Workplace procedures and educational materials should incorporate terminology from relevant agencies, including CDC, EPA, and the Food and Drug Administration in addition to OSHA. At the very least, workers need to know which regulatory authority or authorities are appropriate for the task and where they can find clarification and other definitions that may help them understand critical information.  Let’s consider sodium hypochlorite as an example. Sodium hypochlorite, better known as bleach, is one of the most common workplace chemicals and has a variety of uses. When diluted to appropriate levels, bleach is used as a disinfectant in healthcare, remediation services, housekeeping, and disaster response. At high concentrations, bleach can be used as a pesticide. Workers in the food industry use bleach to sanitize food and equipment.

The labels of some FDA- regulated products will include “drug facts” along with terms such as antiseptic, antibacterial, and sanitizer. FDA’s regulatory requirements and guidance on usage for over-the-counter products will differ from products intended for use by healthcare professionals. In 2017, FDA provided clarification via updated guidance and regulation for healthcare and over-the-counter antiseptics for human use. FDA also regulates antiseptics used in veterinary medicine.  Determining whether a product is regulated by FDA as a cosmetic or a drug is sometimes difficult. For example, a skin moisturizer is classified as a cosmetic, but if the manufacturer claims that the product also provides protection from the sun, it can be classified as a drug, too. The use and labeling of such products must comply with the requirements for both cosmetics and drugs. If you are providing workers something classified as a drug, it is even more critical to ensure their use is per manufacturer directions; the product could interact with a user’s medications, for example. You might expect that FDA regulates soaps as cosmetics, since (like shampoos) they’re used for cleansing. But FDA does not regulate normal soap—that is, soap meant only for cleansing—at all. Where applicable, FDA uses the definition of soap from the Consumer Product Safety Commission. According to CPSC, a product is a soap when “the bulk of the nonvolatile matter in the product consists of an alkali salt of fatty acids and the product’s detergent properties are due to the alkali-fatty acid compounds, and the product is labeled, sold, and represented solely as soap” (21 CFR 701.20). FDA issued a final rule on safety and effectiveness of antibacterial soaps in 2016. See FDA for more information regarding the and such as . In addition to cosmetics and drugs, FDA regulates antimicrobials used in or on processed food as food additives; applied to raw agricultural commodities where food is prepared, packed, or held for commercial purposes; added to water in a food processing facility when the water is to contact raw agricultural commodities or processed food in some circumstances; and incorporated in objects that have a food-contact surface in specified circumstances. See FDA’s “” for more information, including a useful for determining whether FDA or EPA has regulatory authority for specific antimicrobial substances. When choosing a product, consider whether it is appropriate as a control for all likely physical states of a hazard. For example, many fungi types are often present in both spore and non-spore form, and have a variety of surface structures and treatment requirements. Often a sequence of  products or treatments will be necessary to achieve desired results; the removal of gross debris (“cleaning”) might be required before the product is applied. Other considerations when selecting products include the following: Different surface types often require different contact times. The product could degrade finishes and coatings on the treated surface; unfortunately, this may become apparent only after damage has become substantial enough to be noticed by the naked eye.  For example, consider a product that needs to remain wet on a surface for 10 minutes. Will the product remain wet for the whole 10 minutes after initial application, or will someone need to watch the area and reapply the product to maintain surface conditions for the duration? Some products may require ventilation or other controls to limit exposure. For example, will the product require respirator usage or impose different chemical storage needs than those already in place at the facility? Decontaminating is “the process of removing or neutralizing contaminants that have accumulated on personnel and equipment,” according to OSHA. Returning to our healthcare example, CDC’s “Guideline for Disinfection and Sterilization in Healthcare Facilities” uses OSHA’s definition for decontamination but defines “decontamination area” as an “[a]rea of a health-care facility designated for collection, retention, and cleaning of soiled and/or contaminated items.” Cleaning is often a critical step of physically removing gross debris, germs, dirt, and impurities from surfaces or objects before more thorough processes such as sterilizing, using sporicides, disinfecting, or sanitizing. In cleaning, a surfactant, such as basic soap and water, is commonly used to reduce infectious material on surfaces without necessarily killing it. Cleaning can be manual or mechanical (the use of ultrasonic devices is an example of mechanical cleaning). Some disinfection and sterilization processes require cleaning as a first step because organic matter on surfaces can interfere with those processes. When educating workers about a product, don’t rely on general information found online or even on your previous experience with the product—it may have contained a different concentration of the chemical in question, or the chemical formula may have changed. Safety Data Sheets won’t necessarily reveal everything workers need to know, either. Something as simple as the size of a product’s container can affect what is reported on the SDS. Consider the specific batch for the products in your facility when reviewing product information. If in doubt, contact vendors and the manufacturer for additional information—it may save you headaches down the line and help ensure that you’re complying with all regulations that pertain to your operation.   The author of the information herein is a federal government employee. The content is unrelated to official work and/or duties and does not necessarily represent any position or opinion of the government. thanks Bruce Donato, CSP, CHMM, CECD, of K&A First Aid and Safety Inc. in Gaithersburg, Md., for reviewing a draft of this article.  Send feedback to The Synergist.