---
title: Is the EPA condoning the use of Steroids?
description: Is the EPA condoning the use of Steroids?
---

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## Is the EPA condoning the use of Steroids?

<http://static1.squarespace.com/static/595689fc9de4bbc892200518/t/59568acf5fd63b5f29287a33/1498845539112//img.png.com/static/595689fc9de4bbc892200518/t/59568acf5fd63b5f29287a34/1498843855823/1000w/>

The baseball season has started and for those of you  
 diehard fans watching your favorite player hitting yet another ball out of the  
 park, like me you may be wondering “How the heck do they do that!” 

Professional sports are a great example of an  
 industry that has perhaps raised the bar too high and set too many unrealistic  
 goals for players to achieve. We wonder  
 who will be the next Barry Bonds.  We get  
 caught in the thrill of watching these talented players and rarely think to ask  
 “How did they get that good, that strong, or that big?” Then we open the front pages of the sports  
 section and hear of yet another steroid scandal. 

The disinfectant world is not unlike professional  
 sports.  There are new bugs cropping up  
 that Infection Prevention and Control, Public Health and Environmental Services  
 expect their disinfectant of choice to kill.   
The bar is being raised to unrealistic expectations – kill a greater  
 spectrum of bugs in a shorter contact time.   
To meet these demands, disinfectant manufacturers “juice up” or increase  
 the chemical concentration or combination of chemicals in their disinfectant  
 formulations in order to achieve the desired claims.  Like the long term affect steroids can have  
 on a baseball player, “juicing up” a disinfectant formulation means the safety  
 profile of the disinfectant will be compromised. 

Let me give you an example of this.  There is a popular disinfectant brand on the  
 market advertising that in recent years they have knocked their contact time  
 down from 5 minutes to 3 minutes and now 1 minute!  From an infection prevention perspective you  
 may be screaming “FANTASTIC”!  But have  
 you taken the time to look at the MSDS in order to determine how they have  
 performed such a feat?  I have.  It’s “juiced up”, one of the active ingredients  
 has tripled in concentration and they have added a second type of alcohol.  What is the end result?  A 1 minute disinfectant that now carries a  
 HMIS Rating of 2/3/0.  To handle this  
 product you should wear gloves and goggles and the toxicity profile shows it is  
 Toxic by inhalation per OSHA regulations, slightly irritating to eyes and skin,  
 contains material which can cause target organ damage and contains material  
 which both causes and may cause damage to the organs.  That’s just the health effects.  The Flammability rating of 3 indicates the  
 product is highly flammable and should be stored in a segregated and approved  
 area and all possible sources of ignition (spark or flame) should be  
 avoided.  Is this a product you want to  
 use?  Is a one minute contact time so  
 important that we would knowingly choose a product that would put cleaning and  
 nursing staff at risk?

Federal law requires that before selling or distributing  
 a pesticide in the United States, a person or company must obtain registration,  
 or license, from EPA.  Before registering  
 a new pesticide (including disinfectants) or new use for a registered  
 pesticide, EPA must first ensure that the pesticide, when used according to  
 label directions, can be used with a reasonable certainty of no harm to human  
 health and without posing unreasonable risks to the environment.   Herein lays the crux of the problem. 

To generate bactericidal efficacy data, the EPA requires  
 the use of a test method that was introduced in the early 1950’s and is known  
 to have flaws.  In a study recently  
 published in the Journal of AOAC International, titled[ “Should the AOACUse-Dilution Method be Continued for Regulatory Purposes?”](http://virox.com/infection_control/peer_document/default.aspx) a statistical  
 evaluation of the Use-Dilution Method (UDM) was conducted.  I won’t bore you with the details or formulas  
 used – you can read the study at your own leisure.  Suffice it to say, the study showed that  
 there was a significant disconnect between the probabilities of a pass/fail  
 result when compared to the random testing conducted by the EPA’s Antimicrobial  
 Testing Program.  The difference can in  
 part be attributed to the fact that the method shows significant variability in  
 the numbers of bacteria that adhere to carriers, however, the main cause is in  
 fact highly operator sensitive such as how the lab technician places of the  
 cylinders into the test tubes or places the test specimens for drying as well as  
 any variations in growth conditions.

Further, UDM is not representative of real world  
 conditions, especially for products with rapid evaporation rates (alcohol based  
 products) as the concentration of the active decreases rapidly when exposed to  
 a surface.  UDM provides a much higher  
 ratio of disinfectant volume to surface and does not account for evaporation  
 rate that occurs when used in accordance to the product’s label.  Similarly, the ratio of disinfectant to  
 inoculum is very different than what is encountered in practice and lastly,  
 there is limited ability to include other environmental surfaces which can also  
 alter the outcomes of efficacy capabilities of a given disinfectant.

It is also important to consider the affect development  
 of very robust formulations have from an environmental impact perspective. Globally, users of chemicals are looking for  
 and demanding access to more environmentally friendly products, however, the  
 EPA’s rigid stance and refusal to transition to methodologies that have been  
 shown to be more accurate and consistently reproducible such as Quantitative  
 Carrier Tests impacts both the environment through higher carbon footprints in  
 the production of the disinfectants, unnecessary disposal of higher  
 concentrations of disinfectants by the end user and also increased risk to the  
 user as a result of less favorable health profiles.

By no means am I saying that from an infection prevention  
 perspective we should use inferior products with contact times that are  
 unrealistic.  I am saying that we as a  
 community who uses disinfectants on a daily basis should consider not just what  
 a product kills, but also the safety profile of the product and lobby the EPA  
 for the use of test methods that have been shown to be reproducible, reliable and  
 more accurate than the Use-Dilution Method.   
Formulation of disinfectants is a complex process that involves finding  
 the balance between the desired efficacy traits and the desired safety and  
 environmental profile of a product.  The  
 EPA’s mandate is to ensure that the use of disinfectants “can be used with a  
 reasonable certainty no harm to human health and without posing unreasonable  
 risks to the environment”. The use of UDM completely contraindicates this  
 mandate as it forces disinfectant formulators to “juice up” their formulations  
 in order to achieve the kill claims and knowingly decrease the safety profile  
 of the product. 

I hope you’ll consider this the next time someone comes  
 your way with the next “fastest” disinfectant on the market.  A fast kill is a double edged sword.  Are you willing to forego safety for speed  
 knowing that the test methods used to determine efficacy are faulty?

*Bugging Off!*

* *

**

*Nicole* 

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