Food Safety Systems, LLC

September 20, 2007
California Environmental Protection Agency
10011 Street
P.O. Box 2815
Sacramento, CA
95812-2815
RE: Proposed Regulation to Limit Ozone Emissions from Indoor Air Cleaning Devices
To: California Air Resource Board:
My name is Pamela Hatesohl. I am Director of Research for Food Safety Systems, LLC. The California ARB has identified a safe level for indoor ozone exposure and I support the 0.05 ppm standard. However, there is an issue that needs to be addressed before the regulation is finalized - that is a modification in the method for measuring indoor ozone levels for the purpose of certifying conformance to the proposed standard.
I was involved in evaluating the EcoQuest RCI and AT Ozone producing systems. Both produce low levels of ozone in indoor environments and both will meet the proposed standard. However, through my research, I observed that measuring ozone levels in an empty chamber can lead to erroneous results. I assisted in a research project that resulted in the publication - Efficacy of EcoQuest Radiant Catalytic lonization and Breeze AT Ozone Generator in Reducing Microbial Populations on Stainless Steel Surfaces.
This research was conducted in a mini environmental enclosure. When samples were placed in the enclosure, the ozone levels were naturally maintained at 0.02 ppm. This is due to the highly reactive nature of ozone and the fact that it readily reacts with any available biological substrate. However, if the testing chamber is sterile and free of any biological material (as proposed in the UL testing protocol), there is nothing for ozone to react with and levels will simply increase over time. This will not simulate actual conditions and will result in false and erroneous measures of ozone levels.
13OO Sharingbrook Drive » Manhattan, KS 665O3 » Phone 785-537-4043 » Fax 785-537-4043

This is an extremely critical issue and must be resolved before a regulation is put into effect. If not, the significant public health benefits associated with low levels of ozone due to infection prevention will be lost.
Sincerely,

Pamela Hatesohl Director of Research