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 of non-EPA registered bleaches for antimicrobial purposes.

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.