PPB November 2020

efficacy, and the manufacturer’s proscribed environment for usage based on guidelines established under FIFRA. Products labeled, packaged or marketed with claims to kill, control, repel, mitigate, destroy or reduce a pest, germ or microbe are considered to be or to contain a pesticide subject to EPA regulations and registration requirements. The EPA distinguishes between those antimicrobial pesticides intended to address needs in a public health setting and those that do not. Both categories require products to be labeled with application instructions for effective usage and first aid instructions in case of accidental exposure. • Public health antimicrobials are intended to control germs infectious to humans in an inanimate environment. These products include sterilizers, disinfectants and sanitizers. Hospitals, schools, other institutions, industrial settings such as food processing facilities and homes rely on these products in their cleaning regimens to contain the spread of a range of infectious microorganisms, including COVID-19. • Non-public health antimicrobials are intended to inhibit growth of microbes that cause aesthetic or economic harm. Examples include algae, odor-causing bacteria, and microbes that result in spoilage of materials including, but not limited to, textiles, paints and jet fuel. Products that control a pest, germ or microbe through a physical or mechanical action can also be labeled as antimicrobial. These products, considered to be devices, are not subject to EPA regulation. (Examples of promotional products that kill microbes include a UV case for sanitizing cellphones or an air purifier.) Some products treated with an antimicrobial are expressly exempt from FIFRA’s registration requirements. Many promotional products for which antimicrobial claims are made fall within this last category. Examples of Treated Product Antimcrobial Claims For Mold- or Mildew- Resistant Claims: For Odor- Resistant Claims This article has been treated with a fungistatic agent to protect the product from fungal growth. This product contains an antimicrobial agent to control odors. Mildew-resistant - Extends useful life of article by controlling deterioration caused by mildew. This product contains an antimicrobial agent to prevent microorganisms from degrading the product. The fungistatic agent in this article makes it especially useful for resisting deterioration caused by mildew. Resists odors - This product has been treated to resist bacterial odors. Article treated to resist deterioration by mold fungus. Inhibits the growth of bacterial odors. Provides mildew- resistant coating. Resists microbial odor development. Retards the growth of odors from microbial causes. Guards against degradation from microorganisms. Reduces odors from microorganisms. Odor-resistant. Acts to mitigate the development of odors. Figure 1 Christoph Burgstedt / Shutterstock.com Products labeled, packaged or marketedwith claims to kill, control, repel, mitigate, destroy or reduce a pest, germormicrobe are considered to be or to contain a pesticide subject toEPA regulations and registration requirements. | NOVEMBER 2020 | 65 THINK