From a manufacturer's perspective, EPA registration of
disinfectants is a long and windy road often filled with potholes, U-turns and
the occasional dead end. It's true,
there are defined test methods that a manufacturer must use to prove product
disinfectant efficacy, toxicity profiles and chemistry profiles etc. There are also a number of supporting
documents that the EPA has published such as the EPA Label Review Manual and
Code of Federal Regulations - Labeling Requirements to "help" ensure that disinfectant product labels,
marketing materials, advertisements, websites and even tradeshow booth graphics
use "approved" language and avoid the use of
"inappropriate" language.
Safe, Safely, Safer, Safest, Green, Non-Toxic,
Harmless... etc, etc are wonderfully simple yet descriptive words that clearly
impart in plain English a meaning that the general population can
understand. These words can easily be
found in the Merriam or Webster dictionary, however, in the EPA's Dictionary of
Approved Words that CAN be used on Disinfectant Product Labels or Marketing
Materials they do not exist. They are
banned, they are taboo, they are to be avoided at all costs and if
used....there can be hefty repercussions.
Unfortunately, from a consumer perspective there is no
class that can be taken to learn what can and cannot, should and should not be
included on disinfectant product labels or marketing materials. "Policing" of disinfectant
marketing materials, advertisement etc is primarily left to industry to monitor
their competitors. Most reputable
manufacturers follow the rules and ensure that they do not use words or phrases
that are considered false or misleading, however, there are those unscrupulous
companies that know the general consumer does not understand what can be said
by law on their marketing materials and also know that "simple" words
such as Safe or Harmless will resonate with the consumer looking to choose a
product. They have no qualms pulling the
wool over your eyes to sell more product or position their product against
similar competitive products to gain a competitive edge so to speak and make
another buck.
To become a "Pro" at reading and interpreting
disinfectant labels and marketing materials you certainly can use the EPA Label
Review Manual or CFR Labeling Requirements regulation, but having read them
myself, save yourself the trouble.
Instead when reviewing new disinfectant products ask yourself the
following:
1. Do these claims seem too good to be true? If they do, ask to see the data used to make
the claims.
2. Is the wool being pulled over my eyes? Do these claims
or statements seem misleading? If so,
investigate further and ask lots of questions and gather the data to support
the claims.
3. Are they using "Bathroom" words? If they are, you should question the accuracy
and appropriateness of such claims.
As a consumer if you are uncertain as to the
appropriateness of claims or statements made on disinfectant products and their
associated marketing materials you can submit an inquiry to the EPA or just
call or email me...I'd be happy to provide clarification for you!
Bugging Off!
Nicole
