Thread by @masknerd

[1] Roundtable discussion with participants from both governmental and non-governmental agencies on future regulatory pathways for Far-UVC
#ICFUST
#ICFUST2023

[2] Moderator: Lew Radonovich (CDC, NIST)
Participants: Belal Abboushi (Pacific Northwest National Laboratory), Aline Heffernan (EPA Office of Pesticide Programs), Cameron Miller (NIST), David Sliney (perspectives from ACGIH), Richard Vincent (perspectives from ASHRAE)

[3] Lew Radonovich (CDC) opens that we will discuss the regulatory space(or really lack of)
NIOSH in US is focused on occupational safety and health, seek knowledge and apply it to the workplace. Will move through the panel now.

[4] Aline Heffernan introduced, and explains focus on this space at EPA to give devices an even playing field.
Cameron Miller from NIST, a photonic expert, has measured from 4nm -2500nm. Wants the community to start talking consensuses standards for how much fluence needed.

[5] Richard Vincent - ASHREA perspective. Looking back at upper-room UV and how well it worked against TB.  Interest in the tech went away as TB become less of an issue, but now we are revisiting this all again.

[6] Also building design has changed over the last 50 years and a lot of work is different, used to use radiator heaters, higher ceilings. Work at ASHREA to help give guidance for upper-room implementation now.

[7] David Sliney - ACGIH representative. Organiziation is focused on TLVs , for example the UV values we have talked about all week. Prior limits had not been changed for 50 years, because there was no interest or need.

[8] The trigger to look at these limits came from lasers used in ophthalmologist space for eye surgery. Doctors very annoyed that limits were so low for them and required so much PPE. Funny given it's eye doctors complaining about eye safety limits at this conference!

[9] Helped limits get lifted, and was already started before COVID but 222nm space really helped push it over. There is not enough action spectra for the data, and want more especially in steep area of the ACGIH curve.

[10] Want higher resolution response, and would love to have lasers which are much more monotonic in the wavelength of light emitted.

[11] Belal Abboushi - PPNNL. Role is to publish educational pieces to advance Far UV, and and looking at test sites(rooms) and taking measurements in these installations and creating case studies to help increase adoption.

[12] Educational research and testing of products to help push the industry forward.

[13] Aline - Anything that kills or hurts a pest (including virus/bacteria) is considered a pesticide. This means it falls under the EPA, which means all pesticides are regulated by the EPA. All UV devices are regulated by EPA, but in 1976, "devices" exempt from registration.

[14] Typically, UV lights are considered "devices".  EPA is seeing more UV devices and enforces misbranding and misleading claims of pesticides.

[15] There are specifically defined terms: "disinfection" is a specific meaning for EPA and is ~99.9%, if less than this it's not "disinfection". Disinfection, sanitization (99%) and sterilization (99.99%) are specific EPA language and is "regulated" by them for claims:

[16] All devices need to be made in a EPA establishment location (just generally paperwork), but registration would mean that if you change claims then also need to make update. Have questions? This is the person who manufacturers contact for help.

[17] Moving into Q&A now:
Q: Have ionization products ever got in trouble for mislabling devices (bi-polar, specifically)?
A: Yes, they have.
Q: Can you call the EPA if you see false claims, like from ionization devices?
A: Yes, and please do.

[18] Q: I can't call lamp germicidal if it's not 254nm, true?
A: EPA sees each device having its own claims, and requires data to support it.

[19] Discussion of an issue is around what define a device, (USHIO sells lamps but not finished devices)
A: Mostly driven by what is the intent and what is being said about the product
Q: Do FDA have a different framework from EPA?
A: Yes, but not familiar

[20] Q[Ewan Eadie]: Loves steady state standards, but wants to see matching international standards across the world. Germany working on standard. Is there collaboration w/ international bodies?
A: Typically doesn't work w/ EU, but is collaborating with Canada and meet regularly

[21] A: Previously during covid pandemic, you couldn't sell a UV product in Canada, and you couldn't register it, as they had no standard to test it against in order to register. Standards are the way to go, regulation maybe not so much

[22] A [Sliney]: Too early likely for regulation, but need to focus on standardization. Setting a threshold at 99% seems to not apply to what are we talking about.

[23] A: Not to much the 99% issue, but more so making claims of 99% of specific pathogens, and then having other devices make claims better or worse. That is the issue.

[24] Q: Some labs are doing modified ASTM test using lamps, and putting it 2" from coupon and getting 99.9999% but in real life you would never get that. How do you deal w/ that from consensus standards to being helpful to consumer, installation and manufacturing doing it right?

[25] A: Some companies do things such as claim it can do a room this big, but lab data from a much, much smaller room. So having a standard to compare helps. There will be a rule clarification, and can provide to the 1976 FRN, photocatalytics and generators(NaOH generators)