tal sustainability has also become a major decision-making criterion and more envi-ronmentally preferable disinfectant tech-nologies have become available, the EPA has yet to adopt a similar policy for the cat-egorization or identification of products based on their environmental preferability. In fact, the EPA currently prohibits the use of any claims of environmental prefer-ability, including the use of eco-labels, in relation to any hard, non-porous surface disinfectants or sanitizers. But, why? The dictionary defines disinfectant as a noun meaning: Any chemical that destroys vegetative forms of harmful microorgan-isms — such as bacteria and fungi — espe-cially on inanimate objects. This simple definition has caused many policymakers to believe that environmental sustainability or preferability of a disinfec-tant is simply a chemical impossibility. If it kills pathogenic microorganisms such as bacteria, whatʼs to say the chemical wonʼt kill other non-threatening life forms? In reality, this is true of most legacy disin-fectant chemistries, including quaternary ammonium compounds. aquatic invertebrates and fish. Their EC50/LC50 (concentration in water that is lethal to 50 percent of organisms) has been shown to be below 1 PPM. It is these characteristics exhibited by QACs and other legacy disinfectants — chemistries that are used ubiquitously in a number of industries — that perpetuate the thought that disinfectants cannot, and will not, be environmentally preferable. However, exciting new technologies and chemistries that exhibit true environmental sustainability and preferability are currently being developed and commercialized. Unfortunately, there are simply no poli-cies currently in place at the EPA to recog-nize their superior attributes. made about a productʼs so called green characteristics. Bill Balek, director of Legislative Affairs for the International Sanitary Supply Association (ISSA), is part of this work group and notes, “EPAʼs announcement of the Internal Pilot is a positive step forward in developing an Agency policy that mesh-es with the demands of todayʼs greener marketplace.” Potential Impact Although the implementation of this pilot and the development of the working group are simply the initial stages in the possible revision of the EPAʼs current policy, these first exploratory steps clearly represent those in the right direction. Should the pilot bring forth recommenda-tions for change and the allowance of vali-dated green claims granted by the Agency, the potential impact on the industry could be considerable. The current situation finds decision-mak-ers in many industries searching for disin-fectant products that offer a favorable and sustainable environmental profile. Regrettably, the lack of regulatory over-sight, combined with the development of elaborate marketing campaigns making claims of environmental preferability with-out substantiation, is causing a confusing landscape for consumers and end users. Many industry insiders refer to this as “greenwashing” and it can present itself in many different forms. With the implementation of a formal reg-istration and validation process, the indus-try decision-makers will no longer be forced to wade through the mire of smoke and mir-rors marketing to uncover the true environ-mental profile of a disinfectant. The result will undoubtedly be the emer-gence of products that are successful in finding the balance between efficacy, safe-ty and environmental sustainability without compromise. With pathogenic outbreaks no longer only a health care concern, infection control has gone mainstream, infiltrating our schools and workplaces. Disinfectant use is on a dramatic rise and everyone will benefit from the use of green-er product choices once credible certifica-tion exists. CM So What, If Anything, Is Being Done To Change This? Not a moment too soon and no doubt as a result of significant consumer pressure, the EPA, in conjunction with the Agencyʼs own Design for the Environment Formulator Program (DfE), recently conducted an “Internal Pilot” into a potential policy change that would allow claims of environ-mental preferability in regard to hard, non-porous surface disinfectants and sanitizers. The intent of the “Internal Pilot” was to generate a greater understanding for both the DfE scientists and the Antimicrobial Registration Review staff as to what is involved in a review of environmental preferability and how that could ultimately be incorporated into the antimicrobial/disin-fectant registration process. Under this initial pilot program, both DfE and Office of Pesticide Program (OPP) staff evaluated products previously recognized under current DfE programs. From this evaluation, the scientists will consider any modifications to criteria or to the actual process of reviewing environ-mental attributes. At the completion of the “Internal Pilot,” if the EPA perceives benefit in the continua-tion of such a program, the Agency antici-pates the launch of an “External Pilot” that would presumably involve the participation of industry-leading companies and experts. The EPA has also established a working group that will serve to develop options for further consideration, including an approach in which factual claims could be Legacy Disinfectants: Quaternary Ammonium Compounds (QACs) QACs are cationic, or positively charged, surfactants that act as disinfectants when used at the appropriate concentration. They are also widely recognized as hav-ing an unfavorable overall environmental profile. Although they are eventually biodegrad-able under aerobic conditions, they show no or very poor primary biodegradation and no evidence of any extent of ultimate biodegradation under anaerobic conditions. Furthermore, the presence of QACs may also decrease the biodegradation of other surfactants. It has also been found that cationic sur-factants (QACs) are more toxic than anion-ic, or negatively charged, and non-ionic surfactants. The Median Effective Concentration (EC50) of most quats is below 1 part per million (PPM), meaning the biological activ-ity of QACs is very high. As a result, QACs are acutely toxic to www.cmmonline.com 21
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