Understanding Regulation And Documentation For Sanitizers And Disinfectants

Rebecca Kaufold

By: Rebecca Kaufold, Spartan Chemical manager of government affairs & sustainability

Disinfectants play a critical role in a managed cleaning program. To ensure efficacy (the ability to kill organisms), disinfectants must be used as directed, and cleaning staff should follow product labels, safety data sheets (SDS), and regulatory guidance. Every successfully structured disinfecting program should also include ongoing training, as well as a system to document and manage disinfectant and sanitizing operations and validate that proper products are used, and proper procedures are followed.

Understanding safety documentation and regulatory guidance is essential for selecting appropriate products and establishing a comprehensive sanitization and disinfection program.

Multiple separate government agencies are responsible for different aspects of the regulations surrounding the use of chemical sanitizers and disinfectants.

• The Occupational Safety and Health Association (OSHA) is the federal agency that oversees workplace safety. OSHA, through the Hazard Communication Standard (HSC), requires employers utilizing disinfectants and sanitizers to have safety data sheets (SDSs), employee training programs, and PPE (Personal Protective Equipment). It is the responsibility of the employer to determine appropriate PPE requirements in the context of the hazards identified in the SDS and how employees use disinfectants and sanitizers in the workplace.
• The Environmental Protection Agency (EPA) oversees all aspects of registering, labeling, and marketing of surface sanitizers, disinfectants, and sterilizers. This includes the classification of hazards and identifies PPE, directions for use, and storage and disposal. Directions for use includes the method of application (such as spray or mop and bucket), surfaces the product may be applied, and the dilution rate and contact time required for efficacy. Disinfectants and sanitizers cannot be sold until the EPA approves all test data supporting product claims, all marketing statements, and each labeling element.
• The Centers for Disease Control (CDC) does not register or regulate disinfectants or sanitizers. Their primary role is to provide guidance on protecting human health. In the case of infection control, CDC provides information and guidance on selecting and using registered products that fall within EPA’s regulatory authority. CDC publishes information about emerging and ongoing health issues and provides general guidelines on how to clean and disinfect specific types of facilities for infection control.

Safety Data Sheets (SDS) include information on the physical and health hazards of disinfectants and sanitizers, including hazard statements, precautionary information, and first aid response. The SDS also includes recommendations on protective measures, like PPE, and precautions for safe handling and storage. Finally, the SDS lists transportation classification information. Employers must ensure that SDSs are readily accessible to employees for all hazardous chemicals in their workplace.

Disinfectant and sanitizer label instructions identify the contact time and dilution rate required for efficacy against the organisms listed on the label. It is critical to strictly follow the label directions for use instructions for all disinfectants and sanitizers to ensure the product removes the pathogens listed on the label. Disinfectant and sanitizer labels also include precautionary information that outlines human health and environmental hazards, as well as proper storage, disposal and container handling. EPA registered disinfectant and sanitizer labeling have requirements that differ from the classification criteria and hazard information required for OSHA HSC. For example, EPA uses its own signal words, such as Caution.

Disinfectants and sanitizers must have labeling, even in the diluted form. User-prepared solution labels for service containers may include the contact information for the manufacturer, the product name, EPA registration number, active ingredients (with percent) of the concentrate product, and the signal word and precautionary information identified on the EPA-approved label. While the EPA does not require directions for use on user-prepared labels, it does require a statement to refer to the concentrate label for directions. Properly labeled containers are required by OSHA and EPA. Adhesive user-prepared solution labels can be applied to any applicator including a spray bottle, pump-up sprayer, bucket or similar.

Training And Documentation

Every managed disinfectant program should also include ongoing staff training and education to ensure that proper disinfection and sanitizing procedures are both understood and followed. Cleaning management software can automate tracking of disinfecting operations and validate that proper disinfecting processes are utilized.

Training is essential for new employees and should remain available for existing staff to help ensure that custodial workers maintain proper usage and handling procedures. OSHA requires employers to train employees on the GHS Hazard Communication Standard 29 CFR 1910.1200, to ensure they understand the hazards of products they encounter in the workplace and employ the correct precautions in response. Employees who encounter bodily fluids are required to be trained on the OSHA Blood Borne Pathogen Standard 29 CFR 1910.1030. This standard prescribes safeguards to protect workers from occupational exposures of blood or other potentially infectious materials while cleaning up such soils.

In addition, cleaning management software provides tracking and documentation of day-to-day disinfection. A good software package should include a variety of functions to improve quality assurance, inventory management, workload scheduling and documentation of facility cleaning operations. Mobile app capability offers convenience to workers on the go, allowing cleaning staff to perform quality inspections and report in real-time where disinfection or sanitization took place and who performed it. Tracking and documenting disinfecting operations not only validates that the job was done correctly, but it also allows supervisors to target potential reoccurring trouble spots and implement process improvement and retraining as needed.

Conclusion

Proper disinfecting and sanitization as part of a managed program is the most effective weapon against the spread of pathogens that cause human disease. Understanding the various, overlapping roles of regulatory organizations in communicating where and how to use disinfectants and sanitizers, as well how to properly protect employees utilizing these products, is critical for the building occupants, employees, and businesses.

Spartan prides itself on offering end-to-end solutions for all industrial disinfection and sanitization needs. For more than 60 years, Spartan has set the industry standard of excellence with unparalleled solutions, including a broad spectrum of disinfectants and sanitizers, custodial management software and apps, and employee training programs.

Becky Kaufold holds a BS in Molecular Biology and an MBA. She has been working for Spartan for almost 25 years, including 3 summers as a college intern, 18 years as a formulator, and the last 5 years in regulatory.  She is a wife, mother of twins, perpetual volunteer, and an avid runner.

At Spartan Chemical Company, we make clean simple®. Family owned and operated since 1956, Spartan Chemical is a leading manufacturer of superior and cost-effective specialty chemical products sold through select, trusted distributors. Developed through conservative, stringent and environmentally responsible practices, with a focus on innovation, Spartan products include industrial cleaners, disinfectants, wipes, skin care, food processing, laundry care, warewash, floor care and vehicle wash products. In addition to cleaning products, Spartan offers CleanCheck® learning management system and CompuClean® facility management software to ensure the safety of staff and optimal efficiency of facility operations. From tools to training, Spartan’s solutions ensure consistently clean, healthy and safe environments for building occupants and cleaning staff in education, health care, food processing, hospitality and public facilities. Learn more at www.spartanchemical.com.