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Comments to the CPSC on Chronic Hazards Associated with Gas Ranges and Proposed Solutions

In March 2023, the Consumer Product Safety Commission (CPSC) published a Request for Information on Chronic Hazards Associated with Gas Ranges and Proposed Solutions. We submitted comments which highlighted the major findings from our report.

We explained that since the Consumer Product Safety Act (CPSA) authorizes the CPSC to issue performance standards and require warning labels if “reasonably necessary to prevent or reduce an unreasonable risk of injury” posed by a consumer product, the CPSC could reasonably conclude that gas stove emissions create an “unreasonable risk” by causing indoor air pollutant concentrations that exceed relevant U.S. and international air quality standards and guidelines.

We also highlighted that the CPSC has previously taken discretionary action under the CPSA to regulate products that present chronic hazards akin to those posed by gas stove emissions and has the relevant expertise to weigh any associated hard-to-quantify effects.

We recommended that the CPSC consider taking several possible further actions:

  1. Issue a mandatory performance standard that reduces the risk of health harm from gas stove emissions by alerting users to unsafe indoor air pollutant concentrations, automatically shutting off the device when those levels are reached and/or activating a connected range hood to increase ventilation.
  2. Issue a mandatory performance standard for ducted range hoods that ensures adequate ventilation of stove emissions focused on capture efficiency and automatization as a complement to any stove-focused standards.
  3. Require a warning label that alerts consumers to the pollutants emitted by gas stoves, their potential health consequences, and the importance of ventilation as a risk-reduction tool. Such a label could serve as a low-cost, quickly implementable precursor or supplement to a performance standard.
  4. Create accessible public education materials regarding the risks posed by gas stove emissions and strategies for mitigating them.

Create accessible public education materials regarding the risks posed by gas stove emissions and strategies for mitigating them.