Comment Log Display

 


To: California Air Resource Board

RE: Proposed Regulation to Limit Ozone Emissions from Indoor Air
Cleaning Devices

ClearWater Tech is a manufacturer of Ozone generators located in
San Luis Obispo, Ca.  

We support the need to regulate indoor Ozone generators and are in
agreement with the proposed regulation as written.

The comments we have concern the UL test procedure. 

1) The room that the device is tested in needs some amount of air
exchanges or it will not be a realistic test.  The test calls for
0 to 0.35 changes /hr.  We would propose that the spec be 0.2 to
0.35 changes/hr.

Reason.  A room that has no air exchanges over a 24 hour period
would be most likely unbearable for a human.

2) The test room should have some sort of typical household
material placed in it such as carpet, drapes or upholstery
material.

Reason:  In a normal room occupied by humans, these materials
would be present.

3) The Ozone level in the room should be monitored at a greater
distance than two inches from the product.  We suggest at least
two feet.

Reason: We can't imagine someone putting his or her face 2 inches
from an Ozone generator for 24 hours.



Best Regards

Cameron Tapp
President

Howard McClary
Director of Engineering
ClearWater Tech