GERMICIDAL UV SAFETY AND STANDARDS

IEC Photobiological Safety The International Electrotechnical Commission published standard 62471, photobiological safety of lamps and lamp systems. This document assigns an LED risk group for each system. The LED risk group ranges from an exempt risk group that poses no photobiological hazard to risk group three with systems that may pose a hazard even for momentary or brief exposure. UL Photobiological Safety with IEC Risk Groups

IES Photobiological Safety The Illuminating Engineering Society published ANSI IES RP-27-20 Photobiological Safety for Lighting Systems. Their lamp classifications are very similar to the IEC in that they have an exempt group as well as three risk groups that range from a very low risk low risk in high-risk sources. The document also offers a spectral weighting function for assessing ultraviolet hazards, broken out by wavelength. IES Lighting Library

ACGIH Threshold Limit Values Another scientific organization focusing on health and safety, The American Conference of Governmental Industrial Hygienists has published guidelines for the level of UV exposure that a typical worker can be exposed to without adverse health effects. Known as TLV‘s or threshold limit values, the ACGIH has established a 22 milli-Joule per centimeter squared value based on eight hours at 222 nm.

As an example, many people may not know that over exposure to UV can happen in just seconds but symptoms may not become apparent for a day or two. Also, because UVC lamps have such little visible light output, people’s natural defensive reactions to optical hazards including blinking, squinting, and looking away may not even be triggered with enough effect to protect the eyes. ACGIH TLV Guidelines

FIFRA Registration as a Pesticide As the COVID-19 pandemic has affected the lives and livelihoods of millions, the lighting industry has marketed germicidal ultraviolet devices with claims that they kill germs, bacteria, and viruses. All devices that carry these claims are subject to regulation by the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), which governs the registration, distribution, sale, and use of pesticides in the United States. FIFRA requirements are enforced by the Environmental Protection Agency (EPA), which recently issued a Compliance Advisory regarding such devices.

FIFRA states that a pesticide device is “any instrument or contrivance (other than a firearm) intended for trapping, destroying, repelling, or mitigating any pest or other form of plant or animal life…” Pesticide devices must work solely by physical means (i.e., electricity, light, or other mechanisms) and are categorized differently than pesticide products, which work through substances. While pesticide devices do not need to be registered with the Agency, they are subject to various requirements regarding labeling, production, importation and exportation, and packaging. See 40 C.F.R. § 152.500(b).

The EPA’s Compliance Advisory provides that these UV devices must be produced in an EPA-registered pesticide producing establishment; must be labeled pursuant to federal regulations, which includes warning and caution statements, directions for use, among other requirements; and must be marketed in compliance with FIRA Section 12(a)(1)(F), which prohibits false or misleading claims.

Unfortunately, these regulations fail to address germicidal UV performance and effectiveness. Rather, the EPA advises that the effectiveness of any UV device “will depend on a variety of factors including, but not limited

to, the device’s duration of use, distance of the light from the surface intended to be treated, the UV wavelength, the specific pest being targeted, the strength or wattage of the UV light bulb, the age of the UV light bulb, shadow areas or other factors.” EPA compliance advisory PDF

FDA Guidance The US Food and Drug Administration (FDA) regulates UV devices as “electronic products” and has issued general guidance regarding effectiveness. According to the FDA, UVC is a known disinfectant for air, water, and nonporous surfaces, and has been used for decades to reduce the spread of bacteria. The FDA has advised that UVC may also deactivate some viruses by destroying their bonds of DNA and RNA, if the viruses are directly exposed to the radiation in the proper dose and duration.

However, at this time, the effectiveness of UVC in deactivating the SARS-CoV-2 virus is unknown, given the limited published data regarding the wavelength, dose, and duration of UVC required. The FDA also notes that direct UVC exposure poses health and safety risks to humans in that it can cause burns to the skin and eye injuries, and some UVC devices are also capable of generating ozone, the inhalation of which can be irritating to airways. FDA UVC FAQ

Future Performance Measurement Standards The The Illuminating Engineering Society (IES, est. 1906) and the International Ultraviolet Association (IUVA, est. 1999) have partnered to assemble experts in the measurement of ultraviolet C-band emissions (UV-C) to develop American National Standards for the measurement and characterization of UV-C device performance. Through this partnership IES and IUVA aim to cooperatively promote awareness of and improve the application of ultraviolet “disinfection” technology in the healthcare system, initially through the development of standardized methods of measurement of ultraviolet “disinfection” products including UV lamps, luminaires and lighting/radiating systems, utilizing both discharge (e.g. low-pressure mercury and xenon) and solid-state (e.g. light-emitting diode) technologies.

A series of American National Standards (ANSI standards) are envisioned. The first standard, Approved Method for Electrical and Ultraviolet Measurement of Discharge Sources, will detail laboratory procedures for the measurement and characterization of lowpressure mercury and other discharge sources. The second, Approved Method for Electrical and Ultraviolet Measurement of Solid-State Sources, will do the same for UV-LED components. IES and IUVA UVC collaboration

Conclusion As the public learns about the effectiveness and limitations of GUV, the lighting industry must continue to provide standards and guidance that provide a complete framework for both safety and performance. Only then will lighting practitioners have the proper tools to design and install germicidal lighting in a way that inactivates viruses, kills bacteria, and ultimately save lives.

About the Author

Frank Agraz has worked in the energy efficient lighting community for 27 years and is currently senior director of strategic initiatives at Eco Engineering. He is responsible for improving the customer experience by enhancing the company process and raising awareness of Eco Engineering as a leading design-build lighting retrofit provider. Prior to his current role, he founded Maneri-Agraz Enterprises, a national turnkey energy services company. Mr. Agraz is Lighting Certified by the NCQLP and is currently its Exam Committee Chair, the group that develops and maintains the content of the annual exam. He serves on the board as an At-Large Director for the Illuminating Engineering Society. Mr. Agraz graduated from Texas A&M University with a BS in Industrial Distribution.

About Eco Engineering Eco Engineering is a national design-build energy services company specializing in providing turnkey lighting system upgrade services. We design and implement energy saving lighting and lighting control projects with compelling financial paybacks. Eco Engineering helps its customers reduce operating and maintenance expenses, boost employee productivity, while positively impacting the environment through reduced energy consumption. Visit https://ecoengineering.com/