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.

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 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. Therefore, 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 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.