How Bleach Is Regulated
The Occupational Health Branch of the California Department of Public Health has been working to educate users of disinfectants and sanitizers that these products are regulated by the EPA as pesticides. Therefore, we would like to correct a misrepresentation in the otherwise very informative piece “
Sources of Confusion
” [November issue]. The author stated, “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.”

Bleach (sodium hypochlorite), even at lower concentrations, is regulated as a pesticide, specifically an antimicrobial pesticide, for all of the disinfecting and sanitizing tasks listed above (see EPA’s web page “
What Are Antimicrobial Pesticides?
”). This is more than mere semantics: we recommend that organizations and workers treat disinfecting and sanitizing products as different and separate from cleaning products. This helps protect worker health by ensuring the use of the most appropriate products for the task at hand. In addition, pesticide labels, unlike labels for other products, are legally enforceable, and include the statement: “It is a violation of Federal law to use this product in a manner inconsistent with its labeling.” More information is available from the EPA
Justine Weinberg, MSEHS, CIH Occupational Health Branch, California Department of Public Health

The opinions expressed in letters to the editor are those of the authors and do not necessarily reflect the views of AIHA® or
The Synergist
®. Letters are published at the discretion of the editor and may be edited for clarity. Send letters to
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By the Numbers: Laboratory Chemical Safety Incidents, 2001–2018
” [November issue] references the tragic case of Sheri Sangji, who died in 2009 from injuries sustained in an accident while working as a lab assistant at UCLA. According to the article, 129 chemical safety incidents occurred in laboratories during the eight years before Sangji's death, and 132 incidents occurred in the ten years after her death. This comparison suggests virtually no difference in chemical safety at laboratories between the two periods. However, 129 incidents in eight years cannot be compared to 132 incidents in ten years. By normalizing the eight-year period to ten years (129/8x10=161), we arrive at a more useful comparison. As a result, there is an estimated drop of approximately 18 percent from the 10 years before to the 10 years after. There is a similar misrepresentation in “
By the Numbers: Combustible Dust Incidents, 2006–2017
” [December issue], which compares incidents, total injuries, and total fatalities over two time periods. Period one spans 25 years (1980–2005) and period two spans 11 years (2006–2017). The figure accompanying the article incorrectly suggests that there is a substantial drop in all categories. In fact, the presented count data cannot be compared because the time periods are different; there are different denominators. A much better approach would be to compare counts per year. According to the data presented in the article, 11.2 combustible dust incidents occurred per year between 1980 and 2005, and 9.5 occurred per year between 2006 and 2017—a decrease of 15 percent. The number of injuries per year fell from 28.7 in period one to 27.5 in period two, a 4 percent decrease. These numbers suggest a very different picture, with small decreases in the number of combustible incidents and injuries—although fatalities per year increased 13 percent (from 4.8 to 5.4). Also, I suggest showing scatter plots with trend lines, because individual years may drastically influence the results. I do like the “By the Numbers” articles, and I hope that
The Synergist
will continue publishing them.
Boris Reiss, PhD, CIH Assistant Professor The University of Arizona Mel & Enid Zuckerman College of Public Health

We recommend that organizations and workers treat disinfecting and sanitizing products as different and separate from cleaning products.