Chemgeek,
“I just wrote to APVMA about some of these issues so we'll see what they say.”
Good luck with this!
For me this is a very timely post as I am currently investigating the Waterco Hydroxypure system. During the last six months I have had communications with both the APVMA and also Gold Coast City Council who are running a trial of the Hydroxypure system in a children’s water park on the Gold Coast, Queensland, home of the "inventor".
You may not be aware, but currently there is much discussion in Australia regarding the safety of this much-publicised system. I have now come to the opinion that Waterco have hurried this to market in a reckless rush of commercialization without any thought for public health and safety. I also believe the APVMA are demonstrating double standards, when it comes to the Wateco Hydroxypure system and they are putting the interests of the chemical industry before public health and safety, my reasoning for this as follows.
Waterco, a public listed company have pitched their launch to primarily financial/investment media, example
here, as expected this has created a lot if industry interest, scrutiny & concern example
here. Not really red tape in my opinion more like safe guards.
There are two possibilities as I see it.
1. The inventor claims a new invention, if this is correct, public safety comes first, it should be tested to the APVMA
guidelines before trialing in a childrens water park.
2. The Hydroxypure is not a new invention and falls under existing APVMA registered sanitisers. It appears that in the APVMA's reply to me they do not consider it new technology. They also highlighted that UV/Ozone does not come under their authority, they only have jurisdiction over the chemical hydrogen peroxide.
- The Waterco Hydroxypure System contains an ozone generating device. Devices do not fall within the legal jurisdiction of APVMA. Ozone generated on-site for treatment of pool or spa water is declared not to be an agricultural chemical product by the Agricultural and Veterinary Chemical Code Regulations 1995 at Schedule 3, Part 3, Item 17.
and this
- There are current registered chemical products containing hydrogen peroxide that can be legally used in conjunction with ozone generating devices, noting that some of these chemical products are currently approved for use in domestic situations only. Please note that information on the APVMA’s website relating to the testing of efficacy for pool and spa products is guideline material. The APVMA has recently published draft guideline information regarding demonstrating efficacy for pool and spa sanitisers at:http://new.apvma.gov.au/node/1039.
and this
The registered products are described variously on the website as ‘chlorine’, ‘sanitiser’ or algaecide’. Of these there are two products registered to Waterco and containing hydrogen peroxide which are described as ‘sanitisers’. These are P39380 Poppit Sanitiser and P40742 Poppit Sanosil Pool & Spa Sanitiser
more
Based on the approved label P39380 could be used in a commercial pool. The label refers to other products such as ‘Quick fix oxidiser’, ‘Poppit filter cleaner’ as well as use of Poppit Test Kit or Poppit Peroxide test Strip. As far as we can determine none of these products would require registration. The label is silent as to whether the product could be used with ozone however compatibility claims are not assessed and as stated above ozone does not require registration. In general any registered pool product can be used in conjunction with any other pool product (registerable or not) provided such use is not precluded on the label.
According to the APVMA feedback above, they have approved hydrogen peroxide for use in any commercial pool in Australia as a residual sanitiser despite most state health departments ruling that the methodology is unsatisfactory for use as a disinfectant in commercial pools. I have since asked APVMA for the scientific data they have relied upon to support approval. That was six weeks ago and despite frequent follow up requests I have not received the courtesy of a reply to date. The more I investigate this the more I feel there is protectionism within the APVMA and possible influenced by the chemical industry rather than putting public safety first. As an example, in my research I came across a lot of references to the APVMA when it comes to copper/silver ionisation, a methodology shown to reduce chemical volumes. TFP also makes regular reference to the APVMA ioniser recall as peer review material.
This
document could also be construed as bias in favour of ionisation but does raise some questions on the APVMA's position and modus operandi. Interestingly the following extract from the document shows that the Hydroxypure methodology using ozone/hydrogen peroxide was incorrectly used by the APVMA in their case against ionisers. Ref 5.4 pg14 Extract

Despite the similarities, an ioniser is the only system to be registered. Although the APVMA has clearly stated that it is not willing to guarantee the efficacy of any other systems it has chosen to exempt the systems from registration and testing.
The system known as Ultra Violet + Hydrogen Peroxide also presents a situation where there is one rule for one and another rule for another.
An article published in a Commonwealth Government publication - CDI (Communicable Diseases Intelligence), Volume 21 No23, 25 December 1997 notes an incident of infections from a spa in Victoria that used Ultra Violet + Hydrogen Peroxide. The extract is self explanatory - "The outdoor spa pool was being treated with hydrogen peroxide solution.......... The use of UV - hydrogen peroxide systems is not allowed in public pools in Victoria due to poor performance levels."
The APVMA was made aware of the problem at the time and since then. The APVMA has chosen to do nothing and when quizzed about its inaction the reasons could be interpreted as it could not be bothered.
Even though the Victorian Government unambiguously states "The use of UV- hydrogen peroxide systems is not allowed in public pools in Victoria due to poor performance levels." The APVMA has not acted on the expressed risk to public health but yet acts against ionisers with no evidence.
Interestingly, as part of the tactics of half truths, misrepresentation and innuendo adopted by the APVMA, it has used the reference to the incident published in the CDI article as justification of its actions against ionisers and for continued warnings on its web site.
Many years have passed since the ioniser recall but it appears the APVMA's actions are still questionable when it comes to chemicals of concern.
I contacted Gold Coast City Council asking what efficacy data they are relying on to allow the trial to be conducted in a childrens water park. The reply was alarming, they are acting on advice from the manufacturer and are using a local council sub law to allow the trial to run even though Queensland State Health Department does not endorse the system. I am told that when contacted Queensland Health commented that "they can not take action until someone becomes sick as a result of swimming in the pool".
Right now my investigation is on the Hydroxypure system. TFP's expert opinions and comments would be much appreciated. This forum regularly refers to CDC documentation to back up the science. I came across the following CDC documentation that highlights the ineffectiveness of hydrogen peroxide + ag as a pool or spa disinfectant.
link
Extract pg 52/53
Hydrogen peroxide is not registered by the US EPA as a disinfectant for recreational water. Since it is not registered, the use of hydrogen peroxide as a recreational water disinfectant, or any market claims that implies hydrogen peroxide provides any biological control in recreational water is a violation of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). Hydrogen peroxide has been granted registration by the US EPA as a hard surface disinfectant and several other applications. The US EPA Registration Eligibility Document (RED) on hydrogen peroxide is available from the EPA website at
www.epa.gov/oppsrrd1/REDs/old_reds/peroxy_compounds. pdf. The US EPA posts PDF copies of accepted product labels on the National Pesticide Information Retrieval System website
http://ppis.ceris.purdue.edu/#. Product claims for uses and concentration may be verified by reading the PDF of the US EPA stamped and accepted copy of the product use directions at this website.
When used as a hard surface disinfectant hydrogen peroxide is normally used at around 3%. When used in recreational water, hydrogen peroxide is used at 27 to 100 PPM (MG/L), which is 1111 and 300 times, respectively, more dilute than that used on hard surfaces. Borgmann- Strahsen evaluated the antimicrobial properties of hydrogen peroxide at 80 and 150 PPM (MG/L) in simulated POOL conditions.71 Whether 150 PPM (MG/L) of hydrogen peroxide was used by itself or in combination with 24 ppb of silver nitrate it had negligible killing power against Pseudomonas aeruginosa, E. coli. Staphylococcus aureus, Legionella pneumophila or Candida albicans, even with a 30 minute contact period. In the same tests the sodium hypochlorite controls displayed typical kill patterns widely reported in literature. Borgmann-Strahsen concluded that hydrogen peroxide, with or without the addition of silver ions, was, “no real alternative to CHLORINE-based DISINFECTION of swimming POOL water from the microbiological point of view.”
Conclusion: The APVMA are going against all the available scientific data and worldwide health departments advise in their recent confirmation to me on the approval of hydrogen peroxide for use as the residual sanitiser in public pools. I personally think they have opened up a pandora's box. Despite their claims to the contrary the APVMA is not putting public health & safety first when it comes to the approval and registration pool sanitising products.
Extract: The Board also discussed the matters raised in the Four Corners' program of 22 July relating to spray drift and dioxins in chemicals. The Board stressed the importance of taking a scientific, evidence-based approach to protecting the health and safety of the Australian community in relation to these matters. Close”
Since it's launch I have discovered many problems and issues with Waterco's Hydroxypure system. The manufacturer is acting irresponsibly, making deceiving and unsubstantiated claims and attempting to circumvent the efficacy test stage, most likely in the knowledge that it would fail. Children are currently being used as human guinea pigs in a commercial waterpark and Gold Coast City Council's "approval" of the trial has being deliberately misrepresented as a national approval of the system in company press releases aimed at consumers and investors.
I would appreciate you and your fellow advisors responses to this? Do you agree with the APVMA approval of hydrogen peroxide or the CDC document and most world health departments views that it is an unsatisfactory pool sanitiser.
In closing, I have just being informed that a request under freedom of information act has recently being submitted to the APVMA for the efficacy data they have relied upon for the approval of Hydrogen peroxide along with a request for a review of all registered pool sanitisers to demonstrate that they can meet the new efficacy guidelines.
KB