The labels of cleaning chemicals serve a variety of functions including providing directions for product usage, displaying health warnings and acting as a marketing device to entice potential buyers with eye catching graphics and/or wording. However, when a label is placed on a “disinfectant” product used to kill germs, it instantly changes from a label into a binding legal document.
An EPA-registered disinfectant label is considered a legal document because the United States Environmental Protection Agency uses the label exclusively to summarize all of the scientific information about that formula and how it applies to a piece of legislation called FIFRA (Federal Insecticide Fungicide Rodenticide Act). The scientific information of the disinfectant formula includes data on the following:
- Environmental Impact
- Efficacy/ Germ Kills
This data is listed under distinct sections on the registered label, so it is very clear to the end user how to use the disinfectant safely and effectively to kill the microorganisms on the applicable hard surface.
Without these one-page labels, the user would have to sift through hundreds of pages of data to determine if the disinfectant will be effective on each individual job site. And it is certainly hard enough to understand a one-page label, let alone hundreds of pages!
The toxicology data is based on six different tests evaluating how the disinfectant formula affects our eyes, skin, respiratory and digestive systems. All of this data is shown on the label under the following sections:
- Precautionary Statements
- Physical Hazards
- First Aid Statements
- Signal Words: Danger, Poison,Warning and Caution
The more toxic the product is, the more detail goes into warnings and precautionary statement sections. Signal words on the front panel of the label are a quick identifier to users to the level of the products toxicity, with level or category 1 being the most toxic and category 4 being the least toxic.
- Category 1 = Danger or Poison
- Category 2 = Warning
- Category 3 = Caution
- Category 4: no signal word
Disinfectants can be toxic to humans using these products, and they can also be toxic to the environment once they are disposed of via a sanitary sewer or down a septic tank. On many water-damage claims, contractors dispose of the extracted sewage that has been treated with a disinfectant down the sanitary system. Due to the environmental impact of many of the disinfectants that are used on these claims, the treated sewage could now require disposal in an EPA-approved pesticide disposal facility. The “Storage and Disposal” section will give clear instructions on whether an extra disposal step and cost is required. If the disinfectant-treated sewage is not disposed of it could have negative effects on the environment as well as your business in the form of fines from the EPA and the bad press that follows.
In EPA language, To Disinfect means to kill 99.99% of a gram-negative and a gram-positive bacteria. This minimum standard is acceptable for many applications,but may not be suitable for sewage, mold or trauma scenes as a multitude of microorganisms are often present on these jobs. Efficacy or germ-kill claims are summarized on the label under different antimicrobial classes: Bactericide, Germicide,Funigcide, Virucide and Tuberculocide.On mold jobs, contractors need to make sure that the product not only has an EPA registration number but also the antimicrobial claims needed for that job (in this case a fungicide claim).
The chemical makeup or formula of the disinfectant is evaluated by the EPA to determine the minimum level of active ingredient required to kill the 99.99% of the desired microorganisms. Active ingredients are defined as the ingredients responsible for the germ killing.
Some active ingredients, like quaternaryammonia compounds, can be bound by hard water, which prevents them from being as effective and requires higher levels of dilution. Check the “Directions for Use” section for special dilution instructions for applications with hard water. If this applies to the products you are using, make sure they have hard water test strips to adjust the dilution in these settings. Be careful not to simply dilute to the hard water rates. If the water is not hard, you now have too much active compound in the solution, and this will change the health and safety profile.
Now that you have a guide to the information that is on the EPA-registered label, what happens if the product label doesn’t have some of the sections that were referenced? If the disinfectant has an EPA registration number (e.g. 74771-1), then the EPA has determined that those sections are not required for that particular disinfectant. No “First Aid,” no “PhysicalHazards,” but as long as there is an EPA number on the label, you shouldn’t have to worry.
As our society moves towards a “greener” social conscious, and consumers and contractors keep demanding safer and healthier alternatives, it can be confusing to determine which disinfectant provides the safest option. “Green” terminology is not permitted on labels, and words that indicate heightened safety are strictly forbidden(even if the product can prove it).
To determine which disinfectant is safest, go back to the “Signal Words” (Danger, Poison, Warning, Caution), “Physical Hazards” and “First Aid” sections to see what the label includes or excludes. A disinfectant with ‘Caution’ on the label is a lot safer that one marked ‘Poison.’
Since all products with an EPA number have met a minimum standard of kill, 99.99% of bacteria, no disinfectant is “Stronger” than it’s competition. Therefore, a phenol is not stronger than a quaternary ammonia disinfectant as they have both met the same standard. Products can have a different spectrum of efficacy, which means some kill viruses or fungi or TB in addition to the bacterial claims. As long as contractors purchase disinfectants they need to kill specific organisms they are in compliance with the EPA requirements. For example, make sure your disinfectant has Fungicidal claims when working a mold job.
The EPA is also very strict when dealing with terms that may elude to “Heightened Efficacy” such as:• Hospital Strength• Super Strength• Ultra • Superior • Professional Strength• High Powered• Maximum Efficacy• Triple Strength If you are at a trade show and come across the latest and greatest disinfectant, but you want to make sure that everything the salesperson has stated reflects the EPA labeling, you can go onto the EPA website and find the disinfectant label at http;//oaspub.epa.gov/pestlabl/ppls.home .
Understanding the EPA label benefits contractors in myriad ways because by only representing the claims on that registered label you can effectively use the product safely to get the results you need.
It also keeps you, your staff and your customers healthier by using the minimum amount of product you need to get the job done. No longer will you have staff going into a water loss or mold remediation product saying, “this job is a lot dirtier than the last one so we better use more product.” This is not true since according to the label all disinfectants require a preclean step, so it doesn’t matter how dirty the job was, the disinfectant application is always done with the same amount of product.
Utilizing the same amount of disinfectant on each job will also keep the amount of Personal Protective Equipment (PPE) consistent. The label (and MSDS) will state what PPE is required for each job.
As society becomes more aware of chemical usage in the home and with the ease of access to health and safety information on the internet, your disinfectants and cleaning chemicals will be more heavily scrutinized. By understanding the EPA label, you can now use this as a tool to communicate to your customers (and employees) what products you are using and how to use these products safely and effectively.
Your label knowledge will also become a valuable marketing tool when you are communicating to customers about the products you will be using in their home or business. This will be especially important if you are competing with a competitor on a job that involves a high-risk client. High-risk clients are clients that could raise a health issue from the disinfectants that you are using.
By having these criteria clearly written on the back of your Work Authorization or Chemical Authorization Forms, this will reduce your liability by communicating with your customers that you will be using disinfectants with lower impact or bringing in extra environmental controls to reduce the possibility of triggering any liability issues.
Some contractors in the marketplace are offering their customers different levels of chemical programs:
Contractor: “Our company, XYZ Restoration and Cleaning can offer your family a choice between a GOLD or GREEN chemical program. Both programs will result in eliminating the same amount of germs from your water loss, but the products have a different health and safety profile. Since you mentioned that one of your family members has asthma, you may wish to take a look at the Green products to satisfy your needs. Mr/Mrs Homeowner, here is a copy of the EPA label for both disinfectants and please let me know what product you would like me to use in your home.”
By understanding the EPA label as a legal document that summarizes all of the scientific data, this empowers business owners to keep themselves, their staff and customers healthier and safer when using EPA registered products. The label knowledge also can be used to reduce any potential liabilities when dealing with customers and may even allow you to market your company as superior to your competition.