A HYPOTHETICAL STORY.
A large financial institution on Wall Street opened their doors October 1st and allowed their 700 employees the choice to work from the office again. The firm thought they had done everything right. In September, they installed UVC (254 nm) devices in their HVAC, as close to the coils as possible. Upper air disinfectors (254 nm) had been mounted to the eightfoot ceilings. The restrooms troffers had been retrofitted, and two of the four LED tubes that had been retrofitted in 2015 were removed and replaced with magnetic disinfectant strips (405 nm), giving the bathroom a weird bluish hue.
Many of the LED flat panels that were installed in 2015 were replaced with new luminaires (far-UVC light 222 nm) that provided lumens and continuous disinfection during the day. Still, other devices (254 nm) were installed to disinfect only at night when the space was unoccupied. Vacancy sensors were placed at all entrances and, as an added precaution, each 254 nm fixture had its own sensor equipped with PIR technology.
On October 1st, 212 associates showed up, eager to have a break from their kids and desperate to find some sense of normalcy. All 212 wore masks. By 10 a.m., a few of the older employees moved their masks to their chin in an effort to talk. The associates were aware of the many safety measures in place with UV disinfection being one of those components. Later that day two employees from the customer retention team began to see small lesions on their skin. A third complained of eye fatigue. By 2:00 p.m. five employees from that department complained about skin and eye irritation, and all suspected it came from the luminaires above their work area. They moved to a conference room and filed a maintenance report. The next day, maintenance, unsure of what to do, disconnected the fixtures above their work area.
Because they were in a safe building, on October 2nd, many workers removed their masks entirely while working at their desk, but most would reapply them when walking to a conference room or restroom. Monday, October 4th, two associates said they were not feeling well and left work early. They did not return on October 5th and four other people, who worked in close proximity decided to work from home. Late in the day, all six people realized they were all working from home and none felt well. They agreed to get tested the following day. One took an instant test which came back positive for COVID-19, two more took a two-hour test–also positive–and three others took a sendaway test and did not have immediate results. The text messages went out with a fury, and by 3 p.m. on October 6th a decision was made to close the building again.
All fixtures were certified by a third party; the job was designed by an experienced, award-winning lighting designer; and the plans were approved by the manufacturers. The contractor was licensed, although not trained on UV disinfection, and really had no idea of the complications.
On October 8th, an army of people arrived at the building including four engineers and one PhD from two different manufacturers, two regional managers from those manufacturers, two contractors and their supervisor, as well as the rep that sold the job. The team discovered that two vacancy sensors were simply not installed on the fixtures in the customer retainment area. No one knew why. All disinfection units installed on the four HVAC units were correctly connected and working as designed. Unfortunately, two additional HVAC units had been added in 2012 and were not on the original plans, so those units did not receive any disinfection devices. Of the 50 upper air units that were shipped, only 45 were installed and the remaining 5 were unaccounted for. The open-office layout was designed with 4-foot-high panels and, because of COVID, one of the managers insisted that his team have 8-foot panels. This extra protection actually blocked much of the UV disinfection in that area.
“With UV-C, too much can cause harm, not enough can cause harm, and the wrong type can cause harm. In other words, the dose has to be perfect!”
In my opinion, it is not an issue of certifying the products but of certifying the installation. Our industry has strong electrical compliance, but there is no application compliance. What body or organization will be responsible for ensuring accurate installs? Which organization will act as the UV-C Police to ensure the fixtures are installed correctly? Who will measure the radiance and at what levels?
Should the measurements be taken at desk height, or at 6 foot?
UV disinfection is like the Wild, Wild, West, with lots of claims and different companies making outlandish promises. No one quite knows where to turn. Where have we heard the “Wild, Wild, West” term before? In 2006-2008 as LEDs were moving into general lighting. It was complete chaos with outrageous and unproven claims. In 2008, the industry stepped up and IES gave us LM79 and LM80. That same year ENERGY STAR®, along with the DOE Solid State Lighting (SSL) team, created a qualification process for consumer-focused LED lighting products in order to avoid the market-introduction pitfalls that compact fluorescent light bulbs (CFLs) had suffered in the early 1990s, with their stark color temperatures, long warm up time, low CRI, short life and over-hyped expectations.
Also, in 2008 energy efficiency program managers in the Northeast turned to a little-known organization in our industry, the DLC, to create a similar resource for commercial-grade LED luminaires, and thus, the DLC, as we know it today, was born. The DLC continues to help us over a decade later, and their role is greatly expanded.
Today we are in a similar situation. Simply replace the initials LED with UVC and its deja vu all over again.
In general lighting, most lighting designers tell me they usually err on the side of too much light instead of not enough, as tuning down lumens is much easier than adding additional luminaries. It is very difficult to achieve surface disinfection in inhabited spaces, like offices because of the risk of exposure to the people working in the space. With UV-C, too much can cause harm, not enough can cause harm, and the wrong type can cause harm. In other words, the dose has to be perfect!
Once the UV-C disinfection job has been installed, whose job is it to make sure it is, in fact, perfect? Does the luminaire manufacturer have a responsibility to send an engineer to ensure the upper air fixtures are not reflecting radiance off a shiny object? What about the local rep that may have done the commissioning? What is the role of the lighting designer, who worked close with the manufacturer to prescribe the proper dose? If a person is injured, who gets sued?
What is the industry doing to tame the UV-C beast?
WE ASKED IES. Mark Lien, Market Relations Manager, explained that the IES Testing Procedures Committee is developing a method of measurement of UV sources to enable manufacturers to test products in a way that can be compared. He also said that the IES Photobiology Committee is also working on an RP for UV applications. Alex Baker, IES Manager of Government Affairs & Public Policy, explained that IES is working on a project to promote awareness and improve the application of ultraviolet “disinfection” technology with the International Ultraviolet Association. Today’s IES is more professional and much faster than the IES in years past, so we expect these results soon. However, at this point the IES has no plans in getting into the application verification business.
NEXT, WE ASKED UL. Adam Lilien,Global Business Development Manager, Connected Technologies and Pamela Gwynn, Principal Engineer, explained that UL, the American Lighting Association (ALA) and NEMA have released a new position paper due to an increased demand for sanitizing and germicidal capabilities in the face of COVID-19. The paper “Ultraviolet-C (UVC) Germicidal Devices: What Consumers Need To Know” provides a deeper look at the UVC germicidal devices available to consumers and their potential to cause severe injuries to humans and pets, as well as damage to plants and materials. UL has a path to certification for many types of consumer, healthcare, and professional products that meet appropriate containment criteria and caution against products without safety certifications.
THEN, WE ASKED THE DLC. We spoke to Leora Radetsky, Senior Lighting Scientist, who explained that the DLC has no plans to add disinfection lighting product to the QPL. The DLC is drafting a white paper for their members to introduce them to the topic. The paper will provide enough information for the members to understand the technology, the terminology, and the applications regarding dosing and disinfection rates to inactivate specific pathogens. The paper will also discuss the various types: Upper Air, Surface Disinfection, and HVAC. Originally, I misunderstood thinking the members were the OEMs who pay the bills, but it is only for their utility customers.
LAST, WE ASKED TWO LUMINAIRE MANUFACTURES. Cliff Yahnke, Ph.D., Director of Clinical Affairs at Kenall is arguably one of the country’s experts in visible light disinfection, due to his role in the development of Indigo-Clean Continuous Environmental Disinfection. He said, “Although we employ 405 nanometer and not UV, we know our product is completely safe because we invest in third party testing to IEC62471. Safety of lighting disinfection is critical, and easy to misunderstand, so it’s important to insist on a test certificate –for each product being used, and against all hazard categories– from a third party UL certified laboratory.” Yahnke also explained that Kenall has strict dosing parameters for every installation and hospitals submit room dimensions and Kenall determines the number of fixtures required to meet their clinical performance claim.
Santino Nemi, Chief Operating Officer at Viscor cautioned that a little knowledge is harmful. Santino explained that some agents berate him to quickly bring UV products to the market. He has been successful in fending them off by asking if they would be willing to sign a hold-harmless agreement. An immediate change in tone occurs and the rep begins to understand the inherent risks. “The UV-C products resemble the look of a luminaire—but that is the only thing it has in common with lighting.”
Santino said, “Responses from regulatory bodies have evolved, but there is still no framework in place to certify a job.”
We went back to UL for a second call and Pamela Gwynn explained that it is unclear who should have the final sign-off once the disinfection luminaires have been installed. Pam said, “It is up to the manufacturer to get their protocol tested and get conformity documents that show if you follow the protocol, the device will meet its specifications.”
In some cases, the FDA is involved as medical claims are part of their jurisdiction. UL is not overly concerned about misuse in the medical field as most health care facilities have a governing body of individuals who have jurisdiction to ensure what is being used in the hospitals is correct. Adam Lilien said, “UL is developing new guidelines as the technology adapts.”
The conversation evolved from less of an interview to more of a brainstorming session with all of us asking each other questions. We agreed that the lack of application verification is a huge problem. Adam suggested creating a financial program either from the utilities or federal stimulus, to fund a pot of money that would be rebated to end users who install UV disinfection combined with the best practices of the Well Building Standard. Buildings could become healthy and safe at the same time. The question is where would the money come from and which body would manage it?
If we are going to gain trust and help get the world back to work, the industry has to come together and ensure we prevent those issues experienced in our hypothetical financial firm.
As an industry, we can’t introduce UV to the world the way we launched CFL.