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NHICEP Conference NH Hospital Association September 15, 2009 Cleaning Chemicals: Risk, Cleanliness Testing and EPA Regulatory Update Jack Fellman Greener Chemistry Associates LLC 1 Topics for Discussion Chemical Risk Assessment Model ATP Bioluminescence Test Method U.S. EPA Actions July 30, 2009 Regulatory Update-Antimicrobial Labeling Update (Joan Harrigan-Farrelly, Director) June 12, 2009 Pesticide News Story: antimicrobial Testing Program Web Page Now Available July 31, 2009 EPA Reaches Settlement with Nation’s Largest Manufacturer of Hospital Disinfectants; Company Agrees to Pay $550,000 in Penalties 2 Chemical Risk Assessment Model 3 GCA Cleaning Product Risk Assessment Considerations Health Environment Potential For Exposure of Personnel Storage & Handling Product Cost/Working Gallon Product Performance 4 GCA Cleaning Product Risk Assessment Objectives Reduce Health and Environmental risks Reduce potential personnel exposure Product upgrade should be cost neutral Increase usage of 3rd party certified products or better 5 What is a GCA Chemical Risk Assessment? A method to quantify the risk to personnel and the environment of using a chemical for a cleaning function A tool to facilitate the comparison of one product to another for the same potential use A lower number for the risk assessment indicates a safer chemical Water would have a GCA rating of zero 6 Criteria for GCA Risk Assessments The Globally Harmonized System of Classification and Labelling of Chemicals (GHS) EPA/s Design for the Environment (DfE) Green Seal Certification Standards Health & Environmental Risk Assessment Project (HERA) Hodge and Sterner Scale for Toxicity Classes Arizona State University - Chemical Risk Assessment Form Tool (CRAFT) 7 The GCA Risk Assessment Process Steps 1. 2. 3. 4. 5. 6. Product is identified with the MSDS Hazardous ingredients are determined Risk assessments of individual hazardous ingredients are made Data for individual ingredients are combined to produce a product risk assessment Typical application data (i.e., 1 gallon/hour) is used to calculate and compare the estimated exposure to documented exposure limits (OSHA) Product cost and typical dilutions used to calculate cost/working gallon 8 Product is Selected Product name MSDS number Product codes Recommended use Manufacturer Concentrate or Ready to Use Dilution Ratio Estimated Usage per Hour 9 Hazardous Ingredients are Identified Chemical name(s) CAS Number(s) % Weight Concentration 10 Component Risk Assessments Hazards Health Physical Degree of Hazard Flash point Toxicity Aquatic Toxicity Risks Acute health effects Chronic health effects Exposure limits Exposure indicators Routes of exposure Physical form Vapor hazard ratio 11 Product Risk Assessment Example 12 Product Information Product Name: ABC MSDS #: Number Product Code: 123456 Cleaning Product 7/10/2009 Use: Concentrate or RTU: Concentrate Manufacturer: DEF 13 Hazardous Components & Summary of GCA Component Assessment Component: 1 2Total Ingredient: Benzyl Alcohol Ethanolamine CAS #: 100-51-6 141-43-5 Max in Product: 25% 7% GCA Health Hazard 8 30 GCA Physical Hazard 2 2 GCA Degree of Hazard 9 12 56 42 14 19 89 105 GCA Risks GCA Probability of Exposure GCA Product Risk Assessment 194.0 14 Component Risk Assessment Chemical Name: Hazards: Ethanolamine (2-aminoethanol) 141CAS # 43-5 Potential Actual 7/10/2009 Health Hazards Carcinogen 10 Corrosive 2 2 Irritant 2 2 Sensitizer 4 Toxic 2 Highly Toxic 4 4 15 Component Risk Assessment Target Organ Effect Liver 3 3 Kidney 3 3 Lymphoid system 3 Central nervous system 3 Blood forming organs 3 Respiratory tract 3 3 Lungs 3 3 3 16 Component Risk Assessment Reproductive toxin Teratogen 4 Mutagen 4 Skin 3 3 Eyes 4 4 Total Health Hazards 30 17 Component Risk Assessment Physical Hazards Combustible Liquid 2 Flammable 3 Oxidizer 4 Total Physical Hazards: 2 2 18 Component Risk Assessment Degree of Hazard: Flash Point (oF) >200 0 150-200 1 100-150 2 1-100 3 <0 4 1 19 Component Risk Assessment Oral, rat LD50 (mg/kgbw) >15,000 0 5,000-15,000 1 500-5,000 1,720 2 50-500 3 1.0-50 4 <1 5 2 20 Component Risk Assessment Inhalation, mouse LC50 (ppm) >100,000 0 10,000-100,000 1 1,000-10,000 2,420 2 100-1,000 3 10-100 4 <10 5 2 21 Component Risk Assessment Skin, rabbit LD50 (mg/kg) >22,600 0 2,820-22,590 1 350-2,810 1,000 2 44-340 3 5.0-43 4 <5 5 2 22 Component Risk Assessment Corrosivity (pH) 6.0-9.0 0 5-6 or 9-10 1 3-5 or 10-12 2 1-3 or 12-14 3 <1 or >14 4 3 23 Component Risk Assessment Aquatic Toxicity-Acute (L/E/IC50) >100 ppm 0 10-100 ppm 1 1-10 ppm 2 <1 ppm 3 0 Biological Half-life minutes 0 hours 1 days 2 weeks 3 years 4 Total Degree of Hazards: 2 12 24 Component Risk Assessment Risks: Acute Health Effects Irritation 1 1 Sore throat 2 2 Coughing 2 2 Redness 2 2 Burning 4 4 Pain 4 4 Tearing 2 2 Stinging 2 Swelling 2 25 Component Risk Assessment Nausea 3 3 Vomiting 3 3 Diarrhea 3 Headache 2 Dizziness 2 Narcotic effect 3 3 Difficulty breathing 4 4 Convulsions 4 Sensitization 4 Death 2 20 26 Component Risk Assessment Chronic Health Effects Cancer 10 Teratogenesis 10 Mutagenesis 10 Exposure limits (PEL and TLV) >1,000 ppm 0 100-1,000 ppm 2 10-100 ppm 5 1-10 ppm <1 ppm Total Risks: 3 ppm TWA, 6 ppm STEL 10 10 20 42 27 Component Risk Assessment Probability of Exposure Indicators: Routes of Exposure Ingestion 1 Ingestion + Inhalation 3 Ingestion + Inhalation + Skin Contact 6 Solids, pellets 0 Liquids, granules 1 Mists 2 Vapors, fumes 3 6 Physical Form 1 28 Component Risk Assessment Boiling Point >400C 0 300-400C 1 200-299C 5 100-199C 170 C 10 0-99C 15 <0C 20 10 29 Component Risk Assessment Vapor Pressure (mm Hg @ 20C) <1 0.4 mm 1-10 0 0 2 11-100 10 101-760 20 Vapor Hazard Ratio [(Vpress)(10E6)/760]/TLV or PEL (Arizona State Un.) <10 0 10-1,000 2 1,000-10,000 5 10,000-100,000 10 >100,000 20 Total Probability of Exposure: GCA Material Rating 2 19 105 30 Exposure Risk Determination Exposure Risk: Components in 1 ml of concentrated cleaner: Benzyl Alcohol - 269 ppm Ethanolamine - 75 ppm Dilution to working strength: 1 parts cleaner diluted with 4 parts water to 20% concentration Components in 1 ml of diluted cleaner: Benzyl Alcohol - 54 ppm Ethanolamine - 15 ppm 500 mls in 15 minutes (33.3 Typical usage: mls/min.) Potential Exposure: 1,800 ppm/min. 500 ppm/min. Permitted Exposure Level: 10 ppm 3 ppm TWA/6 ppm STEL Exposure Assessment: Expected: 2 Hour* usage>>> PEL Target: 2 Hour usage < PEL 31 Cost Assessment Cost Assessment: Container size: Price per container: 2 Liters Dilution: Cost/Working Gallon: Dilute 1:5 $25.00 $9.47 32 ATP Bioluminescence Test Method 33 How Clean Is It? Visual assessment is not adequate Testing for microorganisms is better Testing takes a relatively long time – not relevant to a “re-clean” possibility if results are not acceptable Testing requires laboratory facilities and skilled personnel A new rapid test method must be quick, sensitive and capable of detecting unacceptable cleaning performance Bioluminescence test for adenosine triphosphate (ATP) has been developed for this need 34 C. Ramsay, Biotrace International July 29, 2003 What is ATP and how do we measure it? ATP is contained in the nucleus of microorganisms 1947 bioluminescence first reported using the enzyme/substrate of firefly (luciferase/luciferin) to detect ATP Methods developed to provide a linear relationship between luminescence intensity and ATP concentration Reagent chemistry and portable instrumentation refined for a rapid test 35 Reaction for Light Measurement Luciferin + Luciferase + ATP + Mg++ -> (Luciferin-Luciferase-AMP) + Pyrophosphate (Luciferin-Luciferase-AMP) + O2 -> Oxyluciferin + Luciferase + CO2 + AMP + Light 36 New Portable Cleaning Test System The New Portable Cleaning Test System is a tool to help healthcare professionals address the question, “How can I feel comfortable a surface has been properly cleaned?” The technology of ATP bioluminescence is an accepted method for protein detection and it has been made portable with “real time results”. In only 30 seconds, a quantifiable result is available to provide “peace of mind” or to “initiate corrective action”. 37 How does it work? Swab without ATP is pre-moistened Swab is wiped across a surface, approximately 4” x 4” in area Contaminated swab is placed in contact with luciferin/luciferase reagents Swab is then placed in the portable luminescence meter Readings in Relative Light Units (RLUs) are available in 30 seconds 38 How long can contaminated swabs be held before analysis? Up to 4 hours The contaminated swab can be placed back in the packaging tube and taken with other samples to a “workstation”, if preferred 39 Is monitoring hospital cleaning practices with New Portable Cleaning Test system “effective”? Study by Boyce, et. al., Hospital of Saint Raphael and Yale University School of Medicine Conclusions: The ATP bioluminescence assay method of the study gave quantitative assessment of cleanliness The ATP method can be used for training purposes The ATP method can provide feedback in “real-time” Digital readings with data analysis software provide data tracking 40 How does the New Portable Cleaning Test System compare to other methods for “sensitivity”? Independent study by Simpson and Giles, Cara Technology, Ltd (2006) “Protocol for assessing the sensitivity of hygiene test systems for live microorganisms and food residue”. Conclusions: The New Portable Cleaning Test System has better sensitivity to low level contamination and repeatability for food residues and microorganisms. A similar instrument produced almost 60% false negatives based on the samples tested: serial dilutions of Staphylococcus aureus, Citrobacter freundii, Zagosaccharomyce bailiis, Yeast extract and Yogurt drink, with manufacturer recommended pass/fail limits, for each dilution level. 41 How does the New Portable cleaning Test System compare to other systems for “repeatability”? Independent study by Simpson and Giles, Cara Technology, Ltd (2006), “The repeatability of hygiene test systems in measurement of low levels of ATP”. Conclusions 30 tests on each of 4 different systems, concluded that the New Portable Cleaning Test System had the lowest Coefficient of Variation (%CV) and was more repeatable. %CV = 7.4, 38.1, 58.7, 89.4 42 Features/Benefits of New Portable Cleaning Test System Features Benefits Consistent, measureable results Reliable results to confirm cleaning effectiveness Real time proactive solutions To implement immediate corrective actions and assure surfaces are clean Ease of use (swabs) Reduces variability between users Ease of use (instrument) Reduces errors, training time and costs Data management Track results of cleaning effectiveness over time with statistical control 43 Field Experience with the New ATP Test System One local user reported a decrease in MRSA cases from about 9 per month to 2 per month, since they started using the New ATP Test System 44 “Infection Control QA in the Patient Care Environment using ATP Bioluminescent Technology” Mark Gallivan, Un of Minnesota Sampling To compare the RLUs of occupied vs discharged patient rooms Location 4 Different Wards Bone marrow transplant Neurology Solid organ transplant Medical intensive care Surfaces 610 Samples 5 Different Surfaces Bedrail Keyboard Treatment cart Bathroom door knob Toilet flush handle 45 “Infection Control QA in the Patient Care Environment using ATP Bioluminescent Technology” Mark Gallivan, Un of Minnesota Mean RLU Values Surfaces Bedrail Occupied Median RLU Values Discharged Occupied Range RLU Values Discharged Occupied Discharged 1287 458 363 142(37-26,825) (57-6,891) Keyboard 223 238 111 71(15-6,911) (15-5,642) Treatment Cart 399 309 129 104(20-4,571) (20-4,280) Door Knob 608 445 379 282(56-6,640) (25-2,949) Toilet Flush Handle 422 856 194 126(14-3,458) (21-27,896) 46 “Infection Control QA in the Patient Care Environment using ATP Bioluminescent Technology” Mark Gallivan, Un of Minnesota Sensitivity High Variability Capable of achieving p < 0.05 results Comparability of Surfaces Data skewed to the right from high outliers Real Time Monitoring of Protocol Capable of detecting clean and unclean surfaces Not valid due to surface area and type Creation of Baseline RLU Values Should be created for individual surfaces 47 U.S. EPA Actions 48 Antimicrobial Labeling Update From U.S. EPA July 30, 2009 Presented by: Joan Harrigan-Farrelly, Antimicrobial Div. Director Dennis Edwards, Chief, Regulatory Management Branch 1, Antimicrobials Division Ben Chambliss, Microbiologist, Antimicrobial Div. Tajah Blackburn, Team Leader, Efficacy Team, Product Science Branch, Antimicrobials Division 49 Presentation Overview How EPA regulates Antimicrobials How EPA ensures product efficacy for hospital disinfectants Overview of EPA’s Antimicrobials Test Program Availability of Information on the Antimicrobial Program Antimicrobial Division’s Hospital Community Outreach Initiative How can AD best communicate with hospital community and maintain an open forum for future discussions? 50 How AD Ensures Product Efficacy for Hospital Disinfectants Product Performance Laboratory studies are submitted by the registrants to demonstrate that their product will perform against target pests (microorganisms) when the product is used according to label directions Studies are conducted using standardized tests, usually from the AOAC International Hospital disinfectants must demonstrate effectiveness against: Staphylococcus aureus Salmonella enterica Pseudomonas aeruginosa Using: AOAC Use-dilution Test Germicidal Spray Products Test or EPA Towlette Test 51 Overview of the AD Testing Program 52 Antimicrobial Testing Program Web Page Now Available Current as of June 12, 2009 Program overview Testing results What if a product fails? Product universe Collection of products How tests are performed Next steps 53 Program Overview Antimicrobial Testing Program (ATP) started testing hospital sterilants, disinfectants and tuberculosides in 1991 EPA collects samples from manufacturers or other places Test methods are rigorous challenge with bacteria levels at least 1,000 times greater than typical contamination levels found in healthcare facilities Current focus is on “primary” registration of each product formulation 54 Program Overview Manufacturers often contract with distributors, who then register products with identical formulas Current results: About two-thirds of hospital disinfectants and one-half of tuberculocides are fully efficacious when challenged at the highest bacteria challenge level Those that do not meet this high standard are brought into compliance through regulatory or enforcement measures, or a combination of both. Continuing efforts to complete testing the initial group of products and developing long term strategy for continued oversight of both the primary products and the larger group of distributor products 55 Testing Results Products tested through the ATP (pdf available) 325 hospital disinfectants (~218 met standards) 72 tuberculocides (~36 met standards) Tuberculocides must be effective also against mocobacterium bovis BCG 56 What If a Product Fails? EPA will determine the appropriate action: Product reformulation and retest by mfgr Removal of Hospital Disinf or TB claims from label Modification of label directions, i.e., contact times, and retesting by the mfgr following new directions Voluntary cancellation of product by mfgr EPA initiates removal of product from market place (e.g. stop sale orders) 57 Product Universe 1991 ATP initiated 1993 Tuberculocides Hospital disinfectants Sterilants Sterilant testing completed 1996 Regulatory authority for certain liquid chemical sterilant products transferred to FDA under Food Quality Protection Act amendments to FIFRA. 58 Collection of Products In the past: Collection by official federal or state inspectors Present: Collection Internet purchases Direct shipment from registrant Purchase from marketplace December 2008 EPA letter to primary registrants requesting samples be sent directly to their laboratories for testing. This form of sampling only for completion of initial testing EPA expects to return to random testing of products after initial testing is complete 59 How Tests are Performed Product registration & post-registration Specific methods for testing effectiveness maintained and published by Association of Analytical Chemists (AOAC) International Challenge microorganisms: Staphylococcus aureus, Pseudomonas aeruginosa, and Mycobacterium bovis BCG Four laboratories do testing: Ohio Department of Agriculture/Consumer Analytical Laboratory North Carolina Department of Agriculture and Consumer Services Michigan Department of Agriculture/Laboratory Division EPA’s Office of Pesticide Program’s Microbiology Laboratory Branch 60 EPA’s Standard Operating Procedures for ATP Testing MB-02-03 Culture initiation, maintenance and Quality Control MB-02-04 Tracking of test microorganisms MB-03-04 Screening carriers used in disinfectant efficacy testing MB-04-05 Enumeration of bacterial inocula on carriers MB-05-06 AOAC Use dilution Method for testing disinfectants 61 EPA’s Standard Operating Procedures for ATP Testing MB-06-03 Germicidal Spray Products as Disinfectants: MB-07-04 Tuberculocidal Activity of Disinfectants: II. Confirmative in vitro Test for determining tuberculocidal activity MB-09-02 Disinfectant Towlette Test against Staphylococcus aureus and Pseudomonas aeruginosa MB-11-02 Neutralization Confirmation Assay for Disinfectant Products Tested against Mycobacterium bovis (BCG) MB-22-00 Disinfectant sample preparation 62 List of Products Tested or Pending Definitions Claims Tested: Hospital Disinfectant (HD) and or Tuberculocide (TB) Claims in Compliance: Label claim is in compliance with EPA Standards. NA indicates claim confirmation not applicable Product Voluntarily Cancelled: Product was voluntarily canceled by the registrant Claim Removed: Pathogen claim removed from product labeling Under Agency Review: Products tested, Agency action pending Voluntarily Submitted to EPA for Testing: Sample submitted by mfgr in response to EPA letter of request dated December 19, 2008 RTC: Retest claim due to issues with initial testing 63 Table Format (pdf) Sample Number: Registration Number: Registrant: Product Name: Claims Tested (HD) (TB): Yes or No Claims in Compliance (HD) (TB): Yes, NA, RTC Product Voluntarily Canceled: Yes, Blank Claim Removed: Blank, Removed hospital site, TB claim removed, HD/TB claims removed Under Agency Review: Blank, HD claims under Agency review, HD and TB under Agency review, TB under Agency review Voluntarily Submitted to EPA For Testing: Yes, Blank 64 Familiar Company Names 3M AIRKEM Professional Products Clorox Company ECOLAB JohnsonDiversey Spartan Chemical Company 65 3M Number Product Name Status 328 HB Quat Disinfectant Cleaner Concentrate Voluntarily Submitted 66 AIRKEM Professional Products # Product Name Claims Tested Claims in Status HD/TB Compliance HD/TB 275 A-33 Yes/No 0/NA HD under Agency Review 276 Omega Yes/No 0/NA HD under Agency Review 277 Asepticare 278 A-33 Dry Yes/No 0/NA 279 A-456-N Yes/No Yes/NA 280 A-464-N Yes/No Yes/NA Voluntarily Submitted HD Under Agency Review Product Voluntarily Canceled 67 Clorox Company # Product Name Claims Tested HD/TB Claims in Status Compliance HD/TB 170 Clean-Up Yes/No Yes/NA 171 Disinfecting Bathroom Cleaner 172 Ultra Clorox Yes/Yes Yes/Yes 173 Spruce-Ups Yes/No 0/NA 344 Disinfecting Spray 345 CPPC Everest 346 Germicidal Wipes Vol. Sub. 347 Germicidal Spray Vol. Sub. Vol. Sub. Agency Review Vol. Sub. Yes/No Yes/NA 68 ECOLAB # Product Name Claims Tested HD/TB Claims in Status Compliance HD/TB 86 MIKRO-QUAT Yes/No Yes/NA 87 Mikroklene Yes/No Yes/NA 88 D-QUAT II Yes/No Yes/NA 89 Oxonia Active Yes/Yes Yes/0 90 Quorum Cleaner Yes/No Yes/NA 91 Vortexx Yes/No Yes/NA 92 Multi-Quat Yes/No Yes/NA TB Claim Removed 69 ECOLAB (cont.) # Product Name Claims Tested HD/TB Claims in Compliance HD/TB Status 93 65 Disinf. HD Acid Bathroom Cleaner Yes/No Yes/NA 94 Octave FS Vol. Sub. 95 Exspor Base Conc. Vol. Sub. 131 ENVERROS Sanimaster 4 Yes/No Yes/NA 287 Exspor Base Conc. Yes/Yes Yes/Yes 288 LD Base Conc. Yes/No Yes/NA 70 JohnsonDiversey # Product Name Claims Tested HD/TB Claims in Status Compliance HD/TB 49 Quat 256 Yes/No Yes/NA 187 CREW NA Bathroom Cl Vol. Sub. 361 Disinf. DC100 Vol. Sub. 362 Phenolic Disin. HG Vol. Sub. 363 Blue Chip Germicide Cleaner for Hospitals Vol. Sub. 365 Envy Liq. Dis. Cl. Vol. Sub. 366 ALPHA HP Vol. Sub. 367 OXIVIR TB Vol. Sub. 368 Carpe Diem Conc. Five 16 Vol. Sub. Removed Hospital Site 71 Spartan Chemical Co. # Product Name Claims Tested HD/TB Claims in Compliance HD/TB 160 STERIGENT Yes/No Yes/NA 161 PD-64 Phenolic Base Cl&Dis Yes/Yes Yes/Yes 162 METAQUAT Germ. CLE Yes/No Yes/NA 163 SANI-T-10 Yes/No Yes/NA 164 TNT Tub & Tile Cleaner Yes/No Yes/NA 165 DMQ Yes/No Yes/NA 166 CDC-10 Yes/No Yes/NA 167 STERIPHENE II Deod. Yes/Yes Yes/Yes 168 FOAMY Q&A Yes/No Yes/NA 169 Green Sol. Rroom Cleanser Yes/No Status Vol. Sub. 72 Next Steps Goal is set for completion of post-registration evaluation of efficacy by end of 2011 EPA developing an ATP Strategy to include continued oversight of “primary” and “distributor” products Strategy and implementation plan scheduled for completion early 2010 and will be publicly available 73 EPA Reaches Settlement Release date: July 31, 2009 Region 2 (NY) Contact Information: Sophia Kelly (212) 637-3670, [email protected] Third pesticide enforcement case settled against Lonza Inc., the nation’s largest manufacturer of hospital disinfectants, for multiple violations of the federal law that regulates pesticides. Agreed to pay fines for allegedly making misleading claims regarding the efficacy of two products. Settlement (>$640,000.00) is one of the largest civil penalties under FIFRA. Company previously agreed to develop a supplemental ground-breaking environmental project, valued at $390,000.00. 74 EPA Reaches Settlement George Pavlou, acting EPA Regional Admin. said “It may surprise people to know that part of EPA’s job is to make sure disinfectants are as effective as they claim, and we take this job very seriously.” “Products that make claims that are not met put people at risk of getting sick. We are pleased that Lonza has agreed to not only pay penalties but to take steps that will go a long way toward rectifying the problem.” 75 EPA Reaches Settlement Products cited for inefficacy Saniphor No. 450, registered as Tuberculocide, but found ineffective against a bacteria causing Tuberculosis 7 Healthcare Disinfectant Neutral Cleaner, did not kill the pathogen Pseudomonas aeruginosa, as claimed on the label Klear Guard Tub & Tile Foaming Germicidal Cleaner, cited as misbranded for use of label with missing first aid information 76 EPA Reaches Settlement Lonza has already begun its project to institute rigorous quality assurance and product efficacy testing at more than 470 formulators of Lonza products nationwide. This will help ensure that the products sold are effective and provide public health protection. 77 Feedback to EPA’s Healthcare Outreach Launch? 1. 78 Questions??? Thank You!!! 79