Re: Another new technology

[Guest guest]

Carl,

I have been through their website, and I cannot find anything

resembling an EPA-registration number. My first thought is that I

want to see what EPA was willing to accept after reviewing their data

(if any), not what they say about their treatment process.

Do you have an EPA registration number for CIMR or the constituent

biocide being used to generate the HOOH gas?

Suspiciously Yours,

Cole Stanton

FIBERLOCK

>

> Anyone know about this new CIMR technology?

>

> They claim testing by Kansas State University and Sandia Labs.

> Doesn't appear to be MLM oriented and, despite the name, doesn't

> appear to be related to EcoQuest and others - although I found out

> about it from someone who was approached by a salesperson for the

> $400 home unit.

>

> Press release at: http://www.mmdnewswire.com/globl-ecotek-llc-

> announces-brekthrough-cimr-tm-infecti-ctrol-technology-1997-2.html

>

> http://www.ecotekltd.com/

>

> Carl Grimes

> Healthy Habitats LLC

>

[Guest guest]

Carl,

Killing the bacteria and/or mold although I

see no provision for removing the dead matter from the air stream. As we all

know, the dead body parts and/or spores are a concern as well.

EnviroBob

From: iequality [mailto:iequality ] On Behalf Of Carl E. Grimes

Sent: Monday, August 13, 2007 1:34

PM

To: iequality

Subject: Another new

technology

Anyone

know about this new CIMR technology?

They claim testing by Kansas

State University

and Sandia Labs.

Doesn't appear to be MLM oriented and, despite the name, doesn't

appear to be related to EcoQuest and others - although I found out

about it from someone who was approached by a salesperson for the

$400 home unit.

Press release at: http://www.mmdnewswire.com/globl-ecotek-llc-

announces-brekthrough-cimr-tm-infecti-ctrol-technology-1997-2.html

http://www.ecotekltd.com/

Carl Grimes

Healthy Habitats LLC

[Guest guest]

Carl,

Killing the bacteria and/or mold although I

see no provision for removing the dead matter from the air stream. As we all

know, the dead body parts and/or spores are a concern as well.

EnviroBob

From: iequality [mailto:iequality ] On Behalf Of Carl E. Grimes

Sent: Monday, August 13, 2007 1:34

PM

To: iequality

Subject: Another new

technology

Anyone

know about this new CIMR technology?

They claim testing by Kansas

State University

and Sandia Labs.

Doesn't appear to be MLM oriented and, despite the name, doesn't

appear to be related to EcoQuest and others - although I found out

about it from someone who was approached by a salesperson for the

$400 home unit.

Press release at: http://www.mmdnewswire.com/globl-ecotek-llc-

announces-brekthrough-cimr-tm-infecti-ctrol-technology-1997-2.html

http://www.ecotekltd.com/

Carl Grimes

Healthy Habitats LLC

[Guest guest]

Cole,

It seems obvious the CIMR concept does not require EPA registration.

For that matter neither does Carl Grimes' services require EPA

registration. You on the other hand sell a product which by law

requires registration.

You can rest assured Mr. Holt like other prime government

contractors has all the licenses, registrations and clearances needed

to act in the environmental field.

Gibala

===========================

> >

> > Anyone know about this new CIMR technology?

> >

> > They claim testing by Kansas State University and Sandia Labs.

> > Doesn't appear to be MLM oriented and, despite the name, doesn't

> > appear to be related to EcoQuest and others - although I found

out

> > about it from someone who was approached by a salesperson for the

> > $400 home unit.

> >

> > Press release at: http://www.mmdnewswire.com/globl-ecotek-llc-

> > announces-brekthrough-cimr-tm-infecti-ctrol-technology-1997-2.html

> >

> > http://www.ecotekltd.com/

> >

> > Carl Grimes

> > Healthy Habitats LLC

> >

>

[Guest guest]

Cole,

It seems obvious the CIMR concept does not require EPA registration.

For that matter neither does Carl Grimes' services require EPA

registration. You on the other hand sell a product which by law

requires registration.

You can rest assured Mr. Holt like other prime government

contractors has all the licenses, registrations and clearances needed

to act in the environmental field.

Gibala

===========================

> >

> > Anyone know about this new CIMR technology?

> >

> > They claim testing by Kansas State University and Sandia Labs.

> > Doesn't appear to be MLM oriented and, despite the name, doesn't

> > appear to be related to EcoQuest and others - although I found

out

> > about it from someone who was approached by a salesperson for the

> > $400 home unit.

> >

> > Press release at: http://www.mmdnewswire.com/globl-ecotek-llc-

> > announces-brekthrough-cimr-tm-infecti-ctrol-technology-1997-2.html

> >

> > http://www.ecotekltd.com/

> >

> > Carl Grimes

> > Healthy Habitats LLC

> >

>

[Guest guest]

When referring to abrasive method, are you (collective you) referring

to simply scraping it off surfaces or soda blasting, for example off

of wood, since I think most agree drywall should be removed and

replaced.

>

> Carl,

>

> I don't believe that the abrasive method can be skipped

[Guest guest]

Ken,

Apologies for the lateness of the reply, but your response to my post

raises an interesting topic worth discussion.

Your are quite correct on two points

• Consulting services do not require EPA registration as a pesticide,

as they do not kill anything (except when improperly employed and

then budgets, schedules, customer patience can all suffer painful

deaths).

• Biocides and antimicrobial products, among them products from

Fiberlock and others, which are formulated for

killing/destroying/disinfecting/sanitizing, etc. must be EPA-

registered in accordance with FIFRA, as well as be registered in any

state in which the products are sold or used.

The topic of pesticidal devices (a term of convenience for this post,

not an official category as far as I know) is an interesting one

where perhaps some of the EPA participants in this group might help

with a clarification (Henry, if you are reading, help us out here!).

My understanding is that whether processes or equipment have to be

registered as pesticides would depend on what the process or

equipment is, and what claims are being made. In some cases,

equipment could fall into a pesticide device category, which doesn't

require registration but which is subject to a number of pesticide

requirements in relation to labeling, or perhaps invoke requirements

for production in registered establishments. Throwing it out for

discussion, I would surmise that such devices might be UV light or

other equipment/processes that kill or mitigate by physical means.

(How about flyswatters?)

Similar to the Treated Articles Exemption in FIFRA, if a process or

equipment that creates a physical barrier against a pest, and no kill

claim is made, then registration would not be required.

Once a chemical is involved, then EPA-registration would be required,

as I understand things. In this case a chemical is involved, as

noted in the first paragraph on the EcoTek home page:

" Global Ecotek, LLC is the only provider of CIMR™ Infection Control

Technology. CIMR™ Infection Control Technology is an ozone-free

process that uses minute amounts of hydrogen peroxide gas to

disinfect viruses, bacteria, molds, and other fungi. "

Moreover, elsewhere on the website there are organism specific

pesticidal claims that would seem to warrant EPA-registration, such

as:

" The hydrogen peroxide gas technology used in CIMR™ Infection Control

Technology has been demonstrated to be effective against every virus,

bacteria, mold, and other fungus against which it has been applied to

date. Also, independent university studies have documented that it is

effective against the H5N8 virus, MRSA (Methycillin Resistant

Staphylococcus Aureus), nonresistant Staphylococcus Aureus, E-Coli,

Listeria Monocytogenes, Candida Albicans, Stachybotrus Chartarum

(Black Mold), Streptococcus, Pseudomonas, and Bacillus Subtillus. "

Thus, my first thought when reading Carl's post was to look for EPA-

registration information. What I expected to find was something

similar to the SABRE chlorine dioxide method, i.e., the equipment

used to generate the gas are not EPA-registered pesticides, but the

constituent chemical used to generate the gas has an EPA-registered

label with important safety & health information, use instructions,

etc. An EPA-registered label for the CIMR constituents would provide

a good starting basis for evaluating and validating the performance

claims on the EcoTek website.

Again, this post contains my understandings/assumptions concerning

various aspects of what I would call pesticidal devices, and is

intended to elicit discussion from everyone. If any of these

thoughts are off-base or inaccurate, please reply post, as a better

understanding of this topic will likely benefit many of us.

Cole

FIBERLOCK

cwds@...

> > >

> > > Anyone know about this new CIMR technology?

> > >

> > > They claim testing by Kansas State University and Sandia Labs.

> > > Doesn't appear to be MLM oriented and, despite the name,

doesn't

> > > appear to be related to EcoQuest and others - although I found

> out

> > > about it from someone who was approached by a salesperson for

the

> > > $400 home unit.

> > >

> > > Press release at: http://www.mmdnewswire.com/globl-ecotek-llc-

> > > announces-brekthrough-cimr-tm-infecti-ctrol-technology-1997-

2.html

> > >

> > > http://www.ecotekltd.com/

> > >

> > > Carl Grimes

> > > Healthy Habitats LLC

> > >

> >

>

[Guest guest]

I just reviewed a case file regarding inadequate and/or negligent remediation. I think you will find the facts interesting, and applicable to this discussion of spores, dry or wet, removal or abrasion, etc.

In this particular case, during a 2002 inspection of an area with a leaky appliance an IH stated that the active mold growth he identified was the result of the left over, but dormant, spores from a previous 1996 remediation cleaning up mold from a leak in the same appliance. By the way, in 2002, the floor was wet, as in active, liquid water present.

He does not attempt to opine about the source of the 2002 mold, other than a leaky appliance.

Nor is there documentation about the appliance being fixed or replaced.

Interestingly enough, a third inspection, this time in 2004, found similar problems, and it related the wet moldy condition to the previous 2002 remediation. Yes, wet, again.

Also, the 2002 spec did not address any water leaks or problems. Just the remediation and clean up of mold. Which by the way included cleaning of all contents, including those on the second floor.

(there's a lot more, but you get the point)

So, I ask, if the 2004 mold was result of poor remediation of the 2002 mold and the 2002 mold was result of poor remediation of the 1996 mold, where did the 1996 mold originate?

Or, simply, Which came first, the Chicken or the Egg?

Oh yeah, and just for kix, the IH consultant in 2002 was hired by the insurance company addressing the loss, by 2004 he had switched consulting firms and was then the IH hired by the owner, who is suing the same insurance company who was his client in 2002! How this happens is beyond me.

Armour, M.S.Armour Applied Science, LLCGreen Building Healthy BuildingCleveland, OH

"The problems that exist in the world today cannot be solved by the level of thinking that created them." A.Einstein"If having endured much, we at last asserted our 'right to know' and if,knowing, we have concluded that we are being asked to take senseless andfrightening risks, then we should no longer accept the counsel of thosewho tell us that we must fill our world with poisonous chemicals, weshould look around and see what other course is open to us." CarsonGet a sneak peek of the all-new AOL.com.

[Guest guest]

Friends and colleagues:A few quick comments, based on what I've learned, but not necessarily authoritative.A "pesticidal device" is any equipment that can kill bugs without a chemical pesticide. You could register a shoe as a pesticidal device; put it on and stomp on any cockroach that you see. Generally, the law covering such devices is not as stringent as the laws for pesticides. No proof of efficacy is required, for instance.Is H2O2/hydrogen peroxide a pesticide? I don't ever recall hearing it labeled as such, but I could be wrong. Most store-brand bleach is not sold as a pesticide, but as a laundry additive, so it does not need EPA registration, as long as they make no pesticidal claims for it. Ditto for H2O2. If this firm is making a claim that the H2O2 kills some form of living creature, then the H2O2 is considered a pesticide and must be registered as such.FYI: I forwarded information about this Web site to our regional pesticide office. They will presumably take appropriate action. Stay tuned!Henry SlackAlthough this is the best information I can put down at this moment, that doesn't mean that it's entirely correct. Please don't treat it as necesarily complete or representing EPA's positions accurately. Thank you.

[Guest guest]

:

Thankx for your points.

Regarding the definition of pesticide: Congress passed the Federal

Insecticide, Fungicide, and Rodenticide Act (FIFRA) which defined

fungicides as " pesticides " . You can of course feel free to make words

do what you want them to, but us folks here from the government (and

yes, we're all here to help you) must in this case follow whatever

Congress says.

EPA registration is only required if you make a " pesticidal claim " --

that is, if you, the manufacturer, state that " Our product kills mold. "

Again, this is defined by FIFRA. As the bumper sticker says, " 186,0000

miles per second -- not just a good idea, but THE LAW! "

Henry

Re: Another new technology

Posted by: " Geyer " mgeyer@... bs101master

Sun Aug 19, 2007 6:58 pm (PST)

Henry:

Your information regarding these nuances are very relevant. Thanks. This

area, i.e., what defines a ³pesticide² vs ³biocide,² is beginning to get

blurred and muddied. The original intent and application of pesticides

and

pest control involved the control of insects and nuisance animals (e.g.,

birds and rodents). I now see the term (i.e., pesticide) being broadened

to

include non-motile critters (e.g., mold). I also foresee turf wars

between

regulating agencies as the blurr crosses jurisdictions. I, for one, see

both advantages and disadvantage of defining mold as a pest; within the

current framework of governmental controls. And I am not sure which side

of

the fence to sit on. Maybe the framework of governmental controls in

this

area warrant restructuring? Moreover, I have significant issues and do

not

readily agree with including mold (essentially a non-motile plant) with

other pests (e.g., termites, mosquitoes, starlings, gophers, mice, etc).

My

crystal ball is not to clear with respect to where this is all going.

Yes......Bleach is a laundry additive; and many bleach products state

that

they sanitize. H2O2 based medical products similarly state that they

disinfect. OK. And common sense tells us that these products have their

attributes in mold remediation too. Are we trying to beat square pegs

into

round holes?, or are we avoiding the obvious. I can understand from a

manufacturer¹s perspective why I would avoid labeling my bleach or H2O2

product as one that kills mold.....because the EPA would require

registration!; which is costly and time consuming and of little value

for a

common sense application of a common product. EPA registration may be a

big

disincentive for the obvious.

Bleach and H2O2 based products are not used for insects and nuisance

animals

(i.e., pests), but they are for mold. So why are we including mold with

these other pests? Are they similar?

I ask rhetorical questions, for which there is no need to answer.

>

> Friends and colleagues:

>

> A few quick comments, based on what I've learned, but not necessarily

> authoritative.

>

> A " pesticidal device " is any equipment that can kill bugs without a

chemical

> pesticide. You could register a shoe as a pesticidal device; put it on

and

> stomp on any cockroach that you see.

>

> Generally, the law covering such devices is not as stringent as the

laws for

> pesticides. No proof of efficacy is required, for instance.

>

> Is H2O2/hydrogen peroxide a pesticide? I don't ever recall hearing it

labeled

> as such, but I could be wrong. Most store-brand bleach is not sold as

a

> pesticide, but as a laundry additive, so it does not need EPA

registration, as

> long as they make no pesticidal claims for it. Ditto for H2O2. If this

firm

> is making a claim that the H2O2 kills some form of living creature,

then the

> H2O2 is considered a pesticide and must be registered as such.

>

> FYI: I forwarded information about this Web site to our regional

pesticide

> office. They will presumably take appropriate action. Stay tuned!

>

>

> Henry Slack

>

> Although this is the best information I can put down at this moment,

that

> doesn't mean that it's entirely correct. Please don't treat it as

necesarily

> complete or representing EPA's positions accurately. Thank you.

>

[Guest guest]

ge -

Sanitizers, disinfectants, and sterilizers are all defined as pesticides

with specific killing abilities . Registration is required for all.

Got to http://www.epa.gov/oppad001/ for " Regulating Antimicrobial

Pesticides " for more information.

Henry

>Henry,

>

>I would respectfully like a clarification on your statement. IF a

product is labeled a sanitizer or disinfectant, is it not required to

have an EPA >registration?

[Guest guest]

,

I don't recall your position on comparing inside to outside mold

levels but you just convinced me against such a comparision. Which

way is the air flow? What pressure differential? What size particles

can move through this particular structure? How long does the

transfer take so the inside sample can be taken at the appropriate

interval after the outside sample. Among other variables.

Carl Grimes

Healthy Habitats LLC

-----

> Quack:

>

> Thanks for posting this abstract. Yes....I believe that this is the

> article that was being referenced by EnviroBob. (And I have seen

> this study before, about 6 months ago, now that I have read it again.)

>

> What I find very interesting are the contradictions in the study, and

> the unfounded conclusion:

> * " ... particles with diameter of 4.0 µm did not penetrate through the

> structure at all even at a higher-pressure difference of 20

Pa. "

> * " Determined penetration factors were highly dependent on pressure

> difference. "

> * " Results have important consequences for practical design showing

> that penetration of fungal spores is difficult to control by

sealing

> the building envelope. "

>

> I don´t disagree that pressure differentials are a determining

> factor.....assuming a pathway is present. All buildings have

> pathways to air leakage, some small, some large, however, not all

> pathways have a higher pressure outdoors and a lower pressure

> indoors; sometimes the reverse is true and sometimes there is a

> negligible pressure differential across the pathway. Flow is not

> always outdoors to indoors! Moreover, it should be noted that the

> VAST MAJORITY of fungal spores are larger then 4-microns. With the

> most notable exception being Aspergillus sp; which is maybe why

> Aspergillus can colonize in the lungs???? Therefore, if the vast

> majority of fungal spores are larger than 4 microns, and study data

> shows particles greater than 4-microns DID NOT penetrated through the

> structure at pressures exceeding 20-Pa, how the hell can they

> conclude that these results show penetration of fungal spores is

> difficult to control? Am I missing something? I think not!

>

> If one reads the entire study and looks at the building assemblies

> that were constructed in the lab, there were holes and openings in

> the assemblies that were made to " represent " large flow pathways.

> Guess what, if you create a big hole, big things will flow through

> it. Duh! When these big holes were sealed, the data shows leakage

> of particle sizes in the range of 0.6 to 2.5-microns.....as long as

> there was a pressure gradient. I can accept this. What I cannot

> accept is the conclusion " fungal spores penetrated throughout the

> structure " .......not without allowing them to move through the BIG

> holes!

>

> Maybe that is why I did not commit this study to memory.....I felt it

> was bogus; with respect to mold spore transport. Lets also not

> forget that this is a lab experiment and it needs field verifications

> studies to have any real merit in the real world.

>

> For what it is worth......

>

>