 Good afternoon, everybody, and thank you, Reshkan, for those kind words, I appreciate that. I'm here to talk to you about ultraviolet hydrogen peroxide for float tanks, but before we get started, I want to do a demonstration for you. I think this will be fairly informative, but to do it, I'm going to need a volunteer So, anybody want to volunteer? Little hands anywhere? How about the lady up here? Come on up on there. Hi, and what is your name? Ginny. Ginny, Ginny, Stanwell Smith. Okay, very good. And where are you from, Ginny? I'm from upstate New York, all been in New York, but I've been in Europe for two thirds of my life. Are you from Europe now? Yeah. Wow, you've come a long way. Yes. Did you... 16 hours flight? Did you travel by float tank? Yeah. We rode all the way across the Atlantic, yeah. And did you bring your spouse or significant other with you? Yes, I did. And what's his name? Colin. Where's he at? He's right there. And Colin is Ginny a smart and bright woman. She's no smart ass. Yeah, well, you better say yes, or you'll be sleeping in that float tank tonight. I'll tell you that. Well, Ginny, this is a very technical scientific demonstration, so I want you to be prepared. Right now. And watch it concentrate and follow instructions very carefully. So, what we're going to do here is I'm going to hand you this glass of clear liquid. Hold it tight. Now, you can smell it, but don't drink it, because we need it for the demonstration. Okay, don't drink it. It smells good. Okay. It smells lemony. The first thing I want to do, and I'll tell you what, I'll hold the mic for you. Put it in one hand, you left-handed or right-handed? You're left-handed, okay. Watch, put your finger in it and start stirring it around there. Just keep stirring. Yeah, there you go. Anybody tell you that you stir it very well? Good, good. It's very complicated. Okay. Now, what I'm going to do is I'm going to count to three, and when you can stop stirring now, but leave your finger in there, okay. When I get to the end of three, I want you to take out your finger, stick it in your mouth and lick off your finger, and then I want you to hold that finger high and yell float tanks are number one. Now, make sure you use your pointer finger and not your middle finger. Would you please? Okay. All right. One, two, three, go. It's our number one. Okay. Hold on a second. Hold on to it for a second. Just hold on to it. Okay. I'll hold on to that while you do that. Okay. Yeah, it's not for the taste. Okay. There you go. Now, what I'm going to have you do next, Jeannie, you're not done yet. Okay. On there. Okay. Well, I'll hold this for you. Good. Make it easy. I'm going to give you this box of pH test strips. Now, show of hands. Is everybody familiar with the concept of pH? Okay. Okay. Make sure you got everybody in the same playing field here. pH concept determines the acidity or alkalinity of a substance. And we have a scale that we use for measurement from zero to 14. Seven is exactly neutral. As you go downwards, things become more acidic. As you go upwards, they become more alkaline or base. And of course, it's a logarithmic scale. So like when you go from seven to six, it's 10 times more acidic. You go to six to five, now you're 100 times. And so now when you get like below two or above 12, you basically have hazardous chemicals at that point. Very, very dangerous. You know, like in the below two, you have the acids like battery acid or hydrochloric acid, sulfuric acid. You know, very, very dangerous. So that's the concept of pH. And what I want you to do here, Jeannie, is just take one of those test strips. Okay. And now, you see here, there's a scale and you hold that and you'll be putting the four, you know, it gets matching up like that. Why don't you put that in there for a second or two and hold it out and then hold it up to... How long in the water? About a second or two more. Yeah. Okay. Now match it up and... Sure. Want to tell people what that is? We have a pH of zero and I just drank this stuff. You sure? Yeah. Want to try it again? If you want me to. Yeah. Let's make sure you're... Same thing. pH of zero and I'm not dead. It's amazing. You're sure of that because, you know, Jeannie, those television shows or movies or the bad guys when they kill somebody, put them in the bathtub, par in the acid with zero to get rid of the evidence. You know, it takes away both bones and everything else. Want to check your finger again? Yeah, it's still there. Okay. Very good. Well, what we've done here, folks, is this shouldn't happen. You know, there's no way that that should happen. A pH of zero defies science logic. That should have... If not start eating through her skin after stirring it around that long, should definitely burn her and putting it in her mouth or tongue would have been burned. It doesn't taste good, but it didn't hurt her at all. This is just unbelievable. So, it just goes to prove, this is amazing how you can bring people up on a stage and give them to do all kinds of incredible things. Could you take off your clothes, Jeannie? I'll take that from you. You're a great sport, Jeannie. And I really appreciate it. Give me a hug on that. Thank you. Thank you very much. Okay. Okay. Okay. Silling us aside, I just wanted to show you to that because there is a method to my madness in that and a purpose to why I did that. The purpose of that demonstration was to show that scientific conventional wisdom isn't always correct. In fact, sometimes it can be just the opposite. And called out of box thinking or paradigm shifts or whatever terminology you want to use. But the main point is that preconceived conventional wisdom only applies within a certain established context. But outside of that context, we should open up our minds to other possibilities. The possibilities that are more appropriate or desirable to meet the needs of the new context that we are working with. I think float tank facilities seem to fit into a new context. I'm mainly here to tell you about UV peroxide as a process for water treatment. But I also have a sub-message that I think can be applied to the development of your float tank business. I don't mean just technically, but in regard to procedures, policies, standards, and even construction and marketing approaches. My experience in developing the UV peroxide process not only provide a valuable tool for water quality management, but serves to serve a case history related to innovation. You folks are providing innovative facilities for recreational and therapeutic uses of water. And so I believe that my experience is possibly instructive for what you're doing. I want to describe my journey in arriving at the solution of UV peroxide because it illustrates a type of solid box thinking that goes against conventional wisdom. Same thing we saw in the demonstration to fit more appropriate solutions. My journey started in Chicago with a partnership and a business involved in the wholesale distribution of swimming pool equipment, chemicals, and supplies. We were a fast growing and innovative company. We did testing for several manufacturers for their new products before they went to market. In fact, we pre-tested probing for the chemical company that introduced probing for spas. We also trained pool operators on maintenance and pool water quality, and we were one of the first companies to actively market spas in the country. In doing so, we needed to train spawners and operators on spa water quality, and we applied the same principles that we used for our pools. And unfortunately, we found out that spawners had problems, but they weren't the only ones. We had problems with our own spa in our office. We realized that there's something definitely different about spas. These are the problem areas that I discovered. Excuse me. I can't go into depth in all of them, but as you can see, the area has covered a wide range of technical factors and standards and policies. About this time, I started doing other projects in water quality, working in things such as lakes and ponds treatment, industrial water treatment, and even some aquaculture with Ralston Perino where we developed a shrimp farm in a warehouse. These projects kind of caught my interest, and I wanted to get more involved in other water areas, so I decided to go back to graduate school and get my master's. I chose to attend the University of British Columbia in Vancouver, Canada. I think we got some people here from British Columbia. There I met Irving Fox, a professor who became a thesis advisor. Irving was a brilliant man. He was one of the original founders of the environmental movement, and at one time he was the number two man in the US Department of Interior for years. My initial thesis topic was going to be on toxic and hazardous waste contamination. This is right after the infamous Love Canal incident that created all kinds of headlines. So I researched that topic for about two or three months, and finally I just threw up my hands and went and met with Irving, and I said, Irving, I can't do this. This is just too extensive an issue, and nobody else can find the answers to all these problems. There's too many unanswered questions and uncertainties. I'll be here forever. But at the same time, I started telling him, well, I said there's some similarities between the difficulties we had between pool management and spa management, and I started describing these in more detail. So he turned to me and he said, why don't you do your thesis on policy for spas and hot tubs? And I looked at him and I kind of gave him a blank stare and I chuckled, I said, Irving, I can't do a thesis on spas and hot tubs. They'll laugh me out of here. And he said, no, no. He said the purpose of the thesis is to take the principles that you learn in graduate school, apply them to a specific topic, and be unique. So he said it'd be very appropriate that you have a lot of knowledge of your subject. So I said I agreed with them, went on, and did my thesis on public policy for public spas and hot tubs in British Columbia. In my thesis, I identified four major public health and safety hazards, but my research clearly showed that pathogenic hazards was the main concern. As I wrote, it is becoming increasingly evident that public spas and hot tubs provide a favorable environment for the growth of pathogenic organisms in the spread of infectious disease, particularly where facilities are poorly maintained. And then I looked at the environmental characteristics of spas and hot tubs and modeled the spa environment. It became obvious that spas were potentially a strong breeding environment for many disease-causing microorganisms, and that a significant reason for the problems created by spa hot tub use is the failure to recognize their unique characteristics apart from swimming pools. And this is going to come back when we talk about float tanks. This was the main theme of my thesis, and although today this is a commonly accepted concept, back in the 80s this was really revolutionary. Most people considered spas nothing but baby swimming pools. Concurrent to writing my thesis, I also teamed up with my healthcare and epidemiologist, Professor Dr. Kourt McKenzie, who was at that time the top epidemiologist in Canada. And we wrote a paper on the pathogenic hazards in spas and hot tubs. The paper was published in the Canadian Public Health Journal and it drew the attention of both the public health community and industry. Using my model of the spa environment in a thorough review and examination of the range of microorganisms, we developed a matrix which is shown here from the paper comparing spa characteristics with those of selected pathogens. Our research confirmed the pathogenic hazards from a few pathogens already implicated in disease outbreaks. And more importantly, it predicted a few more pathogens that later would cause disease outbreaks. Notably, up here legionella pneumophila, which creates the deadly legionary disease, vaginitis microorganism. And then a very nasty amoeba called neglaria fowlerii. This, if you're infected by just one or two of these amoeba, it will go straight to your brain and cause fatal meningoencephalitis and you'll be dead within two to three days. And it's almost incurable. Copies of both my master's thesis and my publication in the Canadian Public Health Journal were requested only by a large number of public health agencies throughout North America, including the Centers for Disease Control, but also by health officials throughout the world. Some members of industry also requested them. I believe that my thesis and paper had a major influence on changing the perception of spa hot tub management and creating an openness to alternative methods. Studies done by public health officials such as this one by Spitali, Vogue and Witherall provide a confirmation of pathogenic hazards. This study was only the tip of the iceberg. Note that it didn't include Oregon, which was the most stringent and comprehensive state program in the country. It also showed zero outbreaks in California, something that's really hard to believe seeing that California had a predominant number of spas and hot tubs. This was likely just a reporting and investigation weakness. Also note that the two cases of Pontiac fever, this is from a strain of Legionella that just creates an illness that's a flu-like illness. It's not deadly. But later, we did have people who did die from Legionnaires' disease in spas and hot tubs. Also, I want to note to you that in this investigation, there were outbreaks when chlorine, bromine, and pH were all within acceptable standards. Excuse you a lot of confidence. Oregon's health department was headed at the time by a fellow named Jim Brown, who was extremely aggressive in trying to identify and solve the disease problems in spas and hot tubs. As you can see, Oregon alone had almost as many outbreaks as the whole country as reported in that Spitalni study. Noteworthy was the fact that even in Oregon, reporting was generally poor. So how many cases were there really? Again, Oregon found outbreaks when chlorine levels were within required standards. To sum up the problems with the use of chlorine and bromine in spa management, these are the main factors that I knew back then that spa equipment, operational procedures, standards, and a few other factors needed to be improved. But it was clear to me that the biggest key to improve spa management was improved disinfection. Keep in mind that at this time, chlorine or bromine was the only game in town. So if they didn't work properly, where could we turn? In my Canadian Public Health Journal paper, I briefly explored alternatives, no one in any detail at the time. In the 1980s, alternatives were considered to be black boxes that didn't work. That's how I came to discover and embrace the UV peroxide process. It was really pretty remarkable. I have to tell you about this because this kind of leads to how weird things do happen in your life. A path began when I finished my master's thesis at UBC and moved to Sacramento where I rented a basement apartment in a house, a couple blocks from the state capitol, and I planned again a job at the state of California. But upon arriving in Sacramento, I found out that they had a hiring freeze on and no plans to lift it soon. So I started looking for other jobs to no avail. And then finally, about two or three weeks later, I get a call from a couple guys who somehow tracked me down and I have no idea how they found me. But they did. They wanted to interview me for a job. One fellow was the owner of a number of health clubs, and the other was a custom home builder who built million-dollar-plus homes up in Lake Tahoe. Both of them were desperately looking for a solution and alternative to chlorine to solve their spa water quality problems. The guy at the health clubs obviously wanted to improve his facilities, and the guy with the custom home builder, he was putting in spa tubs into his house and the people just didn't like the chlorine. So they started research alternatives and came across UV disinfection. And then they stumbled across academic studies on the use of UV and hydrogen peroxide together. Not for pools and spas, but just general studies on what's called photo oxidation. So they thought this might be their solution. However, they had absolutely no idea how to make it work for spas or even if it would work. Further, they didn't have a clue about developing the data and the process and figuring out details to make the process repeatable in order to get public health approvals, department approvals, or to be able to market it. They decided that I could do it for them and they offered me a job on the spot and it kind of intrigued me and seeing that I didn't have a better option. I said yes, and the rest, as they say, was history. So what is the UV peroxide process and how does it work? First of all, let me show you hands. The UV peroxide process has three principal components. The first is UV light, which is a disinfectant. It's a physical process where energy inactivates microorganisms by disrupting their DNA, preventing them from replicating. Inactivation and kill rate depends on the dosage delivered. Hydrogen peroxide, which is the oxidant, it controls organic loading and has two main roles in this whole process. It eliminates bacterial nutrients, meaning it's starving out the food source out in the spa for bacteria. And the second thing is it clarifies the water to allow higher UV transmission and make the UV units work more effectively. And then the third component are what we call free hydroxyl radicals. This is a synergistic photochemical reaction which occurs when hydrogen peroxide is irradiated by ultraviolet light. It's an intermediary product that produces high oxidation potential that aids both in the oxidation process and in the disinfection process overall. Ultraviolet radiation. Ultraviolet radiation is part of the electromagnetic spectrum and it encompasses a wide range of wavelengths, including the longer wavelengths that we see in sunlight. However, it is a short-wave UV rays at 253.7 nanometers. It's hard to read up there. Or you can abbreviate to 254, just round it off, which are germicidal. UV lamps electrically excite mercury vapor within the bulbs to reduce UV radiation. Now, a normal glass filters out the short-wave UV rays, but high-quality quartz glass allows its transmission. This is what is used in the UV lamps for germicidal use. Fluorescent light bulbs operate on the same principle. The only difference is they've got regular glass and so that's why you're not affected by the short-wave UV. Some UV units use Teflon tubes like pipes and pass the water through them with lamps in an air chamber surrounding the Teflon tube. I earlier mentioned UV dosage. UV dosage is defined as UV intensity multiplied by exposure time or in units of measurement, microwatts per square centimeter multiplied by seconds or microwatts seconds per square centimeter. Its energy applied to a unit area over a length of time and gives the amount of energy at a given time applied to a unit area. Now, historically, the industry has long used the term microwatts seconds per square centimeter, but in recent years, they've gone to the terminology milligels per seconds per square centimeter. So, for example, in the old-fashioned terms you'd use 30,000 microwatts seconds per square centimeter. Now, you just drop the thousands and it becomes 30 milligels per second per square centimeter. I also mentioned the term dosage delivered. UV dosage is absolutely meaningless unless the dosage actually gets delivered to the targeted magnet organisms. So you can have all the UV in the world, but if you don't take care of all these different factors, you've got a problem. Time doesn't permit you to go into detail and it would take a long time to go through each and every one of these. However, let me point out that there is substantial design in engineering that must go into consideration for all these variables in order to achieve the disinfection efficacy desired. This is a chart, it's an old chart, but I just put up here just to give you an idea of how they've looked at the range of microorganisms. This is only a small list too. Some of the academic and other lab studies have been done to determine inactivation rates for other specific microorganisms. And in this study that was done here, E. coli was killed, really easy coliform, at a range of 3,000 microns per second per square centimeter to 6,600, or 3 to 6.6 milligel seconds per square centimeter. When I first got involved with this, I was often asked, does UV need to be registered as a pesticide for your disinfectants? As this letter to me from USEPA indicates, UV does not require pesticide registration unlike chemical disinfectants. But other typical requirements such as fraudulent claims or you can't still mis-advertise a product, it has to be accurate. Now here's an example of how to properly size UV units for the application. Size is independent on flow rate and these show size requirements. First one A is for a spa and the second one is for a hospital therapy pool of larger volume. For a float tank with, let's say, 250 gallons, if one 15-minute turnover of the water is desired, the flow rate would be 16 gallons per minute and the UV unit would need to be at least of that capacity. If three turnovers of five minutes each are desired within a 15-minute span, then the flow rate would be 50 gallons per minute and require a UV unit of that capacity. Flow rate is not the only determinant for sizing. Recall that dosage is both a function of intensity which is related to the flow rate and, I mean, I'm sorry, exposure time and UV intensity which relates to the overall engineering and design of the unit. Here's an example, kind of a holy grail for substantiating the UV dose of specific UV units. This is a report of a bioassay done with a UV unit on Pseudomonas aeruginosa. A bioassay is generally done in a lab but it can also be done in the field to determine the ability of the UV unit to disinfect. The lab cultivates a large number of bacteria and pumps it in a water solution through the unit and then counts the bacteria that survived afterwards. The result of percentage reduction can be correlated to known doses needed to inactivate that bacteria or virus and determine the dose output of the UV unit at various flow rates. I mean, here you can see this one unit as well. It has a 40-gallon per minute capacity. At 40-gallon per minute, you get a 99.997 reduction, better than four log. If you slow that down to 20-gallon per minute, cut it in half, it jumps way up to 99.999%. That's a big jump, by the way. And if you speed it up to 80-gallon per minute, you can see that the disinfection rate goes significantly down. If a manufacturer of a UV unit does not do bioassays of its products and does not provide you with copies of the results, if you ask them, be a little cautious because they can make all the claims they want about capacity and effectiveness of their units. But without bioassays being done, there's no proof. This is important both for your operational success and as a matter of liability, in my opinion. This is a picture of a Teflon type of UV unit. There's also quartz units of the more popular ones and ones that are used there more effectively, but I had this picture here anyhow. The water enters the unit through the PVC pipe, goes through the Teflon tube that's inside the unit, where the lamps are surrounding it, and then exits through the pipe there. And then there's also a diagram of how to plummet for a spot application that's similar with float tanks. You have your pump pumping through the filter, then through the UV unit, then through a heater. There's a check valve and a vacuum breaker that hold the column of water within this Teflon unit that's necessary. And then you have an optional feed pump where you can feed by hand. Okay, the second component. Hydrogen peroxide. Hydrogen peroxide is chemical forming in H202. It's water with an extra oxygen. So the breakdown products are water and oxygen, and obviously very safe for people in the environment. The keys here really are the fact that it's very missable or soluble in water, very strong oxidizer, and it's highly stable. And I think for your application, I would recommend the 35% concentration. Safe storage and handling is important. Peroxide must be treated with the same respect as any chemical, but it's no more dangerous than chlorine if stored and handled properly. And the third component is free hydroxyl radicals. As described earlier, free hydroxyl radicals are intermediary products created when peroxide is irradiated by UV. This photochemical reaction occurs only within the UV chamber, and the short-lived radicals are gone by the time the water exits the unit. However, the oxidation strength of the hydroxyl radicals are so strong that it breaks down those organics just within seconds and microorganisms as well. As shown by this chart, it's shown that the hydroxyl radical is the second strongest oxidant known, significantly stronger than ozone or hydrogen peroxide by itself and just dwarfs chlorine or bromine as an oxidant. And let's quickly turn our attention to the operation benefits of the UV peroxide process. Harkening back to my experience in training swimming pool operators and owners, I learned that it was best to try and make it as simple and direct as possible. Too many people in the pool industry would try to complicate pool water quality management, which caused operators to have difficulties and fail. They would either get confused or it would take more time than they could devote, or they did things that worked counter to their efforts and made things worse. I was determined to keep UV peroxide simple, understandable, and easy. So here are the three basics, and really straightforward, proper UV operation. Number one, size a unit correctly. So that's when you purchase a unit and install it. Just make sure you get the right size. It's a one-time thing. Second, check to see the unit is on. Duh, not too tough to do. Three, operate at 24 hours a day. I'm not sure that's going to apply with float tanks, as some of you are going to have to look at. Four, change lamps annually. Now, there are some manufacturers now that are producing much higher quality lamps. They'll go 18 months to two years. And if so, then you don't have to change them frequently. Second, maintain the recommended peroxide residual. You can either chemically feed that or feed it by hand, but because peroxide's so stable, you're able to hold a residual unless you don't do number three, which is clean filters on a regular basis. We found after a lot of work in the field and everything that as water kept passing through the filters, contaminants would fall out of the water and start collecting in the filter, the filter would capture them. And so now when your water passes through the filters, all that peroxide in there would try to clean your filter. It was trying to work to do that. And so what would happen is that after a certain point in a lot of time, your peroxide level on the spot just dropped dramatically. You couldn't hold a residual. And so we learned by going in and cleaning the filters otherwise then you were able to maintain their residual consistently. These are some of spa water quality guidelines that I developed for the spas. UV is not affected by water chemistry, so water quality focuses mainly on peroxide levels and filtration. 15 parts per million peroxide is shown here as a minimum because in my data I saw problems occurring below that. I recommended, but you should probably have more as a cushion, and I recommended 30 to 40 parts per million is what I called ideal. I mean it's not ideal, but I just recommended to serve a trade-off between effectiveness and economy in terms of peroxide use. 100 ppm is listed as a maximum. That's not for safety reasons. You can go much, much, much higher. But rather than the higher you went, there were diminishing returns on the effectiveness, so you're just kind of wasting more peroxide. And if there wasn't a better reason because of Baylor load or something like that, I wouldn't recommend it. These are the most compatible chemicals with UV peroxide, and what I don't have up here, but I should mention because I've talked to people ahead of time, I've heard the question asked, why do diatomaceous earth filters with peroxide? Peroxide will break down the diatomaceous earth and send it back to your water and make your filtration network properly. Spa owners and operators are absolutely thrilled. It was one of the most fun times of my life working with them because they were just so thrilled about the process and what they saw the differences between what they were trying to do with chlorine or bromine. They had the benefits of no odors, eliminated the foam that was constantly in these public spas. They looked like they were still gross. There's no chlorine or bromine to deal with. These are maintenance, effective disinfection, in organics control, high water quality, clarity, non-toxic, and I should add up there, also non-corrosive as well. The UV peroxide process was the first disinfection process in the United States to be approved by state and county health departments for spas and pools without the use of a halogen chemical. In other words, chlorine, bromine, or iodine. This was a breakthrough that was unbelievable to get this approved by the health departments. Directly you're working with my customers. I obtained more than 50 approvals in various state and county jurisdictions. I'm going to give you a quick sampling of the data which provided the evidence to secure the approvals. These are relatively common results for typical health club spas. Coal form is what's called a bacterial indicator organism and is a standard for water treatment, even to today. Pseudomonas is another specific disease-causing organism but it is not used as a standard. We tested for it regardless. Plate counts also referred to as total plate counts or standard plate counts are a measure of all bacteria present, harmful and harmless. You can see that the counts are excellent and likely zero for both coliform and pseudomonas. While total plate counts, which can be solely harmless bacteria, are low and in the one case at the bottom less than one. That's virtually sterile water, something almost absolutely unheard of. This is a summary of results from a wide variety of facilities including those of heavy use and a few large swimming pool size. These are just a handful of installations. There are numerous more throughout North America and even in Australia. If you look in Colorado, we had three pools there, 45,000 to 55,000 gallons. We had other large ones in other states, Nebraska, the Isar Medical Center where the famous Betty Ford Clinic was at, terrific installations. This one in the University of Utah is very interesting. It's a 750-gallon spa. That's a very small public spa. Mostly college kids use it and who knows what they're bringing in, right? 250 to 500 people a day. If you can just imagine the contaminant loading per person coming into that per gallon of water, it's just absolutely fantastic. The fact that we could take care of that was amazing. In collating the data, the bacteriological results were excellent in all cases. And there was strong evidence of correlation between peroxide levels and disinfection. You can see by this table that peroxide levels are a good indicator of disinfection and that dropping below 15 parts per million was a problem and that higher levels produced the desired efficacy. The four samples with higher total plate counts, and again, those could be harmless bacteria, were those at the Utah facility when the filters weren't cleaned and peroxide levels became less stable. This data regarding hydrogen peroxide residuals as a reliable indicator of efficacy was critical toward obtaining the Health Department approvals. And since we're here in the lovely city of Portland, it is entirely appropriate that I discuss the major breakthrough for UV peroxide in the public health community. I publish results of this Oregon spot test in the Journal of Environmental Health and presented at their annual conference. This testing conducted in Portland provided the definitive data showing that UV peroxide was not only an equivalent disinfection process to chlorination, but that it was actually superior. In a side-by-side test, the two processes were compared in a real-world setting. Here are some of the results. First, chlorine and coliform counts, and the second, that solid line represents when chlorine was used, the broken line is UV peroxide, and you can see that standard plate counts were much higher with the use of chlorine. Likewise, pseudomonas counts were higher with chlorine and those two spikes with UV peroxide occurred when peroxide levels were low. Chemical oxygen demand, or COD, is a measurement of organics in the water. As you can see here, UV peroxide controlled organics better than chlorine. Note how the initial COD levels when UV peroxide was used were it was driven down and then controlled, whereas when chlorine was used, it increased over time. I also should point out that when peroxide, peroxide also produces a measurable COD when COD is tested in the laboratory. So, the COD values for UV peroxide shown here were actually lower when peroxide factor was subtracted. One of the problems with chlorine is showing this chart as you see the high variability of chlorine levels over the course of the day. Even on the days when bacteriological samples were taken and the corresponding chlorine levels were measured and were low, the daily operator logs showed chlorine levels at at least three parts per million. Now, three parts per million is double what's required for chlorine. The SPA was monitored and tested with a number of water quality parameters beyond bacteriological. This is an example of some interesting data showing the presence of cyanide in the water when chlorine was used. Not shown in this chart, but we had another data. We were shown the presence of trihalomethane, which are carcinogens when chlorine was used. And also, on three of the sampling dates, when the SPA was chlorinated, we had air quality samples with high levels of oxidants that are chlorine compounds. Based upon the excellent performance of the UV peroxide process compared to chlorine in this test, the Oregon State Health Department, the most stringent in the country for deposit pools, approved the use of UV peroxide. I wanted to digress here for a minute and take a few minutes to talk about working with regulators. In securing a number of public health department approvals, and later in my career, I worked as a regulator for the state of California for almost 30 years and saw the regulator perspective from the other side of the fence. So I believe they have reasonably good credentials to talk about dealing with regulators and I want to pass on my observations to you. There are three areas of dealing with regulators I want to talk about. The first is their mindset and goals. In a regulator's mind, only three things can happen when they are not cautious and all of them are bad. Their associates may be critical or jealous. Their boss may get upset or go to promotions or they may do something to endanger public health and safety and they lose their job. There is little or no upside for them taking risk in their minds they have nothing to gain and everything to lose. Second, they are often distrustful of industry. They have a tendency to distrust the motives, behavior, information, etc. of industry and industry people. Third, they are seldom entrepreneurial minded. Unlike yourselves. So it is a different personality entirely. But if you do find someone like this, mind that person like Gold. They are uncommon but they do exist and they can be a proponent for you in many different aspects especially in regard to innovative technology or ideas. Fourth, they have a job to do and outputs to meet despite inadequate resources. In almost all cases there are never enough resources for regulators to do their jobs fully. They always are engaged in prioritizing and trying to meet their outputs and goals. Number five, most public health regulators are dedicated public health but some are overzealous to the point of being unreasonable. So you have run into that. And sixth, don't assume that they are all highly knowledgeable particularly on something new and innovative. They may not understand that and you may have to educate them. And finally, regulators always always default to laws and regulations. Tying in with the first point of being cautious and risk averse, regulators know that they can't go wrong on the laws and regulations even if the laws and regulations make no sense for that situation or if there is an unclear gray area interpretation. They will always choose the most conservative interpretation and force you to prove differently. So how do you use knowledge of the regulators' mindset and goals to get your projects approved and permitted? First, be respectful. There is no quicker way to end up at the end of the line or get otherwise mistreated than by showing bad behaviors and attitudes like arrogance, bullying tactics, confrontation or obvious failure to provide them with information or respond to their request. On the other hand, don't try to falsely suck up to regulators. They get that a lot and they see through it easily and they may even find it insulting and you'll also lose credibility with them. So just be respectful like you wouldn't with anybody in another social situation. Second, understand their needs and goals. Going back to the previous slide, understand that they will almost always choose a cautious route, have at least some distrust of you and look to meet their quotas as quickly and easily as possible while following the regs so that they can't be criticized. As much as possible, avoid putting them into uncomfortable situations that threaten their needs and goals. One way to make them comfortable is to cooperate with the process of procedures and readily provide them information for the request. Another way to make them feel comfortable is that it's always a good idea to follow templates of previously approved plans and projects, especially those within their own jurisdiction. The more cookie cutter, the easier and faster for them to give you the green light. If you're doing something new or innovative within their jurisdiction, try to find an improved template elsewhere and provide them with a reference contact. Fifth, don't underestimate the importance of data and monitoring, whether existing or promised, especially when you are doing something new or innovative. Data monitoring programs and record keeping are the mother's milk for regulators. When they have to decide on permitting something, they want something solid and in writing that they can base their decision upon, not some subjective information. You saw how critical it was the data from my obtaining approvals for the UV proxide process. Number six, where necessary, use or draw a pine outside experts to make your case. This helps you neutralize the regulators innate distrust or, at a minimum, lets the regulators know that their decisions are being observed by others who might have more ability to challenge or expose bad or unreasonable decisions. Usually an outside or impartial expert will also bring new knowledge and information to the table, which sometimes gives the regulator an out to reverse course without losing face. Finally, whenever possible, especially with something new or innovative, find and communicate with the highest level person in the agency who exercises oversight and management. If your operation is really simple and cookie cutter, then it's probably not necessary. But if it is all complicated or significantly different then you best reach out and up because the underlings aren't going to be making the final decision. You'll be made at a much higher level and it's best if you can directly inform the higher level of management yourself instead of hoping that your situation is adequately and properly represented to managers by lower level regulators. Too often, upper managers will take the cautious route also and reject projects or delay them when there is any doubt whatsoever expressed by their staff. And then third, I'm just going to go through this quickly because I know you're all good actors and never create problems so we'll talk real quickly. The first, you'll avoid enforcement. You don't want to go there. Not good. Second, be prepared. Know the laws and regulations and follow them and always use good faith. Exercise good faith effort. Third, record keeping. Keep records and document your adherence to the regulations and your good faith efforts. Fourth, be responsive but don't volunteer. Obviously, if they want something and they respond and they ask you questions, provide them information whenever you need to provide that. But don't go astray and start offering stuff they're not asking for. Believe me, you'll be going down a path you may not want to go to and you may walk into something that's not good. Documentation, yours and theirs. If they come out in inspections or enforcement, it's a good idea to document what they're doing and keep track of that and everything. But theirs is even more important. If they take an enforcement action against you, you should do your very best to get the documents that they're relying upon for that enforcement action. You don't want to be surprised down the road that they've got some information that you didn't think they had. And then finally, if you do have a problem, propose solutions. Try to work with the regulator and come up with an idea on how to take care of the problem and then follow up. The worst thing you can do is promise something than that follow-through. Last but certainly not least, let's look at UV PROC site for float tanks. I have emphasized the importance of not settling for simply adopting one method, concept, technology, standard, et cetera, from one seemingly similar application to a new one. So to be consistent with that learning experience and approach, we need to seriously examine any differences between the applications. How they might have an impact and what can be done to deal with those differences and impacts to ensure a successful operation of float tank operations in the long run. Can what was learned in the application of UV PROC site for spa hot tub management be applied to float tanks? As a whole, my hunch is yes, especially since the water temperature of float tanks is similar to the hospital therapy pools that I worked with. Regardless, I do see some significant differences and those need to be accounted for. The first one related to water chemistry and water quality. With UV PROC site, water chemistry is not as big an issue as it might be with chlorine or ozone. So the guidelines for spas are likely very applicable. However, overall water quality which includes things like turbidity, temperature, contaminant, loading and other factors which can and likely will be different than in spas. Those things should be taken into account for design engineering and operational float tanks. Second, with regard to bacterial growth rates, with water temperatures closer to the hospital therapy pools, bacteria will not replicate as quickly as they do in spas which gives you a larger question for treatment. But on the other hand, the design of float tanks may not be optimal for recirculation. And it's also my understanding that float tanks are not constantly recirculated and that the time allowed for treatment between sessions can be short. So these differences need to be considered and factored in. Third, water system turnover rate. It's also my understanding that there's some debate over the appropriate turnover rate for float tanks. In spas, we want no greater than 30 minutes and the hospital therapy pools no more than 2 to 4 hours. But because of the tight window for treatment of float tank application, it appears that a number of people have an opinion that it should be a 5 minute turnover. So if the water can be recirculated and treated at least 3 times, this is significantly different than for spas. And then fourth, sizing. When I was actively involved, UV dose for spas and subsequent unit sizing was based upon the prevailing microbiological and other standards at the time. The key standard being coliform. As you saw earlier, UV easily kills coliform bacteria and the design UV dose at least a 5 times safety factor. And other common pathogenic bacteria can be killed as easily or almost as easily. However, there's an awareness today that the coliform standard may not be sufficient and also there's an awareness of more resistant and exotic microorganisms that may cause, based either on your choice or future regulatory requirements, a need to upgrade the dose and consequently the UV unit sizing. Number 5, peroxide levels. The appropriate peroxide levels that we learned through this application probably will hold true. However, not having done work myself with float tanks with the system, there are open questions about the effects of the ups and salts, the organic clothing, and the pattern of recirculation and treatment that are found in float tanks. I wouldn't automatically assume that my suggested levels were correct for float tanks. And I certainly would question whether it's optimal in terms of balancing effectiveness versus cost. And then finally, the small volume of water in float tanks may present some challenges related to water chemistry and water quality overall. In larger facilities, things can be masked or even become a non-factor simply by dilution of the larger volume of water. Small volumes also imply that changes to the water can occur both rapidly and dramatically. So in summary, there are some significant differences between the spa hot tub application and the water tank application. Let's not make the same mistake that we made trying to transition pool water quality management to spa water quality management. Let's identify the differences, investigate, and experiment with them, and adopt technologies, procedures, and standards appropriate to float tanks. And my last thing I want to cover here, I developed some recommendations that I wanted to share with you. The first is testing and monitoring. I believe that the success, the return of water quality and overall environmental quality in order to stay away from disease problems or customer dissatisfaction in the float tank application will be a result of good, solid testing, and monitoring programs. And by this I also mean to include experimentation. Without it, at best you're going to get lucky and find enough commonality between the spa application and the float tank application to achieve adequate results, particularly in the short run. Yet, this may not hold true over time. Moreover, not doing so reduces the opportunity to optimize systems by balancing desired effectiveness with the cost to achieve it. It's a dual risk. One hand you may try to cut corners and risk serious problems, or you may excessively try to overcompensate and waste time and or money. Second, testing the effects of magnesium sulfate. I've heard of the theory that magnesium sulfate by itself creates such a hostile environment to bacteria that perhaps no additional treatment is necessary. I have no personal experience with this and haven't seen any convincing data by others. So I can't say either way, but I think it's worthy to be investigated. Knowledge of this in one way or another would greatly influence decisions related to water treatment in float tanks. Third, UV disinfection. If magnesium sulfate does satisfactorily handle bacteria, it still may be wise to use UV as a backup for disinfection and to ensure public health protection, particularly since UV is a physical process and there is little or no impact from the water chemistry. The possible efficacy of high concentration of Epsom salts also begs the question, what to do with the organics they'll build up in the water and if nothing else become objectionable to your customers. If so, then an oxidizer is needed. Either chlorine, ozone or peroxide. For reasons stated above, I would rule out chlorine. Ozone would work, but peroxide would be the better choice due to its solubility, ease of control and more usually friendly feel and smell. So even if magnesium sulfate does show some efficacy, but you have a desire to have additional treatment, the fact that you'd know whether it would work like that, you could allow that down sizing of both the equipment and the treatment methods. Fourth as indicated above, questions seem to exist about proper turnover rates and subsequent equipment sizing. I would recommend experimentation to determine the optimal flow rate and I'd recommend doing that testing before some organization tries to set it arbitrarily. Number five, although not really related to UV peroxide, although there's no guarantee it's not, I would do air quality monitoring. Air quality should be tested and monitored in float tanks. The environment is confined enough to make even small levels of air contaminants a factor in either the health or enjoyment of your users. My final recommendation is that the industry is individual and has a whole develop and maintain good records related to water treatment to share that information with everyone. In my presentation so far, I hope that I have convinced you that obtaining and maintaining good data and information is critical to developing safe and sound technology, procedures, standards, etc. I also realize that business, businesses really like to keep their data and information proprietary for fear of losing a competitive edge. However, in any industry especially a new and growing one like yours, it's far more important to bring everyone up to speed and up to acceptable standards as soon as possible. The competitive edge is really lost when some businesses either unknowingly or by intent failed to operate within acceptable standards and thereby cast a bad light on the industry as a whole or on businesses that are trying to do it right. So I recommend getting everyone up to a high level of public health and safety protection. Let the competitive drive be limited to things like efficiency, good old-fashioned hard work, customer service, innovation, marketing, and other non-public health-related standards. Thank you. Thank you so much.