16 replies to this topic

[TimG]

Was reading through some compliance emails this morning. Topic was using disinfectants on surfaces this cold/flu season safely:

 

Disinfectants used on surfaces are classified as pesticides and are regulated by both MDARD and the U.S. Environmental Protection Agency (EPA).

 

SQF 11.6.4.2 v:

Designed such that pesticides, rodenticides, fumigants, and insecticides are stored separately from sanitizers and detergents

 

It is a sanitizer. And according to MDARD/EPA it is also a pesticide. 

 

Janitorial staff are trained; the disinfectant is locked up (controlled) and inventoried. I'm not moving it into the super lockdown ant bait cabinet.

 

But it is a new bit of info I didn't know prior to this morning.

 

 

[MDaleDDF]

I didn't know that, never gave it a thought, but I suppose it makes sense.   Killin bugs is killin bugs.....

[Scampi]

hmmmmmmmmmm   isn't the product TYPE determined by the label?

[GMO]

There is a bizarre thing in the EU on this.  When the rule came in around MRL for quaternary disinfectants, it wasn't due to it being a disinfectant, it was because they can ALSO be used as pesticides.

 

So all the changes in plants to change to different disinfectants were to avoid contamination which would be unrelated to the use they were being controlled for. 

 

Well exactly...

 

I got on my ranty high horse about it a lot of times.  I confidently forecast that Listeria rates would shoot up.

 

Reality?  I was pretty wrong.  Some places did a crappy job and ended up with issues but whose to say they wouldn't have anyway?

 

So I'm wondering if it's something similar.  Some of these disinfectants CAN be pesticides but that's not the purpose of their use in this space and it would do you more harm than good to store them with rodenticides (albeit why are you storing rodenticides, insecticides etc on site?)

[Setanta]

We have sanitizing wipes (Alpet) throughout the facility. Do these fall into this...because, rut roh.

 

Also experiencing deja vu over this.

[TimG]

I'll go ahead and post the whole email I guess, because there was something else in there that interested me. 

Disinfectants used on surfaces must have an EPA registration number on the label, indicating they are proven effective against the viruses or bacteria listed or similar ones. 

 

Uhh, I don't verify that..

 

Anyway, this email seems geared toward home users, but MDARD does my FDA food safety inspections, so I'm keeping this info on my radar. Of course, non-Michiganders probably have your own state version since EPA is also listed:

 

For immediate release: October 9, 2025

Media contact: Lynsey Mukomel, 517-290-1734

MDARD Reminds Michiganders to Use Disinfectants Safely This Cold and Flu Season

Follow these tips from MDARD’s Experts to Help Protect Your Household

LANSING, Mich. —  As colder temperatures set in and cold and flu season begins, the Michigan Department of Agriculture and Rural Development (MDARD) is reminding Michiganders to use disinfectants safely and responsibly to help prevent the spread of illness. 

Disinfectants used on surfaces are classified as pesticides and are regulated by both MDARD and the U.S. Environmental Protection Agency (EPA). Before using any disinfectant, MDARD urges consumers to:

• Read the label to ensure the product is effective against the bacteria and virus that can make people sick. 

• Follow all label directions carefully.

• Confirm the type of surface or area you plan to disinfect is listed on the product label.

• Use personal protective equipment when directed by the label.

• Apply the disinfectant to the surface or area for the length of time provided on  the label. 

• If specified on the product label, rinse food-contact surfaces with water that is safe to drink after applying the disinfectant.

When using and storing disinfectants:

• Never apply disinfectants to skin or ingest them.

• Do not combine or mix different cleaning products.

• Keep containers sealed and out of reach of children and pets when not in use.

• Always wash your hands with soap and water after using disinfectants or disinfectant wipes.

• Keep people and pets away from treated surfaces until dry.

• Routinely disinfect high-touch surfaces and handle waste responsibly.

Viruses, bacteria, and other harmful microbes often linger on high-touch surfaces such as shopping cart handles, doorknobs, and cell phones. While frequent handwashing remains the best defense, disinfectants can provide an important second layer of protection.

Disinfectants used on surfaces must have an EPA registration number on the label, indicating they are proven effective against the viruses or bacteria listed or similar ones. In contrast, products for use on human skin, like hand sanitizers and antiseptic wipes are not considered pesticides, though label directions should still be followed.

MDARD’s Pesticide and Plant Pest Management Division (PPPM) is responsible for regulating the sale, use, and disposal of pesticides in Michigan, ensuring they are used safely and in accordance with state and federal laws. This work plays an important role in supporting public health and ensuring the people of Michigan have the resources necessary to protect themselves against the spread of illness.

For more information about safe disinfectant use, visit: https://npic.orst.edu/videos/‌aapcc-chat.html. 

.

###

[Lynx42]

The disinfectant we use mentions it's a pesticide only in the disposal section and it's listed as a fungicide on the front of the label.  We are not using it as a pesticide and have never had an issue. 

Pesticides have different disposal requirements once they become "waste."  My last warehouse (non-food) was filled with product that was not hazardous during any shipping or storage if it was whole and sellable.  As soon as a case or bottle was damaged and set for disposal it had to have a hazardous waste label on it and the truck picking it up had to have the proper placards on it. If we were sending it back to the manufacturer to recoup, not hazardous, sending it to be incinerated or "placed in the ground", hazardous.  

[Scampi]

I read the link                that looks like MRAD added a red herring by calling disinfectants pesticides when by there very nature, bacterium are not "pests" 

 

what a mess!!!

 

What you posted also speaks SPECIFICALLY to public health, which would be restaurants, day cares, hospitals etc.......are you governed by public health at all?  If not, I suggest a big ol disregard

[TimG]

I read the link                that looks like MRAD added a red herring by calling disinfectants pesticides when by there very nature, bacterium are not "pests" 

 

what a mess!!!

 

What you posted also speaks SPECIFICALLY to public health, which would be restaurants, day cares, hospitals etc.......are you governed by public health at all?  If not, I suggest a big ol disregard

Eh, it's not going to be a full disregard. But it's going into my MDARD email file and that's it. I'm not changing anything right now in my FSQS based on this and mostly wanted to put it out there as a 'what the heck, did anyone else know this?' post.

 

Of course, I was half expecting replies like "uhh, yeah dummy didn't you know that? All the cool kids lock their lysol in with their rodenticide!" 

[SQFconsultant]

Classification is in process to be changed/eliminated.

[Lynx42]

Eh, it's not going to be a full disregard. But it's going into my MDARD email file and that's it. I'm not changing anything right now in my FSQS based on this and mostly wanted to put it out there as a 'what the heck, did anyone else know this?' post.

 

Of course, I was half expecting replies like "uhh, yeah dummy didn't you know that? All the cool kids lock their lysol in with their rodenticide!" 

 

To be honest, I would not have noticed this on our stuff if I didn't have a background in hazardous waste disposal.

[jfrey123]

I didn't know this OP.  Too bad we can't go verify the EPA definition of pesticide as the website is currently non-functioning:  www.epa.gov

 

Common definitions of pesticide don't include sanitizers designed to kill germs or pathogens, so I'd be happy to argue the definition of pesticide all day long with an auditor if they decided to go down this rabbit hole.  

 

Now, for the sake of steel-manning this weird Michigan/EPA potential definition that I disagree with, one might speculate there is a difference between food contact and non-food contact surface sanitizers.  There's a reason we don't treat FC equipment with Lysol, despite its claimed 99.9% effectiveness.  But ultimately, we as an industry need to treat chemicals the way they are labeled.  Following GMO's comment regarding quat sanitizers can ALSO be used as pesticides, I dare say gasoline is an incredibly effective pesticide but should remain regulated as a fuel.

Edited by jfrey123, Yesterday, 04:06 PM.

[GMO]

As an aside... It wasn't until I did my SUSSLE* training that I found out just how ineffective some disinfectants are against spore formers. Worth a look sometime and strictly speaking should be part of your HACCP validation but it's SO easy to just assume that most disinfectants will be effective against most bacteria and viruses right?  Nope.  It really varies.


(*Life extension beyond 10 days for chilled foods about C. bot. risk, we're really anally retentive about that in the UK.)

[kfromNE]

Scampi is right - it's meant for the general public. Plus daycares, mom and pop businesses, etc. I taught restaurant food safety and nutrition education to childcare providers - this is exactly their audience. 

 

Why it falls under the category of a pesticide - odd. It must be because of the type of product/definition - which we could go down a rabbit hole with. My favorite example. The difference between a open faced sandwich and closed sandwich - different federal jurisdictions. 

[Scampi]

EPA website contradicts themselves

 

What is a Pesticide?

 

Pesticide law defines a “pesticide” (with certain minor exceptions) as:

• Any substance or mixture of substances intended for preventing, destroying, repelling, or mitigating any pest.
• Any substance or mixture of substances intended for use as a plant regulator, defoliant, or desiccant.
• Any nitrogen stabilizer.

https://www.epa.gov/.../what-pesticide

[Tony-C]

Sounds like a whole load of baloney  

 

Take Hydrogen Peroxide which can be used as a disinfectant and breaks down into water and oxygen, so nothing nasty left behind at all. Is that a pesticide? 

 

Regards,

 

Tony

 

 

 

 

[GMO]

Following GMO's comment regarding quat sanitizers can ALSO be used as pesticides, I dare say gasoline is an incredibly effective pesticide but should remain regulated as a fuel.

 

I have to admit I didn't question this explanation but I assume they are actually effective albeit rarely used against a certain type of pest (actually a crawling, living pest not a bacterium) but their main use is disinfection.

 

Much like biology will state a tomato is a fruit but common sense will suggest not putting it in a fruit salad.