In the United States, the U.S. Environmental Protection Agency (EPA) classifies disinfectants as pesticides. They are required to be strictly regulated by the EPA as a result of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), which was passed more than 60 years ago.
The act has been amended over the years, with a major revision in 1972 and less noteworthy changes made in 1984 and again in 1996. However, as we will discuss further, another revision — this time one quite significant — is slowly moving up the pipeline and could make substantial changes in Green Cleaning, specifically regarding the use of more environmentally-responsible disinfectants.
The Current Status of Disinfectants
Currently, when a manufacturer develops a disinfectant for use in the United States, the product must be submitted to the EPA for review and registration before it can be offered for sale. The manufacturer is required to provide current data that indicates the product will “kill” all the microorganisms listed on the product’s label when used per instructions.
For instance, if the product label claims to kill Methicillin-Resistant Staphylococcus Aureus (MRSA), then test data must be submitted to the EPA to prove that the product, when used and diluted according to label directions, kills the MRSA bacteria. Further, tests designed to measure the effectiveness of the disinfectant on various pathogenic (disease causing) organisms must be passed. These are referred to as efficacy tests.
All efficacy test methods must be pre-approved by the EPA. Typically, the most common efficacy test used by the EPA is the Association of Official Analytical Chemist (AOAC) Use Dilution Confirmation Test. For a disinfectant cleaner to be registered by the EPA and listed as a “hospital strength” disinfectant, it must be effective at killing specific pathogens in the presence of 400 ppm (parts per million) hard water and 5 percent organic serum. It must kill 100 percent of the targeted test organisms.
Upon approval, the EPA assigns a registration number for the disinfectant, which must be displayed on every label and all related materials identifying the product. This number indicates that the product has been thoroughly tested and verifies the effectiveness of the disinfectant as indicated by its label and kill claims. Registration also notes that the product “will not generally cause unreasonable adverse effects on the environment.”
In many ways, this is where the problem lies for those who wish to use Green disinfectants and only environmentally preferable cleaning products in their facilities. The EPA currently believes its registration process is sufficient and forbids manufacturers and third-party Green certification organizations from marketing or placing their logos or seals of approval on disinfectants sold in the United States.
Further, conventional disinfectants are by their very nature toxic. They are designed to kill pathogens and microorganisms, which means their negative impact on users, building occupants, and the environment can be significant.
Some of the most effective disinfectants used today can also be the most harmful to the environment, especially if used incorrectly. For instance, sodium hypochlorite (bleach) is very effective against bloodborne pathogens, but can be extremely corrosive, is a known respiratory irritant, can damage many different types of surfaces where used, and is detrimental to the environment and when mixed with other commonly used cleaning products, can produce a poisonous gas.
Phenolic-based disinfectants are another example. Although they are very effective at killing a large array of pathogens, these disinfectants must be used sparingly – especially in areas where children are present because they cannot metabolize them.
But in recent years, manufacturers have introduced disinfectants that have a reduced effect on the environment. These disinfectants are pH neutral, which makes them less corrosive (irritating) to workers and building occupants, and less damaging to cleaned surfaces. Additionally, they contain fewer or no volatile organic compounds (VOCs), so they have less impact on indoor air quality, causing fewer respiratory problems.
Many of these disinfectants are quaternary or hydrogen peroxide-based. They have a “wide” kill rate, are effective against many types of pathogens, but are not as harsh as the more conventional disinfectants that have been used for years. But administrators and cleaning professionals are advised to use even these less environmentally harmful but still powerful products sparingly and only in appropriate settings to target specific pathogens and organisms, and, if possible, on an as-needed basis. The user and the environment can still be at risk when these disinfectants are used.
The Green Path
Over the years, the EPA has been approached several times about reviewing its current policies that prohibit manufacturers from placing Green certification labels on their disinfectant products. These calls have grown in recent years as the overall demand for Green Cleaning has increased and as technology has progressed, producing Green disinfectants that are comparable and equally as effective as EPA registered disinfectants, but with far less impact on the environment.
In April 2009, Stephen Ashkin, president of The Ashkin Group, the professional cleaning industries’ most vocal proponent for Green Cleaning, along with ISSA, the leading cleaning association, announced that the EPA has recommended a policy that may allow manufacturers to place certification logos and other factually based environmentally preferable claims on disinfectants.
According to Ashkin, who has been working with the EPA directly on this transformation, this represents a significant departure from the EPA’s previous policies and opens the door “so that hospital, medical, and other administrators and cleaning professionals can easily identify and begin using ‘Greener’ disinfectants in their facilities.” Ashkin adds that this will help eliminate confusion in the marketplace and allow those facilities that want to incorporate Green Cleaning throughout their facilities to do so.
As of 2017, there have been few changes in the EPA’s stand when it comes to green disinfectants. And with changes being made at the agency this year, we are not sure this is an issue that will even be considered. However, we are hopeful that it will be considered in years to come.