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.