rufidrue

Agsinstlf ir e D wtbs 1l w. .
@rrr 6on[: ilcbuce fkc Eentljs llrr tl;c 01..€,. pty g0o/o

December 17, 1998

George D. Miller, President

National Fire Protection Association
One Batterymarch Place
Quincy, MA 02269-9101

Subject: False and Potentially Deadly Advertisements

Dear Mr. Miller:

As a Professional Fire Protection Engineer, by this registered letter I am

advising you that the enclosed ad that appeared in your Fire Journal magazine is
providing false and dangerous information to the public.

The ad is clearly claiming that the canned vaporizing spray, which is labeled as
a "smoke detector testei', will test an ionization detector's ability to detect a real fire in
a real home. That claim is misleading and, in the majority of the cases, false.

What has never been explained to the American public is that the ionization-type
detector is really a "particulate cloud detectoi' and not necessarily a smoke detector. lt
is capable of deiecting particulate clouds containing solid or liquid particulates that
number into the millions per cubic inch and are mainly so tiny that they are invisible to
the human eye.

lf the combustion products produced by a fire fit the particle cloud profile that will
cause the detector to sound, why then that detector is capable of warning that the fire
exists. But, if the combustion products created by the fire do not fit the narrow
detection capabilities of the device, why then the fire continues to create conditions that
can eventually kill while the detector remains silent.

The smoke detector "teste/' is formulated so as to produce a particulate cloud

that contains the "right" number and the "right" sized particulates so as to cause the
device to alarm. By implying that the type of particulate cloud produced by the "tested'
will simulate the conditrons created by a wide variety of fire conditions likely to occur

F 09. ?Eux 196 . (Ittrus ldrtgts, gA q5b11-[1g6 . (9].6) 72I-7799. TAX (gi6) 7n-ng4
within a home, the manufaclurers are simply deceiving the public in order to make a
profit. Normally, that type of marketing deception is referred to as FRAUD.

The visible type of particulate cloud (called smoke) will be produced by a

smoldering fire, and also when very small particulates from a flaming fire agglomerate
on the way to the detector. The ionization detector will likely fail to warn of the
potentially deadly condition under these circumstances.

There is an abundance of scientific and statistical evidence to show that a very

high percentage of the fires that occur in the home create particulate clouds that are of
a [ype that are not capable of causing the ionization detector to sound. The
smoke (consisting of large particulates) can become so dense as to make it virtually
impossible to even see the smoke detector from ten feet distant. Yet, though the
device is blotted out by that thick smoke, it will not detect that life threatening
condition because the smoke does not fit the detection capabilities of the
detector.

Based on my studies of the performance data of smoke detectors in residential

properties, as published by NFPA, FEMA and Texas, it is apparent that the ionization
detector is sounding (prior to untenable conditions being created), only aboul2Oo/o of
the time when fires occur in homes.

Iconsider a 7% level of obscuration (light reduction per foot) to be entering the

"deadly" stage. A7o/o reduction in visibility can cause a person to be so fearful of
passing through that smoke that that person will become trapped. Death or serious
injury will likely occur soon thereafter. However, studies, field tests, reports, etc.,
known to and published by the NFPA, UL, NIST, the Boston Fire Department and
others clearly reveal that smoke densities will often exceed 30% with the
ionization detector unable to detect the smoke or sound an alarm.

THE NFPA HAS AN OBLIGATION TO WARN THE PUBLIC RELATIVE TO THE

CONDITIONS UNDER WHICH THE IONIZATION DETECTOR WILL FAIL TO WARN
OF A SMOKE CONDITION PRIOR TO THE SMOKE ENTERING WELL INTO THE
DEADLY LEVEL. YOUR FAILURE TO DO SO IN THE PAST HAS BEEN A PRIMARY
FACTOR IN AT LEAST 5O,OOO FIRE DEATHS AND PROBABLY 3OO,OOO SERIOUS
INJURIES.

Now, with regard to the vaporizing liquid spray, which is sold with the claim that
it will "test" a smoke detector, clearly that claim represents false and dangerous
advertising. The spray produces a cloud of the "right sized" particulates in the "right
numbers". So, the vapor cloud produced is specifically consistent with the performance
capabilities of the detector. When spraying the cloud into the detection chamber, the
consumer will assume that the spray is reasonably similar to the smoke likely to be
produced by a fire in the home. More often than not, it is not.
DEFECTS of the ionization detector.

I suggest you begin by publishing the article I enclose with this letter within your
Fire Journ?l magazine. However, far more is required in order to begin to compensate
for the prior deaths and injuries due to smoke detector fraud, and to prevent future
unnecessary deaths and injuries.

Richard M. Patton
Registered Fire Protection Engineer
President, Crusade Against Fire Deaths, lnc.

RMP/Iff

Enclosures: 1. The lnherent Defects Of The lonization Detector

2. Federal Emergency Management Agency Fire Loss Data
 fTil
1{FPff

National Fire Protection Association

International

I Batterymarch Park, Quincy, Massachusetts 02269-9101 USA

Telephone (617) 770-3000 . Fax (617) 770-0700' www.nfpa.org
Arthur E. Cote, P.E.
Senior Vice Presidertt & Chief Engineer
Operations

March 15,1999

Mr. Richard Patton

PO Box 196
Citrus Heights, CA 9561l-0196

Dear Mr. Patton:

Your letter of December 17, 1998 has been referred to me for a reply. Your letter raises a number of
technical issues concerning home smoke alarms. The response to your points follows.

Your objections to the aerosol smoke product advertisement that appeare d in N FPA Journal are misplaced.
That advertisement was reviewed by NFPA using its normal procedures, and both the advertisement and
the product meet our criteria for acceptability. Advertisements appearing in NFPA publications do not in
any way represent an endorsement ofthe advertised product, and I note that your objections to this product
appear to be based on a misperception of its function. The aerosol smoke product in question is evaluated
and listed by a nationally recognized independent testing laboratory. If you feel that the product standard is
inadequate, please work with the appropriate testing laboratory.

Aerosol smoke products are designed to simply provide a functional "golno-go" test of smoke alarms and
smoke detectors. This product is not, in any way, designed to provide a sensitivity test of the smoke alarm
or smoke detector because it administers an unmeasured quantity of aerosol to the device. This test only
provides a convenient method of determining if the smoke alarm or detector is sufficiently clear of debris to
allow smoke to enter the sensing chamber.

Please note ihat NFPA 72-1996, National Fire Alarm CoCe requires a monthly test by homeowners. The
monthly test is to be conducted according to manufacturer's instructions. This test usually involves a
simple push button test of the smoke alarm. The push button test ensures that the smoke alarm is
operating within its listed sensitivity range, and tests all the electronics of the device. NFPA 72 does not
require the use of an aerosol smoke product as part of the required testing program, unless required by the
manufacturer of the smoke alarm. I am not aware of any manufacturer that currently requires an aerosol
smoke test of a smoke alarm intended for dwelling use. However, most manufacturers allow the use of the
product as a supplementary means of testing their smoke alarms.

NFPA 72 also allows either ionization-type smoke alarms or photoelectric-type smoke alarms to be used.
NFPA 72 also requires smoke alarms to be listed by an independent testing laboratory. Both types of
smoke alarms are tested to rJL 2l'7 , Standard for Safety, Single- and Multiple-Station Smoke Alarms.
This test requires both types of smoke alarms to be subjected to the same quantity of the same kind of
smoke. Both types of alarms must respond within the same time limits during these tests. This ensures
that both types of smoke alarms respond fast enough to all types of fires to provide acceptable life safety.

An international nonprofit membership organization dedicated to reducing the burden of fire on the quality of life by advocating scientifically-based codes and standards,
Mr. Richard Patton
March 15,1999
Page Two

Nearly 93 percent of all U.S. households have at least one smoke alarm. Many residential fire deaths in the
U.S. occur in homes not protected, or homes that have no working smoke alarm. According to a recent
U.S. Consumer Product Safety Commission (CPSC) study, nearly 20 percent of all installed smoke alarms
suffer fiom failure. These failures are largely due to failed or disconnected power supplies. Nuisance alarms
are also one of the reasons that occupants disconnect smoke alarm power supplies. Many nuisance alarms
are preventable by properly locating and maintaining the smoke alarms as required by manufacturer's
requirements. Failures can also be minimized through a rudimentary maintenance and testing program as
required by NFPA 72.

Current code requirements are based on testing under real world conditions. The U.S. Consumer Product
Safety Commission (CPSC) is currently developing a research project that will determine if dwelling fires
today are different than they were during the early development of smoke alarms. This project is expected
to follow up the Indiana Dunes Tests conducted about twenty years ago. These new tests will hopefully
determine the characteristics of fires most common in dwellings today. The Technical Committee on
Household Fire Waming Equipment will then evaluate any relevant new data as it relates to the National
Fire Alarm Code requirements.

We do not support the publication of your proposed article because many of the unsubstantiated statements
are in conflict with technical data that is currently accepted by experts on the subject. The manner of your
presentation maligns many individuals and organizations. We are receptive to balanced presentations of
conflicting views, but a responsible editor cannot endorse attacks on people or organizations in our
publications.

lf you disagree with the requirements of NFPA 72, National Fire Alarm Code I suggest you submit
recommendations for changes and substantiation that includes scientifically based data in the form of public
proposals in future revision cycles of NFPA72. The 1999 edition of NFPA 72will be published in
September 1999. The proposal closing date for the2002 edition will be November 2000. A blank
proposal form and exact dates for the revision cycle will be included inside the back cover ofthe 1999 Code
and are also available from our staff.

Sincarety,
(,-
i L:-" { I
&_ ,- '\,. i:-
^-\
Arthurts€ote, Eg.
Senior Vice President & Chief Engineer
Operations

cc: Wayne Moore, Chair, NFA-AAC

Richard Bukowski, Chair, NFA-HOU
Jim Roberls, Chair, NFA-lDS
G. D. Miller
J. M. Shannon
R. J. Vondrasek
M. W. Earley
C. C. Grant
M. W. Bunker
J. R. Hall
K. Robinson