WHAT YOU NEED TO KNOW ABOUT THE EPA,
ANTIMICROBIAL PRODUCTS & THEIR LABELS
Antimicrobial Products are defined as substances or combinations of substances that are formulated and used to kill or inhibit the growth of one or more types of microorganisms, such as bacteria, viruses, mold, fungi or any other microbes. All Sanitizers, Disinfectants and other products that make any type of germ-kill claim are considered Antimicrobials.
In the United States, all antimicrobial products are regulated by the U. S. Environmental Protection Agency, or "EPA," through their Antimicrobials Division. The EPA is an executive agency of the federal government that was granted the authority to establish, oversee, manage and enforce environmental policy with the passage of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). The EPA is responsible for, among other things, ensuring that antimicrobial products are safe and effective when used in a manner consistent with the Directions for Use printed on their labels.
Before any antimicrobial product can be offered for sale in the US, it must first successfully complete the EPA's antimicrobial product evaluation and registration process. To qualify for EPA registration, an antimicrobial product must undergo extensive, certified, third party testing, the results of which must support all product microorganism kill claims, as well as the product's compliance with the EPA's stringent health, safety, efficacy and other performance standards. Antimicrobial products that satisfy all such requirements are ultimately assigned an EPA Product Registration Number, which federal law mandates must appear on every bottle of product produced, as well as a corresponding EPA Product "Master Label."
THE TRUTH, THE WHOLE TRUTH AND NOTHING BUT THE TRUTH
Despite its name, an antimicrobial product's "Master Label" is not actually a label, like a typical bottle label, but rather a legal document, usually of multiple pages, that is based on, and essentially a synopsis of the EPA's product evaluation process.
An antimicrobial product's Master Label includes general information regarding the product and its manufacturer, as well as EPA reviewed and approved directions for use, first aid information, product efficacy and performance data, marketing claims, surface compatibility limitations, precautionary statements, approved uses, approved use sites and other vital product information, all of which must also appear on the retail labels that are affixed to each individual bottle of product sold.
When it comes to marketing antimicrobial products, and specifically with regards to describing any aspect of an antimicrobial product's safety or performance properties, their labels are "the law." More precisely, every statement, data point and word that appears on an antimicrobial product's label is governed by and subject to federal law, which is strictly enforced by the EPA. For instance, only text that is contained on an antimicrobial product's Master Label can be displayed on its bottle labels, and this text must appear precisely on the bottle labels as it does on the product's Master Label. This policy also applies to all antimicrobial product marketing materials, including product brochures, web sites and social media text.
LEVERAGING LABELS TO ENSURE SANITIZATION SUCCESS
Even more important than knowing where to look for accurate information when seeking the ideal disinfectant, sanitizer or other antimicrobial solution for your needs, is knowing what information to look for. And that begins with determining exactly what constitutes an Ideal Antimicrobial Product. Thankfully, the US Centers for Disease Control (the "CDC") already tackled that task, by publishing "The Properties of an Ideal Disinfectant."
U.S CENTERS FOR DISEASE CONTROL AND PREVENTION (CDC)
PROPERTIES OF AN IDEAL DISINFECTANT
BROAD SPECTRUM: Should kill wide range of pathogens FAST ACTING: Should quickly eliminate microorganisms
NON-TOXIC: Should not be harmful to installers or others EASY TO USE: Should have easy to follow use directions
FRIENDLY TO ENVIRONMENT: Should not harm environment ECONOMICAL: Should not be unreasonably high in cost
SURFACE COMPATIBLE: Should not damage surfaces WATER SOLUBLE: Should be water-based, water-soluble
ODORLESS: Should have a pleasant scent or no scent UNAFFECTED BY ENVIRONMENT: Effective in organic matter
HIGHLY STABLE: Should be stable in all use conditions POWERFUL CLEANER: Should be a powerful cleaner
PROVIDES RESIDUAL EFFECT ON TREATED SURFACES: Should provide post-application antimicrobial surface protection
Armed with an understanding of antimicrobial product labels, as well as what properties constitute an ideal antimicrobial product and where that information can be found, the final step in identifying antimicrobial products that meet such standards is simply … reading their labels.
CRITICAL PRODUCT LABEL POINTS TO REMEMBER
No matter what you may have read or heard about an antimicrobial product's capabilities or possible uses, only performance claims, product uses and other information specifically listed on its bottle label can be considered true and accurate. In other words, never attempt to use an antimicrobial product for any task, nor expect it to safely or effectively accomplish any task, that is not specifically listed on its label. No matter the task, if any component of it is not clearly stated on the product's label, the product isn't a fit for that use.
There are no gray areas when it comes to antimicrobial product labels. And the EPA takes all label statements and proper product usage very seriously. Take a look at the label on any bottle of any disinfectant, sanitizer or other antimicrobial product. Federal Law requires manufacturers to insert the following sentence directly under the product label's Directions for Use: "It is a violation of Federal Law to use this product in a manner inconsistent with its labeling."
For example, if you are searching an antimicrobial product's label to confirm it is capable of sanitizing carpets (PermaSafe CLEAN STEP 1 is, but few others are), or can both clean and disinfect a surface in one step, and can do so without the need to rinse the surface with water before or after applying it (CLEAN, STEP 1 can, but most others can't), or to verify it can be used on Food Contact Surfaces like CLEAN can, and no such statements exist on its label, it's because the product is either not capable of achieving such standards, not safe for such uses, or has otherwise failed to satisfy the EPA's testing standards for these uses. Regardless of the reason, it cannot be used for such purposes.
Further, if an antimicrobial product's bottle label lists "fogging" as an application method option for cleaning, but doesn't also specifically list fogging as an application option for sanitization or disinfection, both of which represent very specific levels of germ reduction, that product can only be applied with a fogger for cleaning, not for attempting to achieve sanitization or disinfection.
By way of example, the following text is from the "TO CLEAN" section of a popular disinfectant cleaner's bottle label. Despite this product being EPA registered and labeled as a "Disinfectant, Sanitizer, Cleaner, Deodorizer and Allergen Remover," Cleaning is the only use that includes Fogging as an application method option:
TO CLEAN via Fogging: This product can be applied effectively with a fogger as a supplement to normal cleaning procedures on restoration and remediation projects in confined, vacant areas of schools, healthcare facilities and other vacant, indoor areas. It is effective for pre-cleaning or as a supplement to final cleaning.
Now note the below text, from the "DISINFECTION" section of PermaSafe CLEAN, STEP 1's label, confirming that, among other product uses, fogging is an approved application method option for disinfection:
TO DISINFECT HARD NON-POROUS SURFACES: This product can be applied by fogging or misting to disinfect hard, nonporous surfaces. Apply fogging or misting until surface is moist using equipment manufacturer's directions for use.
In each of these examples, it would not only be unsafe, but also a "Violation of Federal Law" to use the antimicrobial product to perform a task that it wasn't specifically approved for. And in a commercial setting, such use could become a serious problem if a business was claiming a certain surface or area was sanitized or disinfected, when the antimicrobial product used was incapable of achieving those standards, or if that product's unsafe use endangered a customer or employee.
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