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The U.S. Environmental Protection Agency has adopted and implemented a new process for labeling pesticide products, following "concerns regarding the possible use of sanitizer and/or disinfectant products to treat HVAC systems" due to confusion over the previous labeling system.
In a two-page letter addressed to the National Air Duct Cleaners Association, the director of the Office of Pesticides' Antimicrobials Division cautions against making "incorrect assumptions and about the status of ERA review and conclusions about [pesticides]."
"Products registered for use on hard, nonporous surfaces ... may not specifically be registered for use in HVAC systems," Frank T. Sanders notes. "The agency may not have received and reviewed adequate data to fully evaluate risks to humans" for HVAC uses of sanitizers and disinfectants. He says this applies even to those labels specifically including HVAC systems as a possible use.
In future EPA registration of pesticide products, the agency would "conduct a risk assessment to support the HVAC systems use for all new submissions," while prior registrants with possibly misleading labels would eventually be held accountable, according to Sanders. "We intend to work with pesticide registrants to make certain that these labels clearly communicate the uses which EPA has or has not authorized," he states.
In the letter, Sanders references me following 15 guidelines for the use of antimicrobial products in HVAC systems. Prefacing the list, the Antimicrobials Division states: "The following are elements to consider in using antimicrobial products to treat microbial contamination in HVAC systems."
1. The product must be registered with EPA. Look for an identification statement on the label that says "EPA Registration Number XXXX-XX"
2. Clear description of what microbes the product is intended to control and what level of efficacy will be achieved. Most products will likely claim bacteriostatic/fungistatic (inhibition of bacteria/mold) properties. Efficacy testing methods/performance standards/data are lacking to support public health claims such as sanitization.
3. Distinctly separate set of label directions set apart from any other use directions grouped placed under a heading such as Air Ducts or HVAC Systems or similar designations.
4. Directions to inspect the HVAC system first. Reference/directions as to how you inspect an HVAC system.
5. Label statements and directions limiting use of the product on HVAC systems/duct work or other HVAC system components that are in sound mechanical condition only.
6. Guidance as to conditions that suggest the need for repairs or possible replacement of the system and/or components.
7. Requirement that the HVAC system and assocaited components be clenaed prior to the application of the product.
8. Statement on the label advising that the product be used only in cases where visible microbial growth has been detected in the system and then only after removing that growth and identifying and correcting the conditions that led to the growth.
9. List of the HVAC components that can be treated. If duct work is included, then a list of the types of duct work such as bear metal ducts, flexible ducts, semi porous ducts with a descriptor and any other.
10. Use on lined duct work is likely not to be allowed due to efficacy concerns.
11. List and detailed description of application equipment, devices or other means of applying the product should be on the label.
12. Mixing instructions including dilution chart/table.
13. An application rate for each application method listed on the label that clearly describes how much area a gallon of product will treat.
14. Frequency of application needs to be addressed.
15. Reentry into treated rooms/buildings and drying time need to be addressed on a label.
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