First Name | Ronald |
---|---|
Last Name | Barnes |
Email Address | rbarnes@prozoneint.com |
Affiliation | Prozone |
Subject | Comments |
Comment | 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. |
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Date and Time Comment Was Submitted | 2008-07-16 16:39:58 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.