ActivePure’s 4 IAQ Recommendations to the EPA

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To help promote the Clean Air in Buildings Challenge, the EPA recently published a formal request for information (RFI) titled “Better Indoor Air Quality Management to Help Reduce COVID-19 and Other Disease Transmission in Buildings: Technical Assistance Needs and Priorities to Improve Public Health.” In other words, the EPA asked the public for tools and ideas that could create a long-term improvement in indoor air quality (IAQ), especially as it relates to disease transmission.

As part of our mission to improve indoor air quality standards, ActivePure provided a thorough response to this request, composed in cooperation with one of our university partners. Below is a summary of the major points. All quotes are from ActivePure’s response unless otherwise cited.

1. Develop Holistic Indoor Air Quality Standards

“If the EPA adopts such a rigorous and comprehensive characterization, of all aspects of indoor air quality in the built environment, it will be a watershed moment on par with the passage of the Clean Air Act in the 1970s.”

One component of ActivePure’s response to the RFI is to call for holistic, universal indoor air quality standards. While organizations such as ASHRAE may make recommendations, the EPA neither regulates nor provides comprehensive standards for indoor air.

2. Adopt a “Clean First” Approach

“Adjusting the ventilation rate is clearly effective for treating stale air and reducing so-called sick-building syndrome, but when dealing with contaminants and airborne pathogens, solely adjusting the ventilation rate falls short.”

Per the EPA, “Ventilation, filtration, and air cleaning in buildings are essential components of a multilayered approach to preventing disease transmission, including COVID-19.” ActivePure agrees with this guidance but wishes to convey the need for a different “order of operations.” When it comes to disease prevention, air cleaning ought to be prioritized over ventilation and filtration because:

  1. Increased ventilation does not necessarily reduce disease transmission. For instance, per a study by scientists at the National Institute of Health, “‘the most important contributing factor to contaminant transmission in [an] enclosed and mechanically ventilated environment is the path between the contaminant source and the exhaust, not the air changes per hour.’”
  2. Increased filtration does not necessarily reduce disease transmission. This is at least partially because “air filters only clean the air they come into contact with.” For instance, a contact-tracing case study “found that six students were infected by a teacher in a distant room, despite the use of high-efficiency particulate air filters throughout the building.”

Thus, we turn to air cleaning (specifically active purification) for such contaminants (please see Section 4 below.)

3. Accommodate Economic Realities

“Advanced Photocatalysis technology, when deployed within an HVAC system, does not impede or stress HVAC components, allowing all [school] districts nationwide, regardless of economic circumstances or the average age of facilities, to participate in the full health benefits possible from this air cleaning technology.”

An oversimplified prioritization of ventilation and filtration is also problematic because of its impact on the economic capabilities of most organizations. An increase in filter grades may strain or damage the HVAC system. Meanwhile, a universal increase in air changes per hour would also increase energy consumption. These detriments would be a “non-starter” for many organizations trying to reduce their carbon footprint while protecting the budget.

In addition, the ongoing cost associated with increased ventilation and filtration makes such improvements less accessible to poorer communities, especially schools. The EPA thus risks, as our response phrases it, “inadvertently promoting an increase in health and economic disparities by failing to consider the very real fiscal cost associated with increased air changes.”

Layered air cleaning solutions can help balance air quality improvements with this economic reality. For instance, the introduction of ActivePure Technology allowed at least one Fortune 500 company to move from MERV 13 back to its original MERV 8 filtration. Overall, the areas with ActivePure devices and MERV 8 filters saw a 96% reduction in surface bacteria and a 54.5% reduction in airborne bacteria and fungi. This was above and beyond the levels of bacteria and fungi that the company saw using a combination of MERV 13 filters and UVGI.

4. Install Active Air Cleaners

“More effective air cleaning would address decades of problems that have not been addressed by ventilation and filtration alone.”

One way to adopt a “clean first” approach while acknowledging economic realities is to use available technological innovations in air cleaning, such as Advanced Photocatalysis a.k.a. ActivePure Technology. (Note that active photocatalysis is not the same as classic PCO.) Below are some such results mentioned in our response to the EPA.

Unaffiliated Lab Testing


  • “Testing in an anonymized Large Public School District revealed a 96.5% decrease in baseline levels of Total Aerobic Bacteria and a 67.6% decrease in Total Fungal Count”
  • A long-term study of ActivePure devices in a busy school found:
    • Reduction of bacterial loads “by five orders of magnitude”
    • “Dust loads were not only not reduced, but were also maintained as non-detectable or decreased using the ActivePure devices”
    • No discernable increase in ozone beyond background levels


  • Lab Testing: “Overall, the [ActivePure] Medical Guardian achieves a net log reduction of 4.80 ± 0.74 for all organisms tested.” This means the Medical Guardian neutralized greater than 99.99% of everything thrown against it
  • Field Testing: A Canadian SICU using the ActivePure Medical Guardian saw an 89% reduction in fungal counts and a 94% reduction in bacterial counts
  • Clinical Trial: The ActivePure Medical Guardian was used in a surgical ICU for 7 months, during which said ICU saw the complete elimination of MRSA and C. diff-related hospital-acquired infections


The federal government needs time to create policies that best support the complex needs of the greater good for it justly operates by taking counsel with many at once. The private sector is not similarly bound. It can act swiftly on the best information. If you believe that your organization can benefit from economically and environmentally practical IAQ interventions, you don’t need to wait for the government to mandate them. Contact ActivePure today to get started.

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