:: BBJ NEWS ARTICLES

Dear IAQ Colleagues,

Attached below is a letter recently signed by Marcia Mulkey, Director of the Office of Pesticide Programs, outlining concerns the Agency has regarding the use of antimicrobial products (most often sanitizers and disinfectants) in heating, ventilation, air conditioning and refrigeration systems (HVAC&R). This letter is the first step in a series of actions to be taken by the Agency addressing the use of these types of products in HVAC&R systems. We anticipate that the next step will focus on outreach to the pesticide registrant community.

The Agency's main concern is the use of general purpose disinfectants and sanitizers in HVAC/R systems. Because HVAC/R systems are air conveyance systems, any product that is applied inside it will be transmitted to occupants of the conditioned space in the building. As a result, EPA has always been very cautious in assessing the potential exposure and risks to building occupants or applicators of products that are intended to be used in HVAC/R systems. Hard surface disinfectants and sanitizers that have not been registered by EPA specifically for use in HVAC/R systems have not met the necessary safety and effectiveness criteria for that intended use. There are very few registered products which actually include directions for this type of use.

There are many reasons for the letter. First, to inform the user community that a product labeled for a hard non-porous surface use does not include the HVAC system. Second, an HVAC use requires detailed use directions on how, when, and how much to apply. Third, a much more detailed exposure and risk analysis is needed for an HVAC use since large numbers of people could be potentially exposed to the chemical; and finally efficacy data may be required to show that the product can be delivered through out the system and will work.

From my experience in this work, let me clarify the status of BBJ Products relative to this letter. In meetings during the past several months, I have verified that our present label language on all three of our EPA registered products is accurate and in compliance with this new policy interpretation: 1) BBJ MicroBiocide (EPA Reg. # 67212-1) is specifically registered for use in air-conditioning systems and contains clear directions for such use in HVAC/R systems. Our customers can continue to use this product with confidence as in the past in regards to its safety and effectiveness in HVAC/R systems; and 2) BBJ Spray Disinfectant/Cleaner and 3) BBJ Mold and Mildew Remover (EPA Reg. # 1839-83-67212) are specifically formulated to disinfect hard, non-porous, inanimate environmental surfaces such as floors, walls, metal surfaces, stainless steel surfaces, porcelain, glazed ceramic tile, plastic surfaces, bathrooms, shower stalls, bathtubs, and cabinets and should continue to be used in accordance with their existing label directions. While BBJ Spray and BBJ Mold and Mildew Remover are registered as hard surface disinfectant cleaners, they should not be used on the interior surfaces of HVAC/R systems as that type of use is not included on the label directions.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF PREVENTION, PESTICIDES AND TOXIC SUBSTANCES

March 14, 2002

SUBJECT: Use of Disinfectants and Sanitizers in Heating, Ventilation, Air Conditioning, and Refrigeration Systems

The purpose of this letter is to bring to your attention several concerns that the Agency has regarding the possible use of sanitizer and/or disinfectant products, and possibly other types of antimicrobial products, to treat the surfaces of heating, ventilation, air-conditioning, and refrigeration systems (HVAC&R), typically as part of air duct cleaning. First, although the directions for use of most of these products permit use on hard, non-porous surfaces, such directions may not specifically include the use of the product in HVAC&R systems.

We are particularly concerned about this possibility because the Agency has not assessed the potential exposure and risks to building occupants or applicators from the use of these products in or on any surfaces that are part of HVAC&R systems in circumstances where the labels do not specifically authorize use in HVAC&R systems. Also, the Agency has not assessed whether such products are efficacious when used in HVAC&R systems. Therefore, users cannot assume that EPA registration of these products reflects any conclusions about their safety or effectiveness in this situation. Even in circumstances where labels do list HVAC&R systems as a possible use, we are concerned that the Agency has not received and reviewed adequate data to fully evaluate risks to building occupants or product efficacy in that use pattern.

An additional source of concern arises because some pesticide products also bear labels which identify the product as HVAC&R "cleaners," which could further increase the likelihood that users incorrectly make pesticidal use of such products or make incorrect assumptions about the status of EPA review, evaluation, and conclusions about them.

We believe that all these factors may contribute to possibly unlawful and/or uninformed use of these products, which could have implications for public health and safety and for consumer protection.

In the absence of adequate data and the associated review and evaluation of the registration process, use of these products in HVAC&R systems could lead to significant exposures in indoor environments with potentially unreasonable adverse effects. One indication of the potential scope of the problem is the fact that the National Antimicrobial Information Network has reported to us that it received about 150 calls related to the possible application of antimicrobial pesticide products in HVAC&R systems in a recent 18 month period.

We are writing to you because we believe you would share our concerns about the possibility that these products may be being used as pesticides in a manner not authorized by the label and not contemplated by the pesticide registration process. We also believe that you wish to ensure that these products are not being used in a manner which might be harmful to applicators and/or building occupants.

We recommend that you advise your members not to apply disinfectant, sanitizer or other antimicrobial products to treat HVAC&R systems if such product does not include specific directions for HVAC&R use. The Agency believes that it is important that you ensure that members of your association are not applying products to HVAC&R systems which are not registered for that use. We intend to further evaluate this use to determine the potential exposure and risks as well as the efficacy criteria which are required before pesticide products are registered to be used in HVAC&R systems.

We recognize that it is important to address the labeling of these products, and we intend to work with pesticide registrants to assure that these product labels clearly communicate the uses which EPA has (and has not) authorized. We also expect to assure that appropriate evaluations of risk and effectiveness accompany any authorized uses in these systems. However, we felt it was important to inform you of these issues promptly, without waiting for any further revisions of these product labels and the conditions for their registration.

We hope you will find this information of value to you and your company as part of your approach to serving your customers. Feel free to contact Tracy Lantz at (703) 308-6415 if you have any questions.

Sincerely,
/S/
Marcia E. Mulkey, Director
Office of Pesticide Programs
  

Mr. Baker's field of expertise is the control of contamination in air-conditioning and ventilating systems by mold, mildew and bacteria. He writes and speaks frequently about the efficacy, legal risks, and regulatory issues involved in various control strategies. He serves on ASHRAE Technical Committee TC 2.3, TC 2.4, TC 9.8, and Sampling of Airborne Particulate Concentration in Commercial and Residential Buildings GPC 17P. He also serves as a member of ASTM D22.06 (Indoor Air Quality) and is on the Board of Directors of the Indoor Air Quality Association and the Florida Public Health Foundation. Because HVAC applications encompass new uses from an U.S. EPA regulatory standpoint, Mr. Baker works closely with the EPA and industry groups, including serving as the chair of the IAQ committee of the Consumer Specialty Products Association, to help formulate policy in this area.

Bob Baker is Chairman and CEO of BBJ Environmental Solutions, Inc., a company specializing in providing clean air through environmentally responsible products, such as BBJ MicroBiocide , BBJ Micro Coil Clean , "FreshDuct Odor Eliminator ", and BBJ Mold and Mildew Remover™ as well as the revolutionary new Power Coil Clean™. For additional information, Mr. Baker can be reached at (800) 889-2251 or through the company web site at http://www.bbjenviro.com.