Using EPA Lists for Disinfecting
Jul 24, 2024If COVID taught us anything it's that we're vulnerable. I remember reading the Drudge Report and refreshing it endlessly. Matt Drudge was on the forefront of report this "new" virus when COVID first hit. I remember vividly seeing reports out of China and seeing cell phone videos of people dropping, seemingly dead or dying, on the streets and sidewalks of some of their biggest cities as early as January of 2020. It was a race to see what this new virus was, how it was transmitted, and what we could do to protect ourselves.
Weeks turned into months and by summer of 2020, we had a good understanding of how the virus was structured, how it was transmitted, and how we could kill it. But within that time, it was the Wild West in terms of Snake Oil Salesmen selling a "cure" to this virus. My first clue came from a friend. He served on a leadership board for Nashville's largest Baptist church. That church paid a cleaning company $75,000 to disinfect their church, and effectively scammed in the process. From that spring going forward, I made it a crusade to education myself, my clients, and to spread the word.
One of my clients reached out to me. He said a cleaning company offered to disinfect their church and school for $999. Their claim was that once disinfected, their space would be safe from disease for 30 days (as if the pathogen is looking at a calendar). And for just $1000 more, to $1999, their space will remain germ-free for a year. Red Flags! More stories came in. If you use this product, it will kill this disease or that. Then the government stepped in. Hey, I'm all for limited government but this is where my tax dollars earned their keep. There were agencies pursing cleaning companies on the state level. And then the feds, including agencies like the Federal Trade Commission, the Food and Drug Administration, and the Environmental Protection Agency began to chase after or prosecute these companies making false claims. The EPA stepped up warning letters to product manufacturers to make sure their claims were scientifically proven. I remember attending weekly Zoom conference calls learning about the virus and the products needed to kill it.
The EPA is no stranger to public awareness. Remember the seemingly unending news reports about sick people contained to cruises or confined spaces through Norovirus (stomach bug)? We were TERRIFIED that Norovirus would strike a client's location, and we'd get blamed all because a sick office worker or student never stayed at home like they should have. We didn't want the negative press. So about 17-18 years ago we created a game plan to track pathogens at our clients' location and to have open dialogs with ill workers, students, and guests at the locations we cleaned. Thankfully we remained sick-free but we were well aware what diseases were spreading out there and how to combat them. Whenever there were cold germs floating around or a ringworm outbreak at a local school client (stupid rabbit), or something more serious like MRSA, C. diff, or even the flu, we were ready. Thanks to the EPA, we knew what products to use and how to kill it.
The purpose of this post is to bring to everyone's attention a valuable resource through EPA's lists. There are multiple lists covering different pathogens from HIV to bird flu to monkeypox to COVID, and everything in between. The EPA shares what products will work, and roughly how to use those products. Before I go further, know that each product has a Safety Data Sheet. Always become familiar with each product's sheet. It'll help you identify products that could damage surfaces or harm people, and even gives a chemical breakdown and proper first aid and safety, should it be needed.
The EPA has a list for each pathogen, or purpose, and below is a comprehensive list of Lists.
List A: Registered Antimicrobials Effective as Sterilizers
List B: Registered Antimicrobials Effective against Mycobacterium tuberculosis (TB)
List G: Registered Antimicrobials Effective against Norovirus (feline calicivirus)
List H: Registered Antimicrobials Effective against Methicillin-resistant Staphylococcus aureus (MRSA)
List J: Registered Antimicrobial Products for Medical Waste Treatment
List K: Registered Antimicrobials Effective against Clostridioides difficile Spores (C. diff)
List L: Registered Antimicrobials Effective against Ebola virus
List M: Registered Antimicrobials Effective against Avian Influenza (bird flu)
List N: Registered Antimicrobials Effective against Coronavirus (causes COVID-19)
List N Appendix: Supplemental Residual Antimicrobial Products for Coronavirus
List O: Disinfectants Effective against Rabbit Hemorrhagic Disease Virus (RHDV2)
List P: Registered Antimicrobials Effective against Candida auris (C. auris)
List Q: Disinfectants Effective against Emerging Viral Pathogens (includes Marburg, Ebola, Monkeypox (Mpox), Coronavirus, and Rabbit Hemorrhagic Disease Virus)
List S: Registered Antimicrobials Effective against Bloodborne Pathogens (includes HIV, Hepatitis B, and Hepatitis C)
I know what you're thinking....You're missing some letters! Yup. They're redoing and consolidating some lists. List C (HIV only), List D (HIV and Hep-B), List E (for TB, HIV and Hep-B), and List F (Hep C only) were all retired and eventually consolidated into List S. List I was originally for C.diff but later was expanded. But List R? I couldn't find out anything online. If it ever existed, it would only be about 2 years old and deleted within that time. If you find anything, let me know. I'm curious.
So, how do I use these lists? Generally speaking, your client wants you to "disinfect" their space. Have a convo with that client to ask why they want it disinfected and ask what they are disinfecting for. Clues are sometimes left. If you're cleaning a gym, you may want to use a disinfectant that kills MRSA, since MRSA was commonly found in gyms and some medical facilities. If it's a wellness general practice doctor, their top concern may be COVID, so focus the disinfecting on that. If you're cleaning a facility where injuries could occur, like a factory, or even an urgent care center, you may need something for Bloodborne Pathogens. Something from List S may be best. Or maybe you're in an area where bird flu is making the news rounds starting this summer, namely Colorado and Texas. If there's no clear winner of a pathogen, and the client can't decide, aim for a disinfectant that's well rounded in terms of a claim list, and use that.
Within each EPA list there's vital info.
The above is one of the 690 products (as of this post) that are certified by the EPA to kill coronaviruses as listed on List N. List N is more comprehensive due to the nature of the spread, but each list has comparable information. You'll see a registration number. If you look on each cleaning product, there's an EPA Reg. number. This is the first two sets of the 3 sets of numbers for that product. It helps you match up the right one (how many Lysol products are there????). Going over to the right, you have contact time. This is the dwell needed to kill that pathogen (or in this case coronavirus). So this particular example, the surface needs to remain wet for 1 minute in order to kill it. Oh, and how many times do you see people spraying a disinfectant and immediately wiping it? I see it all the time. Nothing is getting disinfected. This product is RTU and it's for non-porous surfaces (true fact...all List N disinfectants are for non-porous surfaces. If someone claims to disinfect sofas, pillows, rugs, carpet, etc. with a disinfectant, and it they're going after COVID, they are either lying or they don't know what they are talking about).
Moving away from COVID, the other lists are similar in format. Select the pathogen. Select the list. And you can see what products work and how to work those products to kill that particular pathogen. And always check the Safety Data Sheet and it's good practice to review the product sheet as well. Hope this helps.
Next on Deck: Recharging Your Batteries (7/31/2024)