Designing A Greener Disinfectant
It isn't easy being green, especially when it comes to disinfectants. Currently the U.S. Environmental Protection Agency (EPA) forbids marketing disinfectant products as "environmentally preferable" because they are designed to kill microbes, giving them a pesticide designation.
Without a solid means of identifying green disinfectants and sanitizers, some custodial staffs charged with greening their cleaning operations believe they have to completely forgo disinfectant use. In fact, Marion Stecklow, executive director of the Building Wellness Institute LLC, Silver Spring, Md., a firm formed to train commercial-facility cleaning services to adopt environmentally friendly practices, says she's audited more than a few companies where the staff wasn't using disinfectants because they were not green certified.
ISSA Director of Legislative Affairs Bill Balek explains the EPA rule barring claims of preferred environmental, safety and health profiles makes it difficult for purchasers to select greener disinfectants and sanitizers.
"Buyers," he says, "currently have no easy way of identifying disinfectant products with preferred environmental profiles. Because of the confusion, some state policies or individual purchasing entities have questioned their use."
However, disinfectants play an important role in removing disease-causing microbes from indoor environments. Steve Ashkin, president of The Ashkin Group LLC in Bloomington, Ind., emphasizes "disinfectants are a valuable tool in creating healthier buildings." He adds that those who believe they cannot employ disinfectants in green cleaning programs are mistaken, and reminds end-users that these products help protect public health and the environment.
The Dawn of a New Disinfectant
Disinfectants and sanitizers have a long history of being classified as pesticides under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA). FIFRA institutes federal control of pesticide distribution, sale and use, and requires pesticides used in the United States to be EPA registered. Registration assures proper product labeling and promotes their use in accordance with specifications designed to prevent unreasonable environmental harm.
This statute mandates products intended to kill pests be regulated as pesticides. Disinfectants and sanitizers fall under the umbrella of this definition because they kill microorganisms such as bacteria and viruses.
"An all-purpose cleaner would not be regulated, but anything that says it kills bacteria, funguses or whatever, would be," Ashkin explains.
Treating all pesticides equally has posed more than a few challenges to the cleaning industry, adds Balek. With states and cleaning organizations grappling with how to deal with disinfectants in green cleaning programs, the need for the EPA to change its stance has never been more acute. The EPA's policy frustrates innovation as manufacturers put off investing millions of dollars in environmentally preferable disinfectants because they cannot inform purchasers of their efforts. At the same time, professional purchasers are requesting greener disinfectants for cleaning programs. Because of the lack of EPA guidance, Balek points out the marketplace has filled the void by defining greener disinfectants and sanitizers on its own, often creating inconsistent messages across the industry.
"Fortunately, the EPA now realizes these issues," he adds. "It realizes its current policy has made it difficult to select environmentally preferable disinfectants and sanitizers."
In July 2008, the EPA responded by forming the Work Group on Comparative Claims, as part of the Pesticide Policy Dialogue Committee (PPDC), and tasked organizers with forging a policy that would recognize greener disinfectants and sanitizers. The work group made its final recommendations to the PPDC in mid-October 2009 and the EPA will soon announce two pilot programs in the Federal Register.
Michael Hardy, enforcement coordinator in the EPA's Antimicrobials Division, states the reason for two programs became clear as the working group identified differing approaches to defining green products. As a result, one pilot will allow qualified disinfectants and sanitizers to bear the EPA Design for the Environment (DfE) logo while the other will allow manufacturers to make approved factual claims about their products, such as dye-free or scent-free.
Nuts and Bolts
In order to gain approval to add the DfE logo to disinfectant labels, manufacturers must first prove their product formulations meet criteria set by the Office of Toxic Programs then apply for the DfE logo through the Office of Pesticide Programs.
"The first thing we're going to do is check and see if products are of the lower acute toxicity for pesticides," Hardy says. Currently the EPA sets four criteria for acute toxicity classification: Toxicity Class IV (the lowest level and considered nontoxic); Toxicity Class III (Caution); Toxicity Class II (Warning); and Toxicity Class I (Danger). Products classified as Toxicity Class I or II will be unable to bear the DfE logo.
"We don't want any product with a personal protective equipment (PPE) requirement to be part of these pilots," Hardy explains. "For example, you shouldn't have to wear a respirator to apply the product."
This requirement poses a problem for concentrated disinfectants commonly used in the jan/san industry because most fall into Toxicity Class I or II. As a concentrate, the products are corrosive, Balek explains.
"But there are environmental benefits to producing and taking to market concentrated products," he emphasizes. "For one, you include less water, thus using less energy to transport a similar quantity of product."
Industry players have recommended the EPA resolve this issue by assessing the toxicity level of concentrated products in their ready-to-use dilutions. Hardy notes the EPA is currently considering adding this change to pilot requirements.
Another stumbling block may appear in the review process itself, adds Ashkin, who notes the Office of Pesticide Programs must first consider a product's efficacy. In other words: Does it kill the organisms it claims to kill? Approved products will then run through the DfE screen, where Ashkin predicts many disinfectants and sanitizers may fail. He explains the DfE screen considers ingredients from health, safety and environmental perspectives, and some disinfectant ingredients may not pass muster. The success of the pilot hinges on how many products pass DfE screening.
"If only one product passes, that's not a viable program. If everything passes, it's not a viable program either," Ashkin says. "The EPA is really trying to understand the implications of running these products through the DfE screen."
In addition, the DfE pilot will only be open to products currently registered with the EPA, which concerns industry insiders who worry it doesn't allow for the continued development of greener products.
"But this is not a done deal," Hardy emphasizes. He adds that when the EPA announces the pilots later this year, their start date will likely be in mid-2010 giving companies ample time to submit new products for registration before the pilot begins. The EPA is also considering allowing new formulations into the program as the pilot progresses.
The pilots are a work in progress, Hardy adds, and will be tweaked as needed over their two-year run. At the end of 24 months, Balek notes the EPA has the discretion of pulling the plug, continuing the programs in their existing forms, or operating them with additional amendments and revisions.
It all depends on how the pilots affect the market, adds Hardy, who explains if surveys and focus groups find people falsely believe the DfE logo on a disinfectant means it's completely safe, the EPA will halt the program. But if users understand that this labeling means these products are lower in toxicity, do not require PPE, and will not burn their skin or eyes when used correctly, the pilots will continue.
The primary goal, however, is to spur innovation in the marketplace, says Hardy.
"We're hoping we can drive the market to consider reformulating their current formulations so that we can have the same accepted products in the market at lower toxicity concentrations," he says. "That would be a good indicator that these pilots have been a success."
Greening Sanitizers Now
However, cleaning operations needn't wait until mid-2010 or later to green their disinfectants and sanitizers. In the meantime, Ashkin recommends operations look to Executive Order 13423 when comparing these products. This order defines "green" as those products which "reduce health and environmental impacts when compared to similar products and services used for the same purpose."
He explains, people often falsely assume all products must be certified in green cleaning programs, but operations can utilize non-certified products by following the definition of green put forth in this executive order. Purchasers, he says, must go beyond selecting disinfectants that are efficacious and meet cost requirements, and also look for those that do the best job of reducing health and environmental impacts.
For example, selecting a concentrated product helps the environment by reducing the environmental impact associated with packaging and transportation. Likewise, choosing a product with a neutral pH (closer to 7) versus one at extreme ends of the pH scale (0 or 14) reduces the potential for skin and eye irritation. Also, selecting products that meet or exceed California requirements for Volatile Organic Compounds (VOCs) puts less VOCs into the air.
"And a product with lower VOCs reduces the potential for respiratory problems and asthma," Ashkin explains.
Ashkin also stresses that only using disinfectants when absolutely necessary helps green cleaning operations. Hospital-grade disinfectants may be essential when cleaning operating rooms, patient rooms or restrooms, but unnecessary in mail rooms, offices or conference rooms where low-grade and greener disinfectants, or general all-purpose cleaners may be adequate.
The EPA pilots have a long, winding road ahead of them. And while these efforts will make it easier to be green in the future, Ashkin stresses greening disinfectant use can begin today.
Ronnie Garrett is a freelance writer based in Fort Atkinson, Wis.
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