By Bob Baker

ASHRAE held its 1998 annual meeting in Toronto June 20 through 24th. This was the first opportunity this writer has had to visit this modern yet beautiful city. The experience was totally pleasant and I look forward to an opportunity to return. The annual meeting is never as well attended as the winter meeting that is held in conjunction with the AHR Exposition. From the standpoint of technical content and society business, however the annual meeting is often as or more meaningful. This meeting was no exception.

Research Results

For those of us with a strong interest in IAQ, this meeting was especially interesting. ASHRAE sponsors a lot of research into various aspects of the science of HVAC. When it became apparent in the early 90's that poor indoor air quality was a significant concern that was not going away, ASHRAE began to direct a substantial amount of research funding to projects designed to help us better understand the factors that can influence IAQ. Some of that research is underway and preliminary results are being reported and discussed in technical sessions. This early research will not have immediate application to our daily work. Most of the findings will identify areas that need further investigation. Others will need to be validated through more detailed or extensive study. Even so, some of these early results can give us some insight into directions that our industry will take in coming years.

Conditions Inside of Air Ducts

During another conference, there was a presentation reporting research that had been done at Research Triangle Institute on duct liners and duct board. This research indicated that bacteria and fungi grow readily on both new and soiled fiberglass surfaces. Water or a separate food source does not have to be present. Elevated humidity provides enough moisture to support growth. New research results presented at this conference show that humidity inside of ducts might be much higher than we previously suspected. It has always been assumed that the air stream inside of air ducts was quite dry relative to the conditioned space. The early findings suggest that actually there is considerable moisture present in the air stream. If true, this would explain the levels of excessive growth that are often reported in the field in systems where there is no apparent source of water.

This research has not yet been published. When it is, there may turn out that the measurement method or site chosen for the study somehow affected the results. Even if the findings hold up, more study will have to be done to confirm the findings and better explain the causes. Only then will we be able to attempt to develop ways that the moisture level can be lowered.

In the mean time, there will be renewed interest in utilizing duct materials that can resist microbial growth or applying some type of treatment to duct surfaces that will handle growth problems. In the past, this has been an area of much confusion. Some products have been marketed for such applications yet their labels do not show directions for such a use. Other product labels contain confusing or unclear language.

EPA Registration A Must

Products that claim to control bacteria and fungi must be registered with the Environmental Protection Agency. As part of the registration process, EPA reviews the label language, directions for use, and approved sites. EPA has not approved products for use in air ducts during the past several years. Thus, when you see a product label that does not match the verbal claims being made for it, that product is probably not registered for the use that is being claimed.

It is not legal to use a product contrary to the label language. A contractor doing so could be subject to a huge liability. This fact coupled with the greater need to use something to prevent growth creates a real problem. The choices that are legally available are very limited. The above facts received a lot of discussion at the ASHRAE meeting because of another set of events that took place in the weeks before the meeting.

Treated Articles Exemption

The law that requires registration of products that make antimicrobial claims provides for some exemptions to that registration. One of these is for articles that are treated with a registered product so as to preserve them. An example of this is paint. The ingredients in many modern paints are organic. Many of these will spoil like milk would if left out of the refrigerator. Since it is not practical to refrigerate paint prior to use, a means of preventing spoiling was needed. It turns out that adding a small amount of an antimicrobial prevents the bacterial growth that causes spoilage. EPA did not want to face the task of registering every product that had an antimicrobial added to keep it from spoiling so they supported a provision in the law that exempts such products from registration. The provision requires that the antimicrobial is registered for such uses and the product label (i.e., paint) may not make any antimicrobial claims.

This initially worked well for everyone because manufacturers of such products did not wish to claim any antimicrobial properties for their products and certainly did not want to invest the considerable time and money required for getting a registration. They would have to have run expensive tests (which their products may have not passed). They would have been forced to establish regulatory departments and learn to deal with the many complex laws that govern the registration process. Instead, the seller of the additive took care of those matters.

Some manufacturers have taken this exemption well beyond the narrow use allowed by the law. They prominently feature the fact their products contain an "Antimicrobial". Their advertising leads consumers to believe that the antimicrobial additive provides protection well beyond just preserving the product. In some cases, manufacturers have stated that the products so treated will prevent the spread of disease. Products that use such additives (and some of which make such claims) include paints, duct coatings, duct liner materials, air filters, coil coatings, and a large number of common consumer products.

Recent EPA Actions

During the past couple of years the antimicrobial claims being made have become more and more prominent in product advertising. Finally, EPA enforcement officers started to crack down on those in violation. This has had two impacts. First, many of the offending companies refused to come into compliance with EPA's demands. They mounted legal challenges to the enforcement efforts. Second, consumers are confused about the real facts. Most are unable to tell the difference between a legally registered product and those abusing the treated articles exemption. This has especially impacted the HVAC industry and was the subject of a lot of conversation and debate at the Toronto meeting.

Next month we will discuss a research report on filter media that is causing a lot of the discussion, provide some guidelines for telling the difference between registered and unregistered products, and speculate where this entire matter is likely to go during the coming months. The outcome will have a major impact on your business and the confidence customers have in all of us and the products and services we sell.

Mr. Baker's field of expertise is the control of contamination in air-conditioning and ventilating systems by mold, mildew and bacteria. He writes and speaks frequently about the efficacy, legal risks, and regulatory issues involved in various control strategies. He serves on ASHRAE Technical Committee TC 2.3, TC 2.4, TC 9.8, and Sampling of Airborne Particulate Concentration in Commercial and Residential Buildings GPC 17P. He also serves as a member of ASTM D22.06 (Indoor Air Quality) and is on the Board of Directors of the Indoor Air Quality Association and the Florida Public Health Foundation. Because HVAC applications encompass new uses from an U.S. EPA regulatory standpoint, Mr. Baker works closely with the EPA and industry groups, including serving as the chair of the IAQ committee of the Consumer Specialty Products Association, to help formulate policy in this area.

Bob Baker is Chairman and CEO of BBJ Environmental Solutions, Inc., a company specializing in providing clean air through environmentally responsible products, such as BBJ MicroBiocide , BBJ Micro Coil Clean , "FreshDuct Odor Eliminator ", and BBJ Mold and Mildew Remover™ as well as the revolutionary new Power Coil Clean™. For additional information, Mr. Baker can be reached at (800) 889-2251 or through the company web site at http://www.bbjenviro.com.