&EPA
         United States
         Environmental Protection
         Agency
          Office of Chemical Safety and
          Pollution Prevention
          (751 OP)
EPA712-C-07-005
September 4,2012
Product Performance
Test Guidelines
OCSPP 810.2000:
General Considerations
for Uses of Antimicrobial
Agents

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                                     NOTICE
      This guideline is one of a series of test guidelines established by the Office of
Chemical Safety and Pollution Prevention (OCSPP) (formerly the Office of Prevention,
Pesticides and Toxic Substances (OPPTS) prior to April 22, 2010), United States
Environmental Protection Agency for use in testing pesticides and chemical substances to
develop data for submission to the Agency under the Toxic Substances Control Act (TSCA)
(15 U.S.C. 2601, et seq.), the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)
(7 U.S.C. 136, et seq.), and section 408 of the Federal Food, Drug,  and Cosmetic Act
(FFDCA) (21 U.S.C. 346a), referred to hereinafter as the harmonized test guidelines.

     The harmonized test guidelines serve as a compendium of accepted scientific
methodologies and protocols that are intended to provide data to inform regulatory decisions
under TSCA, FIFRA, and/or FFDCA. This document provides guidance for conducting
appropriate tests, and is also used by EPA, the public, and the companies that are subject to
data submission requirements under TSCA, FIFRA and/or the FFDCA. At places in this
guidance, the Agency uses the word "should." In this guidance, use of "should" with regard
to an action means that the action is recommended rather than mandatory. As a guidance
document, these guidelines are not binding on either EPA or any outside parties, and the EPA
may depart from the guidelines where circumstances warrant and without prior notice. The
methods contained in this guideline are strongly recommended for generating the data that
are the subject of the guideline, but EPA recognizes that departures may be appropriate in
specific situations. You may propose alternatives to the methods recommended in these
guidelines, with your supporting rationale. The Agency will assess such proposals on a case-
by-case basis.

     For additional information about OCSPP harmonized test guidelines and to access the
guidelines electronically, please go to http://www.epa.gov/ocspp and select "Test Methods &
Guidelines" on the left side navigation menu.  You may also access the guidelines in
http://www.regulations.gov grouped by Series under Docket ID #s: EPA-HQ-OPPT-2009-
0150 through EPA-HQ-OPPT-2009-0159, and EPA-HQ-OPPT-2009-0576.

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OCSPP 810.2000: General considerations for testing antimicrobial agents.

       (a) Scope.

         (1) Applicability.  This guideline  describes test methods that EPA believes will
generally satisfy testing requirements of the Federal Insecticide, Fungicide, and Rodenticide Act
(FIFRA)(7U.S.C.  136, et seq.) and the Federal Food, Drug, and Cosmetic Act (FFDCA) (21
U.S.C. 346a).

         (2) Background. The source material used in developing this OCSPP test guideline is
OPP guideline  91-1: General Requirements for Antimicrobial  Agents (Pesticide Assessment
Guidelines, Subdivision G, Product Performance, EPA report 540/9-82-026, October 1982).

       (b) Overview—Product performance.

         (1) General concepts. Any evaluation of product performance is conducted in light of
expressed and implied labeling claims or recommendations concerning pests, sites, methods of
application,  application  equipment,  dosage rates, timing  and number  of applications, use
situations, nature  and level of pest control, duration of pest control, compatibility with other
chemicals, benefits and/or adverse effects of product use, compatibility of common practices
associated with the sites, active ingredient status of chemicals in the formulation, and equipment.

       (i) Laboratory and/or simulated-use testing is conducted to determine the effectiveness of
a substance, or mixture  of substances, to control  or kill specific pest organisms, and in some
cases to determine whether the substance has sufficient pesticide potential to warrant larger scale
testing (e.g., swimming pool disinfectants).

       (ii) In some cases, effectiveness and usefulness of the proposed product is further proven
through advanced large-scale laboratory tests, field tests, in-use  tests, or simulated-use tests by
procedures which closely approximate actual use and which employ typically used application
equipment (e.g.  fumigant sterilants).

         (2) [Reserved]

         (3) Waiver policy. As  outlined in  40  CFR Part 161, the Agency has waived all
requirements to submit efficacy data unless the pesticide product bears a claim to control one or
more pest microorganisms that pose a threat to human health and whose presence cannot readily
be observed by the user, including but not limited to, microorganisms infectious to man in any
area of the inanimate environment. However, pursuant to FIFRA, each registrant must ensure
through testing  that its products  are efficacious when  used in accordance with label  directions
and commonly  accepted pest control practices. The registrant must develop and maintain the
relevant data upon which the determination of efficacy is based. The agency reserves the right to
require, on a case-by-case basis submission of efficacy data for any pesticide product, registered
or proposed  for registration.

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          (4)  Series organization. Table  1 outlines the  organization of the OCSPP Test
Guideline Series 810.2000.
        Table 1. Organization of the OCSPP Test Guideline Series 810.2000.
Guideline Name
Sterilants - Efficacy Data
Recommendations
Disinfectants for Use on Hard
Surfaces - Efficacy Data
Recommendations
Sanitizers for Use on Hard
Surfaces - Efficacy Data
Recommendations
Disinfectants and Sanitizers for
Use on Textiles - Efficacy Data
Recommendations
Air Sanitizers - Efficacy Data
Recommendations
Disinfectants for Use in Water -
Efficacy Data Recommendations
Prions - Efficacy Data
Recommendations
Guideline Number
810.2100
810.2200
810.2300
810.2400
810.2500
810.2600
810-2700
Previous Subdivision -G
Guideline Number(s)
91-2(a)
91-2(b)(c)(d)(e)(f)(g)(i)
91-7(a)(l)
91-3
91-2G)(k)(l)(m)
91-3
91-4(a)(l)(2)(3)(4)
91-4(b)(c)(d)
91-5
91-8
Not Applicable
          (5)  Future  guidelines.  The  Agency  recognizes  the  fact that  novel technologies
associated with antimicrobial products may evolve over time and would potentially involve test
methods that are not referenced in this current guideline.  In addition, the Agency is considering
adopting the use of quantitative test methods as  a possible replacement for current qualitative
methods  [e.g., Association of Official Analytical Chemists (AOAC) Use-Dilution Methods]  in
the future. The Agency expects to update the guidelines periodically. However, the use of new
methods may occur, on a case-by-case basis, prior to guideline updates and these new methods
will be published on the EPA Antimicrobial Policy and Guidance Documents website until such
time that they can be added to the guidelines.

       (c) Public health and nonpublic health uses of antimicrobial products

          (1)   Antimicrobial   products   with  public  health   uses,  (i)   Health-related
considerations.  Microbial pests  can be categorized into two basic  types:  Those that present
potential public health hazards because of their infectious nature to humans and those that cause
economic or aesthetic problems such as spoilage, fouling,  or production of offensive odors in the
substrate  in  which  they grow.  The OCSPP  Test  Guideline  Series  810.2000  addresses
antimicrobial pesticide products with public health uses for which efficacy test data are required
to be  submitted to support registration.  These include all antimicrobial products intended  to

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control microorganisms infectious to man in any area of the inanimate environment where these
microorganisms may present a hazard to human health. The label claims for an antimicrobial
product determine whether it is considered to be related to human health.

       (ii) Public health claim.  An antimicrobial pesticide is considered to make a public health
claim if the pesticide product bears a claim to control one or more pest microorganisms that pose
a threat to human health, and whose presence cannot readily be observed by the user, including
but not limited to, microorganisms infectious to man in any area of the environment. A product
makes a public health claim if one or more of the following apply:

       (A) A claim is made for control of one or more specific microorganisms that are directly
or indirectly infectious or pathogenic to man (or both man and animals). Examples of specific
microorganisms include, but are not limited to, Mycobacterium tuberculosis,  Pseudomonas
aeruginosa, Escherichia coli (E. coli\ human immunodeficiency virus (HIV), Streptococcus and
Staphylococcus aureus. Claims for  control  of microorganisms infectious or pathogenic only to
animals (such as canine distemper virus or hog cholera virus) are not considered public health
claims.

       (B) A claim is made for  the pesticide product as a sterilant,  disinfectant, virucide,
sanitizer  or tuberculocide against one or more microorganisms that are infectious or pathogenic
to man.

       (C) A claim is made for the pesticide product as a fungicide  against one or more fungi
infectious or pathogenic to man, or the product does not clearly state that it is intended for use
only against non-public health fungi.

       (D) A claim is made for  the pesticide  product as  a microbiological  water purifier  or
microbial purification system or swimming pool disinfectant/sanitizer.

       (E) A non-specific claim is  made that the pesticide product will beneficially  impact  or
affect public health at the site of use on in the environments in which it is applied.

       (2) Antimicrobial products with non-public health uses. Registrants who propose non-
health related  claims for their product (e.g., control of odor-causing bacteria)  should be aware
that generally the Agency does not require submission of efficacy data to support such claims.
However, the registrant is still responsible for ensuring that these  products perform as intended
by developing efficacy data which should be kept on file. The Agency still has the responsibility
of  making sure  that the use  directions  proposed for non-public  health related claims  are
appropriate and adequate. Therefore, the Agency retains the option of requiring the submission
of efficacy data for non-public health related claims on a case-by-case basis.

       (i)     Non-public health claim. An antimicrobial pesticide is  considered to make a non-
              public  health  claim  if  the pesticide  product  bears  a claim to  control
              microorganisms of economic or aesthetic significance, where the presence of the
              microorganism  would  not  normally lead to  infection or disease in humans.

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              Examples of non-public health claims would include, but are not limited to:

       (A) Slimicides,  odor  control and other non-public health agents. Slimicides and odor
control  agents,  preservatives,  algicides,  and  other  products  expressly claiming  control of
microorganisms of economic or aesthetic significance are not considered to be human health-
related,   but  nevertheless  must  bear  accurate   labeling  claims  and   adequate   dosage
recommendations, and complete directions for use.

       (B) Bacteriostatic/Fungistatic products. Since elimination or significant reduction in the
number of microorganisms  (sterilization,  disinfection,  sanitization) should be demonstrated
before a product is considered acceptable for use against microorganisms infectious for  humans,
or for use in medical or  sickroom environments, products bearing lower level labeling claims for
effectiveness at the bacteriostatic/fungistatic (inhibition of growth) level would generally not be
appropriate for such  uses. Bacteriostatic/fungistatic claims are generally acceptable  only for
products expressly recommended for control of microorganisms of aesthetic significance  (e.g.,
spoilage bacteria, odor-causing bacteria).

       (C) Treated articles. The Agency has clarified its policy on applicability of the treated
articles  exemption to antimicrobial pesticides and provided guidance on appropriate language or
label claims in Pesticide Registration Notice 2000-1 (Ref. 1). The treated articles exemption (40
CFR 152.25(a)) covers  qualifying articles and substances bearing claims to merely protect the
article or  substance itself, if,  among other things, the pesticide is registered  for such use.  This
exemption does not include articles or substances bearing implied or explicit public health claims
against human pathogens. Applicants who intend to market products with claims  (such as public
health claims) that go beyond  the  scope  of the treated  articles exemption  should  contact the
Antimicrobials Division prior to conducting testing to support such a use.

       (D) Animal disease pathogens and zoonotic  microorganisms. For products labeled for
public health  and/or non-public health  uses, submission of studies to EPA on certain animal
disease pathogens and zoonotic  microorganisms may be appropriate prior to approval of the label
claim. For example,  although  label claims against  foot and  mouth  disease virus,  Newcastle
disease  virus,  and avian influenza A virus are not considered to be human health  related, the
Agency requires,  on a case-by-case basis, the submission  of efficacy data to support these claims
because these pathogens  have  animal  health significance  or the potential to infect  humans.
Applicants should consult the  Agency for a current listing of organisms which  meet  these
criteria.  These organisms are also listed on the World Organization for Animal Health's  website,
see, http://www.oie.int/animal -health-in-the-world/oie-listed-diseases-2011/.

       (d) Definitions. Because  of the variety of  microorganisms to be  controlled  and the
different claims and many use patterns of antimicrobial products, consistent product terminology
and a common understanding of a few key words are important to a program for evaluating
product performance. Even though the OCSPP Test Guideline Series 810.2000 guidelines cover
only public health uses, terms covering non-public health use patterns and/or organisms are
included in order to support  consistency and clarity. The terms in the OCSPP  Test Guideline
Series 810.2000, are generally used with the meanings set forth in this paragraph.

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       Algicide  means  any substance,  or mixture of substances,  which  kills  or effectively
reduces the number of living algae in water.

       Algistat means any substance, or mixture of substances, that inhibits the growth of algae
in water.

       Antibacterial means any substance, or mixture of substances, that destroys or eliminates
bacteria in the inanimate environment.

       Antibiotic resistant means the ability of a bacterial cell to resist the effects of antibiotics.

       Antifoulant means any substance, or mixture of substances,  that is  used  to prevent the
biological fouling of underwater structures or objects.

       Bacteriostat means a substance, or mixture of substances, that inhibits  the growth of
bacteria in the inanimate environment.

       Biocide/Microbicide means any  substance,  or mixture of substances, that  kills a number
of living  microorganisms (e.g., virucide—virus, mycobactericide—mycobacteria, algicide—algae;
bactedcide-bacteria; fungicide—fungi; slimicide—slime-forming microorganisms).

       Biofilm  means  a  dynamic,  self-organized  accumulation  of  microorganisms   and
environmental by-products immobilized on a substrate and embedded  in an organic polymer
mix. This organic polymer mix is also known by the term "glycocalyx."

       Confirmatory data is a reduced set of data which may be used to support an application
or amendment for registration of a product, or a minor formulation change of a registered
product. Each guideline further addresses confirmatory data

       Deodorizers means a substance, or mixture of substances, that are of two basic types: (1)
Those that  prevent or delay the formation of bacterial odors by killing microorganisms which
produce them, and (2) those that mask, chemically  destroy or neutralize odors (refer to 40 CFR
152.10). Products that claim deodorization by antimicrobial means are subject to registration as
pesticides under  FIFRA.

       Disinfectant means a substance, or mixture of substances that destroys  or irreversibly
inactivates  bacteria,  fungi and viruses,  but not necessarily bacterial  spores, in  the inanimate
environment.

       Fungicide means a substance, or mixture of substances, that destroys fungi (including
yeasts) and/or fungal spores pathogenic to man or other animals in the inanimate environment.

       Fungistat means a substance, or  mixture  of substances, that inhibits the growth of fungi
in the inanimate  environment.

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       Microbiological water purifier means any unit,  water treatment product or system that
removes, kills or inactivates disease-causing microorganisms from the water, including bacteria,
viruses and protozoan cysts so as to render the treated water safe for drinking.

       Microbiostat means  a substance, or mixture of substances, that inhibits the growth of
microorganisms (e.g., bacteriostat, fungistat, algistat).

       Mycobactericide  means  a  substance,  or  mixture  of substances,  that  destroys or
irreversibly inactivates mycobacteria in the inanimate environment.

       Non-volatile means a substance that does not evaporate readily.

       One-Step Disinfectant means a substance, or mixture of substances, that has been tested
and found to be effective in the presence of light to moderate soil, and, therefore, may be used
without a pre-cleaning step in the use directions.

       Preservative  means  a substance, or mixture of substances  that inhibits the growth of
microorganisms capable of causing biological deterioration of a material(s).

       Product performance refers to all pesticidal  aspects of a product's effectiveness and
usefulness.

       Sanitizer means  a  substance, or  mixture  of  substances,  that  reduces the bacterial
population in the inanimate environment by significant numbers, (e.g., 3 log 10 reduction) or
more, but does not destroy or eliminate all bacteria. Sanitizers meeting Public Health Ordinances
are used on food contact surfaces and are termed sanitizing rinses.

       Slime  means  a  dynamic,   self-organized  accumulation  of  microorganisms  and
environmental by-products  immobilized on a substrate and  embedded in  an organic polymer
mix. This organic polymer mix is also known by the term "glycocalyx."

       Slimicide means a substance, or mixture of substances, that reduces the number of slime-
forming microorganisms in industrial water systems  (e.g., paper mills).

       Sterilant means a  substance,  or mixture  of substances, that destroys or eliminates all
forms of microbial life in the inanimate environment,  including all forms of vegetative bacteria,
bacterial spores, fungi, fungal spores, and viruses.

       Sporicide means a  substance, or mixture  of substances, that  irreversibly  inactivates
bacterial spores in the inanimate environment.

       Tuberculocide means a  substance, or mixture of substances,  that destroys or irreversibly
inactivates tubercle bacilli in the inanimate environment.

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       Two-Step Sanitizer or Two-Step Disinfectant means a substance or mixture of substances
that has not been registered for effectiveness against microorganisms in the presence of light to
moderate  soil, and, therefore, need  a pre-cleaning step for  surfaces  prior to sanitizing  or
disinfecting.

       Virucide means a  substance,  or mixture  of substances, that  destroys  or  irreversibly
inactivates viruses in the inanimate environment.

       Volatile means a substance that evaporates readily.

       Zoonotic microorganism  means an  infectious agent that  can  be transmitted  between
animals and humans.

       (e) General testing considerations

       (1) Test substance.

       (i)  Unless  otherwise  specified, antimicrobial pesticides  should  be  tested  on  the
formulation with the lowest certified limit(s) of the active  ingredient(s) and, in some cases (e.g.,
pressurized sprays, towelettes) with the product in the same packaging  intended to be marketed.
The following information should be provided:

       (ii)  Identification of  the  test substance  and quantitative description of its chemical
composition should be reported.

       (iii) Manufacturer and production batch numbers of the test substance.  If a product is
diluted, the report should specify the quantities and identification of each diluent.

       (iv)  The manufacturer  should also  submit  effectiveness data to show that they can
consistently reproduce the  formulation (batch replication), as well  as to show that the product
will retain its effectiveness for a minimal period of storage under average conditions to which it
is likely to be exposed (shelf-life stability)(Ref. 2).

       (v)  In  situations where it may not be  technically feasible to  test at the exact Lower
Certified Limits (LCL) (e.g.,  reactive chemistries with a degradation profile, multiple active
ingredients, formulations with  inversely related active  ingredients), a rationale  should  be
provided to the Agency for approval  of the testing if testing cannot be performed  at the  LCL.
Efforts should be made to test as close to the LCL as possible.

       (2)  General considerations

       (i) Good Laboratory Practice Standards. Good Laboratory Practice Standards (GLP) as
defined in 40 CFR Part 160 apply to studies to support all antimicrobial products used on hard
surfaces. According to 40 CFR §160.17: "EPA may refuse to consider reliable for  purposes of
supporting an  application for a research or marketing permit any data  from a study which was

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not conducted in accordance with this part." 40 CFR §160.12 (b) requires with any submitted
research data "[a] A statement that the study was conducted in accordance with this part; [b] A
statement describing in detail all differences between the practices used in the study and those
required by this part; or [c] A statement that the person was not a sponsor of the study, did not
conduct the study, and does not know whether the study was conducted in accordance with this
part."

       (ii) Use pattern. Depending upon the type of antimicrobial agent, target microorganisms,
and the site to be treated, all tests should address those factors that would normally be expected
to be encountered in the use pattern intended for the product, such as the method of application,
the nature of the surface, item or substrate to be treated, the presence or absence of soil or other
interfering conditions, temperature, exposure period, and the number of times  or duration of time
that the use solution can be used. Representative surfaces for testing are identified in each 810
Guideline.

       (iii) Additional factors. The actual test procedure to be employed will vary according to
the characteristics of the product, the target pests and the pattern of use intended. A specification
of methods in these guidelines  for all  conceivable public health uses is not feasible, and the
applicant  should be responsible for the validity of the test  method selected to  substantiate a
product's efficacy. The applicants  should ensure themselves that the selected method is current
and applicable to the product and uses proposed for registration.

       (iv) New methods. If applicants believe they have alternative protocols for demonstrating
the efficacy of a product, such protocols should be submitted to the  Agency for review.  In
addition to modifying the standard methods, registrants may, in consultation with  the Agency,
develop and submit protocols for claims where no standard test methods have been developed.

       (3) Use of Antibiotic Resistant Test Organisms. Organisms to be labeled  as antibiotic
resistant should be accompanied by scientific data that substantiates the antibiotic resistance.
The  antibiotic resistance confirmation  should be conducted using the organism(s) listed on the
label, and, if  possible, should be performed at the  same time  as the  efficacy testing.  The
confirmation may also be conducted within the usual transfer cycle or other appropriate transfer
depending upon  organism's growth requirements.   The  following information  identified  in
paragraphs (e)(3)(i) through (e)(3)(iv) in this guideline  should be submitted with the Antibiotic
Resistance Confirmation testing or included in the final report.

       (i) Test organisms should be characterized according to paragraphs (e)(3)(i)(A) through
(e)(3)(i)(D) of this guideline:

       (A) The source and identity (e.g. ATCC, private source, other).

       (B) The method of preparation prior to testing (e.g. transfer history).

       (C) The method  used   to confirm the identity  (e.g. biochemical  test,  Gram  stain,
morphology).

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       (D) The method of preservation/storage (e.g. refrigerated agar slants, cryogenic beads,
other).

       (ii) Results of the testing including the numerical  values of  all  antibiotics tested. An
example of values would be Minimum Inhibitory Concentration (MIC)  s for automated test, zone
sizes for manual  tests, and comparison to a standard Clinical and National  Standards Institute
interpretation of such tests.

       (iii) The scientific method used to obtain the results (Kirby-Bauer,  disc agar diffusion, or
gradient agar diffusion;  automated MIC procedures or equivalent). If automated procedures are
used, the manufacturer of such automation should be specified.

       (iv) Quality control procedures used to verify results.

       (f) Special considerations

       (1) Hard  Surface Carrier Test vs. Use-Dilution Methods   The AOAC International
Hard Surface Carrier Test Method (Ref. 3) has only been validated for use with distilled water.
For other conditions (hard water, organic soil), the AOAC International  Use-Dilution Method
(Ref. 4) is the recommended method.

       (2) Elimination of Phenol Resistance Testing. As described in  Pesticide Registration
Notice 2001-4 (Ref. 5) the Agency is no longer recommending the use of the phenol resistance
assay  when  conducting  carrier-based efficacy  tests.  The  phenol  resistance  assay was  a
component of the AOAC Use-Dilution Test methods, as well as the Tuberculocidal  Activity of
Disinfectants method.

       (3) Surrogate microorganisms. The Agency has approved the use of several surrogate
organisms to be  used as  replacements for microorganisms that cannot  be tested  because of
biohazards or unavailability of scientifically accepted methods. Applicants should consult with
the Agency for guidance on  additional  surrogates. Examples of surrogate organisms  are as
follows in paragraphs (f)(3)(i) through (f)(3)(iv) of this guideline.

       (i) Mycobacterium bovis BCG has been adopted as a  surrogate for human Mycobacterium
tuberculosis. See  Guideline 810.2200.

       (ii)  The  duck  hepatitis B virus (DHBV) has been  adopted as a surrogate  for the
chimpanzee test used in testing efficacy of disinfectants against human  hepatitis B virus (Ref. 6).
The data consistency control (method validation) stated in the referenced  protocol utilizing two
dilutions of ETC  835 has been eliminated.

       (iii) The bovine viral  diarrhea  virus (BVDV) has been adopted as a surrogate for the
hepatitis C virus (Ref. 7). The data consistency control (method  validation) stated  in the
referenced protocol utilizing two dilutions of BARD AC 2280 has been eliminated.

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       (iv) The feline calicivirus has been adopted as a surrogate for the Noroviruses (Ref.8).
The data consistency control (method validation) stated in the referenced protocol utilizing two
dilutions of bleach has been eliminated.

       (4) Antimicrobial rinses for fruits and vegetables. To support label  claims  for
consumer-use products as antimicrobial rinses for fruits and vegetables,  products should meet a
two log  reduction of five outbreak strains of Salmonella  spp., Listeria monocytogenes, and
Escherichia coli O157:H7. Currently there is no standard method for assessing the efficacy of
antimicrobial  rinses  for pathogen  reduction  on the  surfaces of  fruits and vegetables (raw
agricultural commodities). Applicants should consult with the Agency prior to conducting testing
to support this use.

       (5) Use of Dacron Loops. The AOAC International has accepted  the use of Dacron loops
(also  termed braided polyester), instead of silk suture loops, for peracetic  acid containing
products,  as a method modification to the AOAC Sporicidal Activity Test.  Consult the Agency
for other chemistries. (Ref. 9).

       (g) Special situations. When it is intended that an  antimicrobial product be used in a
manner that is not reflected by the test conditions specified in the recommended AOAC methods
(e.g., inclusion of organic soil or hard water), one or more test conditions specified in the method
should be modified and/or supplementary data developed in order to provide meaningful results
relative to the conditions of use of the product.   The information in paragraphs (g)(l) through
(g)(4)  in  this  guideline is  critical  to  the development and  submission  of  the  appropriate
supportive efficacy data.

       (1) Type of surface. When an antimicrobial product is intended to be effective in treating
a hard, porous surface, some of the recommended methods may be modified to simulate this
more  stringent  condition by substitution  of a hard, porous  surface  carrier  (e.g., porcelain
penicylinder or unglazed ceramic tile) for the hard,  nonporous surface carrier (stainless steel
cylinder or glass slide) specified in  the method.  In addition, control data (e.g., quantitation of
dried  carrier, neutralization confirmation, sterility controls) should be developed to assure the
validity of the test results when this modification of the method is employed. Since the use of a
hard, porous surface would simulate  the more stringent test condition, demonstrated efficacy on
hard, porous surfaces would suffice to support an analogous  claim for efficacy of the product on
hard, non-porous surfaces as well.

       (2) Hard water  claim.  Any product that bears label claims  for effectiveness in hard
water should be tested by the  appropriate method which  has been  modified to demonstrate
effectiveness of the product in synthetic hard water at the level claimed. The hard water tolerance
level may differ with the level of antimicrobial activity claimed (e.g.,  sterilization, disinfection,
or sanitization). To establish efficacy in  hard water, all microorganisms (bacteria, viruses, and
fungi) claimed to be controlled by the product should be tested by the appropriate recommended
method at the same hard water tolerance level. Refer to the AOAC International Germicidal and
Detergent Sanitizing Action of Disinfectants test (Official Method 960.09) for  guidance on the

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preparation of synthetic hard water (Ref. 10).

       (3) Organic burden.

       (i) An antimicrobial substance identified as a one-step  cleaner-disinfectant or  cleaner-
sanitizer,  or intended to be effective in the presence of light to moderate amounts of organic
burden, should be tested for efficacy by the appropriate methods which have been modified to in-
clude a minimum of a 5% representative  organic  soil such as blood serum or scientifically
accepted equivalent as  serum may be inhibitory to  some viruses (Ref. 11). Registrants should
check with the Agency to determine the acceptability of an organic burden other than blood
serum.

       (ii) A suggested procedure to simulate in-use conditions where the antimicrobial agent is
intended  to treat  dry inanimate  surfaces  contaminated with  an  organic soil  load involves
contamination  of the  appropriate  carrier surface  with each test microorganisms  culture
containing 5% v/v blood  serum (e.g., 19 mL test microorganism culture +1 mL blood serum)
prior to the specified carrier-drying step in the method. Additional organic material need not be
incorporated into those procedures where at least 5 percent blood serum is already present in the
microbial inoculum to be dried on the surface.  Control data (e.g.,  quantitation of dried carrier
counts,  neutralization confirmation, sterility controls) should also be developed to assure the
validity of the test results when this modification is incorporated into the method.  The organic
soil level  suggested is considered appropriate for simulating lightly  or moderately soiled surface
conditions. When the surface to be treated has heavy soil deposits,  a cleaning step should be
recommended on the label prior to the application of the antimicrobial agent.  The effectiveness
of antimicrobial agents should be demonstrated in the presence of a  specific organic soil at an
appropriate concentration level when specifically claimed and/or indicated by the pattern of use.

       (iii) A suggested procedure for incorporating a light to moderate organic soil load where
the antimicrobial  agent is not tested against  a dry inanimate surface,  such as the AOAC
International   Fungicidal  Activity  of  Disinfectants  test (Ref.  12)  and  the   Quantitative
Tuberculocidal Test (Ref. 13) involves adding a minimum of 5% (v/v) blood serum directly to
the test organism (e.g., 4.75 mL test organism + 0.25 mL blood serum) before inoculating the
test solution.

       (iv) When a product is recommended for certain patterns of use where the organic  soil
claimed is of a specific type,  such as soap film residue, the product should be tested in the
presence of that specific organic soil. Registrants should provide specific information in the data
report regarding the way in which the organic soil, such as soap film residue was prepared (e.g.,
percentages of ingredients).

       (4) Exposure  period.  The exposure period required for an antimicrobial product to be
effective may be shorter than the exposure period  specified in the recommended method.  A
modification  to provide a shorter exposure period is restricted by  the manipulative limitations
inherent in the test procedure. A modification to  provide a longer exposure period is restricted by
the practical considerations of the use patterns (e.g., an exposure period of >10 min cannot be

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recommended for a product that will effectively evaporate from the treated surface in <10 min).
If the product is to be  represented in labeling for use at exposure  periods shorter than those
specified in the method this deviation in the method should be included in  the  test protocol
submitted with the data. For liquid products containing volatile active ingredients where the
product is applied to an  environmental surface, the exposure period should be determined by the
AOAC International Germicidal Spray Products As Disinfectants test (Ref. 14). Use of methods
that immerse contaminated carriers in the disinfectant fluid would not closely  simulate the way
in which the volatile disinfectants perform on environmental surfaces.

       (h) Microbiological technique considerations

       (1)   Microorganism   survival  after  drying  on  a   hard  surface.  Quantitative
determinations of the microbial counts on the untreated control carriers after  drying should be
conducted in order to determine the validity of the test results obtained with the treated carriers.
The control carrier count evaluation should be performed at the  completion of the test. These
quantitative determinations should be performed  for all carrier-based  assays, whether  or not
modifications are made  to the method being used.  The test results should include the individual
dried  carrier counts  obtained by the  method. The detailed final  report for  this testing  should
include information and descriptions regarding: preparation of the inoculum; application of the
inoculum to  the carrier; the time/temperature and relative humidity conditions for drying the
microorganisms on the carrier; the technique for removal of the microorganisms from the carrier;
and the  specific assay  procedure indicating such details as replication,  subculture media,
diluents, and the  incubation  time/temperature   conditions  for  the  enumeration procedure
employed.

       (2)  Microorganism survival  for suspension  tests. Quantitative  determination  of the
microbial count of the inoculum in a parallel untreated diluent should be conducted in order to
determine the level of  microbial  challenge in the test (Numbers Control).  These quantitative
determinations should be performed for all suspension assays, whether or not modifications are
made to the method being used. The test results should include the individual counts obtained by
the recovery method.  The detailed  final report for suspension testing  should include information
and descriptions regarding: preparation of the inoculum, the volumes used for inoculation, and
the  specific assay  procedure indicating such details as replication, subculture media,  diluents,
and the incubation time/temperature conditions for the enumeration procedure employed.

       (3)  Neutralization. Neutralization  is  the  process  for inactivating  or  quenching
antimicrobial  activity during efficacy testing. This may be achieved  through physical (e.g.,
filtration, dilution,  secondary subculture)  and/or chemical (e.g., addition  of sodium thiosulfate to
the diluent) means. For  each efficacy test, neutralization procedures should be  employed, at the
completion of the contact time, in  order to preclude residual effects of the active ingredients in
the subculture medium.  If neutralization is not properly  employed, the results of efficacy testing
may be exaggerated. The method of neutralization, whether that be physical or  chemical,  should
be confirmed. Data  should be submitted (Neutralization Confirmation) in  the final report to
demonstrate that the neutralization method  sufficiently inactivated the active  ingredient(s) and
that any neutralizer medium used did not possess any antimicrobial activity.  In lieu of chemical

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neutralization,  it should  be documented  that  appropriate  subculture techniques  have been
employed that  preclude residual  carryover of active ingredients. To document the  absence of
residual effects of the active ingredients in the subculture medium, the examples of neutralization
techniques procedures in paragraphs  (h)(3)(i) through (h)(3)(ii) in this guideline should  be
followed.

       (i) In qualitative test methods, after treatment, the inoculated carrier is initially deposited
in a tube of growth media (i.e., primary subculture). If the primary subculture tube is  not
sufficient to achieve neutralization by the use of a chemical agent and/or through dilution of the
test substance,  the carrier may then be transferred to a  second tube of growth media (i.e.,
secondary subculture). Secondary subculture may be helpful in achieving neutralization. The
neutralization procedure employed should be confirmed and  reported by running a parallel test
with uninoculated carriers being  added to growth media containing a low level (i.e., 10 - 100
CFU/mL) of bacteria. Both the primary cultures and secondary subcultures should be incubated
and checked for growth in the test and the neutralization confirmation. Dried test carriers should
not be used  to test the ability of a subculture medium to support organism growth, as this would
provide too  large a bioburden and may lead to an inaccurate evaluation of the presence of any
bacteriostasis that may result from the carry-over of the antimicrobial substance on the carrier to
the subculture medium. Growth results for both primary and secondary subcultures should  be
reported for the test and neutralization confirmation in the final report.

       (ii) A neutralization confirmation  for suspension based test methods should be conducted
for all neutralization/recovery methods employed in testing. Neutralization confirmation may be
conducted by  neutralizing  the test  substance,  without the  organism, as in  the  test. After
neutralization, inoculation of a  low level  of organism (10-100 CFU/mL) and subsequent plating
should follow. Plate counts should be within 1.0 log of a parallel population control:
       (A) For virucidal  tests,  scientifically accepted controls,  including proper neutralization
controls should be performed (e.g., ASTM E1482) (Ref. 16).

       (4) Batch replication  for modified tests.  Where batch replication has  already been
performed and  accepted for a product registration with unmodified tests by the recommended
methods,  additional testing  at the  same use  concentration under  modified conditions (e.g.,
different exposure period, presence of organic  soil  or hard water, porous surface carriers, etc.)
may be conducted with reduced batch replications as in paragraphs (h)(4)(i) and (h)(4)(ii) in this
guideline.

       (i) For  basic efficacy  claims  (e.g., sterilants,  disinfectants, sanitizers), two  samples,
representing two different batches, instead of three.

       (ii) For supplemental efficacy claims (e.g., fungicides,  virucides, and tuberculocides), one
sample instead of two.

       (5) Validation of efficacy. The Agency  reserves the option to perform its own tests, on a
case-by-case basis, following the protocol  submitted with the registration if that protocol meets

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current agency standards. In all other cases, the Agency will conduct the validation studies using the
current agency protocol."

       (6)  Test failure.  Failure of a  product formulation  to meet  the  specified testing or
evaluation  of success claimed on the product label, constitutes evidence that the product is
unlikely to be effective as claimed in actual use and is reportable under FIFRA section 6(a)(2).

       (i)  References.  The  references  in  this  paragraph may be  consulted for additional
background information:

       (1)  Environmental Protection  Agency,  Pesticide  Registration  Notice  PR  2000-1,
Applicability of the Treated  Articles Exemption to Antimicrobial  Pesticides,  March 6, 2000.
Office of Pesticide Programs, Antimicrobials Division. See http://www.epa.gov/PR_Notices/.

       (2)  Environmental Protection Agency, Pesticide Registration Notice PR 91-2, Accuracy
of Stated Percentages for Ingredients Statement, May 2, 1991. Office of Pesticide Programs,
Antimicrobials Division. See http://www.epa.gov/PR_Notices/.

       (3)  Official Methods of Analysis of AOAC International. Chapter 6, Disinfectants, Hard
Surface Carrier  Test Methods,  Current edition.   AOAC International,  Suite  500,  481  North
Frederick Avenue, Gaithersburg, MD 20877-2417.

       (4)  Official Methods of Analysis of AOAC International. Chapter 6, Disinfectants, Use-
Dilution Methods, Current edition. AOAC International, Suite 500, 481 North Frederick Avenue,
Gaithersburg, MD 20877-2417.

       (5)  Environmental Protection Agency, Pesticide Registration Notice 2001-4, Elimination
of Phenol Resistance Testing for Antimicrobial Disinfectant and  Sanitizer Pesticides. Office of
Pesticide Programs, Antimicrobials Division.  See http://www.epa.gov/PR_Notices/.

       (6)  Protocols for Testing the Efficacy of Disinfectants Against Hepatitis B Virus (HBV).
Office      of      Pesticide      Programs,       Antimicrobials       Division.      See
http://www.epa.gov/oppad001/regpolicy.htm.

       (7)  Virucidal Effectiveness Test Using  Bovine Viral Diarrhea Virus (BVDV) as a
Surrogate for Human Hepatitis C Virus. Office of Pesticide Programs, Antimicrobials Division.
See http://www.epa.gov/oppad001/regpolicy.htm.

       (8)  Virucidal Effectiveness Test Using Feline Calicivirus as a Surrogate for Norovirus.
Office      of      Pesticide      Programs,       Antimicrobials       Division.      See
http://www.epa.gov/oppad001/regpolicy.htm.

       (9) McDonnell, G. (2003) J. AOAC Int. 86,407-411.

       (10) Official Methods of Analysis of AOAC International. Chapter  6,  Disinfectants,

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Official Method 960.09 - Germicidal and Detergent Sanitizing Action of Disinfectants, Current
edition. AOAC International, Suite 500, 481 North Frederick Avenue, Gaithersburg, MD 20877-
2417.

       (11) Annual Book of ASTM Standards, Test Method for Efficacy of Virucidal Agents
Intended for Inanimate Environmental  Surfaces, Designation El053.  American Society for
Testing and Materials, 100 Barr Harbor Drive, West Conshohocken, PA 19428, current edition. .

       (12)  Official Methods  of Analysis of AOAC International. Chapter 6, Disinfectants,
Official  Method  955.17   Fungicidal  Activity  of  Disinfectants.  Current edition.  AOAC
International, Suite 500, 481 North Frederick Avenue, Gaithersburg, MD 20877-2417.

       (13)  Environmental Protection   Agency, Data  Call-in  Notice   for  Tuberculocidal
Effectiveness Data for All  Antimicrobial Pesticides with Tuberculocidal  Claims (Registration
Division,     Office    of    Pesticide    Programs,     June     13,     1986).     See
http://www.epa.gov/oppadOO l/dis_tss_docs/dis-06.htm.

       (14)  Official Methods  of Analysis  of AOAC International. Chapter 6, Disinfectants,
Official Method 961.02  - Germicidal  Spray Products as Disinfectants, Current  edition. AOAC
International, Suite 500, 481 North Frederick Avenue, Gaithersburg, MD 20877-2417.

       (15) Annual Book of 'ASTM Standards, Standard Test Methods, Evaluation of Inactivators
of Antimicrobial Agents, Designation  E1054. American Society for Testing and Materials, 100
Barr Harbor Drive, West Conshohocken, PA 19428, current edition.

       (16) Annual Book of ASTM Standards,  Standard Test Method  for Neutralization  of
Virucidal Agents in Virucidal  Efficacy Evaluations,  Designation E1482. American Society for
Testing and Materials, 100 Barr Harbor Drive, West Conshohocken, PA 19428, current edition.
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