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gp
gp
X.11
gp
new
section
gp
definition
gp
definition
Data plate
Air Treatment
System:
copy text from draft and show changes in track
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ge
I think a lot of good work has been done here. I think
there are still a few areas that need some attention.
te
Warning that no user shall use the facility when the
Floating in a tank at too warm of a temperature can be
lethal. From Wikipedia - humans may experience lethal temperature is above 34.5°C or 94.2°F.
hyperthermia when the web-bulb temperature is
sustained above 35°C (95°F) for six hours. I propose an
upper safety limit of 34.6°C or 94.3°F. This should be
on the Data plate.
te
The temperature control system must be accurate in
order that the above is meaningful.
Temperature Regulation
Quarterly the temperature controller will be calibrated
with a NIST traceable calibrated thermometer. It will be
corrected, if it can be calibrated, otherwise the amount it
is off will be clearly indicated on the unit.
te
I don’t think these devices are expected to go into
environments requiring disinfection, recirculation and
filtration. And if so, isn’t that a function that should be
handled by the facility not the tank?
Air Treatment System: All materials and equipment related
to air quality.
ge
see comments on section 2.59 Public Sensory
Ancillary Facility: Any area or appurtenance used in
conjunction with or for the operation of a public floatation
system including but not limited to public dressing rooms,
Deprivation or Floatation System:
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lockers, shower or bathroom areas, drinking fountains, or
any room that is intended to be used by floatation system
users.
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Public
Sensory
Deprivation
or Floatation
System:
te
gp
2.59
copy text from draft and show changes in track
change.
The term sensory deprivation should be removed
everywhere in this scientific document. For a more
thorough discussion of this issue see
http://samadhitank.com/sensorydep.html The only way
to deprive a person of their senses are to cut off their
head, etc. We do not have dead people using these
tanks. So the term is not appropriate in a scientific
document.
Public Floatation System: A combination of water holding
vessel and treatment system for the immersion and
floatation of person in temperature-controlled water
circulated in a closed system, and not intended to be drained
to waste and filled with each use. It is manufactured to
factory specifications with specific design, plumbing,
components, and suppliers such that the water is circulated,
treated, and filtered via closed loop system. The floatation
system may be permanently installed or portable and
typically includes certain systems or components integral to
the system or as part of a separate manufacturer specified
assembly or skid-pack: tub, box, or shell structure, liner, and
support system, hand hold(s), pull(s) or rail(s), filter(s),
pump(s), suction fitting(s) or drain(s), water return fittings,
skimmers, piping, tubing, hose, and other air or water
distribution fitting(s), heater(s), supplemental treatment
system(s), and control system. These aquatic vessels are of
a design and size such that it has an unobstructed volume of
water large enough to support floatation in place.
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gp
2.59
Operating
water level:
te
First and foremost the depth should permit floating.
Operating water level: Level at which water must be
maintained to enable proper floating, water circulation and
skimming.
gp
XX
te
Floatation
or Sensory
Deprivation
Systems
and
Related
Equipment
Remove the scientifically misleading term, sensory
deprivation.
Floatation Systems and Related Equipment
gp
X.1
Scope
Remove sensory deprivation. Although it has some
public usage, so do some words for intercourse and
manure. That does not mean they should be used in a
document like this.
This section establishes evaluation design, and testing
criteria including health and performance requirements for
horizontal floatation, and related equipment. The criteria
address factory manufactured, fully self-contained and nonself-contained, portable, and pre-fabricated
floatation
systems including requirements for the materials, design and
construction, marking, installation and use instructions,
performance of the liner or shell and structure, performance
of the water treatment system (or components), including
those involved in the circulation, and treatment (e.g.,
filtration and sanitation) of the water.
ed
This standard does not purport to address all safety
concerns, if any, associated with the use of horizontal
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floatation systems. It is the responsibility of the user of this
Standard to establish appropriate safety and health practices
and determine the applicability of regulatory limitations prior
to use.
te
Substitute floatation for sensory deprivation or remove
sensory deprivation.
Accessibility
A)
ed
This height requirement is unnecessarily restrictive,
prejudicial and has no safety merit - just remove
section A.
X.5.1
Accessibility
B)
ed
This needs reworking or removal. I think it is
inappropriate to require eg., all heaters to be
accessible.
gp
X.5.2.1
Shell, tub, or
liner: material
formulation,
surface
material,
strength
ed
I doubt that the specifications required for materials
that are subjected to direct sun and energetic children
are necessary for products which will always be inside.
And half of those materials will spend most their life in
total darkness. I think all material requirements need to
be revisited. For example, we have used 20 mil vinyl
liners for over 40 years without seeing a need to make
them thicker.
gp
X.5.2.1
Section 5.3
ed
Smoking will not be allowed in any float facility, much
gp
all
clauses
gp
X.5.1
gp
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less a float room so it’s unnecessary to be concerned
with its effects.
gp
X.5.2.3
te
Color may not always be the best choice for clearest
communication.
gp
X.7.2.1
ed
Colin said it “A hydrostatic pressure of 1.5 times 50 psi
exceeds all practical requirements. It is very unlikely a
pump system for a zero head recirculation system will
reach one bar, (15 psi) this is over-specified by a large
factor.” This line should be removed.
gp
X.7.2.2.5
paragraph 3
te
There is NO need to have any amount of air exchange
if the enclosed system meets the requirements in
X.7.2.2.5 and Table X. And there IS a need to
minimize as much as possible ALL distractions. The
second sentence needs to be removed.
gp
X.7.2.2.5
paragraph 4
ed
As someone who was poisoned about 12 years ago
with organo phosphates (what most pesticides were
made out of then - nerve toxins used disrupted the
nervous system of the bugs), I am still very
environmentally sensitive. Floating in halogens scares
me, both personally and company liability wise. I see
Floatation system shall be marked clearly with minimum
and maximum operational level marking on the inside of the
unit to display the allowable solution level range.
All systems, regardless of disinfection method, shall be
tested for Carbon Dioxide and Oxygen levels to meet the
criteria in Table X below.
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no reason to float in halogens when ozone and
Hydrogen Peroxide are effective safe alternatives
when handled properly. This paragraph needs to be
removed.
gp
X.7.3
te
In X.7.2.1 the turnover time has appropriately been
crossed out. It should also be crossed out here. What
is important is spelled out other places - the 3-log
reduction and the 70% turbidity reduction. The second
sentence is not needed.
The water circulation pumps shall be certified to the spa
temperature requirements of NSF/ANSI Standard 50 for
performance including, hydrostatic pressure, pump curve,
strainer performance (if applicable).
gp
X.7.6
ed
Hydrogen Peroxide is not in the NSF/ANSI 50 but is a
safe and effective sanitizer and should be allowed as it
is in the list in X.7.6.7.
Water sanitation in the sensory deprivation system shall be
accomplished disinfection systems sized to meet regulatory
requirements. The sensory deprivation system manufacturer
shall specify or require at least two disinfection systems to
be installed. The sensory deprivation system manufacturer
shall recommend or supply NSF/ANSI 50 certified
disinfection systems or Hydrogen Peroxide that when
combined are capable of producing a minimum 3-log kill
[99.9%] during the between user cleaning cycle. Water
sanitation equipment integral to the sensory deprivation
system shall meet the requirements, but a separate data
plate and operational instructions are not required if the
information is contained within the sensory deprivation unit.
gp
X.7.6.7
te
When the tank’s inventor, Dr John Lilly, gave me
One or more treatment systems or sanitizers shall be
Treatment
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specified by the manufacturer for installation or supplied by
specifications for how to design a tank, he specifically
the manufacturer with the floatation system. Halogens are
told me NOT to use anything copper in the tank
because it was toxic in the epsom salt solution. I do not not acceptable. Examples include but are not limited to:
● Ozone treatment systems
know whether this is true or not but I think copper/silver
● UV treatment systems
ion systems should be removed until they are
● Hydrogen peroxide
determined safe. That is why we have never used
pressure gauges on the filter tops.
The halogens should not be permitted. They pose a
safety risk. EPA registered sanitizers opens the door to
using them so remove that.
gp
X.7.6.7
bottom note
ed
I have no idea what the repercussions of this are.
gp
X.8
paragraph 1
sentence 2
te
Requiring that there be 2 redundant effective sanitation
systems is excessive and produces no risk reduction. It
is not analogous to wearing condoms where two are
safer than one.
gp
X.8
Paragraph 2
te
Hydrogen Peroxide needs to be added to the list of
methods to test and Copper/Silver ion system
removed.
Floatation systems shall use one of the following water
treatment methods (such as ozone, hydrogen peroxide, or
UV) to be tested for disinfection efficacy individually without
another supplemental disinfection system to assess the level
of performance of the disinfection system.
o
o
o
o
No chlorine/bromine chemical dosing
Ozone at manufacturer recommended
level/output
UV generator operating at manufacturer
recommended level or irradiance
Hydrogen Peroxide
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gp
X.9
te
Hydrogen Peroxide needs to be added to the list of
methods and Copper/Silver ion system removed.
gp
X.10
te
Hydrogen Peroxide needs to be added to the list of
methods and Copper/Silver ion system removed.
gp
X,11
te
No need for Maximum number of users (bathers)
Not every system is unsafe to be in the tank during the
cleaning cycle.
After successful initial disinfection efficacy testing, the entire
treatment system shall undergo a simulated 3,000 hour life
test to address stresses on the equipment and treatment
system over time and from repeated on off cycling of the
pump, filtration, UV, Ozone, and or Hydrogen Peroxide
systems after each user.
These requirements shall apply to any equipment
recommended or supplied by the sensory deprivation
system manufacturer for use in treatment of sensory
deprivation chamber water, including:
● Ozone systems,
● UV light systems,
● Hydrogen Peroxide
Each sensory deprivation system shall have a data plate that
is permanent and easy to read. The data plate shall have, at
a minimum, the following information:
● Manufacturer’s name and address;
● Model and serial number;
● Date of manufacture or installation
● Maximum recommended temperature;
● Recommended between user cleaning cycle
process and cycle time
● Warning that no user shall be in system during
the cleaning cycle when appropriate
● Recommended water quality parameters,
including pH, sanitizer level (such as 2.0 ppm
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dissolved ozone)
Dry weight, water capacity, and filled/occupied
weight;
● Certifiers mark attesting to compliance with
requirements of this standard;
A comprehensive manual or manual package shall be
provided with each sensory deprivation system covering
important areas and contains an explanation of the system
operational process or a link to the on line manual listed on
the Date plate.
●
gp
X.12
ed
Many companies are providing online manuals now to
save paper and to always keep it up to date so instead
of a paper manual, a link to the manual could be added
to the Data plate.
gp
X.12.1
te
There is NO drowning hazard in a float system so it
should be removed
gp
X.12.1
ed
I can not think of any situation where a barrier would
add safety to a float center situation. I think the barrier
paragraph should be removed.
gp
X.12.2
te
Instead of maximum number of users, it should say
One person will use the facility at a time.
One person will use the facility at a time.
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