 Good morning. Thank you all for being here. So we are at why can't you disinfect float solution with hydrogen peroxide? Part of the I'm only doing this talk to make Roy Vaughn shut up series part two. In a nutshell, we're going to be talking today about chemical safety and compliance to minimize your risk and your liabilities to your centers. So what is the first place that comes to mind for finding safety information on any given chemical? Well, your answer better have been safety data sheet. These are no longer called MSDS is they're called SDS is now there are 16 sections that are required formats. And these are the 16 sections. I'm going to review just a few items of that I want to highlight out to you. They have recommended uses. Okay, they also have uses that are restricted or advised against. They have handling and storage information, hazardous classification, including hazards that are not otherwise classified, as well as acute toxicity that's unknown. They also talk about the types of ingredients if it's a formulation, first aid measures based on the root of exposure. So how were you exposed and the related symptoms and effects of fire hazard and explosive properties if there are any as well as advice for firefighters. So general and more general features. You want to know what to do in a spill safety data sheets. You're also going to find proper handling and storage, including incompatibilities and proper personal protective equipment people. Because I can tell you right now I've been instructed to inform you that if you're not wearing the proper PPE, what happened to Daffy Duck is what Roy Vaughn is going to do to you. He's going to kick your butt so high that it's between your ears and you're walking funny. Physical and chemical properties are going to be included. You're also going to find stability and reactivity information, what kinds of conditions to avoid. And lastly, I just want to note that sections 12 through 15 of safety data sheets are required, but that content is not actually enforced. Okay, so why do you need to know this? Why should you care? You may recall this information from last year if you came to my talk. There are these pesky little things called regulatory agencies and one of them OSHA regulates workplace safety and safety data sheet training. This can be enforced by the federal or state government. So I'm going to ask by a show of hands who has heard of Hascom. Do you know what it is besides Roy? He doesn't count. Okay, we have one person. All right. Well, good. You're going to learn something today. So it's a standard from OSHA. It's also known as the right to know standard, sometimes referred to as the right to understand standard. It governs how potential dangers of hazardous chemicals should be communicated to the workers who handle them via the use of labels, safety data sheets, and training. There are very few exceptions to this. Basically, you're talking food, alcohol, cosmetics, cigarettes, and wood. If I didn't name it, it's not an exception. You have to have a safety data sheet. What does that mean? That means you have to have safety data sheets for your cleaning, your consumer cleaning products and your magnesium sulfate salt. Okay. So an example of why we really didn't care about this is you all use 35% hydrogen peroxide. That is a hazardous chemical. It's probably one of the most hazardous chemicals you have at your float centers. Hascom is based on global harmonization standard. We'll talk about more of that in a minute. And it governs the container labeling as well as the format of the safety data sheets. So this labeling will include pictograms associated with signal words like danger or warning. And employers must maintain copies of all safety data sheets that are readily accessible to all employees or anyone who needs it. Okay. That could be an inspector coming in as well. And they do permit in this day and age with technology that you have, you can retain electronic copies if that is your wish. However, personally, I would advise you as a best practice. You never know what's going to go wrong with technology. We had a problem with technology this morning. So because we don't know what can go wrong with technology, you don't want to be caught not having access to those safety data sheets and that information when you need it. Because when you need it, you can't be looking around for it. Keep paper copies. Okay. So per Hascom, your centers must have a written Hascom program that details how your center is meeting this standard. And it has to include training on the hazards of chemicals, measures to be used to protect them from these hazards based on the safety data sheets and the labels and the program itself. Don't forget that you have to document every employee's training. They need training when they're on boarded. When they come to work for your center, you've got to train them before they can get to work. But really, that part's required. However, I will tell you that you need to do this training annually. If you don't, you do it one time, do you remember what you learned 20 years ago in chemistry class? I don't think so. So you need to do this training annually. And you got to keep your training records because if you didn't document it, it didn't happen. That's how the inspector is going to view it. These resources, there's so many resources out there available to help you. If you have any questions, come, find me. Because the failure to meet this standard could increase your liability in the case of a chemical injury. I want to give a shout out to Alex Sudow because she has posted some resources for you, including the OSHA Small Business Safety and Health Handbook on FTA's website. There are resources available to you all over the place. We need to be using them. Okay. So if you think that this stuff is not important, I'm going to tell you some stuff that's going to shock you. So the reactivity of hydrogen peroxide. I found this YouTube video that talks about hazards of hydrogen peroxide and it showed that when you drop a piece of lead, a tiny piece of lead into a glass of hydrogen peroxide about 45 seconds later, you have toxic fumes and smoke. That's that first picture. They also showed that after only a few drops and I counted three of hydrogen peroxide on a leather glove, within mere seconds, it ignited and started a fire. Recall that section five of your safety data sheet also includes advice for firefighters. So they will often ask to see your safety data sheets if they're responding to a chemical fire. So another reason to have them handy. But if you think about these incompatibilities that I just rattled off, there's only two of which there are very many for this particular chemical, you need to consider proper storage of your hazardous chemicals. So all hazardous chemicals, especially heavy liquids, they need to not be above the solids. They need to be at a height. All chemicals really need to be at a height. That is eye level with the shortest staff member that needs to get them. You need to keep them always, always away from incompatible materials. And you need to follow your safety data sheets for any requirements on secondary, flammability or other types of containment and ventilation. Picking on 35% hydrogen peroxide again, those storage requirements are cool, dry, well-ventilated area in a vented, corrosion-resistant, properly labeled container. Keep in mind you have some incompatibilities to contend with, steel, iron, nickel, copper, lead and platinum, to name a few. And you have to inspect these containers periodically for damages, leaks or abnormalities. Don't store in the sunlight or near any heat source, never on a wooden pallet or near any combustibles, including organics. And of course not reducing agents as those are incompatible materials. It actually says, contact with organic substances may cause a fire or explosion. Contact with metals, metallic ions, alkalized reducing agents and organic matter may produce self-accelerated thermal decomposition. Okay? All right, who has seen something like this before? Okay, well then you have something to learn here. Hydrogen peroxide, it bleaches skin cells. When I say bleaches, I don't mean you can just stick your hands out of the sink and it just washes right off. If this happened to you, you are now going to have to wait until those skin cells regenerate for that white color to be gone. Okay? What if a member of your staff is pouring hydrogen peroxide into the tank and it splashes on their face and into their eye? This is much more common than you think I've had so many conversations about it this weekend. Okay? The Department of Labor is going to find you because you don't have a Hascom program and proper Hascom training. Did you have proper protective equipment? Otherwise, you're going to be Daffy Duck. Okay? Because otherwise you wouldn't have had this happen to you. Safety goggles people, best practices would really be face shields, nitrile gloves, as well as some sort of protective clothing because the cotton you're wearing is an organics. It's a combustible. So it's also something you don't want to get on your clothes. What if, what about having an eye wash station and a safety shower? The safety data sheet actually requires you to have those if you have this chemical at your center. Okay? You also need to realize that this is a very strong oxidizer, which means that it will intensify a fire and accelerate combustion. Okay? And this is some of the language on the safety data sheet. Keep it away from your clothing because cotton is an organic and it tells you to use protective clothing. All right. Another source of safety information is the container label. This can be found on the product label or container label and it's going to include pictograms, hazard statements and precautionary statements. This is a picture of a drum of 35% hydrogen peroxide. It also has some DOT labeling, Department of Transportation. And this is important. The information on this label is also important. It's more readily accessible than your safety data sheet likely is even as readily accessible as those SDSs should be. But you should never transfer hazardous chemicals from their original containers into an unlabeled bottle or container and preferably not transfer them at all. Okay. The whole reason you guys showed up to my talk this morning, let's just be honest. It's because you wanted to hear about disinfection, right? But first, we need to talk about regulation of disinfectants. Okay? The EPA enforces this little thing called VIFRA, the Federal Insecticide, Fungicide, Rodenticide Act. And yes, I'm going to make you repeat that to me later. No, I'm not. Through EPA registrations, which means through their labeling requirements. And there's this little thing that's on every label, EPA registered label, on every product. Okay? Do you guys know what that sentence is? Might have heard it before. Did this last year, by the way, guys. It is a violation of federal law to use this product in a manner inconsistent with its labeling. That's on every single EPA registered product in the United States. Okay? Now, consider a public swimming pool. Okay. What concentration of disinfectant does a pool use? There's different things telling them different information. Do they go with the state code or the EPA product label? I just told you it's a violation of federal law to use it in a way that's different from what it tells you, right? But you got to think about something else. Who has the authority to shut you down? That's the health inspector. So you need to follow your local codes for your float center as well. Okay. Now we're going to review a little scenario to see what you know. Using hydrogen peroxide, we know is the best practice in the North American FTA float tank standard. And your website says our float tanks are disinfected by UV, ozone, and hydrogen peroxide. Is this statement correct? No. Hydrogen peroxide is not registered by the EPA as a disinfectant for use in float tanks. Period. So this statement would be considered by the EPA misbranding and could be subject to legal action. Actually, it would be subject to legal action. And it's a word game issue. We know that. And it's very common. So you should check all claims of this on your website, any literature, materials you have, pamphlets, and make sure you don't say these words that you're disinfecting float tanks with hydrogen peroxide. Okay. So you cannot disinfect float solution with hydrogen peroxide. Exactly what my talk says, right? The answer you've been waiting for. Hydrogen peroxide does oxidize the float solution, which does help control odor and clarity. But there are no approved hydrogen peroxide products registered as disinfectants for use in the tanks or even in spas. So there are no approved directions for use to tell us what doses or concentrations of it to use for that purpose. Okay. Another scenario. During float solution replacement, you want to disinfect the water line. Again, you follow all the laws, right? You're all listening, right? You're following all the laws, okay? So what EPA registered sanitizer or disinfectant do you use? There aren't any EPA registered sanitizers that specifically cover float tanks, right? However, there are a number of hard nonporous surface sanitizers, sprays and wipes, that are based on hydrogen peroxide and those are registered with the EPA and approved for that use. So since your float tanks are a hard nonporous surface, it's covered by those EPA directions for use and you can use it that way. The preferred formulas are typically alcohol or hydrogen peroxide wipes, but do not use sprays with quats because these are inactivated by high levels of salts, okay? Also, just food for thought, I want you to think about something. What is the frequency of replacing your solution is appropriate? Should it be based on the number of floaters per day, per week? How many volumetric turnovers you have? But you know, at the beginning of the day, at the end of the day, we need a lot more data to understand these things and improve and mitigate our risk. Hopefully, we'll learn something from Dr. Roy Vaughn this afternoon about how to do that. Okay, let's look at another example. While we're on the subject of disinfection, we need to talk about cold plunge tanks, people, okay? Conditions of use that impact risk, all right? This is really important for us because this is a new thing. So we know we normally run these tanks at pretty cold temperatures, right? Typically 45 to 55 degrees. I know there's some variations out there, okay? But these are not just like cold plunge tanks. They are what would be considered special purpose pools. They're pools, okay? What does that mean? That means you need chlorine, all right? Pseudomonas bacteria, they're very opportunistic and they reproduce quickly in water. Although I have some good news, they're susceptible to free chlorine. So as long as you have some free chlorine, you will minimize and keep them from happening and will minimize biofilm formation and all the risk associated with Pseudomonas by just having your minimum free chlorine residual met. Be aware that if you have UV treatment of that cold plunge tank that it can destroy some of that chlorine residual that you need to keep in the water. So you need to check your free chlorine measurements after you treat with UV. Okay, if you have questions about this, please, please come talk to me because swimming pools are my thing. That's what I know. So come talk to me about this. Better yet, go check out some of the posters. If you go outside these doors back here on the brick wall out there, we've got some really nice posters with some really great information. All right. So we've been talking about chemicals. Let's talk about equipment. Your equipment can also impact disinfection. Okay, for UV systems, you need to consider the power output. How many millijoules? Is it a low or medium or high output lamp? Is the system the right size and design based on, you know, that output and flow rate that you're looking for for your specific float tank? Is it because if it's too low or it's too small of an output, then you're not getting the proper disinfection that you need. Okay, we all know what happens there. Don't need to explain those risks, but if it's too high, you're literally setting fire to a pile of cash. Okay, so that's why this is important. For ozone, it's a little different. We have some different watch outs here. Okay, you need to only use ozone systems from reputable, well-established manufacturers. Is your ozone system properly calibrated? Because if it's too low, you're going to have insufficient oxidation and that's going to affect your disinfection as well. Okay, if it's too high, you have different set of problems. You could have an exposure to ozone, and if that exposure were to exceed what's called the short time exposure limit, or the time-weighted average, those are two different values, they have two different meetings, then you could suffer permanent lung damage. Okay, I wanted to share these values with you because a few folks that I spoke to this weekend asked me, so I dug around the internet and found them for you, but if you are unsure or you have any concerns, you need to reach out and connect with your ozone system equipment manufacturer to review their use recommendations and have them help ensure that you're staying below these risk levels. So general do's and don'ts for equipment, bottom line is always, always follow the equipment manufacturer recommendations for use, for maintenance, and for mining the lifetime and replacement timeframes. Okay, if you're not using it properly, you're going to have insufficient or improper maintenance, they can lead to premature lifetimes, in other words, you need to replace it that much sooner and or malfunction. An example would be in swimming pools, like I said, I know swimming pools, if you have your pool pump that's getting exposed to some pool water that runs really high on total dissolved solids, or has exposed to excessive corrosive situations, then that pump is not going to last very long, it's going to need to be replaced quite a bit sooner. Take care of your equipment. Okay, so bottom line is you need to strive for best practices and the use of best available technology so that we can have the most reliable successful outcomes. Occasionally, the best available technology could be a flop, but that's typically only when marketing makes unsupportable claims. So you should ask yourself, is using the best available technology in line with best practice? If not, you go with best practice, always. Okay, now I'm going to ask you a trick question. Can you afford to cut any corners? Good answer. You need to ask yourself, do your practices fit with the risk levels that I am describing to you? Consider the examples and the possible severe consequences associated with monetary and non-monetary cost, okay, including your center's reputation if there's a major incident that occurs. The bottom line is that you should never cut corners when it comes to safety. So what does this, what do best practices look like for your center? Are you being safe, as safe as you can be? Are you compliant? How effective is your training? So the million dollar question, okay, this is going to tell me literally million dollar question because it could turn into a million dollar lawsuit if you don't know these things. Okay, how much have you learned from my talk today? Which of the following is not a takeaway from my talk today? A, you don't disinfect float tanks with hydrogen peroxide. You get an eyewash station and a safety shower as soon as possible. And oh, by the way, you should be inspecting them regularly to make sure they're working. Evaluate and adjust your chemical storage. Okay, to make sure that it's compliant with your safety data sheet requirements for all your chemicals. Prepare a written Hascom program for your center. Have all the safety data sheets for all chemicals, including consumer cleaning products and magnesium sulfate. Train all your employees starting on upon starting before they begin work on Hascom safety data sheets and labels. Train them annually. Keep chlorine in your cold plunged tanks. Please just follow all manufacturer use and maintenance recommendations on all equipment and verify outputs and you'll be good to go. Or is it by Roy vor another beer because that's all he talks about. I hope you guys got that one right. Why not buy him a beer? Well, let me tell you folks. Number one, he's an imposter. There's Carla. All right. Hi Carla. Two, he does things that he shouldn't be doing when he thinks you're not looking entering the employee onlys area when he thinks no one's watching. He has terrible hygiene practices. And oh, by the way, inappropriate to be showering and fraternizing in the shower at our centers with other people. And also, how could you possibly sleep through Dr. Flux's talk? And by the way, there's something very wrong with enjoying stepping on your own face all day. Look at those socks, people. This is why you should not buy him another beer. It's all about safety. It's about data. It's about sharing what you know, sharing the things that you're experiencing at your centers because that's how we're going to learn. There is content coming out for the CPO manual and course on float tanks in the works. So stay tuned. The safer we are and the more data you share about your center, your operations, your best practices, the better we all will be better and safer. So please get involved. I want to say thank you. And I also want to say I'm happy to take the questions. But if you have any complaints, please send them to the complaints department head, Dr. Roy Vor, and he will take good care of you and buy you a beer. A special thank you to Dr. Tom Keekler as well as Dr. Roy Vor for their expertise and help. And oh, by the way, if you have to buy him something that he likes, please make sure it's an IPA in sushi because those are his two absolute favorites. These are our references. Thank you all for being here this morning.