CLIFF ZLOTNIK NOTES
Microban Disinfectant Spray Plus, FIFRA and bleach
By Cliff Zlotnik CR, CMH, WLS
Why
Microban?
The original Microban
formulation was developed in 1962 for the purpose of decontaminating hospital
operating rooms. Microban Disinfectant Spray Plus contains two active
ingredients: o-phenyl phenol (a synthesized phenol at a level of 2,100 ppm) and
benzethonium chloride (a quaternary ammonium compound at a level of 7,000 ppm).
The high level of active ingredients is biocidal upon initial application and
after drying provides residual bacteriostatic and fungistatic action.
The versatile patented
Microban Disinfectant Spray Plus formulation may be applied by spray, fogging or
sponging. Microban is approved for application to both hard and soft surfaces
such as carpets and mattresses. The Microban Disinfectant Spray Plus formulation
has been job tested on thousands of mold and microbial remediation projects
worldwide. Microban Disinfectant Spray Plus is commonly specified as the product
of choice by industrial hygienists, IAQ consultants, etc.
The
law: Although the general population typically knows that
insecticides and rodenticides are considered pesticides, they are inevitably
surprised to learn that disinfectants, sanitizers and even household bleach are
also considered pesticides and are regulated under FIFRA, Federal Insecticide
Fungicide and Rodenticide Act. The Environmental Protection Agency's (EPA's)
Office of Pesticide Programs (OPP) has jurisdiction over pesticides.
The product label as
informational resource: There is much information and confusion in
regard to federally registered pesticides and their use and application. The
best informational resource for information regarding the use and application of
an EPA registered pesticide is the product's label.
The product label and not
the MSDS is the best source of information regarding an EPA registered product.
As product labels are prepared In accordance with EPA regulations, contain
certain uniform language and are reviewed and approved by the agency, legal
protection is provided when applicators closely adhere to the label.
Ingredients: A variety of ingredients are used in
manufacturing disinfectants and sanitizers including: quaternary ammonium
chloride compounds, iodine, synthesized phenols, and bleach (sodium
hypochlorite) based products. Many household general purpose cleaning products
for cleaning hard surfaces in rooms such as kitchens and bathrooms are actually
EPA registered products.
Categories of pesticides: Pesticides fall into two main
categories, restricted use and non-restricted use. Restricted use pesticides are
generally more concentrated and in their concentrated form are more likely to
pose a risk to humans, animals or the environment.
How to
tell if a product is a registered pesticide?: The labels of all
EPA registered products bear an EPA registration number and an establishment
number. For example, Microban Disinfectant Spray Plus identification numbers
are: E.P.A. Registration number 70263-5, E.P.A. Establishment number
70263-PA-001.
FIFRA
requires pesticide applicators to be certified: Although
certification of pesticide applicators is federally mandated under FIFRA, the
enforcement of pesticide applicators is left up to each individual state.
Restricted use pesticides
may only be sold to licensed applicators that are trained in the handling, use,
storage and disposal of these materials. Non-restricted use pesticides including
insecticides, rodenticides and antimicrobials are sold at supermarkets,
drugstores, and hardware stores. In fact, it is easier to buy non-restricted use
pesticides than it is to purchase alcohol or tobacco products.
Most states enforce
licensing of applicators of restricted use pesticides such as insecticides,
rodenticides and herbicides: Enforcement of FIFRA is often handled by the
state's Department of Agriculture. Most states permit the application of
non-restricted use pesticides such as disinfectants and sanitizers (such as Microban
Disinfectant Spray Plus) by non-licensed applicators such as:
cleaning and maintenance personnel (maids and janitors), microbial remediation
firms, etc.
Pesticide misuse: When dealing with either
restricted use or non-restricted use pesticides, the best guidance
recommendation is to consider "the product label is the law." The label
will provide instructions for the proper preparation, mixing, use and disposal
of the product. Common pesticide misuse includes improper application method or
application of the product to use-sites not permitted by the product's
label.
As many brands of bleach are
not registered as disinfectants and sanitizers, the use of a non-registered
bleach formulation for biocidal purposes is a violation of FIFRA. Any individual
who selects an unregistered product for use as a disinfectant is responsible for
any product misuse.
Labeling: The label of an EPA registered
pesticide provides essential information regarding the products use: The label
will list the concentration of active ingredients, provide directions for
product use and application, a signal word to indicate potential health risks,
precautions and a statement of practical treatment in case of injury, storage
and disposal information, contact information for the manufacturer, etc. The
label of all registered pesticides must incorporate the statement: "It is a
violation of Federal Law to use this product in a manner inconsistent with its
labeling."
What
about bleach? Sodium hypochlorite is often misunderstood and
misused. Household bleach (sodium hypochlorite) is widely recommended and used
for antimicrobial applications, the primary reasons for this are bleach is
widely available and is inexpensive.
Chlorine bleach is inherently unstable. To improve the
stability of chlorine bleach the pH is increased during manufacturing. Diluting
bleach with water lowers the pH and actually increases bleach's biocidal
properties.
Some
disadvantages to bleach as a biocide: Bleach doesn't penetrate
well, surfactants and or a detergent is needed to break the surface tension of
soil and or bio-films. Bleach is not a good cleaner, surfaces to be
disinfected must be pre-cleaned. Bleach is corrosive to metals. Bleach is
destructive to many fabrics. Bleach fumes can irritate eyes and respiratory
systems. Bleach is reactive and liberates gases when mixed with ammonia or
acids.
Many brands of household
bleach are not EPA registered for use as disinfectants. One of the more common
FIFRA violations involves the use on non-EPA registered bleaches for
antimicrobial purposes, as it is a violation of FIFRA to
For more information on
antimicrobials For more information on disinfectants and other
pesticide-related topics, contact the EPA Office of Pesticide Programs at
http://www.epa.gov/pesticides/
In
conclusion All Microban
disinfectant products are non-restricted use pesticides and may be sold over the
counter and are approved for purchase and use by professional cleaners and
restorers and the general public.
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