The use of biocides and antimicrobial chemical products in the restorative drying industry is often a hotly debated topic. When querying students in classes, we find students who use antimicrobial products on every water loss and others who use them only occasionally. This article clarifies what biocides and antimicrobial products are intended to accomplish, discusses risk-management issues every restoration business needs to address and conveys the importance of complying with federal, state and local regulations when using these products.

Risk management

A risk assessment regarding the use of biocides and antimicrobials is essential for any restoration business. Divide the word biocide into its two components: "bio" means life and "cide" means destroy. There are numerous hazards that can result from improper or negligent use of biocides. This risk involves workers, occupants and other people who may enter the restoration site. Proper training and communications are essential. This is also known as a Hazardous Communications Program.

It is recommended that workers receive proper training not only in the use of personal protective equipment when using biocides and antimicrobials, but also in the communication to occupants of the building in which the biocides are used. Provide occupants with the label as well as the Material Safety Data Sheet (MSDS) and give written permission to the contractor to use the antimicrobial product in the building. It has further been suggested that contractors provide the Environmental Protection Agency (EPA) registration number of the product along with dilution ratios and application methods when invoicing for services involving antimicrobial pesticides.

Federal Insecticide, Fungicide, and Rodenticide Act

The EPA is charged with administering the (FIFRA). Within the EPA, there is a division that deals with antimicrobial pesticides. FIFRA has jurisdiction over any chemical product sold or distributed that is intended to destroy or control microorganism growth.

Basically, if a product makes claims or is intended to destroy or control microorganisms, it must be registered with the EPA, with only a few exceptions. Some commonly recognized terms that we will see in our industry are disinfectant, sanitizer or words that include the suffix "-cide" (meaning destroy or kill) or "-stat" (meaning to control or mitigate). These terms have legal definitions.

Types of antimicrobial pesticides

Antimicrobial products are divided into two categories based on the type of microbial pest against which the product works. Non-public health products are used to control growth of algae, odor-causing bacteria, bacteria that cause spoilage, deterioration or fouling of materials and microorganisms infectious only to animals. This general category includes products used in cooling towers, jet fuel, paints, and treatments for textile and paper products. Public health products are intended to control microorganisms infectious to humans in any inanimate environment. The more commonly used public health antimicrobial products include the following:

Disinfectants – Disinfectants are used on hard, inanimate surfaces and objects to destroy or irreversibly inactivate infectious fungi and bacteria but not necessarily their spores. Disinfectant products are divided into two major types: hospital and general use. Hospital-type disinfectants are the most critical to infection control and are used on dental and medical instruments, walls, floors, bed linens, toilet seats and other surfaces. General disinfectants are the major source of products used in households, swimming pools, and water purifiers.

Sanitizers – Sanitizers are used to reduce, but not necessarily eliminate, microorganisms from the inanimate environment to levels considered safe as determined by public health codes or regulations. Sanitizers include products for food contact and non-food contact. Sanitizers for surfaces such as dishes and cooking utensils, as well as equipment and utensils found in dairies, food-processing plants, and eating and drinking establishments comprise the food contact sanitizers. These products are important because they are used on sites where consumable food products are placed and stored. Non-food contact surface sanitizers include carpet sanitizers, air sanitizers, laundry additives, and in-tank toilet bowl sanitizers.

"-Cides" – Chemical products with the suffix "-cide," such as fungicide, virucide, bactericide or sporicide, indicate they destroy specific microorganisms when used according to label directions.

"-Stats" — Chemical products with the suffix "-stat," such as bacteriostat, fungistat or mildewstat, indicate they will suppress the growth of specific microorganisms when used according to label directions. "-Stats" means microorganism growth would be suppressed but will not necessarily kill or destroy targeted organisms.

Label components

The most important component in the use of antimicrobial pesticides is the label. All EPA-registered antimicrobial pesticide labels have legally prescribed components. The most important sections of the label are the "Warning and Precautionary Statements" and "Directions for Use" sections.

All EPA-registered antimicrobial pesticides include the statement: "It is a violation of Federal law to use this product inconsistent with its labeling." It is very important to clearly understand this statement. EPA-registered labels will generally specify "sites" or intended surfaces to which they can be applied.

Most antimicrobial pesticides will have in their directions for use the statement "for use on pre-cleaned, hard-surface non-porous materials." If you use such a product on a porous material like carpet, cushion, wood or drywall, you have violated Federal law and exposed yourself to significant liability. If you use EPA-registered products on porous materials, the instructions should be included in the label directions.

An important issue must also be addressed. The labels of EPA registered antimicrobial pesticides that are sold in concentrated form have directions for dilution. It is absolutely essential these directions be followed to the letter of the law. Not using measuring devices is not only a violation of federal law, but usually a waste of chemical product. Just like the cleaning products used in our industry, antimicrobial pesticides have been tested to work at various dilution ratios.

Education is key

EPA-registered chemical products can be useful and often necessary in the restorative drying process. When you use them, be sure you understand what the products are designed to do, make sure you communicate the necessary hazard information to your workers and clients and follow the label directions.

It is also beneficial to check with your state governmental agency that supervises antimicrobial pesticide registration. Each state has different regulations.

Sometimes, restorers will look for a stronger or more powerful chemical product. The effectiveness of products is generally based on the quality of the cleaning, source removal and drying performed. Stronger chemicals don’t always provide the solution.

And by all means get a copy of your industry standard, the IICRC S500. It is loaded with more details and good information. It prescribes a standard of care your customers deserve.

Wording the invoice

If you do use EPA-registered chemical products on a restoration project, you will certainly be invoicing your client for that service. Do not make any legal claims on your invoice. If you state you disinfected or sanitized something, you have made a statement about the end result of your service. It would be much better to state that you "applied a disinfectant or sanitizer" to a material, unless you have the surface tested by a third party post-remediation expert.

Get it clean and dry

The most important component in using a biocide or antimicrobial is probably not the chemical product used, but the efforts taken to get the water-damaged structure clean and dry. Most experts agree removing the organic load with hot water and a good quality restoration cleaning product followed by extraction to remove the waste are probably the most beneficial decontamination procedures. A thorough and rapid drying process would follow this.

In fact, the reference guide of our own industry standard, the IICRC S500, states: "However, biocide application in water damage situations may or may not be beneficial. Restoration specialists must consider many factors before using biocides."

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