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