The Gold Standard of HOCl

The Conundrum of Disinfectant Labels

28 August, 2020


          
            The Conundrum of Disinfectant Labels

You’re standing in the grocery store Household isle (after aimlessly wandering the store for 15 minutes, if you’re a man) for the 1,000,000th time and staring at the label on the bottle of disinfectant. “What the heck does all of this mean?”, you ask yourself. You scratch your head.  Is it a sanitizer, cleaner or disinfectant?  Does it kill germs, bacteria, viruses?  What do the kill claims mean?  What do the active ingredient percentages mean? And on it goes……..

Believe me, you’re not alone.  This mass confusion with labels has, finally, prompted me to write a blog to hopefully shed some light on this perpetual conundrum.  Like most things in life, many have come before me.  Still, I want to take my own shot, which will likely include several blogs. As the CEO of Disinfexol LLC, I admit to writing these blogs from a slightly different perspective.  Yes, I absolutely think FIFRA is critical to keeping us all safe from harmful products.  However, one size doesn’t always fit all.  Not all disinfectants are created equal.  Sometimes I may highlight our own frustrations within the daunting, disinfecting space, but I will also try to be unbiased and educate to the best of my ability.

First, disinfectants are classified by the EPA as pesticides.  Strange, but true.  Most of us think of pesticides as those concoctions that we place in our garages or attics to kill mice or some other mischievous rodent.  Pesticides are, as defined by FIFRA (Federal Insecticide, Fungicide and Rodenticide Act), “Any substance or mixture of substances intended for preventing, destroying, repelling, or mitigating any pest (insect or other organisms harmful to cultivated plants and/or animals).”  FIFRA, originally enacted in 1947, is the federal law that governs how the EPA oversees pesticide use in the United States. Since disinfectants technically kill pests, they fall under FIFRA. Translation: there is a vast array of label requirements, regardless of what actually comprises the disinfectant.  In addition, to complicate matters further, there are wordsmiths who craft careful sentences that can be misleading to the regular shopper. 

Second, there is a distinction between the words, “Cleaner”, “Sanitizer” and “Disinfectant”.  The EPA term used for Cleaners is “cleans away, or washes away”.  Sanitizers are described as “reducing, but not necessarily eliminating microorganisms from inanimate objects”.  Disinfectants “inactive, kill or eliminate” microorganisms”.    So, in the order of efficacy and strength from least to greatest, it is (1) Cleaner, (2) Sanitizer and (3) Disinfectant.  There are also levels of disinfectants, and requirements for same, but this is for another blog!  I will say that Hospital-Grade is the 3rd and highest level of disinfectant, which is the level of Disinfexol Cleaner and Disinfectant.  Now, one last point about Cleaners.  There is language that is permissible by the EPA which does not require EPA registration.  So, if you see a Cleaner on the shelf, and it does not have an EPA number listed on the bottle, it is not registered by the EPA.

Third, label requirements are numerous and specific.  To refresh my own memory, I referred to the 17 page Label Review Manual from the EPA https://www.epa.gov/sites/production/files/2018-04/documents/lrm-complete-mar-2018.pdf, which gives you a flavor of what one must include on the label.  (Remember, this is the Review Manual, so this is the summary of actual EPA guidelines.)  There are font size stipulations, header requirements, content requirements and placement of same, ingredient statements and precautionary statements, among others.

Today, I only want to address one label item:  ingredients.

Ingredients must be listed as “Active” and “Inert” or “Other” with weights of same.  The Active is the ingredient used to sanitize or disinfect.  Its location must be on the front panel of the bottle, so you will see it there if you look closely.  Inert or Other describe what is being used to comprise the balance of the product.  Regardless of what this balance is, Inert or Other must be used.  For example, Clorox lists their Active as 7.5% Sodium Hypochlorite and Other as 92.5%.  While I will discuss how specific weights are calculated in another blog, we don’t know exactly what comprises this Other 92.5%. Disinfexol Cleaner and Disinfectant has an Active of .065% HOCl (hypochlorous acid) and Other of 99.935%.  I do know the Other in Disinfexol is 100% reverse osmosis water.  My point is this:  Other, in this example, is not the same, but it is described as such. Disinfexol would certainly use the word, “Water”, if it could, but this is not allowed under FIFRA.

So, that’s all for today.  Hope you will hang in there with me as I continue to write and explain the meaning of these mysterious, sanitizer and disinfectant labels.

Until next time, be safe and stay well.

Best,

Ken    

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