PS-19 Test Results Show Picarro CRDS Far Outperforms OE-FTIR 

The US EPA recently finalized the updates to 40 CFR 63, Subpart O (otherwise known as the Commercial Sterilizer National Emission Standards for Hazardous Air Pollutants/NESHAP).  The updated rule came into effect through the Risk and Technology Review (RTR) and aims to address Ethylene Oxide (EtO, EO) emissions from point sources and room air emissions. 

Continuous Emissions Monitoring Systems (CEMS) regulations are a large part of this rule causing concern for many in the industry. Performance Specification 19 (PS-19) was finalized at the same time and lays the groundwork for how to certify an EtO CEMS. PS-19 is perhaps the most in-depth and quality assurance-focused performance specification to date. It consists of five tests to be conducted by the CEMS manufacturer or facility, as well as a Relative Accuracy Test Audit (RATA) to be conducted by a certified stack testing firm. 

Picarro and the US EPA have vigorously conducted PS-19 testing using CRDS prior to the finalization Subpart O and PS-19. The table above demonstrates Picarro’s internal results for the required tests, compared to the results published by a competitor using Optically Enhanced Fourier Transform Infrared Spectroscopy (OE-FTIR). The table above perfectly demonstrates why I view Picarro as the most exciting (and groundbreaking) company in emissions monitoring today. We aren’t just meeting requirements – we are blowing them out of the water while providing clients with peace of mind.

In my mind, the most exciting part of this testing was the Interference test results. While consulting, I regularly saw interferences skew EtO readings to an often-unacceptable degree. Obviously, having an established detection limit of 0.2 ppbv with real-time, 2-second averaging intervals is exciting as well! I don’t think there is another technology that can match that precision without incredibly long averaging intervals – which ultimately impacts the facility’s ability to understand their systems!

Simplifying Compliance
Commercial sterilizers provide an essential service to our medical supply chain, ensuring doctors and patients have access to lifesaving medical devices. Picarro wants sterilizers to focus on what they do best – to sterilize! With decades of experience Picarro has the tools, expertise, and services to make compliance with these new CEMS rules easy. We have built our EtO system to be seamlessly integrated into any facility and our Environmental Systems (ESYS) team will help you every step of the way. With thousands of systems installed and operating on every continent, Picarro has built a reputation for having the most accurate, and reliable systems on the planet.

Every Picarro system is built in America at our headquarters in Santa Clara, CA. What does this mean for you? If there is an issue, the people who designed the system are literally just a phone call away to help get you a solution fast. Gone are the days when the company who installs your CEMS tells you to contact the CEMS manufacturer yourself for troubleshooting. With Picarro, you can focus on the business of sterilizing products, and we handle the monitoring.

The Picarro CEMS is designed to meet all current and upcoming performance requirements and regulations for EtO monitoring, including PS-19, QA Procedure 7, and others.

Our systems are designed with a robust Data Acquisition System (DAS) perfectly configured for easy electronic reporting. They come in a portable, weather protected cabinet that is factory equipped with automated above span calibration checks, remote Cylinder Gas Audits (CGA) functionality, and remote access for expert CEMS support. 

Our team will personally develop all Quality Assurance documents to comply with federal/state regulations and operating permits and assist clients with their reporting needs. 

Our team of trained field technicians also provide all necessary preventative maintenance and emergency support. 

And all of this support comes at a fixed cost – meaning Picarro will not be charging hourly rates for additional support.

Benefits of Working with Picarro
The benefits of a Picarro system are vast, but my top three reasons why you should be working with Picarro for commercial sterilizer CEMS compliance are:

1. Rapid response times, allowing for timeshare systems. This saves overall cost as one analyzer can provide up to 3 measurement points.
2. The lowest in class detection limit. There is no need to overreport emissions with Picarro solutions, nor do we need 15 minutes to generate a low response. Our results are on 2-second averages, meaning you get the best data – FAST. 
3. End-to-End emissions monitoring solution. Our team of experts takes care of everything doing what we do best, so you can do what you do best – sterilize.

Contact Us:
Have questions regarding Picarro ethylene oxide monitoring systems? Please contact the Picarro Environmental Systems (ESYS) team via email at: eto@picarro.com.

About the Author - Sean Cronin, Project Manager, Picarro
Sean Cronin is a Project Manager with Picarro, Inc. focusing on the regulatory aspect of Continuous Emissions Monitoring Systems (CEMS). He has 10+ years’ experience in emissions monitoring with certifications for source testing methods, major criteria pollutant CEMS, gas chromatographs, sample system design, and several process analyzer technologies. Prior to joining Picarro, he was a Subject Matter Expert (SME) for CEMS and Source Testing for a large consulting firm. His primary duties there were assisting clients with high-profile projects, regularly interacting with state and federal agencies. It was in that role he first learned about Picarro. Coming from a strong FTIR and gas chromatograph background, he was amazed at how effective and easy to use the Picarro technology was and how committed the Picarro team was to finding complete solutions for their clients. He saw Picarro as the future of emissions monitoring and knew he wanted to help change an industry he has devoted his professional life to.