A

Project Report on
BLOWER ROOM HEATER
Submitted in partial fulfillment of the requirement for
the award of the diploma in
ELECTRICAL ENGG.
By
Anand Kumar Singh
Govind Kumar
Narendra Vikram Singh
Arjun Kumar
Lavkush Gupta
Ram Nazar Chauhan

Under the supervision of

Mr. Ajai Prakash Narayan ( Lecturer )

Department of Electrical Engineering

GOVT. POLYTECHNIC GONDA, U.P.
 GOVT. POLYTECHNIC GONDA
BTEUP
Department of Electrical Engineering

CERTIFICATE
It is certified that Anand Kumar Singh, Govind Kumar, Narendra Vikram
Singh, Arjun Kumar, Lavkush Gupta, Ram Nazar Chauhan have worked under

my supervision and guidance for the project entitled on “Blower Room

Heater “ for the requirements and award of the Diploma with specialization
in “ Electrical Engineering “ from the Board of Technical Education Lucknow
during academic year 2019 - 20. The project embodies result of original work,
and studies are carried out by the students themselves and the contents of the
project do not form the basis for the award of any other courses to the
candidate or to anybody else from this or any other institution.

Mr. A.P. Narayan

( Guide )
 ACKNOWLEDGEMENT

I wish to express my profound gratitude and indebtedness to Lect. A.P.

Narayan and Lect. Shashank Srivastava Department of Electrical
Engineering G.P. Gonda.

Introducing the present topic and for their inspiring guidance,

constructive criticism and valuable suggestion throughout the project

work.

Last but not least, my sincere thanks to all our friends who have patiently

extended all sorts of help for accomplishing this undertaking.

Student Name
Anand Kumar Singh, Govind Kumar
Narendra Vikram Singh, Arjun Kumar
Lavkush Gupta, Ram Nazar Chauhan

Dept. of Electrical Engineering

Govt. Polytechnic Gonda
 TABLE OF CONTENTS

1. EXECUTIVE SUMMARY 3

2. INTRODUCTION 5

3. PRODUCT DESCRIPTION 6

4. VOLUNTARY STANDARDS APPROACH TO 9

HEATER EVALUATION

5. MARKET INFORMATION 10

6. HAZARD ANALYSIS 10

7. PRODUCT SAFETY ASSESSMENTS & RECALLS 14

8. LABORATORY STUDIES 15

9. FAILURE MODES & EFFECTS ANALYSIS 18

10. HUMAN FACTORS EVALUATION 18

11. TECHNICAL EVALUATION OF ELECTRICAL 19

CRIMP CONNECTIONS

12. INDEPENDENT INVESTIGATORS 20

13. RECOMMENDATIONS TO THE VOLUNTARY STANDARDS

A. UL 1042, Electric Baseboard Heating Equipment 21
B. UL 2021, Fixed and Location-Dedicated Electric Room Heaters 28

14.CONCLUSIONS 39
 2. INTRODUCTION

Fixed-position electric room heaters are non-portable appliances that convert

electricity directly to heat. Typically, the heaters are connected directly to the branch
circuit wiring when installed. These products have been in widespread use in the United
States for over 50 years. In areas of the country where electricity costs are historically
low (primarily the Western States) or where winters are not severe (such as in the South),
fixed-position electric heating is often the preferred heating system for small residences.

Some characteristic features of these products are high internal temperatures, high
currents, and line voltages. These attributes can contribute to fire incidents. In 1998,
there were an estimated 1800 fires that resulted in 10 deaths, 110 injuries, and about
$19.3 million in property losses1. This data represents a continuation of a declining rate
of fires over the previous few years.

The U. S. Consumer Product Safety Commission (CPSC) initiated a project on

fixed-position electric heaters in fiscal year 2000, the purpose of which was to:
• Assess the adequacy of the relevant voluntary standards in addressing fire
incidents, and
• Recommend any warranted improvements.

The applicable voluntary standards are UL 1042 Electric Baseboard Heating

Equipment, and UL 2021 Fixed and Location-Dedicated Electric Room Heaters.

Previous CPSC work on voluntary standards associated with fixed-position

electric heaters occurred in 1983 and focused on requiring that a temperature limiting
control (TLC) interrupt all ungrounded conductors when activated. Underwriters
Laboratories Inc. (UL) implemented this requirement for open-coil element heaters only.
Sheathed heating element heaters were exempted from this requirement.

The CPSC staff evaluation presented here includes several studies. Economic and
epidemiological examinations were completed; laboratory and analytical studies were
conducted; and a technical study of connectors used in electric heaters was performed by
a contracted expert in the field. This report presents the results of the contractor’s
evaluation and the staff’s assessments.

1
Mah, Jean et al., “1998 Residential Fire Loss Estimates,” U.S. Consumer Product Safety Commission,
Directorate for Epidemiology, March, 2001.

Page 5 of 41
3. PRODUCT DESCRIPTION

Fixed-position electric heaters create heat by passing electric current through a

heating element made of an alloy of nickel and chromium called nichrome. The
nichrome heating element may be encased in a metal sheath packed with a magnesium
oxide powder or may be exposed in an open-coil geometry. Typically, the heating
element is mounted in a frame and is accompanied by a temperature-sensing thermal
limiter to detect overheating. An alarm (typically a hazard lamp) is used to alert the
consumer of the activation of the limiter. Some heater designs use a fan to force air
across the elements as a means of increasing the convective heating rate. Figure 1 shows
a block diagram of a typical fixed-position electric heater.

Figure 1: Typical Heater Components

+Voltage -Voltage
Heating
Thermal
Elements
Limiter

Hazard Lamp
Fan

These heaters are generally hard-wired to either 110 or 220 VAC, based on their
designs but may be cord-connected heaters that are dedicated to fixed locations.

The three major types of fixed-position electric heaters are natural convection,
forced-air convection, and radiant. Natural convection heaters rely upon heating a large
surface area to warm nearby air and allow it to rise by convection from the heater into the
room. Baseboard heaters are characteristic of natural convection heaters. This design
has no fan or hazard lamp and relatively low temperatures on the heating element and
convective fins. The heating element is almost always a sheathed design with the heating
wire surrounded by a metal tube packed with electrically insulating but thermally
conductive magnesium oxide powder. A few baseboard heaters use a fluid instead of the
powder, and are called hydronic heaters. Baseboard heaters have openings at the bottom
to allow cool air to enter and at the top allowing the warmed air to exit the heater. Figure
2 shows a typical baseboard heater. This particular unit has an optional thermostat at the
left end. Figure 3 shows a section of a sheathed heating element design found in
baseboard and some wall-insert heaters. The picture shows the convective fins attached
to the sheath surface.

Page 6 of 41
 Figure 2: Baseboard Heating Unit

Figure 3: Sheathed Heating Element Example

Convective Fin

Sheathed
Heating
Element

Forced-air convection heaters use a fan to blow air across a sheathed or open-coil
heating element. The heating element is much smaller and hotter than a natural
convection heating element of similar wattage due to the moving air’s high heat transfer
rate. Consequently, forced-air convective heaters are more compact than baseboard
heaters. Forced-air heaters typically have louvered slots at the air input and exhaust areas
to direct the air into and from the heater. Figure 4 shows some typical forced-air
convection heater styles. Figure 5 is a picture of an open-coil heating element that has
been removed from a heater. This element is a nichrome alloy wire with a higher
resistance than copper conductors. This resistance causes the wire to heat throughout its
length. The wire is a live, uninsulated component.

Figure 4: Forced-Air Convection Heaters

Page 7 of 41
 Figure 5: Open-Coil Heating Element Subassembly

Radiant heaters emit infrared radiation that impinges directly on an object to

warm it instead of creating warm air. The heating element is typically hot enough to
visibly glow. This is necessary to create a temperature difference between the heating
element and the surroundings high enough to effect a sufficient heat transfer by radiation,
rather than convection. Because a line-of-sight geometry is required for heat transfer,
radiant heaters have a grid or mesh in front of the heating element rather than a set of
louvers, which would reduce the radiation of heat. Further, because the radiation pattern
from the heater tends to be dispersive, radiant heaters are typically installed in small
rooms, like bathrooms, or in areas where a consumer is likely to be nearby and able to
feel the radiation. Figure 6 shows typical radiant heaters.

Figure 6: Radiant Heater Designs

Page 8 of 41
 Without a failure of some type or a restriction of the airflow, an air-warming
heater can never heat nearby combustibles above the temperature of the exhaust air,
which is typically far below the combustion temperature of common household materials.
However, radiant heater element surfaces are often well above the combustion
temperature of many household materials. The line-of-sight construction requires that the
elements present a large surface area to the front of the heater. Therefore, these heaters
are capable of continuously adding thermal energy to the surface of an object until
equilibrium is reached, perhaps at a temperature above the object’s ignition point.

4. VOLUNTARY STANDARDS APPROACH TO HEATER EVALUATION

Two voluntary standards apply to fixed-position electric heaters. For baseboard heaters
(and cord-connected heaters whose width is more than 3 times its height), UL 1042
Electric Baseboard Heating Equipment is the applicable standard. For other fixed
electric heaters (and cord-connected heaters weighing more than 65 pounds), UL 2021
Fixed and Location-Dedicated Electric Room Heaters is the proper voluntary standard.
UL 1042 was last updated in 1994. UL 2021 underwent revision in 1997.

Both voluntary standards evaluate products similarly. A candidate heater for UL listing
undergoes a series of inspections and tests. Typically one, but up to three samples may
be submitted for assessment. All evaluations are performed on newly manufactured
samples. Unit-to-unit differences that occur due to normal manufacturing variations are
not rigorously addressed in the voluntary standards.

Some of the factors examined during an evaluation include checking for adequate spacing
between components with different electrical potentials, protecting users against
accidentally contacting live electrical parts, providing wiring strain relief, physically
supporting the heating elements adequately, and protecting metal parts against corrosion.
General requirements for switches, lampholders, and warning label texts are also
specified.

A variety of tests are performed on the submitted sample heaters to assess their
conformance to the voluntary standard. Measurements of insulation resistance, power
input, and leakage current are among the non-performance checks carried out during
evaluation. The performance-based tests fall into 2 areas, normal and abnormal operating
conditions. Normal operation performance tests involve energizing the unit-under-test
for 7 or 8 hours and assuring that the maximum temperature increase of the components
and surfaces are below the maximum allowed for each. Abnormal operation testing
involves energizing the heater while draped with test fabrics or blocked with a padded
wall of fabric and felt. Passing an abnormal operation test requires no emission of flame
or molten metal from the heater, and no generation of glowing embers or flames on the
test fabrics during the 7 to 8 hour test interval. In UL 2021, if the manufacturer attaches a
warning label, the heater is exempted from some of the abnormal operation tests.

Page 9 of 41
5. MARKET INFORMATION (See Appendix A)

A study of the fixed-position electric heater market shows an industry

characterized by stability. Little technological innovation, low sales growth, and few
new manufacturers typify this market. There are four main manufacturers responsible for
about 90 percent of the 2.5 million units sold in the United States annually. Baseboard
heaters are reported to account for about 80 percent of sales, with wall-insert, forced-air
heaters constituting another 10 percent, and all other types comprising the remainder.
One industry group estimated average heater life at 10 years, resulting in a base of about
25 million fixed-position electric heaters in service at any one time.

Manufacturers sell their heater production to wholesalers, who generally sell the
heaters to contractors. The contractors install the heaters in new construction or in
existing homes requiring supplemental heat. A typical residence using only fixed-position
electric heaters may contain 5 to 6 units, spread among the rooms. The heater users are
often not the original purchaser of the unit. There are a large number of fixed-position
heaters installed in multi-unit apartment buildings, which adds another intermediary
between the manufacturer and the ultimate user.

When the average costs of fire-related injury is estimated using the Injury Cost
Model, the societal costs of baseboard heater fires is about $16.50, or two-thirds of the
average cost of a new unit. Similar calculations on fires associated with wall units
resulted in an estimated societal cost of about $65.50. This value is almost one-third
higher than the average cost of a heater of this type.

6. HAZARD ANALYSIS (See Appendix B)

Fixed-position electric heater in-depth investigations (IDIs) were assigned from

October 1999 through May 2001 using the Investigative Guideline Appendix 120 –
Fixed-Position Electric Heaters and data record sheet.

Data collection outreach efforts were conducted with the assistance of the Office
of Field Operations and various field staff. The Office of Compliance (EXC) assigned
forty-eight of the IDIs included in this analysis. Although the assignments were made
during the data collection period, a few were based on incidents that occurred prior to
1999. An informational article was placed in the field feedback memo compiled by the
Division of Hazard and Injury Data Systems (EPDS) and a conference call was held
between the project engineer and field supervisors to introduce the project. An appeal to
fire fighters and insurance investigators to provide fixed heater incidents and samples was
submitted to the International Association of Arson Investigators (IAAI) monthly
publication. The field staff also circulated this request to regional and local fire
community publications. Both headquarters and field staff attended regional IAAI
meetings to advertise CPSC data collection efforts.

Page 10 of 41
 Out of 212 investigations assigned, 108 were completed and eligible for inclusion
in the fixed-position electric heater project. The investigations included 45 incidents with
fan-forced heaters, 40 incidents with baseboard heaters, 17 with radiant heaters, and 6 of
unknown type. Twenty-four of the 45 fan-forced heater incidents did not involve fire
scenarios. Three of the baseboard incidents did not involve fire scenarios.

Twenty-three incident heater samples were received from the in-scope IDIs. Of
these incident samples, 12 involved wall-insert units from a single manufacturer, and two
involved baseboard heaters by the same manufacturer. Any conclusions drawn from the
recovered samples should take into consideration that about three-fifths of the heater
samples were made by the same manufacturer.

The IDIs reflected the geographical distribution of fixed-position electric heaters

being installed in areas that experience mild winters or have inexpensive electric rates.
Most western IDIs took place in the Pacific Northwest, while most eastern IDIs took
place in the southeastern states. Within the home, the heaters were installed in living
areas, bedrooms, bathrooms, and storage areas. Consumers often turned off or operated
at the lowest setting heaters installed in storage areas. Over half of the IDIs involved
tenants as the user of the heater. Residence owners who did not install the heater
represented another 12 percent of users. In half of the IDIs, the consumers were not
involved with the installation of the heater. The installer was often identified as a
professional electrician, building contractor, or maintenance worker.

Most fires reported in the IDIs were attributed to the ignition of combustibles
outside, rather than inside, the heater. Towels, clothing, and bedding (including
mattresses) were most often cited as the objects ignited. Fire officials considered the
heaters to be “properly operating electrical equipment” with combustibles placed too
close by consumers. However, the fires usually damaged the heaters so severely as to
make inspection of the unit futile. Thus, the heaters involved in incidents were rarely
examined by fire officials for internal failures.

Some IDIs cited dust accumulation in the heater as a contributing factor to fires.
In half of the IDIs, it could not be determined whether the heater had ever been cleaned.
In IDIs where the cleaning history was known, twice as many heaters had never been
cleaned as had been cleaned at least once. Consumers rarely possessed instruction
manuals for their heaters, which contain the procedures for cleaning and maintenance.
According to evaluations by Human Factors, some manuals indicate that it is the user’s
responsibility to clean (typically by vacuuming) any accumulated dust or lint from inside
the heater on a regular basis. Without these instructions, the consumer would not know
the need for, the procedures to, or the recommended frequency of, cleaning the interior of
the heater, or whether the heater is intended to be cleaned.

Understanding the hazards posed by abnormal operation was difficult for users.
Consumer action upon noticing that a hazard indicator lamp (a requirement in the
voluntary standard UL 2021 since 1992) was lit was not reported in the IDIs. Abnormal
operation was described as more overt actions on the part of the heater such as excessive

Page 11 of 41
heat output, no heat, rapid cycling of the thermostat, and problems with the heater
controls. This implies that the consumers did not know what situations constituted
abnormal operation, did not understand the implications of abnormal operation, or did not
know what actions to take in the event of abnormal operation.

In 13 percent of the IDIs, consumers mistakenly thought that the fixed heaters
were turned off or disconnected from their power source at the time of the incident. In
more than half of the IDIs where this was determined, the controlling thermostat did not
have a positive “off” position. Four IDIs reported consumers turning the thermostat to its
minimum setting and expecting the heater to be disconnected from electric power. Three
of these incidents resulted in fires when the ambient temperature in the rooms dropped,
the heaters activated and nearby combustibles were ignited.

Baseboard Heaters

The average life of the units in the 40 baseboard heater IDIs was 18 years. With
no moving parts, these heaters tend to remain installed and in operation for relatively
long periods of time.

Because of the length of wall space they typically covered, as well as their
proximity to the floor, consumers often placed beds and furniture up against baseboard
heaters. By doing so, consumers acted as though they perceived the heaters as safe
heating sources. Yet, 28 of baseboard heater fires were attributed to “combustibles too
close” to the heater. The printed warnings on the heater stating that all furniture,
materials, and other items should not be placed within 3 feet of the heaters may be
impractical, especially in small areas like storerooms or apartments.

The center of a baseboard heater is the location where the highest temperatures
are found. The ends of the heater are where the electrical connections to the branch
wiring are made. In half of the baseboard IDIs, it was unknown whether ignition or
failure occurred near the center or far end of the baseboard heater. Twenty of the
baseboard heater IDIs where this information was known indicated that ignition or failure
occurred near the far ends of the heater. Of the 12 baseboard heater IDIs that reported
internal failures, three involved melted sheathed heating elements. Other IDIs
documented problems with electrical connectors, failed temperature limiting controls,
and burned off or degraded wire insulation.

Many of the fire incidents occurred when the heaters were energized for an
extended period or when the heater was initially energized after a long (sometimes years)
period of inactivity. The supposition is that various failure mechanisms were at work that
resulted in the incidents documented in the IDIs.

Forced-air Heaters

Forced-air convection heaters involve higher internal and exhaust air temperatures
than do baseboard heaters. Their small size, relative to baseboard heaters, means that
more electrical power per unit volume is being converted to heat. Heaters documented in

Page 12 of 41
the 45 forced-air convective heater IDIs had an average age of 6 years, with half of the
units being less than 3 years old.

The use of a fan in a forced-air heater results in a higher rate of dust

accumulation. Cleaning, however, was still rare. Sixteen respondents did not know if the
heater was ever cleaned. Eighteen of the IDIs where the cleaning frequency was known
involved heaters that were never cleaned. One consumer was able to remove the
faceplate to the heater but was unable to clean the rear due to the obstructions caused by
the internal components.

Similar to baseboard heaters, about two-thirds of respondents who could provide

information about the heater controls said that the thermostat did not have a positive “off”
position. One non-fire incident occurred when a heater suddenly emitted smoke and
displayed a glowing red heating element, while the fan was not operating. Since the
heater had been connected to a pre-existing remote thermostat with no positive “off”
position at the time of installation, the consumer was forced to disconnect power at the
circuit breaker to de-energize the heater.

Heaters listed to the UL 2021 voluntary standard are required to have an alarm
(visual lamp or audible buzzer) if the temperature limiting control is an automatic (as
opposed to manual) reset type. If the temperature limiting control activates, the alarm is
expected to activate in order to notify the user that an abnormal condition exists. Forced-
air heaters were the only types of fixed position electric heaters documented in the IDIs
that included hazard lamps in their designs. Even though the lamp was illuminated, users
usually did not know what the lit lamp meant (an abnormal operating condition), if it was
observed at all. No consumers reported seeing an indicator light as being what first
alerted them in the incidents. Rather, more drastic effects such as sparks, loud noises, or
smoke from the heater most often alerted the users to the hazardous conditions.

The internal failures identified in fan-forced heater fires and potential fires
included problems with wire insulation and electrical connections, failed heating
elements, failed thermal limiting devices and fan problems. All the models were listed as
meeting the current voluntary standard, UL 2021.

Radiant Heaters

The average age of the 17 radiant heaters investigated was 26 years old, the
highest among the heater types. Radiant heaters were more often than not reported to
have positive “off” positions as part of their temperature controls. Three IDIs involved
radiant heater fires where the consumers mistakenly believed the heaters had been
disconnected.

Of the 10 heaters that had known cleaning histories, nine had heating elements
that had never been cleaned. Thirteen IDIs involved consumers who were tenants. The
same number of IDIs involved radiant heaters that were installed as bathroom heaters.
Bathroom installation of radiant heaters puts high temperature devices in rooms with

Page 13 of 41
small clearances and often very near an abundance of combustible materials such as
towels, bathrobes, and paper products.

In addition to fires attributed to combustibles placed too close to the heater, some
fires were blamed on internal failures such as electrical overloading and overheating and
burnt wiring igniting dust.

Summary

Of the 102 (out of 108) IDIs documenting actual and potential fires in which the
heater type was known, baseboard heaters represented 39 percent, forced-air units
represented 44 percent, and radiant heaters represented 17 percent. Considering that
baseboard heaters are about 8 times more numerous in homes than forced-air units
(according to economic data), this data implies a risk difference between these two types
of heaters based on our convenience sample of IDIs. Radiant heaters also appear to be
involved in fires at a rate higher than their relative population in homes.

7. PRODUCT SAFETY ASSESSMENTS & RECALLS

A review of the Product Safety Assessments (PSAs) performed by the CPSC

staff on electric heaters resulted in 47 reports from 1983 to the present. Of these, 9
reports dealt with baseboard heaters, with almost all the remaining reports on wall-insert
forced-air convective heaters. The PSAs dealing with baseboard heaters reported most
often damaged wiring and connectors. The wall-insert heater problem reports included
failed temperature limiting controls, stalled fans leading to overheating conditions, poor
electrical connections resulting in overheating, and sudden failures that emitted sparks,
molten metal, or flames. The failures noted in the PSA reports are similar to the failure
modes reported in the IDIs.

Two PSA reports involved forced-air heaters whose fans stopped rotating. The
heating element temperature increased on each heater to the point that the temperature
limiting control (TLC) activated and cut electric power to the heating elements. Once
cooled, the automatically-resetting TLC re-energized the elements and continued to cycle
without consumer interaction or awareness. This created hot spots inside the heater that
melted the wiring insulation. Once melted, the wires short-circuited to the grounded
heater interior (“heat box”) frame and, in one case, emitted glowing embers into the
room. Follow-up testing with other models from the same manufacturer showed similar
hot spots and melted insulation. The incident heaters and the tested heaters burned their
warning labels before the short-circuit occurred.

Two product recalls were instituted on fixed-position electric heaters in recent

years. In 1997, several models were recalled to replace the plastic-body Temperature
Limiting Device. The plastic-body device would crack, emit sparks, and fail closed
during heater use. A ceramic-body replacement was substituted to resist the heater’s
high internal temperatures. In 2000, another recall program was announced. Over 1.9

Page 14 of 41
million heaters were recalled due to defects that could lead to overheating and fire.
Among the problems experienced with the recalled heaters were failed sheathed heating
elements (the nichrome heating wire short-circuited to the grounded sheath), poor crimp
connections, and an excessive accumulation of dust, which was ignited by the heating
element and emitted into the room. Emission of flaming or molten particles is forbidden
for products listed by Underwriters Laboratories.

8. LABORATORY STUDIES (See Appendix C)

A number of experiments were executed to test the following hypotheses:

• The temperatures achieved anywhere inside or on the surface of a baseboard
heater, when subjected to abnormal conditions, are not high enough to lead to
ignition of common household fabrics.
• Operation of an electric heater under normal and abnormal conditions listed in
UL 2021 and UL 1042 may result in conditions that can damage internal
components. UL evaluation of a heater does not consider this.
• Radiant heater operation is evaluated in UL 2021 with a drape of cheesecloth
plus duck cloth (the Curtain Drape Test). The properties of terrycloth are
sufficiently different from cheesecloth plus duck that a radiant heater that
passes the Curtain Drape Test of UL 2021 can ignite terrycloth when the
terrycloth is draped over the heater.

A separate exploratory experiment was performed to determine if it was possible

to see a change in operation of a forced-air heater after a short-term exposure to airborne
dust. The intent of this test was to show that it is possible to evaluate the dust-trapping
characteristics of a particular model heater as part of a product evaluation by a testing
laboratory.

In selecting and examining the heaters for testing, observations were made with
respect to poor grounding arrangements. Several designs in both baseboard and wall-
insert heaters had unreliable grounding connections. Some designs relied on mating
painted surfaces as a means of grounding. One heater had a wire inserted into a punched
sheet metal slot that had been painted as a means of grounding the frame. Often, a single
screw thread with no locking mechanism or hardware or other means of resisting
vibration-induced loosening was the sole means of establishing a low impedance ground.
With these designs, normal manufacturing variations in parts, clearances, and assembly
may lead to missing, intermittent or high impedance ground connections on any given
heater unit.

Page 15 of 41
 Baseboard Heaters

The baseboard heaters under test were draped, partially covered, or had the space
between the heating element fins and the exhaust vent stuffed with cotton cloth. During
some tests, the temperature limiting control (TLC) was bypassed to simulate a component
failure. The heater was mounted to a wall and instrumented with thermocouples at
various air inlet and exhaust areas, heating element and fin locations, and wiring routes.

In all of the tests, including those tests with the TLC bypassed, the temperature of
the cotton cloth never reached temperatures near its ignition point (about 360 °C).
However, some tests resulted in temperatures above the maximum rated temperature of
the wiring insulation. The temperature rise was not more than 10 °C over the rated
temperature for the wire. This would not manifest itself into a failure during the 7 to 8
hours of a UL test duration but could have long-term effects on the insulation integrity of
the internal wiring of a baseboard heater and lead to a shock or fire hazard.

Forced-air Heaters

Similar to baseboard heater results, temperatures above the wiring insulation’s

maximum rated value were achieved in several circumstances. On one heater, the
“thermal momentum,” or transient internal temperature rise when power is removed,
caused internal temperatures to overshoot the insulation’s rating every time the
thermostat cycled. This condition occurred during normal operation with no blockages,
draping, etc. During the execution of the Stalled Fan Test of UL 2021, the heaters under
test cycled on their auto-reset TLCs. During a part of each cycle, temperatures on the
internal wiring were measured above the insulation’s maximum rated value.

A home’s branch circuit wiring must enter the wall can (the metal box attached to
the wall) to connect to heater internal wiring. Testing showed that the branch wiring was
also subjected to high temperatures. A test heater was installed on an open wooden
frame, a condition that allows maximum convective cooling on the wall can. When a
barrier was placed nine inches from the exhaust of the forced-air heater, the TLC did not
activate. However, the temperatures of some parts of the uninsulated wall can rose to a
level over 60 degrees Celsius above 60 °C, a common temperature rating of household
branch wiring. In this state, the heater would appear to be operating normally to a
consumer. Installing the heater in a wall, especially an insulated wall, would result in
wall can temperatures well above those measured using the open wooden frame.

A potential failure mode exists when wiring insulation is operated above its
maximum rated value. If the insulation softens, the internal wire may creep through the
insulation over an extended period of time and create a potential shock hazard. Further,
polyvinyl chloride insulated wiring that is operated above its maximum rated temperature
may develop cracks over time2.

2
Donald Fink and H. Wayne Beaty, ed., Standard Handbook for Electrical Engineers, Thirteenth Edition,
McGraw-Hill, inc., 1993, page 4-153.

Page 16 of 41
 Radiant Heaters

Two radiant heater styles were tested, one with a sheathed heating element, and
one with an open-coil heating element. Both heaters were tested with terrycloth draping
and a combination of cotton duck cloth plus cheesecloth as a simulation of a curtain, as
specified in the Curtain Drape Test of UL 2021.

Testing of the sheathed element heater did not result in emission of molten metal,
flames, or glowing embers from the heater or either type of draping material. The open-
coil heating element heater quickly ignited whatever material was draped over it. When
measured with a digital flux meter, the highest measured heat flux at the grill was 0.64
W/cm2. Prior CPSC testing achieved ignition of cotton batting with a flux of 0.54
(W/cm2)3.

Dust Testing

For the exploratory test on dust accumulation, two forced-air heaters were
installed in a sealed box. The heating elements were disconnected, leaving the heaters’
fans operational. The heater fans were operated for two hours while a combination of
ISO test dust4 and ground cotton lint was stirred into the chamber air. After the exposure
period, each heater’s heating element was reconnected. The heaters were operated, and
temperatures measured. Both heaters showed markedly different operation from their
pre-dusted state, including repeated cycling of the TLC, unstable exhaust air
temperatures, and charring of the internal dust.

Testing Summary
In summary, the laboratory testing showed that baseboard heaters, even when the
TLC was bypassed, did not generate temperatures capable of ignition of combustibles,
but did result in temperatures capable of damaging the internal wiring of the heater.
Forced-air heater testing showed that abnormal operating conditions, even for a short
time, were capable of heating the internal wiring insulation above its maximum rated
value. In some cases, the branch wiring insulation was overheated. Testing on radiant
heaters did not support the hypothesis that the thermal response of terrycloth is different
from curtain material when draped over a heater. The dust testing showed that a short
exposure time to a dusty ambient environment could result in easily observable
operational changes in a heater, and testing can be used as a means of evaluating whether
the heater design might lead to hazardous conditions when in use.

The cycle time of the automatically-resetting TLC was used to calculate how long
it would take for a heater operating under abnormal conditions to reach the 100,000 cycle
tested life of the TLC. Using measured TLC cycle times and an assumed 152-day
heating season, values ranging from 1.6 to 6.2 years were computed. Therefore,
operation of the temperature limiting control during long-term use will exceed the tested
life of the control long before the expected useful life of the heater is reached.

3
Portable Electric Heaters, Engineering Project Report, Edward W. Krawiec, September, 1987.
4
ISO Fine Test Dust 12103-1, A2

Page 17 of 41
9. FAILURE MODES & EFFECTS ANALYSIS (FMEA)
(See Appendix D)

An analytical study was performed on a generic forced-air heater design to assess

whether identified failure modes would be detected by evaluating a sample according to
the requirements in UL 2021, Fixed and Location-Dedicated Electric Room Heaters. For
each single-point failure named, the effects of that failure were determined. In the event
that a particular failure mode would not likely be identified, suggestions were developed
to increase the fault coverage of the evaluation. The study uncovered the following:
• Some short-duration continuous and abnormal tests may affect the dielectric
resistance of the wiring insulation after the Dielectric Voltage-Withstand Test
and Overvoltage Tests have been completed. Short-term abnormal operation
may result in an undetected shock hazard.
• Fault coverage is missing for some identified failure modes. The effects of
component aging and dust collection are not considered.
• Safety requirements for cord-connected (location-dedicated) heaters include a
requirement for use and care instructions, and carton requirements. Glass-
paneled heaters are required to withstand an impact on their front surface.
These requirements are not extended to other fixed-position heater types.
• Problems that take longer than the test time to manifest a failure may not be
detected.

The Failure Modes and Effects Analysis showed that the order and completeness
of evaluation under UL 2021 can affect the fault coverage of a heater under test. It is
possible for a unit under evaluation by the standard to pass or fail depending on how the
tests are performed and in what order. Since short periods of abnormal operation can be
expected in a consumer installation, these short periods should not result in hazardous
conditions for consumers.

10. HUMAN FACTORS EVALUATION (See Appendix E)

The Division of Human Factors staff conducted a review of UL 2021 with respect
to human interface issues. In addition to the review, two Product Safety Assessment
Reports were completed, evaluating the human interface with specific heater models.

The review and the PSAs uncovered instances of incomplete, contradictory,

confusing, and ineffective instructions and warnings in the labeling and documentation of
the products. These instances were found in both the installation and operation
instructions. Installation and use instructions were intermingled, even though the
installer and user are different persons. In one case, the warning not to remove the grill
of the heater was located on a label behind the grill. In another instance, the instructions
stated that the grill was to be removed for cleaning and that there were no user-
serviceable parts inside the heater. In one instance, consumers were instructed to
lubricate the motor elements on older style motors, while newer style motors needed no

Page 18 of 41
lubrication. The instructions failed to provide any guidance to the consumer on how to
distinguish the older and newer style motors.

Other instructions defined hazard lamp “flashing” as a cycle with a minutes-long

period. Consumers were to take different actions if the lamp “flashed” rather than
remained constantly lit. In this situation, such a determination would take several
minutes of examination to discriminate a “flash” from steady illumination.

11. TECHNICAL EVALUATION OF CRIMP CONNECTIONS

(See Appendix F)

Overheating failures of internal crimp wire terminations of fixed-position electric

heaters have been noted in many field samples. A contract was awarded to an
independent technical expert for the evaluation and analysis of electrical crimp
connectors in fixed-position heaters. The technical expert examined 71 power-
conducting terminals from 10 new heater samples. The samples were evaluated visually,
through microscopic examination and by measuring the connection resistance.

The results of the examinations showed several instances of inadequate

mechanical compression and excessive spring-back (the undesired opening up of a
crimped down connector due to the elastic properties of the crimp metal) of the crimp
connections. Incomplete compression of the wires in the crimp terminals was shown.
These factors result in inadequate metal-to-metal contact and subsequent high connection
resistance. Excessive spring-back and incomplete compression do not always result in a
loose mechanical connection even though the connection resistance is high. Therefore,
mechanical tests on sample connections do not adequately evaluate the connection
resistance. A more than 2 orders of magnitude difference was measured in the
connection resistance of the heaters evaluated. This indicates that present connection
evaluation methods allow for high variation in actual connection resistance.

The results indicate that some field failures that are occurring may be attributable
to deficiencies that exist in the heater terminations when new. Incorporation of
conventional tests during heater manufacturing and more stringent acceptance standards
for the various types of crimp terminations were suggested as a means of addressing the
deficiencies.

Page 19 of 41
12. INDEPENDENT INVESTIGATORS

As a result of the data collection outreach efforts by CPSC field staff, seven
independent investigator technical reports or contacts were received. These reports
involved the failure mode determination of fixed-position electric heaters associated with
fire incidents. The investigators identified the following failure modes in the products
they examined:
• Two cases where a degraded electrical terminal broke and arced to the
grounded case.
• Impurities in the sheathed heating element packing created a conductive path
between the heater wire and the grounded sheath.
• Two cases of lint build-up and subsequent ignition by an open coil heating
element.
• Installation of the heater upside-down (placing safety devices in the wrong
locations relative to the heating element and the airflow).
• Sparks emanating from a heater junction box started a fire.
• Overheated heating element scorching nearby combustibles.

One unsolicited report listed several suggestions for safety improvements. In

large measure, the suggested improvements by the outside investigator mirrored the
project recommendations.

Page 20 of 41
13. RECOMMENDATIONS TO THE VOLUNTARY STANDARDS

Based on the knowledge gained from the previous studies and examinations
presented in this paper, CPSC staff presents the following recommendations to improve
the applicable voluntary standards. The proposed changes are grouped by area.

A. UL 1042, Electric Baseboard Heating Equipment

TEMPERATURE LIMITING CONTROLS AND CONTROL CIRCUITS

1: Add to Section 24, Automatic Controls and Control Circuits: All devices shall
incorporate a temperature limiting control (TLC) that disconnects power from the
heating elements.
Rationale: The abnormal operation test conditions of UL 1042 Section 34 only
approximate conditions of actual use and cannot represent all the
reasonably expected abnormal operating conditions. Temperature limiting
controls should be included in heater designs to protect against conditions
that can be expected during consumer use. Testing on heater samples
showed very high temperatures with a bypassed temperature limiting
control (TLC). Previous recall actions showed that failed TLCs can lead
to fires. Thus, the presence of a working TLC is important in reducing fire
hazards. The Failure Modes & Effects Analysis also indicated that many
possible abnormal operation conditions are not assessed in a 7-hour test.
Without a temperature limiting control, a heater has no protection against
short-term unforeseen conditions or any other circumstance that results in
overheating.

2: Add to Section 24: The operation of a temperature limiting control shall

disconnect all ungrounded conductors from the unit when activated. The
requirements of Section 24 shall apply to all heating element types, including
sheathed heating elements.
Rationale: Abnormal overheating conditions can result in the activation of
temperature limiting devices. Some abnormal conditions involve low
impedance circumstances that can lead to high currents (but not high
enough to activate a circuit breaker) and localized hot spots. Hot spots
could result in insulation breakdown or ignition of combustibles. For 220
VAC heaters, disconnecting a single ungrounded conductor may not
remove power from the low impedance connection, and may not address
the hazard. The Failure Modes & Effects Analysis (Appendix D) predicts
failure modes that don’t immediately trip circuit breakers and involve
excessive current and power that may lead to a fire. Sheathed elements are
not now required to have a TLC that disconnects all ungrounded
conductors. Yet, evaluation of field heater samples and IDI reports
showed sheathed heating elements that failed other than at the ends.
Sections of heaters wired for 220 VAC may remain energized under

Page 21 of 41
 conditions of mid-element short circuits even if the TLC activates.
Heaters with sheathed heating elements should have this fault condition
covered. The style of the heating element is not a sufficient reason to
leave electrical power connected to a heater under detected
overtemperature conditions. All power should be removed from the heater
when the TLC activates, regardless of heating element type.

3: Add to Section 24: All auxiliary control devices (thermostat or combination

thermostat and control switch) shall have a position that disconnects all
ungrounded conductors of the supply circuit, regardless of heating element type or
markings on the control.
Rationale: Based upon information provided in the IDIs, consumers assume that the
lowest position of the switch is synonymous with disconnecting electrical
power from the heater. If cleaning or other maintenance is required, and
the unit has not been de-energized, the user may be exposed to live parts,
especially for heaters connected to 220 VAC. Evaluation of incident data
indicates that users believe power has been removed from the heater if the
control knob is at its lowest setting, regardless of the markings on the
knob. Acting on that belief can expose users to a shock hazard (Section
5). Also, heaters at their lowest setting (not disconnected from all
ungrounded conductors) may unexpectedly activate in response to a low
ambient temperature. Consumers expecting the heater to remain cold have
placed combustibles near the “off” heaters. Subsequent activation resulted
in a fire. Consumers should have assurance that heaters whose controls
are turned fully down will be and stay de-energized.

WIRING
4: An electric baseboard heater shall be constructed to reduce the risk of electric
shock or fire when the appliance is connected to branch circuit power by the use
of an integral Arc Fault Circuit Interrupter (AFCI), or connection to another
device meeting the requirements of Standard for Arc Fault Circuit Interrupters,
UL 1699.
Rationale: Epidemiological data and laboratory studies indicate that an electrical fault
can occur to render a baseboard heater capable of initiating a fire.
Analysis of incident data shows a regular number of baseboard heater fires
with the ignition area at the wiring ends of the heater rather than the
middle of the heating element, which is the hottest location. Laboratory
studies show that baseboard heater temperatures are below the ignition
point of combustibles even under extreme conditions when there is no
electrical fault. The same studies show that short periods of abnormal
operation can seriously degrade the wiring insulation and lead to arcing
faults. Integrating series and parallel arc-fault detection can prevent an
arcing condition resulting in a fire hazard.

Page 22 of 41
5: Add to Section 13: No normal or abnormal operation test shall result in conditions
where the heater wiring reaches temperatures above the maximum rating for the
wiring’s insulation.
Rationale: Degradation of the wiring insulation can lead to shock and fire hazards.
Laboratory experimentation has demonstrated that abnormal conditions
can result in temperatures exceeding the insulation’s maximum
temperature rating and subsequent degradation or melting. Two field
samples failed due to melted wiring insulation. Over a long time, the
wiring may flow through softened insulation and create a shock or fire
hazard. Polyvinyl Chloride (PVC) insulation can develop cracks when
exposed to elevated temperatures for a period of time. The insulation is
necessary to protect the consumer. Operation of the heater normally for a
long time, or abnormally for a short time should not degrade the insulation
and lessen its insulating properties.

6: Add to Section 26, Grounding: “Any surface intended for a ground connection
shall be electrically conductive at the connection area. For example, the area
around a hole through which a grounding screw is inserted shall be conductive.
The threads of the screw shall not be the only source of grounding contact. All
grounding connections shall be made by a positive means, screws, clamps, etc.
Tabs or wires in slots, incidental contact, flat surfaces pushed together, or similar
means are not acceptable for grounding connections.” Add that all grounding (or
earthing) connections shall be compliant with UL 60335-1, Safety of Household
and Similar Electrical Appliances, Part 1: General Requirements.
Rationale: Continuity to ground is essential to shock protection. Heaters should be
designed with features that assure adequate grounding with a high degree
of confidence and repeatability from unit to unit. Some heater designs
show reliance on installers breaking insulating barriers with no
instructions to assure compliance. Other designs showed unreliable
grounding connections. The design of the grounding scheme in a heater
should be one that provides a very high probability of adequate grounding
in every unit manufactured.

Page 23 of 41
TESTING
7: Include a Manufacturing Test to be performed during assembly on a sample basis
to evaluate the electrical integrity of the mechanically assembled wiring
connections. Such testing shall include:
• Connection Resistance, initial, and maximum increases during accelerated life
testing of representative samples
• Manufacturing quality control systems
• Different ratings for power conductors and non-power conductors.
Rationale: Failed wiring connections have been attributed to many fire incidents. To
reduce the frequency of poor quality in electrical connections, the
variability associated with today’s manufacturing processes must be
reduced. Technical Studies performed under contract by the CPSC
(Section 10 and Appendix H) indicate problems with wiring connectors
exist, and can lead to overheating conditions. The Failure Modes &
Effects Analysis studies show that manufacturing problems are not
addressed by UL 1042 evaluation. Multiple field samples showed
corroded and failed crimp connectors. Assurance is needed that units in
manufacture are being assembled with good quality connections. Testing
during assembly can be used to monitor the quality of the electrical
connectors and reduce the variability of the connector manufacturing
process to a point where there is a high probability of good internal
electrical connections in every assembly.

8: In Section 34 (Abnormal Operation Tests), examine the heater for impending

failure modes, such as melted wiring insulation, reduction of the spacing between
components, etc., after completion of the tests. For all tests, run the tests for all 7
or 8 hours to see if these secondary effects appear. Interpret Section 13 (Internal
Wiring) as applying to normal and abnormal operation.
Rationale: As approximations of events that can occur during years of use, the
abnormal tests may not result in a failure during their hours-long
operation. However, there may be evidence of incipient internal failures
that can occur in field units over a longer term. This evidence may
indicate a marginal condition that could lead to a hazard. Testing on
samples showed potential failures that take longer than 7 hours to manifest
as fire, sparks, etc., i.e. “failure result.” Field incidents have occurred
where operation over a long time resulted in a failure. Field samples
showed that even severe failures can still take days to result in a fire.
However, evidence of an impending hazard is apparent inside the heater
much sooner. Tested samples should be examined to determine if
abnormal operation could result in a potential hazard to consumers.

Page 24 of 41
9: Run the Dielectric Voltage-Withstand Test (Section 58) after the operational tests.
Run the Overvoltage Test (Section 35) after the operational tests. Connect a fuse
(of a few amperes) through the ground conductor for each test to detect any short-
term currents less than the amount required to activate a circuit breaker.
Rationale: Undetected potential failures may affect the electrical insulation properties,
create short-circuit or leakage paths to ground, or change the total impedance
of the heater. The Failure Modes & Effects Analysis (Section 8) results
indicate that testing for one fault condition may expose other faults. The
stress of an abnormal test may weaken components other than those tested.
Short-term abnormal operation of consumer units should be expected. The
heater should be able to withstand such short-term operation without
developing a potential consumer hazard. Executing the Dielectric Voltage-
Withstand and Overvoltage Tests after other tests is a means of determining
whether the testing unduly degraded the electrical integrity of the sample.

10: Apply the requirements of Impact (Section 47) to all heater designs.
Rationale: UL 1042 Section 47, Impact, applies only to heaters with glass fronts.
Thin-walled metal fronts are also susceptible to deforming upon impact.
If the front grill of a heater contacts a heating element, a conductive path
could be established through the grill. The Failure Modes & Effects
Analysis (Section 8) predicts that physical impact on a sheathed heating
element can result in a shock or overheating hazard if the conductor wire
in the element establishes a path to ground. Sheathed heating element
construction is susceptible to failures caused by bending. Heater designs
should be capable of withstanding expected impacts without developing a
shock or burn hazard.

11: Include in the standard: Any polymeric material within 3 mm. of the live parts of
a power connector shall have a minimum Glow-Wire Ignitability Temperature
(GWIT) and Glow-Wire Flammability Temperature (GWFT) of 750 degrees C in
accordance with IEC 60695-2-1/3 and IEC 60695-2-1/2 respectively, or comply
with the Glow-Wire End-Product Test (GWEPT) as described in UL 746C.
Rationale: This recommendation is to minimize the effects of connector failures
when they occur. There is an IEC-UL initiative to address the
consequences of failed connectors and harmonize standards. This
proposal has been approved for other products.

Page 25 of 41
LABELING & INSTRUCTIONS
12: Add to Section 54: Require that all warning labels be formatted in accordance
with ANSI Standard Z535.4 for Product Safety Signs and Labels.
Rationale: ANSI Z535.4 was developed for the following reasons: 1) to establish
uniform and consistent visual layouts for labels across all categories of
products 2) to minimize proliferation of label designs and 3) to achieve
application of a national uniform system for recognition of potential
personal injury hazards.5 To promote these objectives, all warning labels
should adhere to these guidelines and principles to make safety
information more recognizable and noticeable to consumers. Some
warning labels incorporated a mixture of text that included clearance
specifications, French translations, and other English text. Warning label
research indicates that such safety messages are likely to be missed
because of competing text. The warnings should be segregated from the
rest of the text and should conform to ANSI Z535.4 guidelines to make the
label conspicuous and recognizable.

13: Add to Section 54: Require all labels to be heat resistant or located where they
will not be subjected to excessive heat during periods of foreseeable abnormal
operation. Require all labels to withstand all abnormal tests while remaining
readable. Add to Section 54: “The marking shall, unless otherwise indicated, be
permanently applied by means such as:
a) etched, molded, die-stamped, or paint-stenciled on the enclosure,
b) stamped or etched on metal, or
c) indelibly stamped lettering on pressure-sensitive labels secured by
adhesive.
Pressure-sensitive label secured by adhesive shall comply with UL 969, Standard
for Marking and Labeling Systems.
Rationale: Foreseeable use of a heater includes temporary periods of abnormal
operation. When the abnormal condition is corrected, the heater is still
usable and in use. Warnings are still valid and should be readable on the
labels, especially for future users of the heater. UL 1278, Movable and
Wall- or Ceiling-Hung Electric Room Heaters contains the language
regarding the permanence of marking. Field incidents and laboratory
testing resulted in unreadable warning labels after very short periods of
operation at abnormal conditions (Section 6). If a user corrects a
temporary abnormal condition the label may no longer exist to warn other
users.

5
ANSI Z535.4-1998 (1998). Product Safety Signs and Labels. National Electrical Manufacturers
Association: Rosslyn, VA.

Page 26 of 41
14: Add to Section 54: Require that instructions on the product that are directed
toward the user be accessible and legible and able to be viewed without
disassembling the product.
Rationale: Critical warning labels should be placed in proximity to the potential
hazard and in plain view to the user. An analysis of an in-wall heater
found that labeling on the face of the heat box did not provide adequate
warning to users because it was concealed behind the heater grill
(Appendix E). Removal of the grill exposes users to a potential hazard
from live electrical components.

15: Add to Section 55: Require separate, complete, instructions for the installer and
the user.
Rationale: Data indicates that heaters are usually installed by professionals, who are
not the end users of the product, and operated by consumers. Each of these
groups requires a different set of instructions tailored to the particular
performance demands of their tasks. Installers need technical information
and consumers need use and care instructions. The instructions relating to
each of these different tasks should be located in the product
documentation in such a way that the individual groups can readily
recognize the sections pertaining to their specific needs.

OTHER SECTIONS
16: In Section 40.1, Stalled Fan Test – add “no risk of electric shock” in addition to
no risk of fire.
Rationale: Stalling a fan may result in temperatures high enough to degrade
insulation and not immediately result in a fire. A shock hazard may be
created instead. Field incident samples and testing for the Office of
Compliance showed that a stalled fan condition could melt wiring
insulation and create a conductive path between the power conductors and
the heater frame.

17: In UL 1042 Section 10.1.1, replace “... accordance with National Electrical Code,
ANSI/NFPA 70-1996, would ...” with “... accordance with the current edition of
the National Electric Code, ANSI/NFPA 70, would ...” (also in UL 1042, Sections
10.2.1, 10.2.6, 10.2.9, 10.2.13, 19.3, 19.4, 19.7, 19.8)
Rationale: ANSI/NFPA 70 keeps changing. Referring to the latest edition as a
typical practice will keep the latest version as the current requirement.

Page 27 of 41
B. UL 2021, Fixed and Location-Dedicated Electric Room
Heaters
TEMPERATURE LIMITING CONTROLS (TLCs) AND CONTROL CIRCUITS
1: Add to Section 25, Temperature Limiting Means: All devices shall incorporate a
temperature limiting control that disconnects power from the heating elements.
Rationale: The use of a TLC is allowed to help the heater pass the abnormal
operation test conditions of Section 42. These tests only approximate
actual use and cannot cover all failure modes or abnormal operating
conditions. Temperature-limiting controls should be included in heater
designs to protect against conditions that are not and can not be tested.
Testing on heater samples showed very high temperatures are achieved
with a bypassed TLC. The Failure Modes & Effects Analysis (FMEA)
indicated that all possible abnormal operation conditions are not assessed
in a 7-hour test. Field samples with failed (shorted) TLCs were involved
in fire incidents. The temperature limiting control is the only protection
available against unpredictable operating conditions. Every heater should
have a means of reacting safely to overheating conditions regardless of
how a sample unit performs on a specific test.

2: Add to Section 25: No temperature limiting control intended for operation during
abnormal operation shall operate during normal operation. This would parallel
the requirement in Section 24.7 in UL 1042.
Rationale: Heaters are in use for many years, on average. If the temperature limiting
control were to operate during normal use, it is likely if not a certainty,
that the design life of the control would be exceeded. Also, operation of a
temperature limiting control during normal use means the loss of
thermostatic control by the user. Calculations using observed TLC
cycling data showed that the 100,000 cycle life of a TLC would be
exceeded in a few years of operation; whereas, the life of a heater is
usually 10 years or more. Once the design life is exceeded, the safe
operation of a TLC during periods of overheating cannot be assumed. The
device needs to be functional when it’s needed.

3: Add to Section 25: A temperature limiting control shall be of the manual reset
type. (Eliminate exceptions a, b, and c, from Section 25.1).
Rationale: Operation of a TLC indicates that abnormal temperatures exist in the
heater and that there may be a problem. TLCs that automatically reset
allow the heater to continue to generate those high temperatures without
user intervention or awareness. Under such conditions, components
continue to be stressed, and may fail, leading to a fire. Epidemiological
data (Section 5) documents incidents where heaters were allowed to
continuously operate without user intervention under abnormal conditions
until fires resulted. CPSC staff is aware of many fires related to failed
TLCs (Section 6). A heater should not be allowed to continue to generate

Page 28 of 41
 overheating conditions automatically and indefinitely. Once the
overheating conditions occur, the heater should de-energize until the
consumer addresses the situation.

4: Add to Section 25: The operation of a temperature limiting control shall

disconnect all ungrounded conductors from the unit when activated. The
requirements of Sections 30.1.6 & 30.1.7 shall apply to all heating element types.
Rationale: Overheating conditions result in the activation of temperature limiting
devices. Some abnormal conditions involve low impedance (but not short
circuit) circumstances leading to high currents and localized hot spots.
Disconnecting a single ungrounded conductor may not remove power
from the low impedance connection (especially for heaters connected to
220 VAC), and may not address the hazard of shock or overheating. The
Failure Modes & Effects Analysis (Section 8) predicts failures that don’t
immediately trip circuit breakers and involve excessive current and power.
Evaluation of heater samples and IDI reports showed sheathed heating
elements that failed other than at the ends (Section 5). Sheathed elements
are not now required to have a TLC that disconnects all ungrounded
conductors. Once an overheating condition progresses to the point of
activating the TLC, all power should be removed from the heater. By
taking this action, the heater (and consumer) can be protected from
unforeseen conditions.

5: Eliminate Exception c) in Section 25.1, which allows an automatic reset type

temperature limiting control or a M1 style manual reset control as the back-up
device in a ceiling-mounted heater or one with a label saying not to mount the
heater less than 6 feet from the floor. Heaters mounted high up must have
overtemperature protection also.
Rationale: The intent of the exception is to not require M1 style temperature limiting
controls in heaters unlikely to be draped because of their location.
Overtemperature conditions can still occur in non-draping conditions. The
Failure Modes & Effects Analysis predicts overheating caused by
conditions other than draping, such as fan problems or high impedance
electrical connectors. Laboratory testing with dust accumulation led to
overheated units independent of height of installation. Epidemiology data
shows incidents involving ceiling-installed heaters that overheated to the
point of ignition. In one incident, sparking was observed, but the heater
continued to operate until a fire resulted. There are many overheating
conditions that do not involve draping the heater. Heaters should have
protection against overheating regardless of their installation height.

Page 29 of 41
6: Change Section 26, Alarms: All heaters with a thermal cut-off or a reset type
temperature limiting control shall have an alarm to alert the user of its activation.
Rationale: Section 26.1 requires alarms only for automatically-resetting TLCs. All
heaters should have alarms (audible or visual) in addition to manual-reset
TLCs. Previous recommendations call for the use of manual-reset TLCs.
The use of a manual-reset device should not allow the removal of alarms
from the heater. The alarm is the first indication of a problem to the user.
All heaters should be capable of alerting the consumer of an abnormal
operating condition resulting in overheating.

7: All auxiliary control devices (thermostat or combination thermostat and control

switch) shall have a position that disconnects all ungrounded conductors of the
supply circuit, regardless of heating element type or markings on the control.
Rationale: Based upon information provided in the IDIs, consumers assume that the
lowest position of the switch is synonymous with disconnecting electrical
power from the heater. If cleaning or other maintenance is required, and
the unit has not been fully de-energized, the user may be exposed to live
parts, especially for heaters connected to 220 VAC. In this case, the
single-pole thermostat disconnects only one of the two Hot power
conductors from the heater. It remains possible for the user to contact the
other Hot conductor. Evaluation of incident data indicates that users
believe power has been removed from the heater if the control knob is at
its lowest setting, regardless of the markings on the knob. Acting on that
belief can expose users to a shock hazard. Also, heaters at their lowest
setting (not disconnected from all ungrounded conductors) may
unexpectedly activate in response to a low ambient temperature.
Consumers expecting the heater to remain cold have placed combustibles
near the “off” heaters. Subsequent activation resulted in a fire.
Consumers should have assurance that heaters whose controls are turned
fully down will stay de-energized.

WIRING
8: Add to Section 15: No normal or abnormal operation test shall result in conditions
where the heater wiring reaches temperatures above the maximum rating for the
wiring’s insulation.
Rationale: Degradation of the wiring insulation can lead to shock and fire hazards.
Laboratory experimentation and field failures have demonstrated that even
a short-term abnormal condition can result in arcing and the emission of
glowing embers from a heater. Normal operation has been shown to result
in temperatures exceeding the insulation’s maximum temperature rating.
One heater exceeded the maximum temperatures every time the thermostat
cycled (see also Proposal 9). Field samples had overheated wiring that led
to arcing. If the insulation is kept below its maximum rated temperature,

Page 30 of 41
 even under short-term abnormal operation, the consumer continues to be
protected against shock and fire hazards.

9: Run the Dielectric Voltage-Withstand Test (Section 47) after the operational tests.
Run the Overvoltage Test (Section 42.4) after the operational tests. Connect a
fuse of a few amperes capacity through the ground conductor for each test to
detect any short-term currents less than the level required to activate a circuit
breaker.
Rationale: Abnormal operation may affect the electrical insulation properties, create
short-circuit or leakage paths to ground, or change the total impedance of the
heater. The Failure Modes & Effects Analysis results indicate that testing for
one fault condition may reveal other faults. The stress of an abnormal test
may weaken components other than those intended to be tested. Since short-
term abnormal operation can be expected in installed heaters, the heater
should be designed to withstand those conditions without developing
consumer hazards.

10: Add to Section 32: Any surface intended for a ground connection shall be
electrically conductive at the connection area. For example, the area around a
hole through which a grounding screw is inserted shall be conductive. The
threads of the screw shall not be the only source of grounding contact. All
grounding connections shall be made by a positive means, for example, screws,
clamps, etc. Tabs or wires in slots, incidental contact, flat surfaces pushed
together, or similar means are not acceptable for grounding connections. Add that
all grounding (or earthing) connections shall be compliant with UL 60335-1,
Safety of Household and Similar Electrical Appliances, Part 1: General
Requirements.
Rationale: Continuity to ground is essential to shock protection. Heaters should be
designed with features that assure adequate grounding with a high degree
of confidence and repeatability. Some heater designs rely on installers
breaking insulating barriers with no instructions to assure compliance.
Other designs showed unreliable grounding connections. One field
sample had operated with the frame connected to the Hot conductor
without activating the circuit breaker. The design of a heater’s grounding
scheme should be one that assures that every unit manufactured has a low-
impedance connection to the branch wiring ground conductor.

Page 31 of 41
LABELING & INSTRUCTIONS
11: Add to Section 60: Require that all warning labels be formatted in accordance
with ANSI Standard Z535.4 for Product Safety Signs and Labels
Rationale: ANSI Z535.4 was developed for the following reasons: 1) to establish
uniform and consistent visual layouts for labels across all categories of
products 2) to minimize proliferation of label designs and 3) to achieve
application of a national uniform system for recognition of potential
personal injury hazards. To promote these objectives, all warning labels
should adhere to these guidelines and principles to make safety
information more recognizable and noticeable to consumers. Some
warning labels incorporated a mixture of text that included clearance
specifications, French translations, and other English text. Warning label
research supports the stance that such safety messages are likely to be
missed because of competing text. The warnings should be segregated
from the rest of the text and should conform to ANSI Z535.4 guidelines to
make the label conspicuous and recognizable.

12: Add to Section 60: A label as described in Section 60.29 shall not exempt a heater
from any abnormal test (Section 42.7.2. and 42.10.1.1).
Rationale: Presently, if a label is on a heater with the words “Caution - source of
possible ignition – high temperature – keep combustible material away
from front heater” (sic), the heater model is exempted from a number of
abnormal operating tests. However, the number of fires that continue to
occur indicate that warning labels are not effective enough to protect users
from the consequences of component failures. Three-fifths of the fire
investigations included in Appendix B attributed the fires to combustibles
stored too close to the heaters. Small rooms with heaters (such as in
apartments) may render it impractical or impossible to clear 3 feet in front
of a heater (Section 5). A heater should not be dependent upon consumers
finding, reading, and strictly following label instructions all the time for
safety. All heaters should be required to pass all the abnormal operating
tests rather than being exempted from some tests by the presence of a
label.

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13: Add to Section 60: Require all labels to be heat resistant or located where they
will not be subjected to excessive heat during periods of foreseeable abnormal
operation. Require all labels to withstand all abnormal tests while remaining
readable. Add to Section 60: “The marking shall, unless otherwise indicated, be
permanently applied by means such as:
a) etched, molded, die-stamped, or paint-stenciled on the enclosure,
b) stamped or etched on metal, or
c) indelibly stamped lettering on pressure-sensitive labels secured by
adhesive.
Pressure-sensitive label secured by adhesive shall comply with UL 969, Standard
for Marking and Labeling Systems.
Rationale: Foreseeable use of a heater includes temporary periods of abnormal
operation. When the abnormal condition is corrected, the heater is still
usable and in use. Warnings are still valid and should be readable on the
labels, especially for future users of the heater. UL 1278, Movable and
Wall- or Ceiling-Hung Electric Room Heaters contains the language
regarding the permanence of marking. Field incidents and laboratory
testing resulted in unreadable warning labels after very short periods of
operation at abnormal conditions (Section 6). If a user corrects a
temporary abnormal condition the label may no longer exist to warn other
users.

14: Add to Section 61: Require that instructions on the product that are directed
toward the user be accessible and legible and able to be viewed without
disassembling the product or removing the grill.
Rationale: Critical warning labels should be placed in proximity to the potential
hazard and in plain view to the user. An analysis of an in-wall heater
found that labeling on the face of the heat box did not provide adequate
warning to users because it was concealed behind the heater grill
(Appendix E). Removal of the grill exposes users to a potential hazard
from live electrical components.

15: Expand Instructions for Use and Care (Section 61) to cover all heaters within the
scope of the voluntary standards, not just cord-connected heaters.
Rationale: Installers and users of fixed-position heaters need instructions too.
Section 61.1.1 states that the requirements for use and care instructions are
for cord-connected and freestanding heaters only. Failure Modes &
Effects Analysis (Section 8) and staff evaluation (Appendix E) show that
maintenance is critical to safety. Manufacturers require periodic cleaning
of heaters, but are not required to include instructions informing the user
of the use and care needed by the product. Lack of maintenance, such as
allowing excessive dust accumulation has been attributed to heater fires.

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16: Add to Section 61: Require that the use and care guide provide cleaning
instructions where applicable or else state that the heater does not need cleaning.
Require that instructions provide, when applicable, reasonable cleaning
procedures that don’t require special tools or skills.
Rationale: Users need explicit instructions to maintain the product in a safe condition
and manner. Users are less likely to comply with instructions that are
time-consuming or troublesome. The use of special tools or special skills
should not be required to clean a heater. Incident samples of in-wall
heaters collected from the field show dirt and lint accumulation that may
impact the fire hazard potential. CPSC staff discovered that maintenance
instructions differ among brands of heaters. Some instruction sets
included detailed cleaning instructions, while other sets had no references
to cleaning. One set of cleaning instructions for an in-wall heater required
the blow-out mode of a vacuum cleaner to dislodge debris from the
heating elements. The instructions stated that a second vacuum cleaner
would be useful to pick up the debris. It is not reasonable to expect users
to clean heaters by blowing dust into a living space.

17: Require that if a heater is to be cleaned as part of a regular maintenance program,

the product design should accommodate such cleaning without damaging the
heater.
Rationale: Heater parts subjected to cleaning must be capable of withstanding normal
cleaning procedures. Maintenance may foreseeably be performed by
users, and should not expose them to potentially hazardous conditions,
such as live electrical parts. Heaters should be designed so that the user is
not likely to damage fragile components when performing the required
cleaning. Fragile components should be protected. The cleaning
instructions should properly instruct the consumer on how to clean the
heater safely and effectively without damaging any components or leaving
any electrical connectors loose.

18: Add to Section 61: Require separate, complete instructions for the installer and
the user.
Rationale: Data from incidents involving in-wall heaters indicate that in-wall heaters
are installed by both professionals, who are not the end users of the
product, and consumers. Each of these two groups requires a different set
of instructions tailored to the particular performance demands of their
tasks. Installers need technical information and consumers need use and
care instructions. The instructions relating to each of these different tasks
should be located in the product documentation in such a way that the
individual groups can readily recognize the sections pertaining to their
specific needs. CPSC staff found that an explanation regarding the
meaning of a hazard lamp on an in-wall heater was located in instructions
geared to installers. The lamp signals an over-temperature condition that is

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 a potential fire hazard. If consumers miss this information because it is
embedded within technical installation instructions, the value of the hazard
lamp as a signal alert for a potential hazard is nullified.

19: Add to Section 60: Require that installers and users be given specific information
on how to respond to an alarm signaling an over-temperature condition. The
responses should be plainly detailed in the use and care guide, and should be
posted on the product near the alarm.
Rationale: Users must know how to react to an audible or visual alarm signaling
overheating conditions. Explicit response instructions should be
conspicuously posted on the front of the heater near the alarm, as the use
and care manual will not always be available for reference. Staff
evaluations of instructions for in-wall heaters found that some did not
provide any reference to the function and significance of the alarm. Users
were not alerted to what type of immediate corrective action was needed
in the event the alarm illuminated. In another instance, users were sent a
mixed message on how to react to the alarm signal (Appendix E).

TESTING
20: Include a Manufacturing Test to be performed during assembly on a sample basis
to evaluate the electrical integrity of the mechanically assembled wiring
connections. Such testing shall include:
• Connection Resistance, initial, and maximum increases during accelerated life
testing of representative samples
• Manufacturing quality control systems
• Different ratings for power conductors and non-power conductors.
Rationale: Failed wiring connections have been attributed to many fire incidents. To
reduce the frequency of poor quality in electrical connections, the
variability associated with today’s manufacturing processes must be
reduced. Technical Studies performed under contract by the CPSC
(Section 10 and Appendix H) indicate problems with wiring connectors
exist, and can lead to overheating conditions. The Failure Modes &
Effects Analysis studies show that manufacturing problems are not
addressed by UL 2021 evaluation. Multiple field samples showed
corroded and failed crimp connectors. Assurance is needed that units in
manufacture are being assembled with good quality connections. Testing
during assembly can be used to monitor the quality of the electrical
connectors and reduce the variability of the connector manufacturing
process. The assembly of every heater should assure a high probability of
good internal electrical connections.

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21: Include in the standard: Any polymeric material within 3 mm. of the live parts of
a power connector shall have a minimum Glow-Wire Ignitability Temperature
(GWIT) and Glow-Wire Flammability Temperature (GWFT) of 750 degrees C in
accordance with IEC 60695-2-1/3 and IEC 60695-2-1/2 respectively, or comply
with the Glow-Wire End-Product Test (GWEPT) as described in UL 746C.
Rationale: This is to minimize the effects of connector failures when they occur.
There is an IEC-UL initiative to address the consequences of failed
connectors and harmonize standards. This proposal has been approved for
other products.

22: The sensitivity of a heater to dust collection and ignition should be evaluated
through exposure testing.
Rationale: Heaters that collect and trap household dust over a period of time exhibit
altered operating characteristics. This can lead to accelerated component
failure or ignition of the dust and the emission of burning embers into the
room. Examination of various designs found that some were intrinsically
prone to accumulating and igniting dust. Laboratory experiments have
shown that a significant change in performance is observable after a very
short exposure time to dusty air (Section 7). Therefore, it is possible to
determine through evaluation and testing on new units, the propensity to
collect dust and create a potential fire hazard.

23: Add to Section 42: The insulation requirements in Section 39.4 are to be used for
all abnormal tests on heaters that are permitted by the manufacturer to be installed
in insulated walls.
Rationale: Heaters in insulated installations need to be considered in the abnormal
tests. Abnormal conditions with insulated boxes may result in wire
insulation degradation or other undesirable conditions inside the heater.
Laboratory testing showed that some wall cans get hot enough during
abnormal operating conditions to have the potential to affect the branch
circuit wiring insulation (Section 7). Short-term abnormal operation may
degrade the branch wiring insulation to the point of creating a shock or
fire hazard. Heater designs need to prevent overheating of branch wiring
during short periods of abnormal operation.

24: In Section 42.10, substitute another suitable, readily available material for the
cattle-hair felt.
Rationale: The test cannot be run to specification if the materials are unavailable.
Communication with UL has found no source for materials called out by
the test. The unavailability of the required materials hinders the relevancy
and repeatability of the test. Also, since consumer products are no longer
manufactured with cattle-hair felt, the applicability of the test is in
question.

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25: In Section 42 (Abnormal Operation Tests), examine the heater for impending
failure modes, such as melting wiring insulation, reduction of the spacing between
components, etc., after completion of the test. For all tests, run the tests for their
full duration to see if secondary effects appear. Interpret Section 15 (Internal
Wiring) as applying to normal and abnormal operating conditions.
Rationale: Test durations of 7 or 8 hours do not fully approximate the foreseeable
lifetime use conditions of a heater. As approximations of events that can
occur during years of use, the abnormal tests may not result in a “failure
result” during their hours-long operation. However, there may be
evidence of incipient failures that can occur in the field if normal or
abnormal use were continued. Internal examination of the heater after the
limited duration abnormal test may reveal evidence of potential failures.
Testing on heaters shows failure modes that will take longer than 7 hours
to create a “failure result.” For these modes, the heater that may develop a
consumer hazard over a long period of time passes its tests.
Epidemiological data (Section 5) indicates that heaters are in use for many
years. The Failure Modes & Effects Analysis supports the inference that
short-term testing on a limited number of samples (one sample) cannot
demonstrate all the failure modes. Since the evaluation uses
approximations of actual long-term conditions, and is conducted on a
limited number of samples, the interior of the tested samples should be
examined for problems that could develop over a longer time.

OTHER PROPOSALS:
26: Radiant heaters shall have a maximum flux of 0.5 W/mm2 or less at a distance of
six inches from any point on the heater.
Rationale: Flux values higher than 0.5 W/mm2 have an increased chance of igniting
combustibles. Measurements and laboratory testing have shown that
higher radiant heat fluxes quickly lead to ignition of common household
materials during draping tests (Section 7). High radiant fluxes have the
potential to raise the temperature of a nearby material to its ignition point.
Lowering the radiant flux reduces the net power transfer per unit area and
lowers the probability of ignition. Heater designs that disperse the radiant
energy are capable of transferring the same amount of energy into the
room without overheating nearby materials.

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27: Include the requirements of Protection Against Personal Injury (Section 54.1) to
all heater designs. Currently, the requirements are for cord-connected heaters
only.
Rationale: If the front grill of a heater contacts a heating element, an electrical or
thermally conductive path could be established through the grill. The
Failure Modes & Effects Analysis (Section 8) predicts that physical
impact on a sheathed heating element can result in a shock or overheating
hazard if the conductor wire in the element establishes a path to ground.
Sheathed heating element construction is susceptible to failures caused by
bending. If an impact disrupts the sheath, or leads to contact with an
open-wire heating element, a shock or burn hazard could result.

28: Section 13.6.2 states that the lens of an alarm shall be visible 10 feet in front of
the heater and 5 feet up. This is measurable and repeatable, but not very
applicable to real life. Heaters are rarely installed 3 feet above the floor. Replace
the single-position test with the following: When a heater is installed at its
minimum height, the pilot light should be visible at an angle +/- X° from the
perpendicular of the heater front and between Y1 and Y2 heights at a distance of
10 feet.
Rationale: Many warning lights are obscured by the grill in front of them. Users
must be able to notice the lights and take corrective action. Evaluation by
ES and Human Factors (Appendix E) staff found hazard lamps obscured
by the grill to the point of invisibility. Epidemiology studies indicate that
users never reported a hazard lamp indication as a warning sign of an
impending failure. The warning lamp does no good if it is not seen. The
hazard warning should be plainly visible from many orientations.

Errata:
Table 31.1 “6/4 mm” should be “6.4 mm.”

32.2 a) “... (see 12.1.25 and 12.1.28), ...” These should be 13.1.25 and 13.1.28.
There is no Table 32.2, use Table 31.2.

33.3.4 “pin” should be “pins.”

Figure 36.1, page 60 A. is “280” supposed to be either 208 or 220?

42.10.1.2 “... moved horizontally one half inch from its initial position ...”
should say “...inch from its initial position away from the heater...”

42.10.1.3 “sufficiently” should be “sufficient.”

44 Stalled fan tests: Section 44.1 references exception 3 of 24.2.3. There is no

Section 24.2.3. Which section is the correct one?

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60.9 Text conflicts with Section 60.7.

60.27 Exception No. 3 calls for requirements in sections 41.10.1 – 41.10.2. There are
no such sections in this specification.

Table 7.1 Typographical error, “5.64 inches” should be “5

Section 25.1 Exception, a) refers to the Abnormal Ambient Test, Sections 42.5.2 –
42.13.3.1. Section 42.5.2. through Section 42.12.3 refer to Abnormal Operation
Tests, The Abnormal Ambient Test starts with Section 42.13
Change the test name or section numbers for consistency between them.

Section 29.15 “...metal-clad element is a grounded...” should be “... metal-clad element

in a grounded...”

14. CONCLUSIONS

Fixed-position electric heaters are high energy, high temperature devices that can
cause fires when they fail. Millions of these heaters are in service every winter across the
nation. Each year, this product group is responsible for thousands of fires and tens of
millions of dollars of property damage. The U.S. CPSC staff evaluated fixed-position
electric heaters and the applicable voluntary standards to improve the safety of the heater
and reduce hazards faced by users.

The voluntary standards created by Underwriters Laboratories, Inc. for fixed-

position electric heaters UL 1042 and UL 2021, were last updated in 1994 and 1997,
respectively. For the most part, these standards depend upon two factors to determine
whether a unit under evaluation meets the standard for safety. First, if the model heater
has a label warning consumers to keep combustibles away, the unit is exempted from
several performance tests. Second, if the unit does not emit flame, glowing embers, or
molten metal during a 7 to 8 hour test period, the heater is considered safe. These criteria
are not sufficient to protect consumers.

The usefulness of labels to render a product safe when in use has limited
effectiveness. Even if users notice the label and understand its warnings, being able to
keep all combustibles, including the carpeting on the floor, three feet from the heater may
be impractical or impossible. The installation instructions often state that the heater may
be installed less than one foot above a carpeted floor, contradicting the warning label.

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 Short-duration testing of single units also has limited utility. The performance
tests of UL 1042 and UL 2021 are at best approximations of some of the conditions that
the products can be expected to be exposed to over their service life. As approximations,
a simple pass-fail criterion is not sufficient for products that will be continuously in use
every heating season for decades. Examining the tested units to determine whether a
failure would have occurred had the test continued has a better chance of uncovering
problems.

One exception clause in UL 2021 allows the use of an automatically-resetting

temperature limiting control (TLC) in virtually every model heater. When the TLC in a
heater activates, that heater is in an unsafe operating condition. The application of
automatically-resetting TLCs allows the heater to remain in that unsafe operating
condition indefinitely, possibly until a more serious failure occurs. Manually-resetting
TLCs in heaters would encourage the user to pay attention to how the heater is
functioning and to correct the abnormal conditions (by removing an obstruction that
blocks the airflow, for example).

Probably the weakest component in a heater covered by UL 1042 and UL 2021 is

the plastic wiring insulation. Most other parts are made of tough metal. Yet the
interpretation of the voluntary standards allows designs of heaters that overheat the
insulation under normal operating conditions. Abnormal operation makes things worse.
Improvements should be made to protect against failure do to insulation degradation.

One of the factors the voluntary standards fail to address in electric heater
production is real-life manufacturing variability. The evaluation of a product does not
include any assessment of whether mass production is likely to result in units essentially
the same as the evaluation unit in its critical features. For example, grounding and crimp
connection repeatability are not considered in UL evaluation.

The review of the human interface of fixed-position electric heaters also revealed
several shortcomings. Some instructions and warnings were contradictory with other
instructions. One heater instruction manual stated that there were no user-serviceable
parts inside and later stated that the cover was to be removed for cleaning. One
manufacturer suggested operating a vacuum cleaner on reverse to blow any accumulated
dust and lint into the room for subsequent cleaning. Consumers are unlikely to follow
that cleaning method.

The opportunities for improving the safety of fixed-position electric heaters are
also supported by the economics of societal loss. For wall heaters, the losses associated
with fires exceed the cost of the heaters. For baseboard heaters, the losses are two-thirds
of the heaters’ cost. In terms of dollars, society would benefit greatly from an increase in
the safety of these devices. For a modest investment in safety, a large net gain can be
realized by reducing the fire incidents associated with fixed-position electric heaters.

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 Over thirty separate recommendations for changes to UL 1042 and UL 2021
resulted from this project. The application of these recommendations should positively
impact the number deaths, injuries, and property loss attributed to these products.

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