Germicidal UV Devices
in Canada

Ultraviolet (UV) is the energy that sits just outside the visible light zone in the electromagnetic radiation spectrum. UV has a shorter wavelength than visible light and transmits energy at different frequencies. UV wavelengths are classified into three ranges:

• UV-A has a long-wavelength, from 315 nm to 400 nm
• UV-B has a mid-wavelength, from 280 nm to 315 nm
• UV-C has a short-wavelength, from 100 nm to 280 nm

The following diagram illustrates this:

Germicidal Ultraviolet (GUV) refers to UV radiant energy that is used to inactivate bacteria, mold spores, fungi or viruses. UV-C wavelengths have been proven to be effective for disinfection.^[1] GUV has been used for decades to disinfect air, water and surfaces.

Ultraviolet Germicidal Irradiation (UVGI) is the disinfection process that is applied to a given location to inactivate bacteria and viruses by using short-wavelength UV energy to disrupt DNA or RNA formation, preventing microorganisms from multiplying and spreading.

[1] https://media.ies.org/docs/standards/IES%20CR-2-20-V1a-20200507.pdf

Studies show that bacteria, mold and fungi can be killed and viruses can be inactivated by UV-C^[1]. UV-C wavelengths comprise photons that are the most energetic and photochemically active in the UV spectrum. UV-C energy photochemically interacts with the RNA and DNA molecules in a virus or bacteria to render these microorganisms non-infectious^[2]. All known microorganisms are proven to be susceptible to UV-C.

[1] https://www.amca.org/educate/articles-and-technical-papers/amca-inmotion-articles/uv-c-for-hvac-air-and-surface-disinfection-2.html
https://www.ashrae.org/file%20library/technical%20resources/covid-19/i-p_a19_ch62_uvairandsurfacetreatment.pdf?bcs-agent-scanner=63ebec5b-d442-c04c-83cb-6959bf2d1a01

[2] https://www.ies.org/standards/committee-reports/ies-committee-report-cr-2-20-faqs/

Many studies have been conducted to confirm the effectiveness of UV-C sources in the inactivation of SARS-CoV-2, the virus that causes COVID-19. Effectiveness depends on factors such as the wavelength of the UV energy, its intensity, exposure time and transmittance.

Most of the published results used UV-C at 254 nm. For example, researchers at the National Emerging Infectious Diseases Lab at Boston University identified that a dose of 22mJ/cm2 of 254 nm UV-C will result in a reduction of 99.99% of SARS-CoV-2^[1]. Other reported studies show similar results with 254 nm UV-C:

“SARS-CoV-2 is highly susceptible to irradiation with ultraviolet light. High viral loads of 5 * 10⁶ TCID50/ml SARS-CoV-2 can be inactivated in 9 minutes by UV-C irradiation.” American Journal of Infection Control

“Far-UV-C (< 240 nm) light has been shown to be as efficient as conventional germicidal UV light in killing microorganisms…studies to date suggest that these wavelengths have reduced human health risks associated with direct exposure compared to conventional germicidal UV light.” Nature Research Journal

[1] https://www.biospace.com/article/uv-c-light-kills-sars-cov-2-triggering-novel-lighting-options-for-public-spaces/

GUV devices are generally safe but can be a health and safety hazard if improperly installed and used (see questions 18 & 19 for safe applications). For information on potential health effects of exposure to UV-C, click here.

Yes. GUV-emitting devices can be used to control, inactivate or kill microorganisms (i.e., bacteria and viruses) but are subject to registration and oversight in Canada within two classification areas:

1. Pest control devices are GUV devices intended for non-medical applications such as general air or surface disinfection (including UV and any products with such claims). These products are classified as Pest Control Products (PCP) by the Pest Control Products Regulations under the Pest Control Products Act (PCPA), which is administered by the Pest Management Regulatory Agency (PMRA), a department of Health Canada.
2. Medical devices are GUV devices intended for medical applications such as medical or personal protective equipment disinfection or for use as a medical treatment in a hospital environment (including UV and any products with such claims). These products are covered by the Medical Devices Regulations under the Food and Drugs Act (FDA), which is administered by Health Canada.

The Pest Management Regulatory Agency (PMRA) is a department of Health Canada. GUV devices intended for non-medical applications are classified as Pest Control Products (PCP) and must be approved by Health Canada. An assigned PCP registration number (PCP Reg. No.) must appear on the product label. This code has up to five digits that may be followed by two characters; for example: Registration No. 12345.xx Pest Control Products Act, or PCP Reg. No. 12345.xx

All GUV devices that are used for non-medical application that make claims to disinfect or sanitize spaces are currently subject to regulation under the Pest Control Products Act and Regulations. Examples include:

• Upper-air GUV devices
• Direct irradiation GUV devices
• Disinfection chambers (cabinets)
• Near-UV luminaires making disinfection/germicidal/sanitization claims

GUV devices intended for medical applications must be approved and registered by Health Canada.

No. The PMRA requires registration of GUV final products. UV-C lamps and components are considered parts of GUV products and, therefore, do not need to be registered separately.

You can go to the PMRA registration database to check: https://pesticide-registry.canada.ca/en/index.html.

You can submit a report via Health Canada’s Product Safety Program.

No. GUV products registered by the U.S. EPA are not accepted for sale or use in Canada. All GUV devices must be registered with PMRA for sale or use in the Canadian market.

All GUV devices must be registered with PMRA. In addition, GUV devices must comply with at least the following three requirements prior to sale and/or installation in Canada:

1. A Safety Certification for Electrical Safety Requirements: issued by an accredited standards organization such as UL, Intertek (ETL) or CSA, this certification evaluates and tests devices for electrical safety.
2. A Safety Certification for Photobiological Safety Requirements: all devices emitting UV must also be evaluated and tested for photobiological safety requirements, issued by an accredited standards organization such as UL, Intertek (ETL) or CSA.
3. Performance Information for Germicidal Efficacy: an application for registration must also submit evidence of germicidal efficacy to Health Canada.

Currently, federal requirements are in place; there are no provincial requirements at this time.

At this time, there is not a consensus standard for safety requirements for GUV devices.
It is expected that in time, a common standard will be developed.

However, UL has published several certification guidelines for the commercial use of GUV devices, which outline the evaluation expectations for several types of UV devices and systems:

1. Photobiological safety of end-use devices for:
   • Occupied spaces: the certification ensures safe operation (risk group exempt) at all times regardless of controls.
   • Non-occupied spaces: the certification ensures that safe operation is by the GUV systems with a combination of controls to prevent any exposure.
2. Ozone safety for products with significant output in the UV-C and far UV-C range: testing is required to ensure ozone emissions are below acceptable limits during operation. The photobiological safety of component devices evaluates a component that may be incorporated into an end-use device to allow for confidence in clear communication between the supplier and integrator, and for a division of responsibilities for the germicidal safety requirements of the end-use device.

Note: these outlined requirements were originally published as annexes to UL 1598 and as part of the new UL8802. Over time, it is expected that the organization of the requirements will evolve into an optimized structure. When in doubt of the applicability of a particular certification, refer to the documentation from the manufacturer of the device and from the issuing certification agency.

3. Proof of Certification/Listing on the GUV device: a registration issued by the Pest Management Regulatory Agency (PMRA) confirmed by a PMRA registration number must be listed on the product label.
4. PMRA requires a marking on the GUV product (example)

It is the EFC’s position that only those GUV devices that are approved and registered by Health Canada are safe and legitimate for sale and installation in Canada.

In addition, all such devices must be certified to Canadian Electrical and Photobiological safety standards.

GUV devices should be installed by professional electricians and used only in accordance with their manufacturers’ requirements and guidelines. The safe use of GUV devices depends strictly on their proper installation.

Selling or installing a non-compliant GUV device is illegal. Any GUV devices that do not have the Electrical certification mark and the PMRA “PCP Reg. No.” must not be purchased or installed.

No, this is not allowed; it is illegal and extremely unsafe. UV-C energy can be harmful if not properly managed. Safety management is maintained through proper, very specific product design and installation instructions that are tailored for specific installations.

Yes, GUV devices that are intended for use in non-occupied spaces must use a room containment control system to ensure that the treated space is not occupied during air/surface disinfection. Such devices must be certified by an accredited standards organization such as UL. See here for UL’s LED Radiation Safety FAQ. The systems must:

1. Comply with requirements for the safety evaluation of germicidal systems where surfaces in an unoccupied area are exposed to ultraviolet (UV) energy at an exposure dose that would otherwise pose a risk of personal injury to occupants.
2. Have application specific installation and operating instructions are considered an integral system component.
3. Have safeguards for both the equipment and the site, combined with criteria for safe shutdowns.

Yes, several types of GUV devices have been certified for use in occupied spaces. For example:

1. High-Intensity UV-C “Upper-Air” disinfection devices are designed to meet the UV-C radiation safety requirements to IEC 62471 and ANSI RP-27. These standards consider the photobiological effects of radiation on one’s skin and eyes.
2. Whole Room Irradiation Below Exposure Limits (WRIBEL) devices are designed to directly provide UV or near-UV treatment of the air and surfaces within occupied spaces while complying with applicable safety requirements.