The COVID-19 pandemic has created challenges for everyone across the globe. For those responsible for making workplaces safe with respect to the coronavirus that causes COVID-19 disease, these challenges have resulted in additional measures relating to cleaning and disinfecting work areas.
Adding to this, during the early stages of the pandemic, some “approved” products were reserved for high-risk areas, such as healthcare facilities. This may have resulted in the use of non-approved, or even dangerous, chemicals/ devices in other areas – creating hazards for those “essential” personnel tasked with cleaning/disinfecting, as well as other workers in these areas.
Background
The Centers for Disease Control (CDC) has issued a series of steps for safe and effective disinfectant use 1:
- Check that the product is EPA-approved. Find the EPA registration number on the product; then, check to see if it is on EPA’s list of approved disinfectants at: epa.gov/listn.2
- Read and follow the product’s directions. Check “use sites” and “surface types” to see where the product can be used. Read the “precautionary statements.”
- Pre-clean the surface. Make sure to wash the surface with soap and water, if the directions mention pre-cleaning or if the surface is visibly dirty.
- Follow the contact time found in the directions. The surface should remain wet the whole time to ensure the product is effective.
- Wear gloves and wash hands. For disposable gloves, discard them after each cleaning. For reusable gloves, dedicate a pair to disinfecting COVID-19. Wash hands after removing the gloves.
- Lock it up. Keep lids tightly closed and store out of reach of children.
Stressing that only “EPA-approved” disinfectants should be used, the CDC refers to the EPA’s “List N” 2, which is their list of registered disinfectants “that have demonstrated efficacy against SARS-CoV-2 (the coronavirus that causes COVID-19)”.3 Presently there are over 500 entries on List N and EPA offers an “e-tool” for users to search this database for a particular product.4
Products on List N are for surfaces only and are regulated under the EPA’s FIFRA (Federal Insecticide Fungicide and Rodenticide Act) program. But manufacturers of these pesticide products may not have originally considered that these products were going to be used in the quantities and/or the duration that has been the case over the last year. Additionally, many of the “essential” workers now tasked with conducting the cleaning/disinfecting may not have received suitable training in the hazards, proper application, or PPE.
According to the CDC, cleaning and disinfecting are equally important for reducing the spread of viral illnesses.5 Cleaning “refers to the removal of germs, dirt, and impurities from surfaces”; while disinfecting “refers to using chemicals to kill germs on surfaces”
The CDC and EPA stress that users of any disinfectant/pesticide refer to safety data sheets (SDS) and product labels. The National Institute of Occupational Safety and Health (NIOSH) offers a chart identifying hazards from active ingredients (AI) in these products and includes precautions and personal protective equipment (PPE) used to protect workers from the hazards. Almost every AI listed presents one or more of the following acute health effects.5
- Skin, eye and respiratory tract irritation. Many cause severe eye burns and skin damage. Several also list “fatal if inhaled” or even fatal through skin contact.
Additionally, many of the AIs also list chronic effects, including toxicity to one of more organ systems; and several are either known or suspected carcinogens. Due to shortages of supplies, some employers have taken it upon themselves to use disinfectants in “devices” that were not originally designed or intended for that particular type of application (e.g. fogging, chemical sprayers).
Pesticide Devices vs. Pesticide Products
How a disinfectant is applied determines who regulates it and the testing it undergoes regarding efficacy. A Pesticide Product contains a substance or mixture of substances that is intended to destroy, repel, prevent or mitigate (lessen the severity of) a pest and must be registered. While a Pesticide Device works by physical means (such as electricity, light or mechanics) to perform its intended pesticidal purpose and does not contain a substance or mixture of substances. For example: ozone generators, ultraviolet lights or air purifiers are samples of “pesticidal devices”.6
“Unlike pesticide products, EPA does not review efficacy of pesticidal devices, and therefore cannot confirm whether, or under what circumstances, such products might be effective against SARS-CoV-2. 7
Companies that offer these pesticide devices or novel application methods are responsible for maintaining their own records and can be held liable under FIFRA and for making false claims of effectiveness.8 And unless the pesticide product label specifically includes directions for fogging, fumigation, wide-area or electrostatic spraying, EPA does not recommend using these methods to apply disinfectants.9
Conclusion
The health hazards associated with chemical disinfectants are well known. Use of these same chemicals in novel or non-approved pesticidal devices creates the potential for widespread exposure to applicators, workers and occupants in these affected areas. Only time will tell if there are long-term effects for the workers who used them or for those employees and building occupants exposed to them unwittingly
Additional Resources
HETI’s Certified Industrial Hygienists, Professional Engineers and Environmental Specialists are available to assist employers with a variety of services to assist with assessing the spread of the COVID-19 virus including surface and air sampling. Additionally, HETI is prepared to provide recommendations for the safe use of pesticides and pesticide products and application devices.
References:
1 Six Steps for Safe & Effective Disinfectant Use, Pesticide Registration, USEPA
2 List N: Disinfectants for Coronavirus (COVID-19), Pesticide Registration, USEPA
3 How does EPA know that the products on List N work on SARS-CoV-2?, Coronavirus (COVID-19), USEPA
4 List N Tool: COVID-19 Disinfectants, USEPA
5 Hazard Communication for Disinfectants Used Against Viruses, NIOSH, CDC)
6 Pesticide Devices: A Guide for Consumers, Pest Control and Pesticide Safety for Consumers, USEPA