Reader Feedback, September 1998

WEAK BLEACH SOLUTION

It has been brought to our attention that in March of 1998, PCT printed an article called “Germ Warfare: Part 2.” This article contained information on protecting oneself from environ-mental pathogens. Though we support you in your efforts to provide sound information, you should be aware of some potential conflicts that may arise due to this article. Some of the suggestions in the article conflict with the requirements of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA).

Under FIFRA, any chemical that is sold or distributed for the control of a pest must be registered with the U.S. EPA. Bleach used in the context of a disinfectant falls in the category of a pesticide, but not all bleach-based products are registered as disinfectants with the EPA. Some bleach products are sold for bleaching purposes only. On page 76 of your article, one suggestion states that soaking gear in “an EPA-registered disinfectant or a weak bleach solution” is suitable for decontaminating equipment from pathogens. By making such recommendations, you are potentially putting individuals who use bleach-based products in a position to harm themselves or others. Without specific label instructions as to the concentration of the “weak bleach solution,” the user is unable to determine how much bleach is required for efficiency. Furthermore, your statement places companies that sell bleach-based products in the position of violating FIFRA. While it is not technically illegal under federal law to advocate the use of an unregistered chemical as a substitute for a registered pesticide, you may unwittingly contribute to a FIFRA violation if your information is referenced by a retailer, distributor or manufacturer. You should also be aware that it is unlawful to use a pesticide in a manner inconsistent with its label directions. Thus, any recommendation for use of a registered pesticide should conform with the manufacturer’s label.

Katherine Taylor
Senior Associate, Cross Media Division
U.S. Environmental Protection Agency
San Francisco, Calif.

INTER-AGENCY COOPERATION WOULD REDUCE CONTRADICTIONS

Having reviewed the comments of Katherine Taylor regarding the use of household bleach for decontamination of items potentially exposed to pathogens, such as hantavirus, I have the following comments.

First, the inclusion of that statement was taken directly from a Centers for Disease Control publication regarding hantavirus. In fact, several bulletins issued by the CDC make a similar recommendation. My article was an overview of the environmental pathogen issue as it relates to the pest control industry. It was not my intention to lead pest management professionals into a gray area that has not been clearly defined by the U.S. EPA. We in the pest control industry fully understand the registration issues of disinfectants. Although not registered with EPA as a disinfectant, household bleach, such as Clorox, does in fact state “disinfectant” on the label, although specific directions for such use are obviously not provided on the product label. It is common knowledge that hospitals, clinical laboratories and others use household bleach as a disinfectant for blood-borne pathogens.

Ms. Taylor’s letter clearly undermines the CDC recommendations which pest management professionals, in a high-risk occupation for hantavirus, have followed.

It would be of great assistance if the EPA could work with CDC in the future to ensure that industries, such as ours, do not inadvertently follow recommendations that may cross the boundaries of current law.

Stoy A. Hedges, B.C.E., R.S.
Terminix International
Memphis, Tenn.

Readers with comments are invited to write: PCT Letters, 4012 Bridge Ave., Cleveland OH 44113. Letters also can be faxed to 216/961-0364, or e-mailed to ljosof@gie.net. Letters may be edited for space or clarity.