What Is Means To Be An Epa Approved Sanitizer

[TinyBubbles]

I learned some fascinating info. from the epa. To be a registered epa sanitizer you must be able to kill 99.9999% of a bacteria, virus, etc. in under 30 seconds. Kill 99.9998% in under 30 seconds, you don't pass. Kill 99.9999% in 31 seconds, you don't pass. N2 for example had 2 water samples where only 99.9917% were killed in the allowed 30 seconds. Because of that, they aren't registered as a sanitizer, only a disinfectant. They did reach 99.9999% killed in under a minute for all samples tested. I have an N2 in my spa but I really haven't been trusting it that much. I kind of had it there as a back up. That information gives me alot more confidence in it and I think on my next fill I'm going to try using it with MPS daily dosing and dichlor shocking. I think it was Hillbilly that said we should learn something new every day. That's one good thing about this forum. We read things and then dive in deeper to get more info. The one big concern I still have is knowing when the cartridge is at the end up it's usefullness. I know they say to replace in 4 months, but I'd like to know how they came to that conclusion. I guess that's something to talk to Zodiac about.

[Dr. Spa]

I'm curious as to where you got this info. My understanding was the kill rate had to be achieved in a much longer period than 30 seconds (I think it was 20 minutes, though it may have been 2 minutes). Also, I've NEVER heard of any test results from N2.

[TinyBubbles]

I'm curious as to where you got this info. My understanding was the kill rate had to be achieved in a much longer period than 30 seconds (I think it was 20 minutes, though it may have been 2 minutes). Also, I've NEVER heard of any test results from N2.

If you can wait until Monday I will post it for you. They do have published paperwork where N2 has been tested by the EPA and the results. I believe the last time was in 06. It's broken down separately for the pool and spa systems. They also have published info. on frog too. It's all really very interesting. The info is from the EPA. They did the testing using chlorine as a control. I'm on the way out the door now, but I will get you info. Monday.

[tony]

I learned some fascinating info. from the epa. To be a registered epa sanitizer you must be able to kill 99.9999% of a bacteria, virus, etc. in under 30 seconds. Kill 99.9998% in under 30 seconds, you don't pass. Kill 99.9999% in 31 seconds, you don't pass. N2 for example had 2 water samples where only 99.9917% were killed in the allowed 30 seconds. Because of that, they aren't registered as a sanitizer, only a disinfectant. They did reach 99.9999% killed in under a minute for all samples tested. I have an N2 in my spa but I really haven't been trusting it that much. I kind of had it there as a back up. That information gives me alot more confidence in it and I think on my next fill I'm going to try using it with MPS daily dosing and dichlor shocking. I think it was Hillbilly that said we should learn something new every day. That's one good thing about this forum. We read things and then dive in deeper to get more info. The one big concern I still have is knowing when the cartridge is at the end up it's usefullness. I know they say to replace in 4 months, but I'd like to know how they came to that conclusion. I guess that's something to talk to Zodiac about.

Though some have had luck with the N2 and MPS routine, I personally have found it to be ineffective. I've tried it with a once a week dichlor shock then a twice a week dichlor shock, all with the same result...cloudy water in a couple of days. After trying it for more than a month I went back to dosing with dichlor after soaking. I have found that my water lasted the longest between soaks using N2/Frog with ozone and chlorine after use with a shock as needed when combined chlorine appeared. I now do not use N2/Frog or ozone and just be sure to dose at least every other day.

[waterbear]

First some facts on N2. Zodiac had to change their directions for use in 2006 to pass EPA testing and paid a hefty fine to the EPA in 1999 for labeling the N2 systems as sanitizers. The old 'recipe' was extremely low chlorine. The new 'recipe' is using basically normal chlorination levels and the kicker is they added the instruction to 'shock with dichlor weekly OR AS NEEDED!

Also, the Nature2 is often said to exceeds drinking water standards (just check out several of the websites selling it--they make this claim over and over). Well the standards for drinking water and spas are differrent since you don't have a bunch of people soaking in your drinking water and you don't keep you drinking water at 104 deg!

Finally, The CT times for the EPA testing is 30 seconds for E. Coli and 2 minutes for E. Faecium for a complete kill. If you doubt me here is the original EPA document on the Nature 2 spa test from 1999 where it did NOT pass. Here is one from 2004 when Zodac was requesting a waiver for product registration. Interesting reading!

[Hillbilly Hot Tub]

First some facts on N2. Zodiac had to change their directions for use in 2006 to pass EPA testing and paid a hefty fine to the EPA in 1999 for labeling the N2 systems as sanitizers. The old 'recipe' was extremely low chlorine. The new 'recipe' is using basically normal chlorination levels and the kicker is they added the instruction to 'shock with dichlor weekly OR AS NEEDED!

Also, the Nature2 is often said to exceeds drinking water standards (just check out several of the websites selling it--they make this claim over and over). Well the standards for drinking water and spas are differrent since you don't have a bunch of people soaking in your drinking water and you don't keep you drinking water at 104 deg!

Finally, The CT times for the EPA testing is 30 seconds for E. Coli and 2 minutes for E. Faecium for a complete kill. If you doubt me here is the original EPA document on the Nature 2 spa test from 1999 where it did NOT pass. Here is one from 2004 when Zodac was requesting a waiver for product registration. Interesting reading!

What about the 2006 info since that seems to be the new one? 1999 was a long time ago. Also, where are you getting that the new recipe is basically normal chlorination levels. I have the book in front of me. here is what it says...After the intial start, where you do "jump start it with chlorine you....before each use, test the water if MPS is low add 1 tbls MPS per 250 gallons of water keep doing so untill test strip indicates a sufficient level of MPS...after each use add 1 tbls of MPS per 250 gallons.....once per week PH etc 4 months replace N2/water. As needed shock with di-chlor to remedy problems which may occur when bathing loads are high or successive tests indicate high demand for MPS, dull hazy water, odors, foam etc. NOTE: as an ALTERNATIVE to MPS Dichlor may be substituted.

How is this new recipe keeping normal chlorine levels?

[Dr. Spa]

NOTE: as an ALTERNATIVE to MPS Dichlor may be substituted.

How is this new recipe keeping normal chlorine levels?

And towards the bottom;

Note: As an alternative to MPS², an EPA registered source of dichlor¹ may be substituted: 1 tablespoon dichlor¹ = approximately 3 tablespoons MPS².

1 tsp of chlorine per 250 gallons is pretty much "normal" chlorine use.

[Hillbilly Hot Tub]

NOTE: as an ALTERNATIVE to MPS Dichlor may be substituted.

How is this new recipe keeping normal chlorine levels?

And towards the bottom;

Note: As an alternative to MPS², an EPA registered source of dichlor¹ may be substituted: 1 tablespoon dichlor¹ = approximately 3 tablespoons MPS².

1 tsp of chlorine per 250 gallons is pretty much "normal" chlorine use.

But they say as an alternative, it does not say you have to? Guess I am confused. I am under the impression that you do not have to use di-chlor...it is an alternative. So if you use the regular recipe it would have very little chlorine. Are they not EPA approved without using di-chlor as the alternative.

[TinyBubbles]

I'm on my laptop and my files are at work on my desktop. If someone wants to use the older study they can read that the kill times someone mentioned of 2 minutes is merely referring to AOAC requirements for chlorine controls. If you scroll down to page 6 you will see that the EPA finds complete kill times over 30 seconds to be unacceptable for a sanitizer. There were clearly problems with the original test which is why it was repeated in 06. The 06 studies has all of the data I referred to in my earlier post including all the results for the 30 second results. Let's prevent this thread from becoming a costco vs. dealer spa type thread. No need for the rudeness of bold or capitized text. Agendas can be left at the door.

Tony, since I've never tried the mps dosing that you have, could you tell me what you did? What level did you maintain your MPS at? Now that you are dosing with dichlor what level of fc are you maintaining? Your experience makes me leary of trying mps dosing. Your input is helpful.

Hillbilly, I think some people might be confused by the zodiac's directions for people choosing to dose with dichlor instead of shocking with it. In that case and that case only, it directs you to substitute dichlor for mps when you soak at a rate of 1tbs dichlor being equal to 3 tbs. mps. If you are using their low chlorine mps dosing, then you are only using dichlor to shock when needed. I have read and reread my N2 manual and can't find anywhere where it says to maintain normal levels of chlorine. If someone has the booklet, can you tell me what page it is on? I just purchased my cartridge last week, but perhaps it has an old booklet in it. From what I can tell, shocking when needed is standard practice regardless of your sanitizer. Bather loads and other factors are big variables.

[waterbear]

Just so there is no confusion here is the old and new N2 spa 'recipes (any dealears out there who have been selling N2 for any length of time can verify that I have listed the recipes accurately!):

The "Old recipe" was :

1) on each refill add 1 teaspoon dichlor for each 250 gal water (this will bring the fc to 2 ppm)

2) before each use add 1 tablespoon MPS per 250 gallons OR 1/3 teaspoon dichlor (this will bring the FC to about .5 ppm)

3) once a week shock with 3 tablespoons MPS per 250 gal, the preferred way OR (in very fine print it says that 1 tablespoon dichlor can be substituted which will bring the FC to about 6 ppm...hardly shock level!)

4) As needed or if water looks hazy shock with 1 teaspoon dichlor per 250 gal (2 ppm...hardly shock level!)

5) Drain, refill, put in new Nature 2 cartridge and start over every 4 months.

The "New recipe" as of 2006 is:

1) on each refill add 1 1/2 TABLESPOONS dichlor for each 250 gal water (this will bring the fc to about 10 ppm...can anyone say 'shock'? )

2) before each use add 1 tablespoon MPS per 250 gallons (1 teaspoon dichlor can be substituted...this will raise the FC 2 ppm!)

3) once a week shock with 1 1/2 TABLESPOONS dichlor per 250 gal, the use of MPS for weekly shocking is no longer even an option! (this will bring the FC to about 10 ppm...standard shock level!)

4) As needed or if water looks hazy shock with 1 TABLESPOON dichlor per 250 gal (6 ppm...Isn't this normal chlorination for a spa?!)

5) Drain, refill, put in new Nature 2 cartridge and start over every 4 months.

Seems to me that this is pretty much standard spa maintenace on chlorine without a Nature 2 cartridge, especially if you don't use the MPS and just use the dichlor, which IS an option that Zodiac has in their instructions!

I think this speaks for itself, especially since the N2 did NOT pass in 1999 and 2004.

Also, let us not forget that the EPA has only approved 3 (count 'em) primary sanitizers--chlorine, bromine, and biguanide. Everything else is a supplimental sanitizer that MUST be used with an EPA approved promary sanitizer. That included metal systems such as N2, Frog, active ionizers, liquid silver and/or copper based sanitizers, UV and Ozone.

[waterbear]

But they say as an alternative, it does not say you have to? Guess I am confused. I am under the impression that you do not have to use di-chlor...it is an alternative. So if you use the regular recipe it would have very little chlorine. Are they not EPA approved without using di-chlor as the alternative.

Dichlor is now required for weekly or as needed shocking and MPS is not even an option for this now. In the past it was possible to use tne N2 without any dichlor except on initial startup, and that was only to about 2 ppm. The level of dichlor suggested weekly or as needed will bring the FC up to about 6 ppm, pretty much standard levels for a chlorine spa. The use of dichlor is optional before and after each use and MPS can be used here. It is interesting that in the old recipe if dichlor was used it was only enough to raise the FC by .5 ppm while in the new recipe it raises the FC about 2 ppm. That is quite a big difference in FC levels, no?

[tony]

I'm on my laptop and my files are at work on my desktop. If someone wants to use the older study they can read that the kill times someone mentioned of 2 minutes is merely referring to AOAC requirements for chlorine controls. If you scroll down to page 6 you will see that the EPA finds complete kill times over 30 seconds to be unacceptable for a sanitizer. There were clearly problems with the original test which is why it was repeated in 06. The 06 studies has all of the data I referred to in my earlier post including all the results for the 30 second results. Let's prevent this thread from becoming a costco vs. dealer spa type thread. No need for the rudeness of bold or capitized text. Agendas can be left at the door.

Tony, since I've never tried the mps dosing that you have, could you tell me what you did? What level did you maintain your MPS at? Now that you are dosing with dichlor what level of fc are you maintaining? Your experience makes me leary of trying mps dosing. Your input is helpful.

Hillbilly, I think some people might be confused by the zodiac's directions for people choosing to dose with dichlor instead of shocking with it. In that case and that case only, it directs you to substitute dichlor for mps when you soak at a rate of 1tbs dichlor being equal to 3 tbs. mps. If you are using their low chlorine mps dosing, then you are only using dichlor to shock when needed. I have read and reread my N2 manual and can't find anywhere where it says to maintain normal levels of chlorine. If someone has the booklet, can you tell me what page it is on? I just purchased my cartridge last week, but perhaps it has an old booklet in it. From what I can tell, shocking when needed is standard practice regardless of your sanitizer. Bather loads and other factors are big variables.

Tiny, I tried the MPS because I like the idea of opening the spa, soaking and then just closing it up. I used Nature2 and ozone along with the MPS. I would shock with dichlor once per week (usually Sunday) to a level of 10ppm free chlorine. Before each soak I would add between one and two tablespoons of non chlorine shock per N2 instructions. I generally use the spa every day. I might get two days use and the third day I would open to a cloudy mess. I would then shock with chlorine and wait to get clear water and try again. I tried to stay with it for a while and even tried a second dichlor dose midweek, but still couldn't rely on the water staying clear. After about a month I stopped and went back to my chlorine dose after soak routine. I think that because I use the spa daily, the silver just couldn't keep up with the use. Either that or I am loaded with bacteria! I never measured the MPS levels in the water. BTW, this is one of the sanitizing methods my dealer recommends. It may very well work for you and is worth a try. If things don't work out, just add chlorine.

[Hillbilly Hot Tub]

But they say as an alternative, it does not say you have to? Guess I am confused. I am under the impression that you do not have to use di-chlor...it is an alternative. So if you use the regular recipe it would have very little chlorine. Are they not EPA approved without using di-chlor as the alternative.

Dichlor is now required for weekly or as needed shocking and MPS is not even an option for this now. In the past it was possible to use tne N2 without any dichlor except on initial startup, and that was only to about 2 ppm. The level of dichlor suggested weekly or as needed will bring the FC up to about 6 ppm, pretty much standard levels for a chlorine spa. The use of dichlor is optional before and after each use and MPS can be used here. It is interesting that in the old recipe if dichlor was used it was only enough to raise the FC by .5 ppm while in the new recipe it raises the FC about 2 ppm. That is quite a big difference in FC levels, no?

Water bear, I have the book in front of me from Nature 2 I just received, not old ones, no where does it say that shocking with di-chlor weekly is mandatory. I just can not find it. It is under as needed..not weekly. The only mandatory di-chlor is at start up. Can you please tell me where to find that weekly doses of di-chlor are mandatory? As needed is stated to be to remedy problems, not weekly.

I understand what you are saying, if you substitute di-chlor for MPs and shock with di-chlor weekly, it would kind of be a waste to have N2, but if you follow their recipe (which they state you must strictly follow) then N2 can be a benifit for people who want little to no chlorine.

I also agree that N2 dose not work well with heavy bather loads as I stated before unless you use the dichlor, if this is the case with people, I would suggest something different.

I have found that 2 people using the tub, no swimsuits, 4 hour filter with ozone do quite well with the N2 recipe with very little dichlor.

[waterbear]

But they say as an alternative, it does not say you have to? Guess I am confused. I am under the impression that you do not have to use di-chlor...it is an alternative. So if you use the regular recipe it would have very little chlorine. Are they not EPA approved without using di-chlor as the alternative.

Dichlor is now required for weekly or as needed shocking and MPS is not even an option for this now. In the past it was possible to use tne N2 without any dichlor except on initial startup, and that was only to about 2 ppm. The level of dichlor suggested weekly or as needed will bring the FC up to about 6 ppm, pretty much standard levels for a chlorine spa. The use of dichlor is optional before and after each use and MPS can be used here. It is interesting that in the old recipe if dichlor was used it was only enough to raise the FC by .5 ppm while in the new recipe it raises the FC about 2 ppm. That is quite a big difference in FC levels, no?

Water bear, I have the book in front of me from Nature 2 I just received, not old ones, no where does it say that shocking with di-chlor weekly is mandatory. I just can not find it. It is under as needed..not weekly. The only mandatory di-chlor is at start up. Can you please tell me where to find that weekly doses of di-chlor are mandatory? As needed is stated to be to remedy problems, not weekly.

I understand what you are saying, if you substitute di-chlor for MPs and shock with di-chlor weekly, it would kind of be a waste to have N2, but if you follow their recipe (which they state you must strictly follow) then N2 can be a benifit for people who want little to no chlorine.

I also agree that N2 dose not work well with heavy bather loads as I stated before unless you use the dichlor, if this is the case with people, I would suggest something different.

I have found that 2 people using the tub, no swimsuits, 4 hour filter with ozone do quite well with the N2 recipe with very little dichlor.

Intersting. The instructions I have are from a 2006 copyright instruction manaual when they first changed the instructions. I just checked and found a manual where the copyright is 2007 and they have been changed again but they play an interesting word game on page 7 that I quote:

"Important: Perform start-up procedures for spas which

have been unused or unattended."

In other words, shock with chlorine! Now they don't say how long the spa can be unused before you have to shock. Is it a week or a month? In the 2006 instructions they did say to shock weekly or as needed. Another word game because if there are water quality problems Zodiac can just say that you are not shocking enough! Gets them off the hook!

Also, on page 6 they call it a low chlorine recipe, not a chlorine free recipe and do list dichlor as one of the things you need. This is after the startup section but like I said they do say on page 7 that you need to perform the startup procedure and they also say to shock as needed with dichlor. Now tell me how the average spa owner is going to know WHEN they need to shock with dichlor. It is going to be a lot more often then they probably are (if they are doing it at all, which many don't!)

All in all cleaver wording to get around stating JUST how much chlorine is really needed with the N2. At least the 2006 copyright instructions were a bit more upfront about it!

[TinyBubbles]

I almost forgot to post this link. http://www.epa.gov/opp00001/foia/reviews/0...2006-01-27a.pdf. This is the 2006 info. for N2 from the epa.

Performing start up procedures on an unattended spa is different than having to maintain the same levels of chlorine with N2 that you would have to have to maintain without it. I use dichlor and if I leave my spa unattended long enough I'm going to need to shock it as well. My instructions with my chlorine start up kit said to shock as needed. My sister uses bromine and I asked her, same thing. She shocks as needed. The literature that I got with my N2 cartridge does state low chlorine, not no chlorine. Many people want to keep their chlorine useage at a minimum. One thing to question is wether or not MPS is better for you than chlorine. If you follow zodiac's instructions you are adding one chemical instead of another. I know chlorine and bromine have health implications. I don't know about MPS. That's definately something to investigate.

Thanks for your info. Tony. I certainly wouldn't want to have cloudy water every third day. Right now, I think you and I are using the exact same method. I want to try Mps daily dosing, but things are going so well that I'm hesitant. I wish you tested your MPS levels to see if possibly you just needed to use more MPS than what is suggested. Kinda like the vermonter dichlor method, add for levels not just by amounts. But, then again, why add 3tbs. of mps when you can get by with less chlorine, right? I think I'll have to look into MPS more before I decide if it's better to be stewing in that than chlorine.

[tony]

I almost forgot to post this link. http://www.epa.gov/opp00001/foia/reviews/0...2006-01-27a.pdf. This is the 2006 info. for N2 from the epa.

Performing start up procedures on an unattended spa is different than having to maintain the same levels of chlorine with N2 that you would have to have to maintain without it. I use dichlor and if I leave my spa unattended long enough I'm going to need to shock it as well. My instructions with my chlorine start up kit said to shock as needed. My sister uses bromine and I asked her, same thing. She shocks as needed. The literature that I got with my N2 cartridge does state low chlorine, not no chlorine. Many people want to keep their chlorine useage at a minimum. One thing to question is wether or not MPS is better for you than chlorine. If you follow zodiac's instructions you are adding one chemical instead of another. I know chlorine and bromine have health implications. I don't know about MPS. That's definately something to investigate.

Thanks for your info. Tony. I certainly wouldn't want to have cloudy water every third day. Right now, I think you and I are using the exact same method. I want to try Mps daily dosing, but things are going so well that I'm hesitant. I wish you tested your MPS levels to see if possibly you just needed to use more MPS than what is suggested. Kinda like the vermonter dichlor method, add for levels not just by amounts. But, then again, why add 3tbs. of mps when you can get by with less chlorine, right? I think I'll have to look into MPS more before I decide if it's better to be stewing in that than chlorine.

Thats where I was comming from. If I need to add so much product, whats the sense. Chlorine has worked real well for me.