Thread by @masknerd

[1]Regulatory framework surrounding UV-C and influencers to the regulatory process
Paul Jensen, Final Approach Inc.
#ICFUST
#ICFUST2023

[2] video: Budlight pilot video
Need to balance risk with benefit, as well as cost and benefit. Risks of secondary adverse health effect, and need to look at the whole picture.

[3]Risk of infection w/ no intervention, risk w/ intervention, risk of transient health effects
risk of secondary health effects (VOC ozone)
Risk of reduction in UV-C dose to lower secondary (ozone and VOC risk)

[4] 1995 NIOSH gets a call about potential overexposure in UV why?Reference installation of 254nm wrong, put in upside down and too low(doh!). How do make sure stuff is installed properly?

[5] Communication problem: "this is no longer an 'experiement' potential. solution; alphabet soup collaborative industry certification collaboration.

[6] Shows journal article -an alarmist title but they were using 2KW of UVC(which is a lot!!!!). We need to be clear and thoughtful about messaging. Reference to mentions the Peng and Jimenz studies presented yesterday AM.

[7] Need a balanced scientific approach
we are our own worst barriers to acceptance!
Mainstream and social media are a close second. The customer doesn't need or benefit from textbooks full of info.

[8] Regulatory framework:
historically new regs come out: after tragic fatal accident,exposure regulations? No one has any
OSHA: no, NIOSH: no, IES could but doesn't.

[9] Efficacy regulations:
EPA: no, FDA: no, AHSRAE not regulatory but can promote consensus standards.
EPA does have some regulations, FIFRA, for misbranding. (no one can "kill" "100%" of something)
FDA: 21 CFR 1000-1005 , Radiation Control for Health and Safety Act

[10]Back to efficacy:
No dosing strategy standards or regulation. Fluence vs irradiance, volumetric dosing.
Industry intiatives: huge market in the global HVAC space ($561B), vs UVGI ($454M)
ventilation outspends UV by a factor of 1200

[11]
The golden rule: he who has the gold makes the rules.
UV-C industry is poor at, 1. Evidence base supporting, UV-C in general, Mainstream and social media, Consensus standards
the term "UV" can't be changed but must be contextualized

[12] ASHREA 241 discussion, only on UV person at the table. Highlights UV needs to be more pro-active.

[13] Consesnus standard bodies:
final ballot june 27  UL8802 Standandar for ":safety"
covers general use height for different types of fixtures (6'3") As long as it doesn't surpass irradiance level, needs signage
speaker is very critical of this

[14] Other UL standards as parallels; standard for electric chainsaws:
not inherently safe!!!!
horrifying slide, then picture of fine print sticker CSA and IEC compliant standards: "how does this help me, my customers, and general public health?"

[15] Limited guidance on dosing between ACGIH, CDC/NIOSH recommendations, ASHREA GPC-37 and ASHREA standard 241P

[16] Summary: Regulatory framework needed, its currently patchwork and very confusing. Currently contradictory. Need more cooperation between federal agencies.

[17] UV-C industry is sub-optimal, uphill battle with other industries, uphill battle with regulatory agencies and Consensus standards orgs

[18] Q from Ed Nardell: Time motion issue with single highest point apporach
A: If you understand TLV's based on total absorbed UV over work period. UL has divided TLV over 8 hrs, assuming the worker is constantly exposed. This is not real world in anyway in workplace.

Cont: There are some cases where this can happen, example of worker who watched TV the whole time, but UV light was right above TV so had exposure above threshold.

Q: from Claus Holger USHIO: If you don't participate in these committees don't complain. Need more active people from UV companies to help give input. Feels like he is just slowing down bad decisions, not stopping them.

Q: Is this just a lawyer question, not driven by health but by litigation
A: Two types of risk, legal risk and risk of transmission. Related but separate, office building that supports hospital without patient care is low transmission risk, low priority compared to hospital itslf

[11]