Are you considering the purchase of an ethylene oxide (EtO) sterilizing unit?
If you are, please be aware that EtO sterilizing units and related emissions require coverage under the UW-Madison air permit and may also require approval from the Wisconsin Department of Natural Resources (DNR) prior to their purchase, installation, and use.
Ethylene Oxide is a highly regulated hazardous air pollutant. Please consider that vaporized hydrogen peroxide (VHP) low temperature sterilization may be a safer and better choice for your needs because water and oxygen are the only by-products from a VHP sterilization process, eliminating the need for an air permit.
If EtO sterilization is still your preferred choice, please contact FP&M Environmental Affairs before you purchase an EtO sterilizing unit (even if it is a one-for-one replacement) to:
- identify whether additional air pollution control equipment will be required (e.g., an air emissions abator fitted with limited use-replaceable ion exchange resin cartridges).
- determine the type of air permit application that will be required:
- Depending on the unit’s estimated EtO emissions and stack exhaust height, an air construction permit may be necessary. Approval and issuance of the construction permit must be gained by the Department of Natural Resources (DNR) before the unit is purchased. Construction permit application fees up to $15,000 should be expected, and this process can take six months or more from submittal of the application to DNR approval.
- Even if a simpler air operating permit revision application request will suffice, an application will still need to be submitted to DNR prior to the purchase of the new/replacement unit.
FP&M Environmental Affairs can help you navigate the air permitting process and assist with your planning before you make any purchase decisions. Please contact us early in your planning process for assistance before any decisions are made on purchasing a new or replacement EtO sterilizer.
Finally, if you are currently operating an EtO sterilizer that does not have coverage under the UW-Madison air permit (i.e., no application to add the unit to the UW’s air permit has been submitted to DNR), please notify us so we can immediately report this deviation and take corrective action, as required under the UW-Madison Air Permit .
Whether you are just starting to plan for an EtO sterilizer, are looking to purchase a replacement, or need to add your sterilizer to UW-Madison’s air permit, Environmental Affairs can help you. Please contact us at environmentalcompliance@fpm.wisc.edu.
by Jeff Zebrowski & Jon Jackson
Jeff Zebrowski is the Director of Chemical Safety – Chemical Hygiene Officer. He joined EH&S in 2005 and oversees the Office of Chemical Safety, Hazardous Waste Program, and Environmental Affairs.
Jon Jackson is the Lead Environmental Affairs Specialist. He joined EH&S in 2020 and oversees environmental compliance for the campus.
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