Re: Health Canada Advisory regarding Ozone Generators
February
5, 1999
On
February 5, 1999 Health Canada issued an Advisory to the
public regarding the use of air cleaners, specifically
ozone generators, used in homes. The purpose of this letter
is to give you some background on this Advisory, as well
as the Ozone Industry we all share an interest in ensuring
we are not arbitrarily dealt with by uninformed regulators.
BACKGROUND
On
January 19th, Health Canada organized a "Manufacturers Teleconference" which they scheduled for January 21, 1999. It was attended by Simpson and others.
This was the first time Simpson became aware of Health
Canada's intentions regarding ozone generators. At
that Teleconference, Health Canada announced their
intention to issue the Advisory. Participants were
given five minutes to express their views. The manufacturers
present included Simpson, Alpine Industries, Azco Industries
and Hankin Ozone.
The participants in turn condemned the process Health Canada was using; were
critical of the new CSA Technical Information Letter No H-13 (which Simpson
had just seen one (1) day before the meeting) and requested that any forward
process include the ozone industry. All Industry comments were ignored by Health
Canada and the Advisory was issued on February 5, 1999. The Industry saw the
publication at the same time as other members of the public. There was no consultation
prior to issuing either the Advisory or CSA TIL No H-13. All technical support
documentation used by Health Canada to support their position was denied to
the Teleconference Attendees prior to February 5, 1999.
On February 12, 1999 Simpson met with Ajmer
Bal, CSA author of TIL H-13, on behalf of the Ozone Industry. CSA were unable to explain why notification
of the new TIL was not provided to members of the Industry. CSA acknowledged that they had no expertise in ozone and that the normal process for new standards development would be to interface
with an Industry Association that would provide the required expertise. They indicated that the standard currently being used for ozone generators was
an electrostatic air cleaner standard, developed without any consideration
for ozone generators. On February 16, 1999 Simpson wrote to the CSA on behalf of the Industry asking
for changes to TIL H-13 and the development of new standards appropriate for
ozone generators. At that meeting, CSA had acknowledged the need for such a
new standard.
HEALTH
CANADA ADVISORY dated February 5, 1999.
In
issuing the Advisory, Health Canada has acted without consulting industry experts. The result is what one would expect from such a
process - a seriously flawed document. Our specific
comments follow:
The Advisory and concerns of Health Canada are focused
on the use of ozone generators in homes. In particular,
they have focused on the sale of units
by Alpine Industries. An Alpine generator was the only unit Health Canada tested
and we believe their reference to most devices being sold door to door is a
reference to Alpine's MLM distribution model. We have found no evidence that
they have given consideration to commercial applications. Simpson generators
are clearly labeled as "Commercial" and
have always been sold as such to the best of our knowledge.
We disagree with several Advisory statements. In particular,
*"The direct and purposeful generation of ozone indoors should
be avoided." Only in Canada is this extreme view prevalent. The rest of the world uses ozone
to purify air and oxidize substances that would otherwise adversely affect
health. In our view, the statement displays ignorance of the use of ozone for
odour control and purification.
*"CSA issued new interim requirements." This
is not true. All Simpson products that carry the CSA label meet current CSA requirements
and continue to be available for sale. CSA have indicated a requirement to
certify products to their new standard. That standard, if left unchanged, requires
new labels on March 1st, 1999, which Simpson intends to provide and a retesting
of products to the new standard before August 1st, 1999. There are no interim requirements.
*"Health Canada advises Commercial ozone generator users to
discontinue use or have the devices tested to ensure exposure levels are not
exceeded." We see no reason to discontinue the use of any Commercial ozone generator. There
is simply no compelling evidence to suggest that this is necessary. In our view, there is no conclusive evidence that exposure to less than the Occupational Health & Safety Administration OHSA (U.S.A.) Standard of 0.1PPM is harmful. In order
to err on the side of caution testing is advised if there is any cause for
concern. Simpson can assist you in that process should you need assistance.
*"Health Canada is working with manufacturers and distributors...to
voluntarily recall generators sold for household use." To the best of our knowledge no such activity is taking place. Simpson units
have been clearly labeled as Commercial and based on our experience and the
number of complaints we have received (there have been none) we do not believe
there is any justification for a recall. We have no intention to issue a recall
on any of our units.
HEALTH
CANADA MISINFORMATION
Health
Canada have engaged in the dissemination of false information
over their web page and through their response to calls
by the public. We do not know of a single case of death or permanent injury resulting from over-exposure
to ozone. As an Industry participant we encourage you to complain to Health Canada regarding
these false statements. The quotations from their web
page are provided below:
"At ground level, ozone is an air pollutant." We
contend that ozone is a natural cleaning agent that oxidizes the pollution from
other sources. Health Canada would be better advised to warn against the real
problems ie. car exhausts & other emissions, rather than attack the cleaning agent as the problem. We are not aware of any adverse health effects, at any time, anywhere in the world, as a result of high ozone levels after a
thunderstorm. Health Canada have now effectively declared those levels to be
a danger to the public. Isolating ozone as the problem in the pea soup that makes
up city smog is very bad science. Extrapolating that situation to the Commercial
ozone industry is totally inappropriate.
Health Canada have stated that "the
largest use of Commercial generators is for treating water in swimming pools." As we are all aware, this is a completely ludicrous statement. You could point
out that the City of Los Angeles purifies their drinking water with ozone.
Health Canada have implied that ozone in small concentrations will not kill
bacteria. This is an area with many different and complex applications in a
commercial setting. Health Canada have demonstrated a bias in not presenting
the complete story. There
are literally hundreds of peer reviewed papers and other evidence that establishes
the effectiveness of ozone as a disinfectant. They have selectively used data in order to further an apparent anti-ozone
bias.
CSA
TIL No H-13
The
New CSA standard which goes into effect August 1st,
1999 is a seriously flawed document. It was poorly
conceived and developed without industry involvement,
contrary to standard CSA practice.
A standard has been set that allows only 0.05 PPM of ozone measured at 50 mm
from the nozzle of the unit. This is a ridiculous standard. It might be appropriate
for devices that produce ozone incidentally but it is certainly inappropriate
for ozone generators intended for Commercial applications.
There
is a requirement to maintain the level of ozone in an indoor space below
0.05 PPM using a control device. The 0.05 PPM is below current OSHA standards. The OSHA standards are a defacto
world standard and used for designing control devices and as a reference
point for provincial authorities. OSHA are a creditor organization for
CSA. We find no justification for the deviation by Health Canada and
CSA from the OSHA standards.
A.H. SIMPSON INDUSTRIES LIMITED
Author: Don Cooper, B. Eng., M. Eng.
To
read the complete document go to www.ozone-machines.com/docs/doc71.html
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