Disinfectants and the EPA
Choosing a disinfecting agent can be a confusing task. There are many factors that play into choosing a disinfectant, and we need to be aware of them all.
By Noel Brandon Kelsch, RDHAP
Choosing a disinfecting agent can be a confusing task. There are many factors that play into choosing a disinfectant, and we need to be aware of them all. The government has created many great resources to aid you in not only the choice of a product but also in interpreting the guidelines and directions for use.
The United States Environmental Protection Agency (EPA) oversees the use of disinfectants. They classify disinfectants in the dental setting as antimicrobial pesticides. These substances or mixtures of substances are used to destroy or suppress the growth of harmful microorganisms -- whether bacteria, viruses, or fungi -- on inanimate objects and surfaces.
Other columns by Noel Kelsch
Amazingly, these products can contain about 275 different active ingredients and are marketed in several formulations: sprays, liquids, concentrated powders, and even gases. The EPA states that approximately one billion dollars each year are spent on a variety of types of antimicrobial products. Over 5,000 antimicrobial products are currently registered with the EPA and sold in the marketplace. Nearly 60% of antimicrobial products are registered to control infectious microorganisms in hospitals and other health-care environments.1
Disinfectants are specifically designed to be used on hard, inanimate surfaces and objects. They either destroy or irreversibly inactivate infectious viruses, fungi, and bacteria. They do not necessarily take care of spores.2
The EPA is very specific about how they look at pesticides. All pesticides must be registered with the EPA unless they meet the specific criteria for minimum-risk pesticides.3
One function of the EPA is to ensure that dental professionals return home safe at the end of the day and that patients are safe. The EPA wants to make sure that the products that are being used (when used following the label directions) will not harm nontarget species -- the environment and, most importantly, people -- yet are effective pesticides.
The EPA examines and evaluates:
- Ingredients of a pesticide
- Where it will be used (medical setting,in the home, or on food)
- Amount, frequency, and timing of its use
- How it will be discarded or stored1
This is all included on the label use and is available on the EPA website in great detail: http://iaspub.epa.gov/apex/pesticides/f?p=PPLS:1 .
When developing a product, companies are required to submit it to the EPA for review. The review includes information about the health effects of pesticides, including cancer, reproductive effects, neurological effects, and acute and chronic toxic effects. Once registered, pesticides are then periodically re-reviewed for safety. If new concerns arise, the EPA can change the conditions for using the pesticides or can cancel the registration of the pesticides. It is very important to note that it is illegal in all states to use a pesticide product in a manner inconsistent with its label directions.3
Some examples of off-label use may surprise you. If a product was made to be used in the medical setting and you use it in a food preparation area or on the phone in the front of the office, it would be considered off-label use. Such use could put staff at risk because this product was not made to work with food or to be handled without proper personal protective equipment, such as utility gloves, a mask, eye protection, and a gown.
To find out the specifics of a product, you can use what was once called the Material Safety Data Sheet (MSDS); it is now referred to as the Safety Data Sheet (SDS). (To see an article that covers the update on SDS, go to: http://www.rdhmag.com/articles/print/volume-33/issue-1/coumns/dental-compliance-with-hazard-communication-standard.html.)
For more specifics on products, go to product labeling for pesticides on the EPA website: http://iaspub.epa.gov/apex/pesticides/f?p=PPLS:1.4 This page will give you both the specifics on and the entire history of the product. Clicking on this page will take you to the products; then click on the approved date and it will give you the details of the use, concerns for the product, effectiveness, etc.
Knowing the use and specification of your disinfectant and the changes that occur over time is vital in the dental setting to assure staff and patient safety. The EPA can supply you with all the information you need to assure that you are not using the product off-label and that you are keeping everyone safe. Do you have questions or an issue with a product? The National Pesticide Information Center (NPIC) can be reached at 1-800-858-7378.
2. Centers for Disease Control and Prevention. Guidelines for Infection Control in Dental Health-Care Settings – 2003. MMWR 2003;52 (No.RR-17).
5. Rutala W. Disinfection, Sterilization and Antisepsis Principles, Practices, Current Issues and New Research. APIC Conference Proceedings, 2006, APIC. Page 13.
Key issues with disinfectants
Off-label uses: There are reasons for every direction that is included with a product. Using suggestions that are not on the label can impact the effectiveness of a product. For example: Turning the canister upside down with disinfectant wipes when that direction is not on the label can impact the effectiveness of the wipes. Many wipes feed from the bottom where the fluid is; when you turn the canister upside down and then turn the can back over, the wipe can be dry on the bottom. The fluid also can leak from the lid. Following the directions exactly is vital; the directions are developed from the research that has been done on the product.3
EPA Registration Number: All disinfectants must have an EPA registration number on them that verifies that they have been approved. If they do not have this number on them, you should not use them for disinfection. The number will appear as EPA Reg#. The first set of numbers identifies the registrant; the second set identifies the product number; and the third set of numbers identifies the distributor. These sets of numbers are followed by the state and location where the product was manufactured.4 The label also includes directions that are developed from the results of clinical testing. The product labels are continually updated as new research is conducted; they should be read prior to use.4,5 These labels allow the consumer to always be able to research the product he or she is using.
NOEL BRANDON KELSCH, RDHAP, is a syndicated columnist, writer, speaker, and cartoonist. She serves on the editorial review committee for the Organization for Safety, Asepsis and Prevention newsletter and has received many national awards. Kelsch owns her dental hygiene practice that focuses on access to care for all and helps facilitate the Simi Valley Free Dental Clinic. She has devoted much of her 35 years in dentistry to educating people about the devastating effects of methamphetamines and drug use. She is a past president of the California Dental Hygienists' Association
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