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, Mold Eliminators, and any and all other such products that claim, on their labels or in any advertising, to kill or inhibit the growth of any microorganism(s) are considered Antimicrobials.
In the United States, all antimicrobial products are regulated by the U. S. Environmental Protection Agency ("EPA"), a governmental agency that establishes, oversees, manages and enforces environmental policy. Among their responsibilities is 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 laboratory testing, the results of which must support all product microorganism elimination and other efficacy claims, as well as the product's compliance with the EPA's stringent health, safety, 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."
THESE LABELS DON’T LIE
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 product’s certified test results and the EPA's 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.
When it comes to marketing antimicrobial products, and specifically with regards to describing any aspect of an antimicrobial product's safety or performance specifications, their Master Labels are "the law." More precisely, every statement, data point and word that appears on an antimicrobial product's retail Bottle Label must come directly from, and appear precisely as it does on the product’s EPA approved Master Label.
WHY IT MATTERS
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 labels 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 undertaking, if any element of it is not clearly stated on the antimicrobial product's label, then the product is either unsafe for your intended use, incapable of achieving the antimicrobial goal you seek, or otherwise failed to satisfy the EPA's testing standards for such use.
For Example:
- Only antimicrobial products with bottle or Master Labels that specifically state: “For Antimicrobial Control in HVAC Systems and Air Ducts” are EPA registered, and therefore approved and proven, to be both safe and antimicrobially effective for use in / on HVAC Systems & Air Duct components and surfaces.
- Only antimicrobial products with bottle or Master Labels that specifically list “Fogging” as an application option can be applied with a Fogger. This is more meaningful than often realized as fogging not only reduces application times by up to 75%, when treating large areas, but also reduces product consumption by up to 80%. However, unlike PermaSafe products, most antimicrobials are too toxic to earn approval for application via fogging, or require so many pre and post application steps that the savings are nullified.
- Only antimicrobial products with bottle or Master Labels that specifically state they can clean, disinfect, and deodorize in one single step, without the need to rinse or wipe the surface before or after their application, are capable of performing this feat. If no such statement is present, that product cannot be used for that purpose.
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."