A.H. SIMPSON INDUSTRIES LIMITED

Author: Don Cooper, B. Eng., M. Eng.

Re: Health Canada Advisory regarding Ozone Generators dated 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. A copy of the advisory is enclosed for your reference. (Advisory Link) 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. We will make every effort to keep you informed of important developments in this matter on a continuing basis.

BACKGROUND

On January 19th, Health Canada organized a "Manufacturers Teleconference" which they scheduled for January 21, 1999. It was attended by Simpson and others within the industry. 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. Distributors were also represented.

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.

Since the Advisory and CSA documents do not adequately differentiate between Residential & Commercial, we remain affected by the Advisory. 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.

Health Canada makes other claims with respect to the effectiveness of ozone. We'll comment on those issues at a later date. In general however, you must seriously question the quality of research and depth of knowledge of an organization that believes the largest Commercial ozone applications are for swimming pools.

CSA TIL No H-13

The New CSA standard which goes into effect August 1st, 1999 is a seriously flawed document. We are working to get it changed. It was poorly conceived and developed without industry involvement, contrary to standard CSA practice. The main issues are:

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. This is often an inappropriate requirement in unoccupied spaces. In addition, 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.

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