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The two proposals do not appear to be backed by evidence that they will eliminate or even reduce casualties. A better approach for life safety would be to prohibit new installations of carbon dioxide systems. There does not seem to be much value in the use of an odorant in the carbon dioxide agent. Three factors argue against the introduction of an odorant. 1) Systems for large spaces are already provided with audible alarms. The proposed addition of an “olfactory alarm” would be redundant to the audible alarm, except for the smaller spaces without audible alarms. 2) It is doubtful that an early warning by olfactory means would help reduce injuries and fatalities associated with carbon dioxide systems. The EPA commissioned a study, released in 2003, titled “Review of the Use of Carbon Dioxide Total Flooding Fire Extinguishing Systems.” This study did not explicitly address whether alarms would have reduced casualties, but the casualties cited in the study were primarily due to inadvertent discharge with people trapped in the space and unable to exit. Put another way, the problem was NOT that the victims were unaware of the agent discharge. 3) As an issue of human factors, there is no convincing evidence that an odorant detected by a person would signify the release of a dangerous gas. If USCG is intent on the concept of an odorant, then the particular odorant should be specified and then publicized, so that its meaning would be unambiguous. The benefit of a lockout device does not appear to be compelling. Many of the casualties cited in the EPA study mentioned above were due to inadvertent release, when the system would not have been locked out. Other casualties have occurred during maintenance or inspection. The deaths on Cape Horn occurred when the inspectors thought the actuation system had been disabled. The point is that another lockout device is not guaranteed to solve the problem.