In this article, industry manufacturers answer common questions asked by building service contractors.
Why are disinfectants classified as pesticides by the EPA? Why does this prevent them from being certified as green?
The U.S Environmental Protection Agency (EPA) law, called FIFRA (Federal Insecticide, Fungicide, and Rodenticide Act) gives EPA the authority to regulate products that kill other things. Whether a crop application pesticide, a spray for termites, or a disinfectant for hard surfaces, all these products are regulated by EPA under the same act. The general grouping for these products is to call them pesticides, since what they kill are referred to as pests and since the regulation chose this term to classify the products.
The EPA issued a position several years ago that disinfectants and sanitizers could not be promoted as being green. This has nothing to do with the products being pesticides, but rather EPA does not want manufacturers claiming their products are safer/better/etc. based on the green certification, which would be outside the EPA registration process. EPA has developed their own program, called Design for the Environment (DfE) to allow for environmental claim based on meeting certain standards.
— Peter Teska, Americas portfolio lead for infection prevention, Diversey, Sturtevant, Wis.
The EPA currently forbids marketing disinfectant products as “environmentally preferable” because they are designed to kill microbes, giving them a pesticide designation. This prevents disinfectants from being certified as green because they are labeled with a Toxicity Class of 1 or 2 signifying “Warning” or “Danger.”
— Robert Neitzel, director of operations, Big 3 Packaging, Philadelphia
The EPA is focused on protecting human health and the environment. It is the agency’s duty to be sure that the nation’s indoor and outdoor environments are exposed to only those products whose efficacy and toxicity is known and whose usage, labeling and distribution are regulated and approved on a scientific and legal basis.
Any product with a non-medicinal “kill” claim on inanimate surfaces is considered a pesticide by the EPA. Products with a kill-claim on living skin or inside a living body are considered drugs and are regulated by the U.S. Food and Drug Administration. We usually think of insects, weeds and vermin as pests but pathogenic organisms are as well; even though we cannot see them with the naked eye.
There is a fundamental paradox that makes the certification of disinfectants as environmentally friendly a problem: they kill. Chemical compounds that are toxic to pathogenic microorganisms such as bacteria, virus and fungus are also toxic to aquatic life even at low concentrations. The smaller aquatic organisms are highly prolific in our natural environment and are very sensitive to toxic substances. Their sensitivity makes them the ideal discriminant of what is and what is not safe to be released untreated into the natural environment.
— John B. Everitt, president, Stearns Packaging Corp., Madison, Wis.
While we wait for the EPA pilot program for green disinfectants, what is a safer disinfectant option for workers and the environment?
Look to the use-dilution MSDS to assess the health risk of the disinfectant. Products with an HMIS rating of 0-0-0 offer a more favorable safety profile than disinfectants with an HMIS rating at dilution of 2-0-0. Products that require protective gloves or eyewear are less preferred than those that require neither.
Additionally, look at the fate of the active ingredient and the risk of surface damage. Products with active ingredients that break down to oxygen and water do not have any active ingredient going through the waste stream, and potentially have a negative environmental impact.
Products that cannot be used on surfaces in a facility due to risks of surface damage should be used cautiously as surface damage can increase the hygiene risk for the surface by making it harder to disinfect in the future. Surface damage creates pitting and fissures that can harbor soil and pathogens, making them a hygiene risk.
— Peter Teska, Americas portfolio lead for infection prevention, Diversey, Sturtevant, Wis.
Here are a few things to keep in mind when seeking a safer alternative from traditional disinfectants:
1. Limit the use of disinfectants.
2. Clean first, then disinfect.
3. Select safer non-alkaline disinfectants that reduce the impact on the user and the environment. They should have neutral pH levels and contain no NPE’s (nonylphenol ethoxylates).
4. Look for disinfectants with higher PPM — the greater the PPM (parts per million) the better. Quality disinfectants should be greater than 600 PPM.
5. Incorporate more effective cleaning systems.
— Robert Neitzel, director of operations, Big 3 Packaging, Philadelphia
Don’t wait for the EPA pilot program.
The scientific and administrative differences between the two relevant departments of EPA, the Office of Pesticide Programs (OPP) and the DfE, are sufficiently large enough that if anything comes out of the program the result will probably be limited in choice, efficacy and cost-effectiveness.
Pathogenic microorganisms should not be treated like endangered species. They kill and maim the young and the old; the people you love. Medical treatment and lost time from work and school cost our economy billions of dollars every year.
Today’s disinfectants are proven safe and effective when used as directed on the label and with the recommended personal protective equipment (PPE); equipment that cleaning staff should be wearing on the job anyway.
— John B. Everitt, president, Stearns Packaging Corp., Madison, Wis.
While the EPA pilot program continues, custodial staff seeking “greener” options should consider using EPA-registered disinfectants that contain more earth-friendly actives, have no harsh chemical fumes and have no volatile organic compounds (VOCs).
Hydrogen peroxide is being utilized in a unique, breakthrough way to eliminate bacteria while effectively cleaning a variety of surfaces. Hydrogen peroxide breaks down into water and oxygen after use.
— Lynda Lurie, marketing manager, Clorox Professional Products Co., Oakland, Calif.
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