EPA/600/R-16/132 I July 2016
www.epa.gov/homeland-security-research
United States
Environmental Protection
Agency
&EPA
Expedient Approaches for the
Management of Wastes
Generated from Biological
Decontamination
Operations in an Indoor Environment
Office of Research and Development
National Homeland Security Research Center

-------
This page is intentionally left blank

-------
EPA 600/R-16/132
July 2016
Expedient Approaches for the Management of Wastes
Generated from Biological Decontamination
Operations in an Indoor Environment
Evaluation of Waste Sampling and Decontamination
Procedures - Part II
Assessment and Evaluation Report
National Homeland Security Research Center
Office of Research and Development
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711

-------
This page is intentionally left blank

-------
Disclaimer
The United States Environmental Protection Agency (EPA), through its Office of Research and
Development's National Homeland Security Research Center, funded and directed this investigation
through contract EP-C-09-027 with ARCADIS U.S., Inc, and contract EP-C-15-008 with Jacobs
Technology Inc. This report has been peer and administratively reviewed and has been approved for
publication as an EPA document. It does not necessarily reflect the views of EPA. No official
endorsement should be inferred. This report includes photographs of commercially available products.
The photographs are included for purposes of illustration only and are not intended to imply that EPA
approves or endorses the product or its manufacturer. EPA does not endorse the purchase or sale of any
commercial products or services.
Questions concerning this document or its application should be addressed to:
M. Worth Calfee, Ph.D.
Decontamination and Consequence Management Division
National Homeland Security Research Center
U.S. Environmental Protection Agency (MD-E343-06)
Office of Research and Development
109 T.W. Alexander Drive
Research Triangle Park, NC 27711
Phone:919-541-7600
Fax: 919-541-0496
E-mail: Calfee.Worth@epa.gov

-------
Acknowledgments
This effort was directed by the principal investigator from the Office of Research and Development's
(ORD) National Homeland Research Center (NHSRC), Decontamination and Consequence Management
Division (DCMD) utilizing support from the U.S. Environmental Protection Agency's (EPA) Chemical,
Biological, Radiological, and Nuclear (CBRN) Consequence Management Advisory Division (CMAD)
within the Office of Emergency Management (OEM). The contributions of the entire team are
acknowledged.
Project Team:
Worth Calfee, Ph.D. (Principal Investigator)
U.S. EPA, Office of Research and Development, NHSRC, DCMD
Research Triangle Park, NC 27711
Paul Lemieux, Ph.D.
U.S. EPA, Office of Research and Development, NHSRC, DCMD
Research Triangle Park, NC 27711
Mario lerardi
U.S. EPA, Land and Emergency Management, OLEM, Office of Resource Conservation and Recovery,
Materials Recovery and Waste Management Division, Water Compliance Branch
Arlington, VA 22202
Paul Kudarauskas
U.S. EPA, Land and Emergency Management, OLEM, OEM, CBRN CMAD
Washington, DC 20004
R. Leroy Mickelsen, M.S., P.E.
U.S. EPA, Office of Land and Emergency Management, OLEM, OEM, CBRN CMAD
Research Triangle Park, NC 27711
Randy Schademann
U.S. EPA, Federal On-Scene Coordinator, Region 7
Lenexa, KS 66219
This effort was completed under U.S. EPA contract #EP-C-09-027 with ARCADIS-US, Inc, and Jacobs
under contract EP-C-15-008. The support and efforts provided by ARCADIS-US, Inc., and Jacobs are
acknowledged.
ii

-------
Table of Contents
Disclaimer	i
Acknowledgments	ii
List of Figures	v
List of Tables	vi
List of Acronyms and Abbreviations	vii
Executive Summary	viii
1	Introduction	1
1.1	Process	2
1.2	Project Objectives	3
1.3	Experimental Approach	3
1.3.1	Testing Sequence	4
1.3.2	Decontamination Strategy	4
1.3.3	Method Development for Neutralization	4
2	Materials and Methods	5
2.1	Facility Design	5
2.2	Agitation	5
2.3	Test Coupon Preparation	6
2.3.1	Carpet and Upholstery	6
2.3.2	Paper	7
2.3.3	Nitrile Gloves	8
2.4	Spore Preparation and Coupon Inoculation	8
2.5	Decontamination Solutions	8
2.6	Decontamination Procedure	9
2.7	Method Development for Neutralization	10
2.8	Test Matrix	10
pAB, pH-adjusted bleach; PPE, personal protective equipment	11
3	Sampling Methods	12
3.1	Sampling Approach	12
3.1.1	Sponge-Stick™ Sampling	12
3.1.2	Extractive Sampling	13
3.2	Sample Type	13
3.2.1	Carpet and Upholstery	13
3.2.2	Paper Samples	13
3.2.3	PPE Samples	14
3.3	Sample Preservation	14
iii

-------
3.4	Sampling Points	14
PPE, personal protective equipment	15
3.5	Sampling Frequency and Sample Quantities	15
dEach finger of a glove is considered one sample; note that, for the gloves, runoff samples
were also collected	16
3.6	Measurement Methods	16
3.6.1 Microbiological Samples	16
3.6.1.1	Sample Extraction	16
3.6.1.2	Sample Analysis	16
3.7	Data Analysis	17
3.7.1	Sampling Efficiency	17
3.7.2	Surface Decontamination Efficacy	17
3.7.3	Statistical Analysis	18
4	Results and Discussion	19
4.1	Sampling Methods Evaluation	19
4.1.1	Carpet Material	19
4.1.1.1	Positive Controls	19
4.1.1.2	Post-Decontamination Sample Recoveries	20
4.1.2	Upholstery Material	22
4.1.3	Paper Material	23
4.1.4	PPE Material	24
4.2	Neutralization Method Evaluation	24
4.3	Dunking/Immersion Decontamination Test Results	25
4.3.1	Carpet Decontamination Results	25
4.3.2	Upholstery Decontamination Results	27
4.3.3	Paper Decontamination Results	28
4.3.4	PPE Decontamination Results	29
5	Quality Assurance	31
5.1	Sampling, Monitoring, and Analysis Equipment Calibration	31
5.2	Data Quality	31
5.3	Acceptance Criteria for Critical Measurements	32
5.4	QA/QC Checks	34
5.4.1	Quality Control Management	34
5.4.2	Quality Control Evaluation	35
6	Summary	37
7	References	39
iv

-------
List of Figures
Figure 2.1: Poly Hog Trough®	5
Figure 2.2: Top view of the immersion vessel retrofitted for agitation	6
Figure 2.3: Carpet tile	6
Figure 2.4: Front of assembled upholstered coupon	7
Figure 2.5: Paper material	7
Figure 2.6: White disposable nitrile glove	8
Figure 3.1: Material section shown with template during sampling with Sponge-Stick™ and
18-mm coupon removal	13
Figure 3.2: PPE sample (finger) excision	14
Figure 3.3: Sampling timeline	15
Figure 4.1: Spore recoveries (± SD) from carpet using the extractive and Sponge-Stick™
methods	20
Figure 4.2: Post-decontamination spore recoveries (± SD) for carpet as a function of
decontaminant procedure and sampling method	21
Figure 4.3: Effect of waste storage time on positive control recoveries (± SD) from upholstered
material for the extractive and Sponge-Stick™ methods	22
Figure 4.4: Effect of waste storage time on positive control recoveries (± SD) from paper (PM,
middle page; PF, front page) for the extractive method	23
Figure 4.5: Effect of waste storage time on positive control recoveries (± SD) from personal
protective equipment for the extractive method	24
Figure 4.6: Decontamination efficacy (± SE) versus decontamination treatment for carpet	27
Figure 4.7: Decontamination Efficacy (± SE) for Upholstered Coupon Using Spor-Klenz®	28
Figure 4.8: Decontamination efficacy (± SE) for Spor-Klenz® and paper coupons for front page
(PF) and middle page (PM)	29
Figure 4.9: Decontamination efficacy (± SE) versus decontamination treatment for personal
protective equipment (PPE) material	30
v

-------
List of Tables
Table 2.1: Decontaminants and Accessibility	11
Table 2.2: Decontamination Procedures and Intensity	11
Table 2.3: Decontamination Test Sequence Event	11
Table 3.1: Coupon Types Used to Evaluate Waste Decontamination Procedures	15
Table 3.2: Number of Sample Types per Material Section per Sampling Sequence	16
Table 4.1: Effects of Waste Storage Time on Positive Control Recoveries from Carpet for the
Extractive and Sponge-Stick™ Sampling Methods	20
Table 4-2: Post-Decontamination Spore Recoveries (CFU) for Carpet as a Function of
Decontaminant Procedure and Sampling Method	21
Table 4.3: Effects of Waste Storage Time on Positive Control Recoveries from Upholstery for the
Extractive and Sponge-Stick™ Sampling Methods	22
Table 4.4: Effects of Waste Storage Time on Positive Control Recoveries from Paper for the
Extractive and Sponge-Stick™ Sampling Methods	23
Table 4.5: Effects of Waste Storage Time on Positive Control Recoveries from Personal
Protective Equipment	24
Table 4.6: Preliminary Neutralization Optimization	25
Table 4.7: Decontamination Efficacy versus Type of Decontamination Treatment for Carpet
Material	26
Table 4.8: Decontamination Efficacy (Log Reduction) versus Type of Decontamination Treatment
for Paper Material	28
Table 4.9: Decontamination Efficacy (CFU LR) versus Type of Decontamination Treatment for
PPE Material	30
Table 5.1: Instrument Calibration Requirements	31
Table 5.2: Critical Measurement Acceptance Criteria	32
Table 5.3: Data Quality Assessment	33
Table 5.4: Quality Control Checks	35
Table 5.5: Quality Control Evaluation	36
Table 6.1: Summary of Waste Decontamination Results	38
vi

-------
List of Acronyms and Abbreviations
ATCC
American Type Culture Collection
BOTE
Bio-response Operational Testing and Evaluation
CBRN
chemical, biological, radiological, and nuclear
CFU
colony-forming unit
CMAD
Consequence Management Advisory Division (EPA/OLEM/OEM)
DCMD
Decontamination and Consequence Management Division (EPA/ORD/NHSRC))
EPA
U.S. Environmental Protection Agency
FAC
free available chlorine
FIFRA
Federal Insecticide, Fungicide, and Rodenticide Act
HSPD
Homeland Security Presidential Directive
HSRP
Homeland Security Research Program
ISO
International Organization for Standardization
LR
log reduction
MOP
miscellaneous operating procedure
NHSRC
National Homeland Security Research Center (EPA/ORD)
NIST
National Institute of Standards and Technology
OEM
Office of Emergency Management (EPA/OLEM)
OLEM
Office Land and Emergency Management (EPA)
OPP
Office of Pesticides Programs (EPA)
ORD
Office of Research and Development (EPA)
pAB
pH-adjusted bleach
PAA
peroxyacetic acid
PBST
phosphate-buffered saline with Tween®20
PF
paper front
PM
paper middle
PPE
personal protective equipment
QA
quality assurance
QAPP
quality assurance project plan
QC
quality control
RH
relative humidity
RTP
Research Triangle Park
SD
standard deviation
SE
sampling efficiency
STS
sodium thiosulfate
TSA
Tryptic Soy Agar
VHP®
vaporized hydrogen peroxide
vii

-------
Executive Summary
This project supports the mission of the U.S. Environmental Protection Agency's (EPA) Office of
Research and Development's (ORD) Homeland Security Research Program (HSRP) by providing
information relevant to the remediation of areas contaminated with biological agents.
Transporting waste contaminated with biological agents to remote treatment/disposal facilities incurs
costs and risks. If waste from a biological contamination incident could be shown to have no residual
biological agent present, then it might be able to be dealt with as conventional solid waste, which would
incur less transportation risk and less cost. The primary objective of this investigation was to determine
the effectiveness of an expedient on-site approach to waste decontamination. In this report, data are
frequently presented as the average log reduction (LR) for a particular test. In laboratory tests, if a
particular set of decontamination conditions achieves > 6 LR (against a 6-7 log challenge), the
decontamination is generally considered "effective." This benchmark is consistent with sporicidal efficacy
tests used to register sporicides under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).
Achieving complete kill (no viable agent recovered following the decontamination treatment) is considered
"highly effective."
A number of waste decontamination and management approaches have been used in previous bioterror
remediation operations, although their effectiveness has yet to be determined experimentally. Previously,
a study was conducted to determine the effectiveness of an immersion-based approach to
decontaminating waste materials contaminated with Bacillus atrophaeus spores (surrogate for Bacillus
anthracis). The study evaluated effectiveness of the immersion approach on high-traffic commercial
carpet tile, nitrile gloves (personal protective equipment [PPE]), books, and upholstered seat pans, which
are typical of porous materials found in an indoor office or items expected to be contaminated during
sampling and remediation (i.e., PPE). Most waste materials, with the exception of carpet, were effectively
decontaminated (greater than 6 log reduction [LR]) by a 15-minute immersion in pH-adjusted bleach
(pAB). Longer immersion times increased decontamination efficacy on carpet, but a 60-minute immersion
failed to provide more than a 4 log reduction in viable spores. In the previous study, diluted bleach and
pAB were unable to achieve complete kill for any of the material types tested.
The current study continued the investigation and sought to determine waste decontamination conditions
that would achieve effective or highly effective decontamination of all material types. For these tests,
more stringent decontamination procedures were evaluated specifically using pAB amended with a
surfactant and/or waste submersion procedures involving agitation. Further, an off-the-shelf
decontaminant solution (Spor-Klenz®) was evaluated for a comparative analysis with pAB submersion
procedures.
Test materials were inoculated with Bacillus spores at known locations and concentrations and subjected
to the prescribed decontamination procedure (i.e., immersion in decontaminant). After the
decontamination procedure, a subset of the test materials was sampled immediately, and then the items
were bagged and stored (to simulate waste handling/staging during a response). The simulated waste
items were resampled in a waste staging area after a drying time of 7 days. A subset of bagged,
inoculated waste samples was left untreated to serve as positive controls.

-------
The efficacies of three decontamination solutions (pAB, pAB with a surfactant, and Spor-Klenz®) were
determined using a single immersion time of 1 hour, with and without agitation of the solution. Two
sampling methods were used for carpet and upholstery: extractive and surface sampling with 3M Sponge-
Stick™. Only extraction-based methods were used for PPE and books.
The decontamination efficacy results were as follows:
•	The efficacy of the decontamination treatments using pAB on carpet materials, with or without
surfactant or agitation, and increasing the storage time up to 7 days was found in the range 2.0 to
3.4 LR, which is less than a 6.0 LR that is generally accepted to be effective during laboratory
evaluations.
•	The efficacy of Spor-Klenz® was found to increase over the 7-day period to reach a greater than 7
LR in colony-forming units (CFUs). Spor-Klenz® was found to be a more effective decontaminant
than pAB for bundled/bagged waste using an immersion/dunking approach. Spor-Klenz®
achieved complete kill of spores for almost all upholstery and paper material samples.
•	The results of the PPE (gloves) decontamination tests showed greater variability than the results
of the tests on office environment materials. In some of the gloves, full decontamination was
achieved in some of the glove fingers, but not in the others. The glove fingers where limited or no
decontamination is achieved might be the result of spores confined in areas (e.g., inside finger
tips) with no contact with the decontamination solution.
In addition to decontamination efficacy, the collection efficiency of the two sampling methods (extractive
and Sponge-Stick™) used in this study were compared as a function of material and elapsed time from
inoculation and from when the sample was collected. Analysis showed no significant effect of sample
storage time of up to 30 days on spore recovery when using either sampling method. The extractive
sampling approach was found to be superior, particularly for wet, porous materials.
The results of this study can inform decision makers regarding the utility of expedient waste
decontamination techniques. However, other inherent risks associated with the shipment of the
contaminated waste, post-decontamination material/decontaminant disposal, and landfill acceptance
criteria should be considered prior to implementation of such decontamination approaches in actual
remediation operations involving infectious or hazardous waste items.
ix

-------
1 Introduction
This project supports the mission of the U.S. Environmental Protection Agency's (EPA) Office of
Research and Development's (ORD) Homeland Security Research Program (HSRP) by providing
information relevant to the decontamination of areas contaminated as a result of an act of terrorism.
Under Homeland Security Presidential Directives (HSPDs) 5, 7, 8, and 10, EPA, in a coordinated effort
with other federal agencies, is responsible for "developing strategies, guidelines, and plans for
decontamination of...equipment, and facilities" to mitigate the risks of contamination following a biological
agent contamination incident.
EPA's National Homeland Security Research Center (NHSRC) aims to help EPA address the mission of
the HSRP by providing expertise and products that can be widely used to prevent, prepare for, and
recover from public health and environmental emergencies arising from terrorist threats and incidents.
NHSRC's mission includes providing expertise and guidance on the selection and implementation of
decontamination methods and providing the scientific basis for a significant reduction in time, cost, and
complexity of decontamination and waste handling activities. NHSRC's research supports EPA's Office of
Land and Emergency Management (OLEM), Office of Chemical Safety and Pesticide Programs, and the
regional offices. Close collaboration among the different program offices with homeland security
responsibilities is sought in order to rapidly increase EPA's capabilities to help the nation recover from a
terrorist event involving the intentional release of chemical, biological, radiological, and nuclear (CBRN)
materials.
In 2001, the introduction of a few letters containing Bacillus anthracis (anthrax) spores into the U.S.
Postal Service system resulted in the contamination of several facilities and the deaths of two postal
employees. Although most of the facilities in which these letters were processed or received were heavily
contaminated, they were successfully decontaminated with approaches such as fumigation with chlorine
dioxide or vaporized hydrogen peroxide (VHP®). Fumigation was used primarily in heavily contaminated
facilities. Other cleaning methods were used in less heavily contaminated facilities such as those that
were secondarily contaminated or those primarily contaminated facilities that showed a minimal presence
of anthrax spores. These other "expedient" or "low-tech" methods included removing contaminated items
from a contaminated area prior to ultimate treatment and disposal of the items at a specialized facility
(i.e., incineration then landfilling of the ash), and/or decontaminating them on-site (within or in proximity to
the contaminated structure) by inactivating the spores. In these incidents, decision makers' selection of
on-site or off-site destruction of spores was facility-dependent and took into account many issues (e.g.,
physical state of the facility). One important factor complicating the decision-making process was that
such decontamination was unprecedented for the United States government and no sporicidal
technologies had been proven or registered for use against B. anthracis spores at the time.
The cost of waste management for the 2001 incident proved to be very significant and was complicated
by the nature of the waste. Additional quick, effective and economical decontamination methods with the
capacity to be employed over wide areas (outdoor and indoor) are required to increase preparedness for
an incident involving the release of a biological agent. If the waste from a biological contamination
incident could be shown to have no residual biological agent present, then it might not require any special
packaging for transport to remote treatment/disposal facilities, and may be able to be dealt with as
conventional solid waste. So, since 2001, the emphasis for facility decontamination research has been to
identify and characterize efficacious on-site decontamination methods and to optimize the
1

-------
decontamination/waste management paradigm; this optimization could reduce the overall time and cost
required for the entire remediation. If proven effective, a lower tech approach to decontaminating waste
on-site could reduce overall decontamination costs by reducing the amount of waste treatment required
by off-site, specialized facilities (e.g., medical waste incinerators). On-site waste treatment could also
reduce the risk and complications associated with transporting contaminated materials to such facilities.
Developing and demonstrating on-site waste management solutions could increase EPA's readiness to
respond to a wide-area release that would generate contaminated waste volumes much larger than those
previously managed. Response and remediation activities associated with this type of incident will require
additional waste handling, segregation, and staging. These additional requirements illustrate the need for
efficacy data and improved process knowledge to support assessments regarding decontamination
operations and waste management.
Waste items (ceiling tile and carpet) generated during a recent facility-scale test (Bio-response
Operational Testing and Evaluation (BOTE study) [1] that were decontaminated during the study by
expedient methods (liquid bleach spray orspritz), bagged/managed in a manner typical of a real
remediation effort, stored (~ 6 months), and subsequently sampled, showed that significant quantities of
the test organism (B. atrophaeus) had survived the treatment and subsequent 6-month storage duration.
This finding indicates that current waste management techniques used during expedient decontamination
efforts can generate waste items that have residual contamination. Since the willingness of waste
treatment/disposal facilities to accept waste items might depend partly on the contamination level of the
items, identification and demonstration of methodologies that effectively decontaminate waste on-site
during low-tech decontamination activities are needed. This study evaluated several waste
decontamination strategies that could be conducted on-site.
For waste generated during the decontamination of typical indoor office or indoor residential settings, no
sampling methods have been standardized. Many waste items generated from the decontamination of
building interiors are expected to consist largely of porous materials [1], which pose challenges to
currently available sampling methods. To provide the data necessary to standardize a waste sampling
method, extraction-based and surface-wipe-based sampling methods were evaluated. Extraction-based
sampling consisted of excision and subsequent extraction of a portion of the material. Surface-wipe-
based sampling consisted of collection of the contaminant from the material surface with a Sponge-
Stick™ (3M, St. Paul, MN).
1.1 Process
The purpose of this study was to identify effective and efficient means to decontaminate waste on-site
and to compare the efficiency of the two sampling methods used. The decontamination and sampling
strategies utilized were selected by an EPA project team, which consisted of staff from the NHSRC within
EPA's Office of Research and Development, OLEM, and Region 7 Office. Effectiveness of each
decontamination approach was evaluated in terms of Logio Reduction (LR). Approaches that achieved >
6 LR (against a 6-7 log challenge), were considered "effective." This benchmark is consistent with
sporicidal efficacy tests used to register sporicides under the Federal Insecticide, Fungicide, and
Rodenticide Act (FIFRA). Achieving complete kill (no viable agent recovered following the
decontamination treatment) was considered "highly effective."
This study investigated decontamination of selected materials by an immersion (dunking) approach of
waste materials contaminated with B. atrophaeus spore inoculum (i.e., surrogate for B. anthracis). The
2

-------
effectiveness of this decontamination approach was evaluated for high-traffic commercial carpet tile,
books, and upholstered seat pans that are typical of materials found in indoor offices, or for items such as
nitrile gloves (personal protective equipment [PPE]) that would be expected to be contaminated during
sampling and decontamination operations. Replicate sections of test materials were inoculated at known
locations with a targeted number of Bacillus spores. After decontamination, sections of the test material
were sampled immediately and then bagged and stored (to simulate field waste handling procedures) in
the waste staging area. The decontaminated test materials were resampled after a drying time of 7 days
to determine if storage duration could increase the effectiveness of the decontamination treatment (where
decontamination treatment is defined, for the purpose of this study, as a prescribed decontamination
procedure). A subset of inoculated bagged waste samples was left untreated to serve as positive
controls. The sampling strategies discussed herein have been selected and optimized to determine the
survival of B. atrophaeus spores following decontamination treatment.
1.2	Project Objectives
The primary objective of this work was to continue efforts from a previous study that estimated the
efficacy of liquid-based decontamination approaches for on-site treatment of bundled or bagged waste
items typically generated during a Bacillus anthracis cleanup response for an indoor office setting. The
waste items, such as contaminated indoor office items, would generally be placed in bags or bundled for
transportation for off-site treatment and disposal during the removal process, however, this previous study
evaluated on-site alternatives. Within that study it was demonstrated that pH-adjusted bleach (pAB)
solution was efficacious (greater than 6 LR) for most of the materials tested (nitrile gloves, books, and
upholstered seat pans), it was less effective for carpet (4 LR in viable spores with 1-hour immersion time),
failing the generally accepted criterion of 6 LR to consider an approach effective during laboratory
evaluations of sporicides. Recovery of no viable spores following treatment was considered highly
effective. None of the waste decontamination procedures evaluated previously achieved complete kill for
any of the tested material types. Waste acceptance criteria are likely to be unknown prior to an incident,
therefore determining conditions that achieve complete kill are of interest.
In an effort to achieve complete kill for all material types, more rigorous tests incorporating a surfactant
and/or agitation have been designed and performed under this study. Additionally, submersion testing
using Spor-Klenz® (STERIS, Mentor, OH), with and without agitation, was performed on all materials for a
comparative analysis with the pAB submersion procedures.
The ultimate objective was to provide data to support development of a stepwise procedure(s) for on-
scene responders and decontamination teams to use for on-site waste treatment during responses
involving expedient approaches for the indoor environment. Demonstrated waste decontamination
procedures could reduce the cost and time of a response by reducing the number of waste
characterization samples required and increasing the acceptance of these types of wastes from more
waste management facilities, thereby providing a great capability for wide-area incidents.
1.3	Experimental Approach
The experimental approaches described throughout this document are consistent with a previous
study[2], whereby waste decontamination and sampling methods were evaluated.
3

-------
1.3.1	Testing Sequence
The following is the testing sequence used to meet the objectives of this project:
1.	Prepare material sections for each test material as described in Section 2.3.
2.	Pre-punch material sections (carpet, upholstery, and book materials), and retain the excised sections
for use as 18-mm (0.7-in) diameter coupons for extraction-based sampling procedure. The nitrile
gloves did not require the use of 18-mm punch coupons, but rather the 25.4-mm (1 -in.) tip of each
finger was used for extraction-based analysis.
3.	Assemble the material sections by reinserting the 18-mm excised coupons into their respective void
areas of the material section.
4.	Sterilize the materials prior to inoculation using ethylene oxide or VHP® sterilization. Wait a minimum
of 7 days after sterilization before inoculating materials (See Section 2.4.1).
5.	Inoculate 18-mm positive control and test material coupons (without removing from larger material
section), each fingertip of each nitrile glove PPE, and the target page samples.
6.	Allow inoculum carrier to dry for at least 18 hours.
7.	Apply the decontamination procedure to the procedural blank material section batch then to the test
material section batch.
8.	Collect the samples from material sections immediately upon completion of the decontamination
procedure.
9.	After sample collection, bag the material batch such that the total weight does not exceed 35 lb per
bag.
10.	Sample remaining bagged material sections in the waste staging area after a drying time of 1 day (at
least 18 hours), 7 days, and 30 days.
1.3.2	Decontamination Strategy
The decontamination procedures used for carpet and PPE materials included submersion in pAB with
surfactant and/or agitation. For all materials, decontamination efficacy was evaluated for Spor-Klenz®
(1.0% by wt. hydrogen peroxide, 0.08% peracetic acid, and <10% acetic acid), for a duration of 60
minutes submersion, with no agitation.
1.3.3	Method Development for Neutralization
The presence of decontamination solution components in the rinsate or extraction liquid (desorbed from
the coupon) could negatively bias colony-forming unit (CFU) quantification results. Prior to the
decontamination testing sequence, neutralization tests were performed to determine the amount of
neutralizer liquid needed to quench each decontaminant/application combination. Decontaminant
neutralizers were added to liquid samples immediately after collection to quench their activity, resulting in
precise chemical exposure durations and lower recovery bias.
4

-------
2 Materials and Methods
2.1 Facility Design
All decontamination activities were conducted inside the spray booth area located in the EPA's Research
Triangle Park (RTP), NC facility in room H122A of the High Bay building, a room with a single access
point and ventilation independent of the High Bay building. The spray booth also served as the waste
staging area.
The immersion tank was a 0.28 m3(10 ft3) Poly Hog Trough® (EZ Grout Corp., Waterford, OH) made of
virgin polyethylene with steel legs (http://www.ezgrout.com/index.php/products/supply/hog-trough) (Figure
2.1). The overall dimensions of the tank were 66.04 cm x 138.43 cm x 60.96 cm (26 in. x 54% in. x 24 in.).
2.2 Agitation
Tests that prescribed agitation during the immersion step utilized a low-pressure air pneumatic apparatus
(Figure 2.2) to simulate physical agitation of waste items during decontamination procedures. It was
hypothesized that agitation may increase decontaminant contact with waste items and thereby increase
treatment efficacy. House air was forced through four 1,9-crn (%-in.) tubes, positioned equidistant along
the length of the submersion vessel, at a rate of 20 L/min. Air was supplied to the decontamination
solution during the entire submersion procedure.
Figure 2.1: Poly Hog Trough®.
5

-------
!¦¦¦
Figure 2.2: Top view of the immersion vessel retrofitted for agitation.
2.3 Test Coupon Preparation
All coupons were sterilized prior to use to prevent any background organisms from confounding the tests.
The books and the glove materials were fumigated with ethylene oxide using an Andersen (Haw River,
NC) EO-Gas® 333 sterilization system. The carpet and the upholstered coupons were fumigated via a 250
ppm, 4 hours vaporous hydrogen peroxide (VHP®) sterilization cycle, followed by an overnight aeration
process. To prevent cross contamination, on the day of testing, procedural blank coupons were moved
into the spray chamber, and procedural blank decontamination occurred before decontamination of any
inoculated coupons.
2.3,1 Carpet and Upholstery
The carpet coupons were ready-made 0.61 -m x 0.61-m (24-in. x 24-in.), 100% nylon tiles (P/N Multiplicity
Tile 54594, Shaw Industries, Dalton, GA, USA), exuberant 00310 color type (Figure 2.3). Upholstered
0.51-m x 0.51-m (20-in. x 20-in.) coupons were prepared in-house with layers of foam and fabric adhered
together (Figure 2.4). Each set of five material coupons were bundled and tested together.
Figure 2.3: Carpet tile.
6

-------
Figure 2.4: Front of assembled upholstered coupon.
2.3.2 Paper
Paper samples consisted of the entire front cover (inside cover inoculated) along with the first page of the
Merck Manual of Medical Information (Second Home Edition, 2004) (Figure 2.5) and pages 955
(inoculated) plus one page before and two pages after (953-960). Each page measured 22.8 cm x 16.5
cm (9 in. x 6.5 in.).
- 	>
THE	
MERCK
MANUAL
OF
MEDICAL INFORMATION
SECOND
HOME EDITION
The world's most widely used
medical reference for the twenty-first century
The complete and unabridged national bestseller
Figure 2.5: Paper material.
7

-------
2.3.3 Nitrile Gloves
The material chosen to represent PPE waste consisted of powder-free white disposable nitrile gloves,
5.5 mm (0.21 in.) thick and 22.8 cm (9 in.) in length (McMaster part #52555T 15, www.mcmaster.com').
illustrated in Figure 2.6. The powder-free gloves are considered superior for applications where
particulate contamination is a concern. Whole gloves were utilized; however, the tips of each finger were
inoculated and served as replicates. Gloves were inverted following inoculation, yet prior to testing, to
simulate field conditions where gloves are turned inside out during doffing procedures.
Figure 2.6: White disposable nitrile glove.
2.4	Spore Preparation and Coupon Inoculation
The test organism for this investigation was a liquid spore suspension of B. atrophaeus (strain: ATCC®
9372) in 29% ethanol solution. This bacterial species was formerly known as B. subtilis var niger and
subsequently B. globigii. The spores were purchased from Yakibou, Inc. (Holly Springs, NC) at a
population density of 1 x 109 CFU per mL. The titer of the stock was confirmed at the start of each testing
event.
Inoculation of the 18-mm coupons (carpet and upholstery) and the front cover and middle pages of the
books was performed by aseptically applying 100 jj.L of a diluted spore solution to reach a target recovery
of 5 x 107 CFU from each positive control sample. Fingertips of the nitrile gloves were inoculated to reach
the same target concentration. Gloves were inoculated on the exterior surface of each fingertip, allowed
to dry for 18-24 hours, and then turned inside out prior to use in testing.
2.5	Decontamination Solutions
The pH-adjusted bleach was prepared as follows: one part Clorox® concentrated germicidal bleach
(Clorox Corp., Oakland, CA) was diluted with eight parts of deionized water and one part 5% (v/v) acetic
acid (Fisher Scientific, Pittsburgh, PA; Part# 13025, or equivalent). The pH was adjusted to 6.5-7.0 with
5% acetic acid, and the free available chlorine (FAC) content was adjusted to 6000-6700 ppm with
deionized water after preparation. The pH-adjusted bleach was used within 3 hours of preparation. The
diluted bleach was prepared fresh prior to testing by mixing one part Clorox® concentrated regular bleach
with approximately 14 parts of deionized water to reach a target FAC of approximately 6000 ppm. Safety
8

-------
precautions were taken to protect personnel from liberated chlorine gas produced as a result of pH
reduction of the bleach solution. The pH-adjusted bleach with surfactant was prepared by adding 1.8 oz.
(50 mL) of the surfactant (original Tide® [Procter and Gamble, Cincinnati, OH]) to every 20 gallons of pH-
adjusted bleach solution.
The FAC concentration of bleach formulations was measured based on ASTM Method D2022-89 [3] .
A 5-mL aliquot was mixed with a buffered potassium iodide solution and iodometrically titrated with
sodium thiosulfate (STS) to a colorless end point. The aliquot was taken and analyzed immediately after
formulation and mixing. The validity of the FAC measurement equipment (Hach® [Hach Company,
Loveland, CO] high-range bleach test kit, Method 10100 [model CN-HRDT]) was confirmed through the
titration of a chlorite ion standard. The pH of each solution was measured with an Oakton Acorn® series
pH 5 meter (Oakton Instruments, Vernon Hills, IL). This meter was calibrated daily.
Spor-Klenz® solutions were prepared from Spor-Klenz® concentrate as directed by the manufacturer for
sterilization by diluting 1 part Spor-Klenz® with 99 parts deionized water. Final hydrogen peroxide and
acetic acid concentrations were measured as follows: A 5-gram sample was mixed with 50 mL of 1 N ice-
cooled sulfuric acid. Ferroin indicator was added, and then the sample was titrated with 0.1 N eerie sulfate
to an orange-pink end point. Next, 4 grams of potassium iodide (Kl) was added and a red color was
allowed to develop. Starch indicator was then added, and the sample was titrated with 0.0375 N STS to a
pale orange end point.
2.6 Decontamination Procedure
The general decontamination procedure consisted of "dunking" a batch of coupons in the immersion tank
containing the decontamination solution for a prescribed immersion time. This decontamination procedure
is described below:
1.	Prepared decontaminant bath in chemical resistant container. Performed all required quality control
(QC) checks listed in Table 5.2.
2.	Collected the material batch for immersion, which consisted of three pre-punched sterile material
sections (containing the test samples) and enough non-punched sterile material sections (did not
contain test samples) to fill the waste storage bag (not to exceed 16 kg [35 lb] when wet; amounts
varied per material). Of the material sections in each batch, only three sections of the decontaminated
material were inoculated with Bacillus spores. For example, of a 16 kg batch of carpet tiles, only three
tiles contained inoculated 18-mm coupons.
3.	The material batch (not to exceed 35 lb when wet) was submerged in the decontaminant bath and
subjected to the prescribed decontamination procedure.
4.	Removed material sections and allowed them to drain briefly (15 minutes) over the decontaminant
bath, and then immediately collected the post-decontamination (To) samples per material type.
5.	Aseptically transferred decontaminated materials to a labeled 55-60 gallon contractor's storage bag
(Uline model S-19876 [Uline, Pleasant Prairie, Wl]), which remained closed in the waste staging area
until the next sampling event. Material types were bagged separately and arranged such that one
inoculated material section was located at the bottom of the batch, one was located in the middle, and
one was located on the top.
9

-------
This procedure was repeated for each material using a single immersion container. Therefore, the
immersion container was sanitized between tests by removing all debris, wiping interior surfaces with
Dispatch® hospital cleaner disinfectant wipes with bleach (The Clorox Company, Oakland, CA), rinsing
interior surfaces with deionized water, and then drying them with 70% ethanol prior to the start of each
test. Containers were sampled by swab prior to test initiation to confirm sterility.
Testing was performed using a "clean team/dirty team" technique. The "dirty team" was responsible for
moving the material sections into and out of the immersion tank and performing the decontamination
procedure. The "clean team" was used for procedural blank, control, and test sampling. Only dirty team
members handled contaminated items, and only clean team members handled procedural blank coupons
and samples. New disposable lab coats were worn for each new material or contamination level. Fresh
gloves were donned prior to performing the decontamination procedure and then changed before
handling the material section after completion of the decontamination procedure. Dirty team members
could become clean team members by donning a new set of protective garb (inner and outer gloves, lab
coat, P95 mask, and hair net).
2.7	Method Development for Neutralization
The presence of decontamination solution components in the rinsate or extraction liquid (desorbed from
the sample) could negatively impact bacterial culture-based assays and therefore bias spore recovery
estimates. Prior to the decontamination testing sequence, neutralization tests were performed to
determine the amount of neutralizer liquid required to quench residual decontaminant produced from
each decontaminant/application combination.
HACH® Method 10100 (http://www.hachco.ca; Hach Company, Loveland, CO) for high-range bleach was
used to experimentally determine the amount of STS required to neutralize in excess the active ingredient
(i.e., free available chlorine [FAC]) in pAB. Hydrogen peroxide (H202)-peracetic acid (PAA) titration was
used to determine the residual hydrogen peroxide and peracetic acid concentrations in exposed samples
to determine the volume of STS required for neutralization. Due to the variation of the amount of
decontaminant solution on the coupons, excess of stoichiometric neutralization was evaluated to ensure
that it did not affect spore recovery estimates. Analyses of the spores in the optimized excess neutralizer
solution was also evaluated at 1-hour and 24-hour hold times to see if the lag time for processing the
samples had an effect on the viable spore recoveries. Finally, the effect of spore inoculation concentration
and the decontamination time on the neutralization test recoveries were also evaluated.
2.8	Test Matrix
The test matrix was initially devised to optimize the on-site decontamination procedures by maximizing
efficacy and minimizing the manual effort and hazard level of the procedure. The decontaminant
optimization process was designed to test decontaminants in order of accessibility (i.e., order of chemical
and equipment availability) and simplicity of execution. This order is shown in Table 2.1. The planned
decontamination procedures, in order of increasing intensity, were immersion and then immersion with
agitation, as shown in Table 2.2. Table 2.3 shows the test matrix that was performed and described in this
report. When a decontaminant procedure was found to be effective for a material type, subsequent tests
with more stringency were forgone for that material type.
10

-------
Table 2.1: Decontaminants and Accessibility
Decontaminant
Decreasing Accessibility
pH-adjusted bleach
i
}
pH-adjusted bleach with surfactant
Spor-Klenz®
Table 2.2: Decontamination Procedures and Intensity
Decontamination Procedure
Increasing Intensity
Immersion

)
Immersion with agitation
Table 2.3: Decontamination Test Sequence Event
Decontamination
Procedure
Decontaminant
Solution
Material
Type
Exposure
Time
Test Date
(DayO)
End Date
(Day 7)
Immersion with agitation
pAB
PPE
60 minutes
Nov 10, 2014
Nov 17, 2014
Immersion
pAB with surfactant
PPE
60 minutes
Nov 18, 2014
Nov 25, 2014
Immersion
pAB with surfactant
Carpet
60 minutes
Jan 6, 2015
Jan 13, 2015
Immersion with agitation
pAB
Carpet
60 minutes
Jan 8, 2015
Jan 15, 2015
Immersion with agitation
pAB with surfactant
Carpet
60 minutes
Jan 20, 2015
Jan 27, 2015
Immersion
Spor-Klenz®
Carpet
60 minutes
Jan 27, 2015
Feb 3, 2015
Immersion with agitation
pAB with surfactant
PPE
60 minutes
Jan 29, 2015
Feb 5, 2015
Immersion
Spor-Klenz®
PPE
60 minutes
Feb 5, 2015
Feb 12, 2015
Immersion
Spor-Klenz®
Upholstery
60 minutes
May 13, 2015
May 20, 2015
Immersion
Spor-Klenz®
Paper
60 minutes
May 21, 2015
May 29, 2015
pAB, pH-adjusted bleach; PPE, personal protective equipment
11

-------
3 Sampling Methods
3.1 Sampling Approach
Prior to each sampling event, all materials needed for sampling were prepared using aseptic techniques
and placed in a bin containing enough sampling kits, gloves, and bleach wipes to accommodate all
required samples for the specific test. The materials specific to each protocol are included in the relevant
sections below.
In an effort to minimize the potential for cross contamination during sampling, and in accordance with
aseptic technique, a sampling team was utilized. The team was made up of a "sampler" (handling only
the sampling media), a "coupon handler" (the only person to handle material coupons during the sampling
event), and a "support person" (who in addition to being responsible for handing sterile templates to the
sampler was also responsible for handling sealed samples and disinfecting outer bags and containers for
transport).
Within a single test, sampling of the material sections was completed for all procedural blank coupons
first before sampling of any test material or control sections. Sampling was done by collecting the
coupons for extraction first, then sponge sampling the remaining coupons according to the protocols
documented below. The surface area for sponge samples was approximately 103 cm2 (16 in.2) for carpet
material and 79 cm2 (12.25 in.2) for the upholstery material. The extraction coupons were 18 mm
(0.71 in.) in diameter. Once sampling was complete, material sections were returned to their original
waste storage bags.
Sponge-stick and stub sample integrity was maintained by storage of samples in triple containers
(1 - sample collection container, 2 - sterile bag, 3 - disinfected container holding all samples from a test).
All individual sample containers remained sealed while in the decontamination lab or in transport after the
introduction of the sample.
Since the current sampling techniques are intrusive, each coupon was sampled only once. However,
each test was replicated 3-5 times, as described in Section 3.5. Test coupons and positive controls were
sampled in parallel for each sampling time sequence. Temperature, pH, and active ingredient
measurements of each decontaminant solution were performed prior to each decontamination procedure.
The temperature and relative humidity (RH) of the waste staging area were recorded by three
strategically placed, calibrated HOBO® data loggers (Onset Computer Corporation, Bourne, MA).
Additional measurements included QC checks on the reagents and equipment used in the
decontamination procedure.
3.1.1 Sponge-Stick™ Sampling
3M™ Sponge-Sticks with Neutralizing Buffer (part number SSL10 NB; 3M, St. Paul, MN) were used to
aseptically sample the surface of carpet and upholstery materials. Sampling templates with 25 individual
sampling areas were used as a guide. The sampling process was performed according to the
standardized Centers for Disease Control and Prevention method "Surface sampling procedures for
Bacillus anthracis spores from smooth, non-porous surfaces" [4].
12

-------
3.1.2 Extractive Sampling
The 18-mm coupons for extractive sampling were removed from the sampling area and transferred to the
into 50-mL sterile vials containing 10 mL phosphate-buffered saline with Tween®20 (PBST) (Sigma-
Aldrich, St. Louis, MO) and the predetermined amount of neutralization liquid (STS). For PPE samples,
excess pAB was captured in a separate vial for subsequent analysis.
3.2 Sample Type
3.2.1 Carpet and Upholstery
Samples were collected from a 5 x 5 pre-drawn sampling grid consisting of 10.2-cm x 10.2-cm (4-in. x
4-in.) grid size sections (Figure 3-1). An 18-mm diameter coupon was excised from the center of each
grid section for sample inoculation. For each sampling event, the 18-mm coupons were either removed
for extraction or left in place to be part of the grid section that was sampled by the Sponge-Stick™
approach. When possible, Sponge-Stick™ and extraction samples were taken from areas representing
different parts of the coupon (center, sides, and corners).
Figure 3.1: Material section shown with template during sampling with Sponge-Stick™ and 18-mm
coupon removal.
3.2.2 Paper Samples
Paper samples, designated paper front (PF) and paper middle (PM), included the front cover and first and
middle pages, as described previously. The additional pages adjacent to those inoculated were collected
to account for any spores being relocated (via capillary action, direct transfer, etc.) to the adjacent pages
during inoculation and/or decontamination. Sterile razor cutters were used to excise the paper samples
after decontamination testing. Once excised, the paper samples were put inside a sterilized pre-labeled
Stomacher® bag (Seward, Sussex, UK) along with 80 mL of PBST and a pre-determined volume of STS
Sampling
template
18 mm coupon
(installed)
Sponge Stick
~
18 mm coupon
(removed)
Material
section
13

-------
neutralizer arid mixed together. Eight books were used for each sampling sequence (three books for test
samples: front and middle pages and inside cover page; two books for positive controls: front and middle
pages; two books for field blank samples: front and middle pages; and one book for laboratory blank: front
and middle pages. A total of 32 books were used for the four test sequences for each decontamination
method.
3.2.3 PPE Samples
Gloves were inoculated on the outside and then aseptically turned inside out to mimic removal and
placement into a decontamination line waste stream. Three gloves were inoculated for each test (three
samples from three inoculated fingers—thumb, middle, and pinky—for each glove, resulting in nine
samples), one glove for positive controls (five samples from all five inoculated fingers), one glove for field
blank sample (three non-inoculated fingers), and one glove for a laboratory blank sample (one sample
from one non-inoculated finger) for a total of six gloves per test sampling sequence, or 24 gloves for the
four test sequences for each decontamination method.
Following decontamination, the terminal 2.5 cm (1 in.) of each finger was excised (Figure 3.2) and
collected as an individual sample.
Figure 3.2: PPE sample (finger) excision.
3.3	Sample Preservation
After sample collection for a single test was complete, all biological samples were transported to the
NHSRC RTF Microbiology Laboratory immediately, with appropriate chain of custody form(s), and stored
at 4 ± 2 °C until processed. All samples were allowed to equilibrate at room temperature for 1 hour prior
to extraction and plating. Liquid samples were stored no longer than 24 hours prior to analysis. Samples
of other matrices were stored no longer than 5 days before the primary analysis. A typical holding time
was 2 days prior to analyses for most biological samples.
3.4	Sampling Points
All samples were collected from wet materials immediately after application of the decontamination
procedure or after the required hold time (as bagged waste in the waste staging area) and neutralized
14

-------
immediately after sample collection. Table 3.1 lists the coupon types and the respective sampling
procedures.
Table 3.1: Coupon Types Used to Evaluate Waste Decontamination Procedures
Material
Porous or
Non-porous
Material Description
Coupon/Sample Size
Sampling
Procedure(s)
Carpet
Porous
Building material, high-traffic
commercial carpet tile, 61 cm x
61 cm (24 in. x 24 in.)
18-mm punch /101 mm
x 101-mm square
Extraction /
Sponge-Stick™
Upholstered
furniture
Porous
Upholstered seat pan, 51 cm x
51 cm (20 in. x 20 in.)
18-mm punch / 89-mm
x 89-mm square
Extraction /
Sponge-Stick™
Paper
Porous
Book pages
Whole front and middle
pages/22.8 cmx 16.5
cm (9 in. x6.5 in.)
Extraction
PPE materials
Non-porous
Nitrile, powder-free, disposable
exam gloves
2.5 cm (1 in.) tip of
finger
Extraction
PPE, personal protective equipment
3.5 Sampling Frequency and Sample Quantities
After the waste decontamination procedure was executed, material sections were either sampled
immediately or bagged and stored in the waste staging area for subsequent sampling after a drying
period of 7 days. Figure 3.3 outlines the sampling timeline for both sampling approaches (extraction and
Sponge-Stick™). The indicated number of test samples was collected from each of the three inoculated
material sections as well as from procedural blanks (non-inoculated coupons that were exposed to test
procedures) and positive control sections (inoculated coupons that were not exposed to test procedures).
This timeline was developed to model the hold times decontaminated materials might be subject to on-
site prior to being transported off-site for final disposal. Three positive control and three procedural blank
samples were collected during each sampling event. Positive control coupons were inoculated
concurrently with test coupons so they would have the same bacterial aging times as the samples. The
synchronization of inoculation and sampling of positive control and test coupons was critical for accurate
log reduction analysis. Bagged untreated positive control materials were sampled at the same time (within
8 hours) as their decontaminated counterparts.
Immediately After Decon (T0)
•	3 test coupons removed for
extraction
•	3 test coupons Sponge- Stick™
sampled
•	3 positive controls, 3
procedural blanks
7 Days After Decon (T7
•	3 test coupons removed for
extraction
•	3 test coupons Sponge- Stick™
sampled
•	3 positive controls, 3
procedural blanks
Figure 3.3: Sampling timeline.
15

-------
The number of samples collected for both the neutralization and on-site decontamination tests are
outlined in Table 3.2. This table includes not only the biological samples, but also samples collected to
describe the decontamination process for each test in the test matrix. Some tests required 18-mm
samples, sponge samples, or both. For tests that indicate both 18-mm and sponge samples were
collected, the sample quantities for sterility blanks, positive control samples, procedural blanks, and test
samples for both sample types were identical.
Table 3.2: Number of Sample Types per Material Section per Sampling Sequence
Test
Type of Sample
Material
Laboratory
Blank
Positive
Control
Samples
Field
Blanks
Test
Samples
Extractive
Samples
(Y/N)
Sponge
Samples
(Y/N)


Ea
S»
E
S
E
S
E
S

STSC
0
0
5
0
0
0
5
0
Y
N
On-Site
Carpet coupons
1
1
3
3
3
3
3
3
Y
Y
Decontamination
Upholstered coupons
1
1
3
3
3
3
3
3
Y
Y
Day (To Days, T7Days)
PPEd
1
0
5
0
3
0
15
0
Y
N

Paper
2
0
6
0
2
0
6
0
Y
N
aNumber of extractive samples
bNumber of Sponge-Stick™ samples
cTests performed for the neutralization tests that span all four materials.
dEach finger of a glove is considered one sample; note that, for the gloves, runoff samples were also collected.
3.6 Measurement Methods
In addition to the collection of material samples, temperature, pH, and active ingredient measurements of
each decontaminant solution were performed prior to each decontamination procedure. The temperature
and RH of the waste staging area were recorded by three strategically placed, calibrated HOBO® data
loggers. Additional measurements included quality control checks on the reagents and equipment used in
the decontamination procedure.
3.6.1 Microbiological Samples
General aseptic laboratory technique was followed to prevent cross contamination. Additionally, the order
of analysis (consistent with the above) was as follows: (1) all blank coupons, (2) all decontaminated
coupons, and then (3) all positive control coupons. Both coupon and Sponge-Stick™ extract samples
were diluted, plated, and manually enumerated. Details of the extraction and analytical procedures are
provided below.
3.6.1.1	Sample Extraction
Extraction sample vials containing 18-mm coupons, PBST (Sigma-Aldrich, St. Louis, MO, P/N P3563-
10PAK), and neutralizer were vortexed for 2 minutes to dislodge viable spores from the coupon. Each vial
was briefly re-vortexed immediately before any solution was withdrawn for dilution or filter plating.
3.6.1.2	Sample Analysis
Experimental samples were subjected to up to five-stage serial dilutions (10-1 to 10-5), plated in triplicate
onto Tryptic Soy Agar (TSA) and incubated overnight at 35 ± 2 °C. Following incubation, CFUs were
manually enumerated. Samples that had fewer than the reportable limit of 30 CFU/plate of the undiluted
sample underwent further analysis filter-plating, and subsequent attempted cultivation of surviving
16

-------
bacterial spores in liquid growth media. This method allowed a lower limit of detection for bacterial
recovery/survivorship assays.
3.7 Data Analysis
The total spore recovery for each method, material, and time point was calculated by multiplying the
mean CFU counts from triplicate plates by the inverse of the volume plated (e.g., 1/0.1 mL or 10), by the
dilution factor, and finally by the volume of the sample extract (X mL for Sponge-Stick™ samples and
Y mL for extracted stubs).
3.7.1	Sampling Efficiency
To determine which of the two sampling methods employed in the study was more efficient at recovering
viable spores on the waste materials tested, the sampling efficiency (SE) for each method, all time points,
and material types was calculated. SE is defined as the ratio of the measured mean sampled CFU
(CFUm) to that of the inoculums (CFUo):
CFU
SE-as?	<3-1)
3.7.2	Surface Decontamination Efficacy
The efficacy of each decontaminant was assessed by determining the number of viable organisms
remaining on each inoculated test coupon after decontamination and comparing this result to the number
of viable organisms extracted from the positive control coupons, which were inoculated but not
decontaminated. Excess decontamination solutions (in the form of rinsate) were also analyzed from PPE
samples to determine if the representative decontamination application washed the spores from the
surface of the PPE coupons or if the decontaminant inactivated the spores.
The surface decontamination efficacy is defined as the extent (as logio reduction) by which viable spores
extracted from test coupons after decontamination were less numerous than the viable spores extracted
from positive control coupons. First, the logarithm of the CFU abundance from each coupon extract was
determined, and then the mean of those logarithm values was determined for each set of control and
associated test coupons, respectively. This value is reported as a log reduction on the specific material
surface as defined in Equation 3-2.
Łlog (CFUck) J>g (CFUsk)
rj=——-	——-		(3-2)
>'	Nc	Ns
where:
Surface decontamination effectiveness; the average log
T], = reduction of spores on a specific material surface (surface
material designated by /).
17

-------
f>g(c™cl)
k=1
The average of the logarithm (or geometric mean) of the
number of viable spores (determined by CFU) recovered on
the control coupons (C indicates control and Nc is the number
of control coupons).
f>g(c™„)
k=1
N,
The average of the logarithm (or geometric mean) of the
number of viable spores (determined by CFU) remaining on
the surface of a decontaminated coupon (S indicates a
decontaminated coupon and Ns is the number of coupons
tested).
When no viable spores were detected, a value of 0.5 CFU was assigned for CFUs,k, and the efficacy was
reported as greater than or equal to the value calculated by Equation 3-2.
The cumulative standard deviation for the LR is calculated as follows:
Let SDUn and SDTr denote the standard deviations of the log reduction values for the untreated carriers
(positive controls) and the treated carriers (post-decontamination samples), respectively. Then, the
cumulative standard deviation is calculated as follows:
Where: nun and ntr designate the number of control and post-decontamination samples, respectively.
3.7.3 Statistical Analysis
To determine if either the extraction or sponge sampling method was better for collecting spores, a paired
independent Student's t-test using the two-tailed distribution was performed for each decontamination/
material combination. The null hypothesis of this test is that no statistical significance is observed
between the paired populations (extraction versus sponge stick methods). In other words, if the p-value is
less than 0.05 (95% confidence interval), the null hypothesis is rejected and there is evidence that the
data from the sampling methods are different. On the other hand, if the p-value is greater than 0.05, then
the two sampling methods are comparable.
(3-3)
18

-------
4 Results and Discussion
This section presents the results of the overall effectiveness of the dunking or immersion of the waste to
reduce and/or inactivate spores of B. atrophaeus from contaminated materials typical of indoor
environments and of PPE waste items generated during sampling and decontamination operations.
Effectiveness was determined by sampling the waste contents following decontamination and comparing
to sampling controls that did not undergo the decontamination treatment. A 7 log spore challenge
(inoculation of simulated waste items with ~ 5 x 107 spores) was used across all tests and materials.
Consistent with sporicidal efficacy tests used to register sporicides under FIFRA, the current study utilized
the generally accepted criterion of 6 LR to consider an approach effective. Recovery of no viable spores
following treatment was considered highly effective.
Evaluation of the two sampling methods (extraction versus Sponge-Stick™) is discussed in Section 4.1.
The results for the neutralization tests performed prior to each decontamination sequence are presented
in Section 4.2. The results of the decontamination approach that utilized dunking or immersion of the
waste are reported in Section 4.3.
4.1 Sampling Methods Evaluation
The performance of the two sampling methods (extractive and Sponge-Stick™) was evaluated by
comparing positive controls and post-decontamination recoveries at Day 0 and Day 7 for carpet,
upholstery, paper materials, and PPE.
4.1.1 Carpet Material
4.1.1.1 Positive Controls
Spore recoveries of positive control samples from carpet as a function of sampling method and over two
simulated waste storage times (sampling time delay) are shown in Figure 4.1 and summarized in
Table 4.1. The average recoveries, independent of storage time, were 1.21 x 107 CFU (SD = 5.69 x 106,
n = 24 samples) using the extractive method (removal of a coupon from a larger sample) and 1.79 x 105
CFU (SD = 1.55 x 105, n = 24 samples) using the Sponge-Stick™ sampling approach. These results
confirm the results from the previous study [2], which showed that the extractive sampling approach is
more efficient than the Sponge-Stick™ sampling method. A two-sample independent t-test for these data
show a p-value less than 0.001, confirming that the populations means between the two sampling
methods are significantly different. No significant effects of storage time on recoveries were detected for
either sampling method (p-value = 0.08 and 0.33 for the extractive and Sponge-Stick™ sampling
techniques, respectively).
19

-------
I I Extractive Method
Sponge-Stick™ Method
Day 0	Day 7
Waste Storage (Days)
Figure 4.1: Spore recoveries (± SD) from carpet using the extractive and Sponge-Stick™ methods.
Table 4.1: Effects of Waste Storage Time on Positive Control Recoveries from Carpet for the
Extractive and Sponge-Stick™ Sampling Methods
Waste Storage Time
Spore Recovery (CFU)
Extraction
Sponge-Stick™
Average
SD
Average
SD
Day 0
1.36E+07
6.11E+06
1.93E+05
1.61E+05
Day 7
1.05E+07
5.04E+06
1.85E+05
1.47E+05
4.1.1.2 Post-Decontamination Sample Recoveries
The results presented in this section report the overall effectiveness of each sampling
method/decontaminant procedure combination applied to carpet coupons. Sections of the test materials
were sampled immediately after the decontamination treatment and were bagged and resampled and
reanalyzed after a drying time of 7 days. The post-decontamination results are presented in Figure 4.2
and summarized in Table 4.2.
20

-------
10-
o
0
§
01
Ł
o
CL
C/D
c
8
0
Q
1)3
R.
10";
1Q2 ¦¦
101":
10°
A
ffl
of®

of®

*2*

] Extractive Sampling (Day 0)
] Extractive Sampling (Day 7)
] Sponge-Stick™ (DayO)
I Sponge-Stick™ (Day 7)
r#'

Decontamination Treatment
9?°

Figure 4.2: Post-decontamination spore recoveries (± SD) for carpet as a function of
decontaminant procedure and sampling method.
Table 4-2: Post-Decontamination Spore Recoveries (CFU) for Carpet as a Function of Decontaminant
Procedure and Sampling Method
Decontamination
Solution
Extraction
Sponge-Stick™
DayO
Day 7
DayO
Day 7
Average
SD
Average
SD
Average
SD
Average
SD
pAB with surfactant
5.65E+03
3.86E+03
5.07E+03
3.29E+03
7.24E-01
3.17E-02
1.54E+00
2.03E+00
pAB with
su rfactant-agitati on
6.84E+04
4.42E+04
4.87E+04
1.99E+04
6.45E-01
1.47E-02
3.41 E+03
4.84E+03
pAB with agitation
2.12E+04
1.50E+04
2.75E+04
1.09E+04
7.17E-01
8.01 E-02
2.05E+00
2.83E+00
Spor-Klenz®
3.41 E+04
1.80E+04
S.7.35E-01*
2.72E-01
S.7.09E-01*
4.68E-02
S.8.52E-01*
8.52E-01
*Less than or equal to the detection limit.
pAB, pH-adjusted bleach
The post-decontamination results confirm that extractive sampling achieves higher recoveries than
Sponge-Stick™ sampling for carpet. The wetness of the samples (Day 0) seems to reduce sampling
efficiency of the Sponge-Stick™ when compared to higher recoveries achieved after the 7-day drying
period. No significant effects of storage time on recoveries for the extraction method were observed for
the decontamination solutions other than Spor-Klenz®. The Spor-Klenz® low post-decontamination
recoveries after a 7-day period indicate a residual decontamination of the coupon during the drying
period, suggesting that the residual decontamination was still ongoing during the 7-day waste storage.
21

-------
4.1.2 Upholstery Material
Spore recoveries from upholstery material as a function of simulated waste storage time (sampling time
delay) are shown in Figure 4.3 and summarized in Table 4.3. The average recoveries were 9.45 x 107
CFU (SD = 9.00 x 107, n = 6 samples) using the extractive method (removal of a coupon from a larger
sample) and 9.24 x 106 CFU (SD = 1.93 x 106, n = 6 samples) using the Sponge-Stick™ sampling
approach. A two-sample independent t-test showed that, at the 95% confidence interval, the difference of
the population means is not significant (p = 0.07).
Extractive Method
Sponge-Stick™ Method
Day 0	Day 7
Waste Storage (Days)
Figure 4.3: Effect of waste storage time on positive control recoveries (± SD) from upholstered
material for the extractive and Sponge-Stick™ methods.
Table 4.3: Effects of Waste Storage Time on Positive Control Recoveries from Upholstery for the
Extractive and Sponge-Stick™ Sampling Methods
Waste Storage Time
Spore Recovery (CFU)
Extraction
Sponge-Stick™
Average
SD
Average
SD
Day 0
1.75E+08
2.49E+07
1.01E+07
2.61 E+06
Day 7
1.44E+07
1.92E+07
8.42E+06
6.95E+05
22

-------
4.1.3 Paper Material
Spore recoveries from the front page paper (PF) and the middle page paper (PM) as a function of
simulated waste storage time (sampling time delay) are shown in Figure 4.4 and summarized in
Table 4.4. Due to the highly porous and absorptive nature of paper, spores were expected to migrate
from the original location to subsequent pages in the book. As such, extraction-based methods were used
on the inoculated page and the adjacent pages to optimize spore recovery. The average CFU recoveries
for the PF and PM samples are 9.45 x 107 (SD = 9.00 x 107, n = 6 samples) and 9.24 x 106 (SD = 1.93 x
106, n = 6 samples), respectively. A two-sample independent t-test showed, that at the 95% confidence
interval, the difference of the spore recovery population means between the PF and PM samples is not
significant (p = 0.07).
PM Sample
PF Sample
O 10
Day 0	Day 7
Waste Storage (Days)
Figure 4.4: Effect of waste storage time on positive control recoveries (± SD) from paper (PM,
middle page; PF, front page) for the extractive method.
Table 4.4: Effects of Waste Storage Time on Positive Control Recoveries from Paper for the
Extractive and Sponge-Stick™ Sampling Methods
Waste Storage Time
Spore Recovery (CFU)
Front Page
Middle Page
Average
SD
Average
SD
Day 0
1.60E+07
4.65E+06
4.62E+06
2.33E+06
Day 7
5.46E+07
8.16E+06
2.08E+07
1.56E+07
CFU, colony-forming unit
23

-------
4.1.4 PPE Material
Spore recoveries from PPE material as a function of simulated waste storage time (sampling time delay) are
shown in Figure 4.5 and summarized in Table 4.5. Due to the irregular shape and small size of the PPE
samples, only extractive sampling methods were used. The average CFU recoveries for two tests, which
included four sampling events with five samples (each finger of nitrile glove is considered a single sample),
were 1.27 x 107 (SD = 5.47 x 106, n = 40 samples). A paired independent Student's t-test using the two-
tailed distribution for these data show no significant effects of storage time on recoveries (p-value = 0.59).
& ^
2
103
o
O
| 102
'(/)
O
o- 101
m
Day 0	Day 7
Waste Storage (Days)
Figure 4.5: Effect of waste storage time on positive control recoveries (± SD) from personal
protective equipment for the extractive method.
Table 4.5: Effects of Waste Storage Time on Positive Control Recoveries from Personal Protective
Equipment
Waste Storage Time
Spore Recovery (CFU)
Extraction
Average
SD
Day 0
1.35E+07
1.96E+07
Day 7
1.19E+07
1.27E+07
4.2 Neutralization Method Evaluation
The presence of decontamination solution components in the rinsate or extraction liquid (desorbed from
the sample) could negatively bias spore recoveries via residual decontamination. Prior to each
decontamination testing sequence, neutralization tests were performed to determine the optimal
neutralization concentration (neutralizerto decontaminant).
24

-------
To determine the optimal amount of neutralizer (STS) for each material/decontaminant, preliminary
neutralization tests were conducted. The samples were neutralized at different stoichiometric ratios of
STS to decontaminant (X); then the solutions (with the samples) were spiked with either approximately
2 x 102 spores (low concentration) or 5 x 107 spores (high concentration) before analysis. The results are
presented in Table 4.6. The data collected showed that complete spore recovery can be obtained when
the required amount of STS, based on stoichiometric ratio, is applied for each material/decontaminant
combination.
The neutralization tests determined that optimal recoveries of the spores were obtained with 2.5 X
(stoichiometric ratio) for both Spor-Klenz® and pAB decontamination solutions. The time lag between the
time the sample was neutralized and the time it was processed over a 24-hour period, the immersion
time, and the spore inoculum concentration did not appear to bias the spore recoveries if adequately
neutralized.
Table 4.6: Preliminary Neutralization Optimization
Decontaminant
Stoichiometric
Ratio
Material Type
Spore Recovery (CFU)
Recovery
(%)
Positive Controls
Neutralized
Samples
Mean
SD
Mean
SD
Mean
SD
pAB
1.3-1.5X
Carpet
3.43E+07
1.12E+07
2.57 x 107
8.84 x10s
74.9
35.6
Upholstery
5.23E+07
6.75E+06
4.46 x 107
2.94 x10s
85.2
12.3
2.5X
Carpet
3.76E+07
2.03E+06
3.89 x 107
7.79x10®
104
21.5
1.3-1.5X
Carpet
2.74E+02
3.38E+01
2.78 x 102
4.91 x 101
101
21.8
Upholstery
4.00E+02
6.13E+01
3.24 x 102
4.42 x101
81.1
16.6
2.5X
Carpet
2.74E+02
3.38E+01
2.40 x 102
1.75 x 101
87.5
12.5
Spor-Klenz®
1.5X
Carpet
3.70E+07
4.71 E+05
2.83 x 107
1.50x10®
76.6
4.2
2.5 X
Paper
6.43E+07
1.75E+06
4.04 x 107
4.34x10®
93.0
10.7
PPE
4.17E+07
2.13E+06
4.03 x 107
9.67x10®
96.7
23.7
2.5X
Carpet
4.49E+01
9.22E+00
5.35 x 101
3.50x10°
119
25.7
Upholstery
9.04E+01
1.06E+01
5.34 x 101
8.68x10°
59.6
11.8
Paper
6.19E+03
3.78E+02
8.51 x 103
8.40 x102
138
16.0
PPE
4.23E+03
5.22E+01
4.14 x 103
2.42.x 102
97.8
5.8
pAB, pH-adjusted bleach, PPE, personal protective equipment
4.3 Dunking/Immersion Decontamination Test Results
This section reports the results for overall effectiveness of the decontamination treatment for each
material/decontaminant/procedure combination. Sections of the test materials were sampled immediately
after the decontamination treatment and were bagged and resampled and reanalyzed after a drying time
of 7 days. A subset of bagged waste samples was left untreated to serve as positive controls.
4.3.1 Carpet Decontamination Results
Evaluation of the two sampling techniques (section 4.1) showed that the extraction method was much
more effective than the Sponge-Stick™ method for carpet material, which can lead to an over/under
estimate of decontamination efficacy for the tested decontaminant. In order to avoid any bias in the
25

-------
calculation of the decontamination efficacy of the decontaminant/procedure combination, only the results
of the extraction method are presented in this section.
The results of the carpet decontamination tests are presented in Table 4.7 and Figure 4.6. The
decontamination effectiveness is presented as the mean Logio reduction in CFUs recovered from all
samples as a function of the decontamination treatment. A paired independent Student's t-test using the
two-tailed distribution for these data show no significant effects of storage time on the decontamination
efficacy for all pAB-related decontamination treatments (p > 0.33). The efficacy of the Spor-Klenz®
method was found to increase after the 7-day storage period to reach greater than 7 LR.
The efficacy of the pAB-related decontamination treatments was in the range 2.0 to 3.4 LR. The addition
of surfactant, and/or agitation seemed to have little or no effect, or even a negative effect, on the overall
decontamination efficacy. No significant effects of storage time on recoveries were observed for pAB-
based decontamination treatments for both carpet and upholstery materials.
Table 4.7: Decontamination Efficacy versus Type of Decontamination Treatment for Carpet
Material
Decontamination Solution
Decontamination Efficacy (LR)a
Day 0
Day 7
Average
SD
Average
SE
pAB with surfactant
3.04
0.18
3.14
0.26
pAB with surfactant-agitation
2.24
0.26
2.37
0.16
pAB with agitation
3.05
0.31
2.82
0.13
Spor-Klenz®
2.74
0.17
7.03
0.11
a Based on extraction sampling
pAB, pH-adjusted bleach; LR, log reduction; SE, sampling efficiency
26

-------
c
o
t5
"O
CD
a:
Ł 2-
03
c
"E
03
-t—<
C
8 1-
CD
Q
I Extraction_Day 0
I Extraction_Day 7
O 5-
O
d)
o
03
O
S
c
o


•\a^



Decxintamination Treatments
svdf


Figure 4.6: Decontamination efficacy (± SE) versus decontamination treatment for carpet.
4.3.2 Upholstery Decontamination Results
The results of the upholstery tests using Spor-Klenz® as the decontaminant are presented in Figure 4.7.
A paired independent Student's t-test using the two-tailed distribution for this limited data show no
significant effects of storage time on the decontamination efficacy (p > 0.5).
The decontamination efficacy is presented as the mean Logio reduction in CFUs recovered from all
samples for the two sampling periods (Day 0 and Day 7). This aggregate approach was utilized since the
t-test indicated no significant interaction between sample storage time and recovery. The average
combined log-io CFU decontamination efficacy for the 60-minute immersion time is 7.35 + 0.20 (n = 6
samples), nearly achieving complete kill.
27

-------
Day 0
Day 7
Waste Storage (Days)
Figure 4.7: Decontamination Efficacy (± SE) for Upholstered Coupon Using Spor-Klenz®.
4.3.3 Paper Decontamination Results
The results of the paper decontamination tests, using Spor-Klenz® as decontaminant, are presented in
Table 4.8 and in Figure 4.8. The mean combined decontamination efficacies (Logio CFU reductions) for
the front and middle pages after a 60-minute immersion time were greater than 5.3 + 0.3 (n = 6 samples)
and 5.6 + 0.25 (n = 6), respectively. The seemingly low recoveries are due to the extraction method; the
paper samples were put inside a sterilized pre-labeled Stomacher bag along with 80 mL of PBST and a
pre-determined volume ofSTS neutralizer, and only a 1-mL aliquot was analyzed, resulting in a high
detection limit of 40 CFU per sample. Only two of the 12 samples resulted in detection of viable spores
following treatment.
Table 4.8: Decontamination Efficacy (Log Reduction) versus Type of Decontamination Treatment
for Paper Material
Samples
Decontamination Efficacy (LR)C
Day 0
Day 7
Average
SD
Average
SE
Front page
5.6a
0.0
5.93a
0.0
Middle page
5.6a
0.0
5.72"
0.25
a All non-detects; b4 out of 6 non-detects;c Efficacy determined by extraction-based sampling.
LR, log reduction; SE, sampling efficiency
28

-------
IPF Samples
IPM Samples
Day 0	Day 7
Waste Storage (Days)
Figure 4.8: Decontamination efficacy (± SE) for Spor-Klenz®and paper coupons for front page (PF)
and middle page (PM).
4.3.4 PPE Decontamination Results
The PPE sampling technique consisted of collecting three inoculated fingers (1st, 3rd, and 5th fingers
starting with the thumb) from each glove separately. Spores were recovered by extraction of individual
glove fingers in 10 mL of PBST. Five gloves were used to produce 15 test samples (five samples from
three inoculated fingers for each glove) for each decontamination treatment (pAB with surfactant, pAB
with surfactant-agitation, pAB with agitation, and Spor-Klenz®).
The results of the PPE decontamination tests are presented in Table 4.9 and Figure 4.9. The
decontamination efficacy is presented as the mean logio reduction in recoveries (CFU) from all samples
within a particular material and treatment. Only extraction-based sampling methods were utilized for PPE.
These data suggest that achieving complete coverage of all PPE surfaces with the decontaminant is
challenging; full decontamination (complete kill) of one finger of a glove sample might be obtained, while
no decontamination is seen on the other fingers from the same glove. As stated in the previous report [2] ,
this is likely to occur as the inside of contaminated glove fingers may have no contact with the
decontamination solution. All decontamination treatments achieved full kill in at least one finger, which
presumably had contact with the decontamination solution. As a result, the high variability observed in the
results did not allow a strong comparative evaluation across the decontamination treatments used in this
study.
29

-------
Table 4.9: Decontamination Efficacy (CFU LR) versus Type of Decontamination Treatment for PPE
Material
Decontamination Solution
Decontamination Efficacy (LR)a
Day 0
Day 7
Average
SE
Average
SE
pAB with surfactant
6.41
0.38
2.30
3.23
pAB with surfactant-agitation
2.62
3.32
2.48
3.65
pAB with agitation
6.48
2.08
6.29
2.08
Spor-Klenz®
2.25
3.00
2.46
2.77
aBased on extraction sampling
CFU LR, colony-forming unit log reduction; pAB, pH-adjusted bleach; PPE, personal
protection equipment; SE, sampling efficiency
Extraction_Day 0
Extraction_Day 7
^Decontamination Treatments
Figure 4.9: Decontamination efficacy (± SE) versus decontamination treatment for personal
protective equipment (PPE) material.
30

-------
5 Quality Assurance
This project was performed according to an approved Category III quality assurance project plan (QAPP).
Sufficient detail of the methods outlined in the QAPP are provided within this report.
5.1 Sampling, Monitoring, and Analysis Equipment Calibration
Operating procedures for the maintenance and calibration of all laboratory and NHSRC RTP Microbiology
Laboratory equipment were followed. All equipment was verified as being certified calibrated or having
the calibration verified by EPA's Air Pollution Prevention and Control Division on-site (Research Triangle
Park, NC) Metrology Laboratory at the time of use. Standard laboratory equipment such as balances, pH
meters, biological safety cabinets, and incubators were routinely monitored for proper performance. Data
gathered with the HOBO thermistors were processed using the factory calibration. Calibration of
instruments was done at the frequency shown in Table 5.1. Any deficiencies were noted. If tolerances
were not met after recalibration, additional corrective action was taken, possibly including, recalibration
and/or replacement of the equipment.
Table 5.1: Instrument Calibration Requirements
Equipment
Calibration/Certification
Expected Tolerance
Thermometer
Compare to independent National Institute of
Standards and Technology (NIST) thermometer
(this is a thermometer that is recertified annually by
either NIST or an International Organization for
Standardization (ISO) 17025 facility) value once
per quarter.
±1°C
pH Meter
Perform a two-point calibration with standard
buffers that bracket the target pH before each use.
±0.1 pH units
HOBO® RH sensor
Compare to calibrated RH sensor prior to use.
± 5%
Stopwatch
Compare against NIST official U.S. time at
httD://nist.time.aov/timezone.cai?Eastern/d/-5/iava
once every 30 days.
±1 min/30 days
Micropipettes
All micropipettes certified as calibrated at least
once per year. Rainin™ pipette liquid handling
devices are recalibrated by gravimetric evaluation
of pipette performance to manufacturer's
specifications every 6 months by the supplier
(Rainin Instruments, Mettler Toledo,
Greifensee, Switzerland).
± 5%
Scale
Check calibration with Class 2 weights
±0.1% weight
5.2 Data Quality
The primary objective of this project was to estimate the efficacy of liquid-based decontamination
approaches for on-site treatment of bundled or bagged waste items typical of an indoor office setting that
had been contaminated with B. anthracis spores. The QAPP in place for this project was followed with
deviations that have been documented in the laboratory notebook. These deviations did not affect data
quality.
31

-------
5.3 Acceptance Criteria for Critical Measurements
The data quality objectives define the critical measurements needed to address the stated objectives and
specify tolerable levels of potential errors associated with simulating the prescribed decontamination
environments. The following measurements were deemed to be critical to accomplish part or all of the
project objectives:
•	Chlorine concentration, determined by measuring FAC in decontaminant solutions
•	pH
•	Temperature
•	Relative Humidity (RH)
•	Decontamination time
•	Plated volume
Data quality indicators for the critical measurements were used to determine if the collected data met the
data quality objectives. The critical measurement acceptance criteria are shown in Table 5.2. The target
values and actual test parameters for each run are shown in Table 5.3.
The tests were conducted so that all the critical parameters were within the acceptance criteria described
in the next section. When a test parameter did not meet the test target value, the test method was
repeated or modified to reach the test target value and therefore achieve 100% completeness for the
task. For example, if the target FAC concentration in the bleach (decontaminant) solution was not met,
the solution was either re-prepared or adjusted. Test RH values were adjusted with data from calibrated
RH sensors. Similarly, if the CFU count for bacterial growth did not fall within the target range, the sample
was either filtered or replated.
Table 5.2: Critical Measurement Acceptance Criteria
Critical Measurement
Measurement Device
Accuracy
Detection Limit
Completeness
Plated volume
Pipette
±2%
Not applicable
100%
CFU/plate
Hand counting
±10 % (between 2
counters)
1 CFU
100%
FAC
HACH® Method 10100
- digital titrator
± 1 %
1 digit (0.5 g/L
chlorine)
100%
Exposure time
Timer
±1 second
1 second
100%
pH
Oakton® pH meter
± 0.01 pH
Not applicable
90%
RH/temp of chamber
HOBO® U12 sensor
± 2.5 % from 10-90 %
Not applicable
40%
CFU, colony-forming unit; FAC, free available chlorine; RH, relative humidity
32

-------
Table 5.3: Data Quality Assessment
Decontaminant
Material
Type
Chlorine Concentration (FAC) - per 5 mL Bleach
titrated
pH
Chamber Parameters (HOBO®)
Target Value
(PPm)
Test Value
(PPm)
Frequency
Target
Value
Test
Value
Frequency
Avg.
RH
(%)
Avg.
Temp
(°C)
Frequency
pAB + surfactant
Carpet
6000-6700
6129
Once before
testing
6.5-7.0
6.87
Once before
testing
NA
NA
Data recorded at 5 min
intervals for the duration of
the test
PPE
6000-6700
6129
Once before
testing
6.5-7.0
6.70
Once before
testing
26.1
19
Data recorded at 5 min
intervals for the duration of
the test
pAB + agitation
Carpet
6000 -6700
6209
Once before
testing
6.5-7.0
6.89
Once before
testing
19.5
17
Data recorded at 5 min
intervals for the duration of
the test
PPE
6000-6700
6430
Once before
testing
6.5-7.0
6.90
Once before
testing
28.2
19
Data recorded at 5 min
intervals for the duration of
the test
pAB + surfactant and
agitation
Carpet
6000-6700
6530
Once before
testing
6.5-7.0
7.02
Once before
testing
NA
NA
Data recorded at 5 min
intervals for the duration of
the test
PPE
6000-6700
6089
Once before
testing
6.5-7.0
6.67
Once before
testing
NA
NA
Data recorded at 5 min
intervals for the duration of
the test
Decontaminant
Material
Type
PAA/H2O2 concentration
pH
Chamber Parameters (HOBO®)
Test Value
(%/%)
Frequency
Test Value
Frequency
RH (%)
Temp
°C
Frequency
Spor-Klenz®
Carpet
0.20/0.44
Once before
testing
2.99
Once before testing
NA
NA
Data recorded at 5 min intervals for the
duration of the test
PPE
0.26/0.10
Once before
testing
3.95
Once before testing
NA
NA
Data recorded at 5 min intervals for the
duration of the test
Upholstery
0.26/0.09
Once before
testing
2.75
Once before testing
42.6
23
Data recorded at 5 min intervals for the
duration of the test
Paper
0.30/0.19
Once before
testing
2.70
Once before testing
NA
NA
Data recorded at 5 min intervals for the
duration of the test
FAC, free available chlorine; NA = Not available; pAB, pH-adjusted bleach; PPE, personal protective equipment; RH, relative humidity
33

-------
5.4 QA/QC Checks
5.4.1 Quality Control Management
Several management controls were put in place in order to prevent cross contamination. This project was
labor intensive and required that many activities be performed on material sections or coupons that were
intentionally contaminated (test samples and positive controls) or intentionally not-contaminated
(procedural blanks). The treatment of these three groups of test areas (positive control, test, and
procedural blank) varied for each group. Hence, specific procedures were put in place to prevent cross-
contamination among the groups. Adequate cleaning of all common materials and equipment was critical
in preventing cross contamination; therefore, all common materials were fumigated using a VHP® or
ethylene oxide sterilant and the swab sampled for sterility prior to each use.
Uniformity of the material sections was a critical attribute to assure reliable test results. Uniformity was
maintained by obtaining a large enough quantity of material that multiple material sections and coupons
could be constructed with presumably uniform characteristics. Samples and test chemicals were
maintained to ensure their integrity. Samples were stored away from standards or other samples that
could cross contaminate them.
Supplies and consumables were acquired from reputable sources and were NIST traceable when
possible. Supplies and consumables were examined for evidence of tampering or damage upon receipt
and prior to use, as appropriate. Supplies and consumables showing evidence of tampering or damage
were not used. All examinations were documented and supplies were appropriately labeled. Project
personnel checked supplies and consumables prior to use to verify that they met specified task quality
objectives and did not exceed expiration dates.
Quantitative standards do not exist for biological agents. Quantitative determinations of organisms in this
investigation did not involve the use of analytical measurement devices. Rather, CFUs were enumerated
manually and recorded. QC checks for critical measurements/parameters are shown in Table 5.4. These
checks also served as data quality indicator goals. The acceptance criteria were set at the most stringent
level that can be routinely achieved. Tests with conditions falling outside of these criteria were rejected or
repeated. Positive controls and procedural blanks were included along with the test samples in the
experiments so that well-controlled quantitative values could be obtained. Background checks were also
included as part of the standard protocol. Replicate coupons were included for each set of test conditions.
The confirmation procedure, controls, blanks, and method validation efforts were the basis of support for
biological investigation results.
Background contamination was controlled by sterilization of test materials and use of aseptic technique,
procedural blank controls, and a pure initial culture. Aseptic technique was used to ensure that the culture
remains pure. Procedural blank controls were run in parallel with the contaminated materials. Assuming
that the procedural blank controls showed no CFUs, the observed colonies from inoculated coupons
indicated surviving spores from the inoculated organisms provided they were consistent with the expected
colony morphology (i.e., orange color, round form, flat elevation, rough texture, and undulate margin).
34

-------
Table 5.4: Quality Control Checks
QC Sample
Information
Provided
Frequency
Acceptance
Criteria
Corrective
Action
Procedural blank
(coupon without
biological agent)
Controls for sterility of
materials and methods
used in the procedure.
1 per test
No observed CFUs.
Reject results of test coupons on
the same order of magnitude.
Identify and remove source of
contamination.
Positive control
(sample from material
coupon contaminated
with biological agent
but not subjected to
the test conditions)
Initial contamination level
on the coupons; allows for
determination of log
reduction; controls for
confounds arising from
history impacting
bioactivity; controls for
special causes. Shows
plate's ability to support
growth.
3 or more
replicates per
test
For high inoculation, target
loading of 1 x 107 CFU per
sample with a standard
deviation of < 0.5 log. (5 x 106 -
5 x 107 CFU/sample). For low
inoculation, target loading of 1 x
102 CFU per sample with a
standard deviation of < 0.25 log
(56 -177 CFU/sample); Grubbs'
outlier test (or equivalent).
Outside target range: correct
loading procedure for next test
and repeat depending on decided
impact.
Outlier: evaluate/exclude value.
Blank plating of
microbiological
supplies
Controls for sterility of
supplies used in dilution
plating.
3 of each supply
per plating event
No observed growth following
incubation.
Sterilize or dispose of source of
contamination. Replate samples.
Blank tryptic soy agar
sterility control (plate
incubated, but not
inoculated)
Controls for sterility of
plates.
Each plate
No observed growth following
incubation.
All plates are incubated prior to
use, so any contaminated ones
will be discarded.
Chlorine concentration
Concentration of FAC in
the fresh pAB or diluted
bleach solution.
1 per use
6000-6700 ppm for fresh pH
adjusted bleach or diluted
bleach.
Reject solution; replace reagents
and prepare a new solution.
pH
Effective concentration of
hydrogen ions in solution.
1 per use
> 6.5 and < 7.0 for fresh pH
adjusted bleach.
Reject solution; replace reagents
and prepare a new solution.
Field blank samples
The level of contamination
present during sampling.
1 per sampling
event
Non-detect.
Clean up environment. Sterilize
sampling materials before use.
5.4.2 Quality Control Evaluation
Table 5.5 illustrates how well QC objectives for maintaining sterility, minimizing cross contamination, and
spore recovery were met. Only carpet and upholstery materials were sampled using the sponge stick
method; therefore, sponge stick sample data are not available for other materials. Positive control data for
each test show that the coupons were dosed with the targeted 1 x107 CFU. The extractive sampling
method proved effective with a median recovery of 8.2 x 106 CFU from all material surfaces. The sponge
stick sampling method performed poorly on carpet surfaces, with a median recovery of only 2.2 x 105
CFU; however, recovery improved when used on the relatively smoother surface of the upholstery
material. The available negative control data suggest the sterilization procedures used for each material
were effective. Sampling data collected from the procedural blanks prove cross contamination prevention
efforts were successful. Temperature and RH data for the decontaminants was not collected on several
occasions (Table 5.3), however these were not critical measures and quality of the efficacy or recovery
data were not affected.
35

-------
Table 5.5: Quality Control Evaluation
Decontaminant
Material Type
Negative Controls (Avg CFU)
Procedural Blanks (Avg CFU)
Positive Controls (Avg CFU)
Extractive
Samples
Sponge Stick
Samples
Extractive
Samples
SD
Sponge Stick
Samples
SD
Extractive
Samples
SD
Sponge Stick
Samples
SD
pAB + surfactant
Carpet
6.67E-01
7.38E-01
6.08E-01
1.46E-02
7.20E-01
2.39E-02
5.82E+06
1.92E+06
2.20E+05
8.54E+04
PPE
7.04E-01
NA
6.75E-01
4.55E-03
NA
NA
3.18E+06
1.39E+06
NA
NA
pAB + agitation
Carpet
6.41 E-01
6.63E-01
6.00E-01
8.38E-03
5.98E-01
1.75E-01
2.01 E+07
1.13E+06
3.05E+05
1.34E+05
PPE
6.25E-01
NA
3.70E+00
5.36E+00
NA
NA
4.29E+07
1.93E+07
NA
NA
pAB + surfactant and
agitation
Carpet
8.62E-01
6.70E-01
6.30E-01
0.00E+00
6.57E-01
1.53E-02
1.06E+07
7.85E+05
2.24E+05
2.31 E+05
PPE
NA
NA
6.03E-01
0.00E+00
NA
NA
3.41 E+06
1.88E+06
NA
NA
Spor-Klenz®
Carpet
7.72E-01
1.30E+00
5.83E-01
1.71E-02
6.54E-01
5.15E-02
1.77E+07
2.64E+06
2.48E+04
2.15E+04
PPE
NA
NA
2.18E+00
2.55E+00
NA
NA
4.60E+06
3.28E+06
NA
NA
Upholstery
6.67E+00
6.67E-01
6.67E+00
1.09E-15
1.84E+01
3.07E+01
1.75E+08
2.49E+07
1.01 E+07
2.61 E+06
Paper
NA
NA
4.00E+01
NA
NA
NA
4.62E+06
2.33E+06
NA
NA
CFU, colony-forming unit; NA = Not available; pAB, pH-adjusted bleach; PPE, personal protective equipment
36

-------
6 Summary
The evaluation of the two sampling techniques (Section 4.1) showed that the extraction method was more
effective than the Sponge-Stick™ method for carpet material. Use of Sponge-Sticks™ to sample carpet
could result in an over estimation of efficacy. In order to avoid any bias in the estimation of the
decontamination efficacy of the decontaminant/procedure combination, only the results of the extraction
method are presented in this section. The following summarizes these results:
•	The efficacy of the pAB-related decontamination treatments on carpet materials was in the range
2.0 to 3.4 LR. The addition of surfactant, and/or agitation or increasing the storage time from
Day 0 (within 1 hour from the immersion) to seven days (Day 7) showed no significant effect on
the overall decontamination efficacy of pAB-related treatment. The efficacy of Spor-Klenz® was
found to increase over the 7-day period to reach greater than 7 LR. These results show that the
use of Spor-Klenz® as a decontamination treatment over time might result in an effective
approach for decontaminating carpet materials (see Table 6.1). However, even with Spor-Klenz®,
four of the six carpet samples yielded viable spores following the decontamination treatment.
•	The results of the upholstery and paper tests using Spor-Klenz® as the decontaminant showed
high efficacy, nearly achieving complete kill of the spores (only 1 out of 6 samples and 2 out of 12
samples showed any spore detection for upholstery and paper, respectively).
•	PPE decontamination, independent of the material/decontaminant/ procedure combination, was
found to be challenging. All the decontamination treatments achieved full kill in at least one glove
finger, while poor decontamination efficacy was observed on the others of the same glove. The
high variability observed in the results hindered our ability to compare across treatments used in
this study.
•	The two sampling methods (extractive and Sponge-Stick™) were evaluated for both carpet and
upholstered materials. For these materials, the extraction-based method consistently achieved
higher recoveries. As a consequence of its lower recoveries, the Sponge-Stick™ method resulted
in overestimation of the decontamination efficacies. If possible, utilization of extraction-based
methods for waste sampling provides improved sensitivity of detection. However, these methods
might not be easily deployed in the field, and could generate samples that are not as easily
analyzed in the laboratory.
37

-------
Table 6.1: Summary of Waste Decontamination Results
Material Type
Decontamination Treatment
Post-Decon Samples with
>6 LR / Total Number of
Samples Collected
Post-Decon Samples with No Viable Spores
Detected / Total Number of Samples
Collected
Carpet
pAB + surfactant
0/6
0/6
pAB + surfactant + agitation
0/6
0/6
pAB + agitation
0/6
0/6
Spor-Klenz®
3/6
1/6
Upholstery
Spor-Klenz®
6/6
5/6
Paper
Spor-Klenz®
0/12a
10/12
PPEb
pAB + surfactant
24/30
23/30
pAB + surfactant + agitation
10/30
10/30
pAB + agitation
10/30
25/30
Spor-Klenz®
11/30
14/30
alow postitive control recoveries resulted in low LR values, >5 LR achieved for all 12 test samples
beach glove finger considered a separate replicate for this table
pAB, pH-adjusted bleach; PPE, personal protective equipment
38

-------
References
US Environmental Protection Agency. Technical Brief - Bio-response Operational Testing and
Evaluation (BOTE) Project Washington, DC. EPA/600/S-12/001
US Environmental Protection Agency. Expedient Approaches for the Management of Wastes
Generated from Biological Decontamination Operations in an Indoor Environment- Evaluation of
Waste Sampling and Decontamination Procedures. Washington, DC. EPA 600/R-14/262
D2022-89, A., Standard Test Methods of Sampling and Chemical Analysis of Chlorine-Containing
Bleaches. Book of Standards 2008.15.04.
US Centers for Disease Control and Prevenetion. Surface sampling procedures for Bacillus
anthracis spores from smooth, non-porous surfaces. NIOSH - Workplace Safety & Health Topics
2012; Available from: http://www.cdc.aov/niosh/topics/emres/surface-samplina-bacillus-
anthracis.html.
39

-------
vvEPA
United States
Environmental Protection
Agency
PRESORTED STANDARD
POSTAGE & FEES PAID
EPA
PERMIT NO. G-35
Office of Research and Development (8101R)
Washington, DC 20460
Official Business
Penalty for Private Use
$300

-------