The SARS-CoV-2 virus and the resulting COVID-19 pandemic has drastically changed the way many organizations approach cleaning and disinfecting. Facilities of all types are using disinfectants more frequently, thus increasing the chance that products are used without proper oversight. Failing to thoroughly read a chemical label can often result in incorrect application, which can put cleaning professionals, building occupants and the environment at risk. This makes correctly following label instructions more important than ever.
How to Know a Disinfectant is Effective
If a manufacturer offers a solution that is intended to inactivate the SARS-CoV-2 virus, the Environmental Protection Agency (EPA) must be aware. In addition, manufacturers of devices that create disinfectant (like on-site generation systems) or those that are used with disinfectants (like electrostatic sprayers) should be able to provide sufficient proof that the device has been tested against the SARS-CoV-2 virus. Manufacturers should also have proof that they produce the devices in an EPA-approved facility.
Meanwhile, bottled solution manufacturers should be registered, have the EPA registration number printed on the product label and either have SARS-CoV-2 testing results available or be displayed on List N, which includes disinfecting products so far proven effective against the virus. It’s important to remember that if your disinfectant isn’t included on List N, this does not mean it is not an effective product for use during the pandemic. List N offers suggestions, not requirements.
There is strict regulation on what can and cannot be put on a bottle’s label. Every claim on the label, from target organisms to directions on disposal of the container to marketing claims, is thoroughly reviewed. This process is essential for securing an EPA registration number for a product label.
So how can you identify whether a product is registered by reading the label? Look for the EPA registration number and the EPA establishment number. This is typically listed on the back panel of the label near the manufacturer’s name and address (see Figure 1).
Optimize Cleaning and Disinfection Protocols
Once you’ve confirmed the product is registered, the next step is to understand proper application. The label should have a distinct section titled “Directions for Use” (see Figure 2). An important requirement for this section is the legally required disclaimer: “It is a violation of Federal law to use this product in a manner inconsistent with the label.”
The “Directions for Use” section will detail how to wipe, spray or even fog the product. Remember: if a certain application method is not listed, it cannot be used. For instance, the EPA now requires specific testing for fogging and electrostatic spraying claims. If there are no instructions for it, by law, the product cannot be applied in that manner. Doing so may lead to safety, performance and even sustainability issues.
Other important information also found in this section includes:
- Whether precleaning is necessary
- Contact time
- Types of surfaces that can be disinfected
- Target organisms the product is proven to be effective against
Minimize Risk by Identifying Potential Hazards
As all disinfectants are intended to destroy harmful living organisms in one form or another, the idea that any one formula is “safe” is not accepted. Words like “safe” or comparisons to other formulations as “safer” are not allowed when registering a product. A disinfectant label is not for marketing purposes – it is meant to communicate any hazards the user may be exposed to, and detail how to minimize risk.
If a product has a known hazard, it must be communicated via a “signal word” on the label’s front panel. Based on strict criteria for the five routes of exposure (as defined in 40 CRF 156.62), a disinfectant can fall into one of four categories based on the toxicity level (see Table 1).
Category I is the highest toxicity category and IV is the lowest. Each category requires a specific signal word. If no signal word is listed on the label, the product has met the criteria for category IV, or the lowest toxicity category.
Making the Most of Disinfectants
As the COVID-19 pandemic stretches on, cleaning professionals must make the most efficient use of disinfecting chemicals and follow each label’s and device’s directions. It is equally essential that facility managers and their teams remember that what appears on a bottled solution’s label or in a device’s instruction manual is just as important as what does not appear there. With proper understanding of disinfectant efficacy, protocols and risks, organizations can enhance cleaning performance, sustainability and safety. This will be key for overcoming the SARS-CoV-2 virus and preventing or reducing the impact of future outbreaks.
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