Comment Log Display

TO ARB COMMITTEE

      Clerk of  the board
Air Resources Board
1001 I Street
Sacramento, California 95814


Electronic mail: http://www.arb.ca.gov/lispub/bclist.php

Facsimile submittal:  (916) 322-3928

                                                  APPENDIX II
 
Modified text for 15- day public comment  period 
June 30,2008 – July 15, 2008
Regulations for Limiting Ozone Emissions from Indoor Air
Cleaning devises.

It is assumed that responses to this June 30, 2008 proposed
regulation will be acknowledged by mail because responses to the
August 10, 2007  were never acknowledge or acted on in the
September 27, 2007 board meeting.

SUGGEST ADDITIONS
   
94803
   
Air cleaning  system to be used in ducting system are to meet the
requirements of 
Definition 94801 (a)(14) and does not exempt “in duct”
electrostatic air cleaners.  Systems may not have to be completely
contained within air duct.  Further the 94801 (a)(14) device for
ducting systems does not require integration by the OEM
manufacturer only and can be attached at a later installation
date.
           
           Current “in ventilation systems requirements” to limit
use of these devises
           constitutes a “restriction of trade” and is not
practical.



       	94803 or 94801 (33)
      
Definition of “industrial supply outlet” is a distributor, or
retailer of
      	service organization that sells to industrial customers as
part of normal
      	business.  Not definition at all.

      


94803(17) 

      Listing mark….. or other “certified lab” listing mark (ie
ETL, other).

     
     94803(d)

     Germicidal lamp systems including titanium dioxide or any
other photo catalytic or
     advanced oxidation devices.


    94803(e)

    Any contact communicator fans, blowers and mechanical filters
(filtration only) that
    generate ozone by brush bounce, or dirty contactors.

    94803(f) 

   Any cooling/air cleaning fans that cool high voltage or
inductive electronic 
   equipment capable of producing or distributing corona
discharge.


   94809(add)

The Executing Officer must provide manufacturer with a “right of
due process,”       proper testing verification, description of
violation and a proper time to cure a violation.   Financial
losses incurred by manufacture or distributor by improper or
inappropriate recall  shall be the financial responsibility of 
ARB or the State of California (as appropriate).

  Tests of all units conducted by ARB will be supplied along with
any analysis done by
  ARB.


 94804

Once data is submitted it shall be acted on timely and approval
shall not be unduly held     or prioritized.  There shall be no
requirement on the manufacture to conform to undue ARB imposed
manufacturing standards.







94800(a)(15)(j)

Any industrial application, with people not physically present,
that completely contains the ozone process or any ozone process
that completely contains the ozone in a container
incapable of having people occupy the container, are exempt from
this Standard but must
still comply with  Equipment Safety Standards.