 181 of the Bureau de Normalisation du Gaz (BNG, gas standardisation office). The standard has just been amended. Article 5.7.2.1 has now recommendations for the prevention of any risk especially when canisters are being changed.
 
In addition, the standard proposes technical solutions that would prevent the improper mounting of the canister. For instance, only when canister is properly fitted onto the body of the appliance can the former be punctured.
 
However, the safety of the appliances now in use, which are of an older design and were made prior to the new EN 521 standard, is inseparable from the safety of piercable canisters. The appliances, which are used seasonally or occasionally, have a very long life cycle, are easily loaned and users are often poorly informed and not very experienced. At the meeting to determine the French position concerning the vote on amending standard EN 521, Standardisation Commission BNG 181 felt that Standard EN 417 needed to be changed as well, and should include additional specifications taking account of technological changes. The specifications would limit piercable canister gas flow when the canister has not been properly punctured or when a canister still containing gas has detached itself from an appliance.
 
Specifications may be very simple since we believe that, overall, standard EN 417 recommendations are relevant. For instance, the following paragraph could simply be added, “In test conditions (to be specified), a punctured canister should not allow a gas release exceeding so many (to be defined) cubic centimetres per minute.” This is absolutely feasible technically. A proposal for a measurement method was submitted by one of the canister manufacturers.
 
Standardisation Commission BNG 181 wrote to the French Agency AFNOR in the same vein (BC/BNG181/2005-545 letter of 1 December 2005). The Agency initiated a consultation to compile the recommendations of Standardisation Commission E 29 H members on the possibility of reviewing standard EN 417 and to submit the question to the European authorities. The result of the consultation is positive. The modification must now be backed by at least 5 countries.
 
The office for the safety of industrial equipment at the Ministry of Industry backed the request for modification, under the specifications of the Directive on transportable pressure equipment (to which standard EN 417 is attached).
 
Although the number of accidents are low, in fact compared to the number of sold canisters, the number of incidents that do no cause any injury (or cause light injuries) or do not cause any (or little) material damage is certainly much higher. Advisably, action should be taken to ensure the full safety of all users, particularly thanks to technological advances.
 
 
ON THE BASIS OF THIS DATA
 
Whereas it is not the piercable gas canister by itself but the inseparable pair it forms with the gas-powered appliance that has to be made safe for consumers since incidents or accidents occur when the canister is being mounted onto the appliance or replaced;
 
Whereas two separate approaches have attracted the CSC’s attention, i.e.,
 
-                                       In 2001, the Dutch authorities lodged a formal objection with the European Commission against harmonised standard EN 521 on appliances, based on the requirements of the Gas Appliances Directive, following a study by TUDelft called Replacing pierceable cartridges in gas lamps by Freija H. Van Duijne and Heimrich Kanis. According to the authors, gas appliances complying with the standard may present a risk when the piercable gas canister is being replaced if the directions for use are not scrupulously complied with;
-                                       In 2004, the Regional Trauma Burn Centre at Conception Hospital in Marseilles, based on proven accidentology, petitioned the CSC about the hazard of so-called piercable pre-filled liquefied gas canisters, meeting the recommendations of European standard EN 417;
 
Whereas amended standard EN 521 is pending publication by AFNOR and whereas in Article 5.7.2.1, the standard includes recommendations for the design of the appliances, to avoid hazardous and/or accidental puncture during canister change;
 
Whereas the recommendations of amended standard EN 521 applicable to gas appliances seem likely to meet expected safety requirements during the operations required to change a canister, according to currently available information;
 
Whereas it will probably be a long time before consumers no longer use currently operational appliances;
 
Whereas advisably, users of the said appliances that no longer meet the requirements of standard EN 521 should be offered solutions so they may safely carry out operations to replace piercable pre-filled gas canisters; 
 
 
IS ISSUING THE FOLLOWING RECOMMENDATION:
 
1.         As soon as possible, the French authorities should initiate a procedure for amending standard EN 417 on “non refillable metallic gas cartridges for liquefied petroleum gases, with or without a valve, for use with portable appliances” (whose last update was in October 2003) so that the standard explicitly includes specifications to limit gas leaks under a certain threshold, which needs to be defined, when canister is mounted or withdrawn to ensure that any kind of handling error or incident whatsoever does not cause any hazard to user.
 
2.         Pending this, industrialists and other industry professionals should:
 
-                    Advance the design, manufacture and distribution of safe canisters
-                    Promote targeted commercial actions urging the replacement of old appliances with appliances compliant with amended standard EN 521
-                    Improve canister signage to alert consumers about the proper procedure for changing a canister, specifically by printing a clearly legible warning on the packaging, “WARNING: read and comply with the replacement operations printed on the canister.”
 
3.         The Commission will publish a data sheet on prevention to inform canister users of the risks inherent to using old appliances and to prompt them to use safe canisters or acquire appliances compliant with amended standard EN 521.
 
 
ADOPTED AT THE SESSION HELD ON 27 APRIL 2006
ON THE BASIS OF THE REPORT BY MRS MARIE-LOUISE AUBIN-SAULIÈRE
 
Assisted by Mr. Jean Michel MAIGNAUD, Commission Technical Advisor, in accordance with Article R. 224-4 of the Consumer Code
 


[1] One of the latest accidents report to the Commission involved a backpacking stove. It seems that the consumer, frightened by the gas leak, accidentally switched on the piezoelectric ignition system.