Danger to human health or safety assessment for portable electric heaters

Legislative background

The Canada Consumer Product Safety Act (CCPSA) addresses dangers to human health or safety posed by consumer products in Canada. Any person who manufactures, imports, advertises, sells or tests a consumer product must comply with all applicable requirements of the CCPSA and its regulations. Paragraphs 7(a) and 8(a) of the CCPSA prohibit the manufacture, importation, advertisement or sale of any consumer product that is a "danger to human health or safety". The CCPSA defines the term as follows:

Scope of affected products

Portable Electric Heaters - A cord-connected appliance that heats the surrounding air and/or objects, constructed for use in more than one location.

Includes:

• All types of portable electric heaters, including but not limited to: convection, fan-forced heaters, portable baseboard heaters, radiant heaters, liquid-filled radiator-style heaters.
• Electric heaters that can operate both mounted and freestanding.
• Portable electric heaters that incorporate other functions, such as fan-only modes and air cleaning.

Excludes:

• Permanently connected electric heaters.
• Fuel-burning heaters.

Hazards of concern

Inadequate protection from abnormal conditions in portable electric heaters may lead to overheating, creating a burn or fire hazard. Some of the abnormal conditions of concern are:

• internal component failure, such as short circuiting of heating element or motor windings.
• a heater placed too close to a flammable object.
• a flammable object placed on the heater.
• an emission of flame or molten material.

Incidents^{Footnote 1}

Health Canada is aware of 252 reports of incidents that occurred between June 20, 2011, and September 30, 2023, involving portable electric heaters in Canada. Within these reported incidents, 5 reported a death and 10 reported injuries.

Health Canada is aware of 567 reports of incidents that occurred between August 1, 2011, and July 31, 2023, involving electric heaters in the United States. This data was obtained from the United States Consumer Product Safety Commission's public database.

The United States National Fire Protection Association estimated that 44,210 structural fires per year involved heating equipment in the United States from 2016-2020. Fixed or portable space heaters (the majority being portable electric heaters) accounted for one third of these home fires. The use of portable electric heaters in the United States, particularly as a supplemental heat source to a central heating system, is expected to be similar in Canada.

Data from the Ontario Fire Marshall showed that from 2017 to 2021, an average of 510 structural fires per year were caused by heating equipment in Ontario. Similar to the United States, it is expected that a large portion of these incidents are due to portable electric heaters. The majority of these fires were not reported to Health Canada, indicating that there is a significant amount of underreporting of fires related to heating equipment, including portable electric heaters.

Danger to human health or safety assessment

Based on the danger to human health or safety considerations and details discussed in the following sections, Health Canada believes that the following products likely pose a danger to human health or safety:

• Certain portable electric heaters that do not conform to the applicable criteria set out in:
  • CSA C22.2 NO. 46-13 (R2018) – Electric Air-Heaters, or
  • CAN/CSA E60335-2-30:13 (R2018) – Household and similar electrical appliances - Safety - Part 2-30: Particular requirements for room heaters (Adopted IEC/CEI 60335-2-30:2009, fifth edition, 2009-11, with Canadian deviations), or
  • the equivalent.
• Certain portable electric heaters where the abnormal testing criteria set out in the following standards indicates a hazard exists:
  • CSA C22.2 NO. 46-13 (R2018) – Electric Air-Heaters, or
  • CAN/CSA E60335-2-30:13 (R2018) – Household and similar electrical appliances - Safety - Part 2-30: Particular requirements for room heaters (Adopted IEC/CEI 60335-2-30:2009, fifth edition, 2009-11, with Canadian deviations), or
  • the equivalent.

Health Canada recognizes that there may be other possible health or safety concerns with the use of these or similar products. Industry should review their products for all potential hazards and respond appropriately to make sure they are safe for consumers.

The Consumer Product Safety Program of Health Canada operates as a post-market regulatory regime, meaning that there is no pre-market review or approval of consumer products by Health Canada.

Health Canada may update this assessment as warranted.

Danger to human health or safety considerations

Considerations for a product to pose a potential danger to human health or safety are outlined in Health Canada's "Industry Guidance - "Danger to Human Health or Safety" Posed by Consumer Products". The main considerations assessed are:

• 1) Unreasonable hazard
• 2) Existing or potential hazard
• 3) Normal or foreseeable use
• 4) May reasonably be expected to cause
  • a) Death
  • b) Adverse effect on health

1) Unreasonable hazard

The consideration of unreasonable hazard includes the following components:

a) Inherent hazard

Overheating of a portable heater (and subsequently nearby objects) poses a burn or fire hazard to consumers.

The high electrical current required for a portable electric heater to function may cause overheating in the following ways:

• if the heat generated is not dissipated to the surrounding air or objects at a sufficient rate,
• if the heat generated causes nearby objects to overheat, or
• if there is a defect in any of the controls or wiring of the heater, they may overheat.

Clause 7.6 of CSA C22.2 NO. 46-13 (R2018) addresses this by including testing for burn and fire hazards in various foreseeable use scenarios that could cause overheating.

b) Severity of hazard

Due to where and how portable electric heaters are used, they have the capacity to cause structural fires, which in turn have the potential to cause life-threatening injuries or death.

c) Intended and foreseeable users

Portable electric heaters are typically used as a supplemental heat source, particularly in dwellings located in colder or more variable climates, and more often by individuals living in disadvantaged communities.

Portable electric heaters are designed for adult use. It is reasonable to expect that adult caregivers may use them to warm disproportionately impacted populations, such as infants, children, and the elderly. These specific groups are at an elevated risk of fire and burn hazards due to the potential of reduced awareness and limited mobility.

d) Obviousness of hazard

While it's reasonable to assume that adults using portable electric heaters should be aware of the burn and fire hazards associated with them, these hazards may not always be evident for a number of reasons. Only some heaters exhibit visible warnings of the hazard, such as visibly glowing heating elements. Additionally, it may be difficult for a user to differentiate between an overheating heater and a normally operating one, or to detect the overheating of objects nearby or on a heater. Furthermore, there's a range of household items that adult users might not recognize as flammable. Portable electric heaters are frequently placed on rugs or carpets or near flammable furnishings like sofas, chairs, or curtains. They are often used to supplement heat in a bedroom, near blankets and sheets. They may also be placed near less obviously flammable items, like plastic items, holiday decorations, and paint cans that can melt or catch fire.

e) Social utility

Portable electric heaters are used for supplemental or temporary heating of a space. They may be needed when there is inadequate permanent heating or insulation in a structure or a portion of a structure. From an economic or environmental perspective, there may be a benefit to using a portable electric heater to heat only a portion of a structure, as opposed to heating it entirely using a central heating system.

f) Available alternatives

Permanently installed heaters, fuel-burning heaters, or central heating systems are the primary alternatives to portable electric heaters. However, these options are generally more expensive and are not as convenient as portable electric heaters.

g) Consensus-based safety standards

The consensus-based Canadian national safety standard applicable to portable electric heaters is CSA C22.2 NO. 46-13 (R2018) – Electric Air-Heaters. This standard sets out testing requirements for portable electric heaters including those related to the burn or fire hazard posed under the following conditions:

• portable heaters directed at a surface,
• drape tests for portable heaters,
• furniture restrictions,
• shredded paper test,
• stalled fan,
• overturning of portable heaters,
• air filter blockage (if applicable),
• ruptured element test (if applicable), and
• dielectric testing pre and post abnormal operation.

There is also CAN/CSA E60335-2-30:13 (R2018) – Household and similar electrical appliances - Safety - Part 2-30: Particular requirements for room heaters (Adopted IEC/CEI 60335-2-30:2009, fifth edition, 2009-11, with Canadian deviations). This standard includes equivalent criteria to CSA C22.2 NO. 46-13, with the addition of criteria to address a slowing fan.

These tests are intended to address the inherent hazards in portable heaters and the foreseeability of those hazards. As per clause 7.6 of CSA C22.2 NO. 46-13 (R2018), a heater shall not become a hazard when operated under abnormal conditions. The abnormal conditions tested are intended to represent all foreseeable conditions in which a heater could be placed. However, Health Canada will continue to explore if this testing represents all conditions and related severity.

Portable electric heaters are required to be certified to the applicable Canadian national standards above, which is a provincial and territorial requirement and is captured under the Canadian Electrical Code (CEC). Due to ongoing safety concerns, Health Canada is proposing to add portable electric heaters to the list of products with hazards that pose a danger to human health or safety under the CCPSA. Health Canada may test these products against specific criteria in the standard and take action if necessary. Testing will also help identify if there are any gaps in these existing safety standards that may require attention.

2) Existing or potential hazard

Incident data from Canada and the United States indicates that portable electric heaters have led to multiple fires, including several that have led to serious injuries and death. Therefore, this is an existing hazard.

3) Normal or foreseeable use (including foreseeable misuse)

A portable heater insufficiently protected from overheating could pose a burn or fire hazard and foreseeably result in a home fire or smoke inhalation injuries if there are flammable materials nearby.

Portable electric heaters are used in a variety of different household environments such as bedrooms, living rooms, home offices and garages. These spaces contain a variety of potentially flammable objects such as bedding, furniture, clothing, textile curtains and rugs, clothing, plastic items, paper & books, cardboard boxes, and paint cans. It is foreseeable for consumers to place a portable electric heater on or near these flammable items. This may result in the overheating of the heater or the objects, posing a burn or fire hazard. Overheating could also occur due to restricted airflow, either from a fan failure or from nearby objects restricting airflow.

Heaters with the type of element that can rupture, are often used during construction or in garages, near objects such as construction materials, cardboard boxes, or flammable liquids. It is foreseeable for consumers to place a portable electric heater on or near these items. As a ruptured heating element may eject high temperature particles, it is foreseeable that these may come into contact with these flammable items.

4) May reasonably be expected to cause

a. Death

Portable electric heaters overheating could result in a home fire or smoke inhalation injuries if there are flammable materials nearby. Home fires and smoke inhalation may reasonably be expected to cause death by severe burns or asphyxiation from carbon monoxide or other combustion products.

Health Canada is aware of 5 deaths associated with portable electric heaters in Canada between June 20, 2011, and September 30, 2023.

The standards CSA C22.2 NO. 46 and E61335-2-30 are designed to address the fire hazard associated with portable electrical heaters. It is therefore reasonable to believe that portable electrical heaters that do not conform to the applicable criteria outlined above, or their equivalent, may reasonably be expected to have an increased risk of causing fires that could lead to death.

b. Adverse effect on health

The circumstances that may reasonably be expected to cause death may also reasonably be expected to cause adverse effects on health, including:

• Smoke inhalation injuries, and
• Burns.

Health Canada is aware of 10 Canadian reports of adverse effects on health associated with portable electric heaters between June 20, 2011, and September 30, 2023.

The standards CSA C22.2 NO. 46 and E61335-2-30 are designed to address the fire hazard associated with portable electrical heaters. It is therefore reasonable to believe that portable electric heaters that do not conform to the applicable criteria to address the burn or fire hazard may reasonably be expected to have an increased risk of an adverse effect on human health.

If you require additional information regarding this Danger to Human Health or Safety Assessment, please contact a Health Canada Consumer Product Safety Office via email (ccpsa-lcspc@hc-sc.gc.ca) or telephone at 1-866-662-0666 (toll-free within Canada and the United States).

Published on February 19, 2024.