What's in a Warning?

California's likely new law requiring labeling of gas stoves

Human factors and safety expert Marc Green, who runs the excellent site Visual Expert has an entire section of his website dedicated to warning labels and their effectiveness or lack of in general safety topics.

Green argues that for a warning label to be effective it needs to include at least the following:

• Attract Attention: It must stand out and be noticeable to consumers.

• Communicate the Risk Clearly: The message should be straightforward and easily understood.

• Be Credible: The warning should be based on solid scientific evidence to be taken seriously.

• Motivate Behavioral Change: It should encourage consumers to take appropriate action to mitigate the risk.

If there’s ever a great examples of how to not do a warning label, it’s California’s Proposition 65, which is seemingly beamed to end users nearly everywhere from consumer products that most people know contain some sort of chemical, to Disneyland, coffee, vinyl records, food, and even toilet paper.

Prop 65 warnings are so ubiquitous, even to consumers outside California, that they’ve become an utter joke. They also often don’t communicate the risk one has to the chemicals (if they’re even mentioned specifically in the warning) or even a dose. End users aren’t given any information as to the scientific evidence for such warnings either and it’s unknown if any of the warnings actually motivate any sort of behavioral change for the end user. In other words, the Prop 65 warnings don’t meet any of the criteria for good warning labels under Green’s criteria.

Now Californians are likely to face a new warning label to bombard their cognitive loads: one for gas stoves.

In other words, the “gas stove wars” have taken a new turn, that is if a new law in California is signed into law.

Enter Assembly Bill 2513 “Gas stoves and ranges: warning label,” authored by Gail Pellerin. If her law is signed by the Governor, it will require all household natural has stoves and ranges sold in the state to include the following warning:

WARNING: Gas stoves can release nitrogen dioxide, benzene, carbon monoxide, formaldehyde, and other harmful pollutants into the air, which can be toxic to people and pets. Stove emissions, especially from gas stoves, are associated with increased respiratory disease. Young children, people with asthma, and people with heart or lung disease are especially vulnerable to the toxic effects of combustion pollutants. To help reduce the risk of breathing harmful gases, allow ventilation in the area and turn on a vent hood when gas-powered stoves and ranges are in use.

The warning, per the law, is to be affixed “to the gas stove in a position that is easily read by a consumer examining the product. The label shall be in a type size and font no smaller than the largest type size and font used for other consumer information on the product.” Furthermore, if the product is sold online, a separate warning on that website must also be included on the website.

Currently for gas stoves and ranges sold, Prop 65 warnings are already required on top of dozens of warnings intended both for installation and for the end-user while cooking.

And for what it’s worth, the law only applies to household natural gas stoves so it doesn’t include warning restaurant cooks or patrons.

So does Pellerin’s law meet the criteria of a good warning per Green and would it, as she claims, “aims to increase consumer awareness of the environmental and health impacts of gas stoves.”

Since this law hasn’t gone into effect yet and no warnings exist in the wild yet, figuring out whether the label will attract attention or not is mostly unknown. It does seem that she, or one of the other editors of the bill, either knowingly or unknowingly nodded to the concept of attracting attention by requiring the label to conform to certain font sizes. The law doesn’t specify where on the product the warning label must be affixed. According to Dr. Green, effective warnings utilize salient features like bold text, contrasting colors, and symbols to attract attention. If the proposed label lacks these features or is overshadowed by other labels and information, it may not be even noticed.

Does the warning properly communicate the risks one has in cooking with a gas stove or range? Not really. It instead lists off a bunch of nasty chemicals, which are no doubt not good for one’s health in certain concentrations, but without doses or some sort of baseline for exposure, the end user isn’t really informed about their risk. For example, end users are not properly informed on the relative risk of heating a tea kettle versus say, cooking in the kitchen using the appliance for three meals a day for hours at a time. Nor are they informed about the risks of the foods they’re actually cooking which may be harmful in and themselves in some way.

What about credibility based on solid scientific evidence? That’s not so great either. Part of how gas stoves became a “culture war” icon stems from a bombardment about their apparent danger thanks to article in the Corporate Press and from “studies,” typically from ideologically captured “authorities.”

In the supporting documentation for an earlier draft of the law, these “studies” were mentioned:

A growing body of evidence on the respiratory and other health risks associated with gas stove pollution has led the American Medical Association, the American Public Health Association, and Physicians for Social Responsibility to raise the alarm, and the Consumer Product Safety Commission has recently opened an investigation into the health risks and potential opportunities to mitigate harm. Gas stoves emit harmful levels of nitrogen dioxide, carbon monoxide, methane, and benzene. Recent Stanford studies found that gas stoves can emit carcinogenic benzene levels above those found in secondhand smoke and nationally, gas stoves have the same climate impact equivalent to 500,000 gasoline-powered cars. A study from the nonprofit group RMI found that 20% of childhood asthma cases in California are attributable to gas stove use. Despite all these studies, lack of education and federal regulations leave consumers largely unaware of the risks associated with gas stove cooking.

Stanford’s studies are ideologically biased and contain significant flaws.

But the RMI’s “study” cited is nonsense.

It’s been debunked by

Handwaving Freakoutery

here.

The Gas Stove Asthma Lie

Freakoutery mentions that these observational studies can’t establish causation, that the study contains confounding variables such as housing quality, lack of ventilation, and that exposure to other pollutants present in particular geographical areas which may be the actual causes of the health issues claim to be caused in the research by gas stoves.

RMI are no stranger to controversy either, being an organization funded by dark money and out of touch billionaires as

Robert Bryce

has noted.

The Dark Money Behind The Gas Bans

The Billionaires Behind The Gas Bans

Furthermore Liz Wolfe of reason summarized its issues in particular with the RMI “study” succinctly in Environmentalists Are Destroying my Kitchen.

It was not full of new findings or bolstered by new and better methodology, but rather a review of existing literature on the topic. It used excess asthma risk calculations from those studies and an estimate of the number of homes in the U.S. with gas stoves in them to calculate how many childhood asthma cases are caused by gas stoves (12.7 percent, they claim). It was funded by the environmentalist group Rocky Mountain Institute (RMI), which seeks to cut greenhouse gas emissions by 50 percent by 2030. Study co-author Brady Seals is part of RMI's carbon-free buildings initiative—a conflict of interest that makes clear where RMI stands on the matter of eliminating gas stoves from people's homes. 

In order for that number to hold up, you have to accept that gas stoves are a significant contributor to the development of childhood asthma. But there's a lot of noise in the data: Namely, that households that own gas stoves tend to look different than households that don't, and that there are a lot of uncontrolled variables which distort the confidence with which we should believe RMI's estimate.

This all puts any sort of scientific credibility to shame.

The last item on Green’s list, does the warning label motivate behavioral change is mostly verdict-less so far given these warnings still don’t exist in the wild but a few things can be deduced. To the credit of Pellerin, she’s ensured the warning label include a clause about ventilation when using the product. However if gas stoves and ranges were really this hazardous for the user and the environment, then why aren’t the warnings also required to be included in real estate agreements such similar to lead paint? How is someone purchasing a home or renting one equipped with an existing gas stove supposed to know of such a risk that demands such a warning? And why, in a state with almost half of its population who speaks a language other than English not warned at all? Lastly, if one is really persuaded by the warnings, what is their alternative to purchasing a gas stove or range? Home kitchens equipped with and built for gas stoves often need additional modification such as closing off the existing gas line and electrical modifications to make alternative all-electric stoves possible to install.