US Environmental Protection Agency
Office of Pesticide Programs

Office of Pesticide Programs

Microbiology Laboratory

Environmental Science Center, Ft. Meade, MD

Standard Operating Procedure for
Neutralization Confirmation Assay for

Disinfectant Products Tested against Mycobacterium bovis (BCG)

SOP Number: MB-11-04

Date Revised: 04-29-13


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SOP No. MB-11-04
Date Revised 04-29-13
Page 1 of 12

SOP Number

MB-11-04

Title

Neutralization Confirmation Assay for Disinfectant Products Tested
against Mycobacterium bovis (BCG)

Scope

Describes the methodology for determining the effectiveness of a
neutralizer used when testing the tuberculocidal activity of
disinfectants against Mycobacterium bovis (BCG) on hard surfaces
using liquid, sprays, or towelettes.

Application

For product evaluations under the Antimicrobial Testing Program
(ATP), a study protocol is developed which identifies the specific test
conditions for a product sample such as contact time, dilutions,
neutralizers, etc.





Approval Date

SOP Developer:



Print Name:

SOP Reviewer



Print Name:

Quality Assurance Unit



Print Name:

Branch Chief



Print Name:





Date SOP issued:



Controlled copy number:



Date SOP withdrawn:




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SOP No. MB-11-04
Date Revised 04-29-13
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TABLE OF CONTENTS
Contents	Page Number

1.

DEFINITIONS

3

2.

HEALTH AND SAFETY

3

3.

PERSONNEL QUALIFICATIONS AND TRAINING

3

4.

INSTRUMENT CALIBRATION

3

5.

SAMPLE HANDLING AND STORAGE

3

6.

QUALITY CONTROL

3

7.

INTERFERENCES

3

8. NON-CONFORMING DATA

3

9.

DATA MANAGEMENT

3

10.

CAUTIONS

3

11.

SPECIAL APPARATUS AND MATERIALS

4

12.

PROCEDURE AND ANALYSIS

4

13.

DATA ANALYSIS/CALCULATIONS

9

14.

FORMS AND DATA SHEETS

9

15.

REFERENCES

10


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1. Definitions

Additional abbreviations/definitions are provided in the text.

1.	"Exposed" Neutralizer: Neutralizer solution which has been used to
inactivate the product.

2.	"Fresh" Neutralizer: Neutralizer solution which has not been used to
inactivate the product.

2. Health and
Safety

Follow procedures specified in SOP MB-01, Laboratory Biosafety. The
Study Director and/or lead analyst should consult the Material Safety Data
Sheet for specific hazards associated with products.

3. Personnel
Qualifications
and Training

Refer to SOP ADM-04, OPP Microbiology Laboratory Training.

4. Instrument
Calibration

Refer to SOPs EQ-01, EQ-02, EQ-03, EQ-04 and EQ-05 for details on
method and frequency of calibration.

5. Sample

Handling and
Storage

Refer to SOP MB-22, Disinfectant Sample Preparation, and SOP COC-01,
Chain of Custody Procedures.

6. Quality Control

Appropriate quality control measures are integrated into each SOP. For
quality control purposes, the required information is documented on the
appropriate forms (see section 14).

7. Interferences

1.	For each assay, use one preparation of each medium for the treatment
and control groups. Differences in media quality (media performance)
between preparations of media may lead to misleading neutralization
results.

2.	An interaction between a product's active ingredient and the
neutralizer can interfere with the reading of results.

3.	Presence of contamination will interfere with the interpretation of
results and may necessitate repeat analysis.

8. Non-
conforming
Data

Management of non-conforming data will be specified in the study
protocol; procedures will be consistent with SOP ADM-07, Non-
Conformance Reports.

9. Data

Management

Data will be archived consistent with SOP ADM-03, Records and
Archives.

10. Cautions

1.	Media performance (Subculture Media Control) must be acceptable in
order to interpret the neutralization results.

2.	There are time sensitive steps in this procedure including the use
period of the test chemical.


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3. Verify the volume of dilution blanks, neutralizer tubes, and subculture
tubes in advance and adjust accordingly.

11. Special

Apparatus and
Materials

1. Refer to section 11 (Special Apparatus and Materials) of MB-07, MB-
23, and MB-24 depending on the type of carrier used in the
neutralization assay.

12. Procedure and
Analysis

1.	For an overview of the setup of this procedure, see Tables 1 and 2.

2.	The general procedure for conducting the assay is the same for liquid,
spray, and towelette products. Follow the test parameters specified for
product testing (e.g., H2O hardness, use dilution, organic soil,
neutralizer, contact time, temperature) for the neutralization
confirmation assay.

3.	This assay is designed to simulate the conditions of the efficacy test;
however, sterile carriers are used instead of inoculated carriers.

Diluted M bo vis (BCG) inoculum is added directly to the various sets
of subculture media tubes. The inoculum is quantified by plating on
Middlebrook 7H9 (M7H9) or Middlebrook 7H11 (M7H11) agar; this
provides a quantitative assessment of the neutralizer's effectiveness
and any bacteriostatic actions resulting from interactions between the
neutralizer, subculture media, and/or disinfectant.

4.	Each assay requires eight sterile carriers: four for the Subculture
Media + Exposed Neutralizer Treatment and four for the Subculture
Media + Fresh Neutralizer Treatment. One carrier is used per each
inoculum dilution described in 12.1c. Use the carrier type required for
the product (i.e. porcelain penicylinders for liquid products or glass
slide carriers for spray or towelette products).

5.	For spray tests: Before conducting the neutralization assay, practice
applying the spray product to sterile glass slides to determine the
product's level of dispersion. If the product beads up and rolls off of
the slide rather than completely covering the glass slide as it would in a
typical efficacy evaluation (with inoculated slides), apply 10 |iL of an
organic material (e.g., broth used for culturing test organism, 5% horse
serum in sterile deionized water) onto the surface of each sterile glass
slide and spread it with a sterile loop and dry the slides for 30 minutes
per SOP MB-24. Once drying is complete, apply the spray product
again to verify that product dispersion is improved, and conduct the
neutralization assay. Based on previous observations in the laboratory,
the addition of an organic substance to the surface of the slide
increases product dispersion on glass slides. If no organic substance is
deemed necessary, no drying of the sterile glass slides is necessary


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SOP No. MB-11-04
Date Revised 04-29-13
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prior to conducting the assay.

6. The Neutralization Confirmation Assay for M bovis (BCG):

Processing Sheet (see section 14) must be used for tracking testing
activities.

12.1 Preparation of
Inoculum

a.	Prepare standardized inoculum per section 12.1 of MB-07, MB-
23, or MB-24.

b.	If the test parameters specify the addition of an organic soil load
to the inoculum, perform the neutralization assay with the organic
soil load added to the inoculum. Otherwise, prepare the inoculum
without the addition of an organic soil load.

c.	Make serial ten-fold dilutions of the standardized inoculum in 9
mL of Modified Proskauer Beck medium (MPB) or phosphate
buffered dilution water (PBDW). Use up to four dilutions (e.g.,
final dilutions of 10"4 through 10"7) to inoculate the subculture
media described below.

d.	Estimate the CFU/mL. Briefly mix each serial dilution tube prior
to plating. Plate 0.1 mL aliquots of appropriate dilutions in
duplicate on M7H9 or M7H11 agar using surface spread plating.
Spread inoculum evenly over the surface of the agar. Plates must
be dry prior to incubation.

e.	Record the dilution and plating information on the Neutralization
Confirmation Assay forM bovis (BCG): Inoculum Enumeration
Form (see section 14).

f.	Incubate plates (inverted) concurrently with the neutralization test
subculture tubes at 36 ± 1°C for 17-21 days. Count colonies.
Plates that have colony counts over 300 will be reported as
TNTC. Record the counts on the Neutralization Confirmation
Assay for M. bovis (BCG): Inoculum Enumeration Form (see
section 14).

12.2 Disinfectant
Sample
Preparation.

a. Follow guidelines for disinfectant sample preparation provided in
SOP MB-22.

12.3 Subculture
Media +
Exposed
Neutralizer
Treatment

a.	Expose four sterile carriers to disinfectant according to the
instructions specified in the test parameters for efficacy testing.

b.	Expose carriers to the disinfectant at appropriate intervals (e.g.,
one minute intervals). Record the carrier transfer information on
the Neutralization Confirmation Assay for M. bovis (BCG): Time


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Recording Sheet for Carrier Transfers (see section 14)

c.	Allow product to remain in contact with the carrier per the
specified contact time. For a contact time of 10 min, the carrier
must be exposed to the disinfectant within ± 5 s of the prescribed
exposure time.

d.	After the fourth carrier has been treated with the disinfectant and
the contact time is complete, sequentially transfer carriers into
tubes containing the specified neutralizer. Transfer carriers
according to methods specified in the appropriate efficacy test
method SOP. Drain the excess disinfectant from the carrier prior
to the transfer.

Note: For spray and towelette products, use 20 mL neutralizer
per 38 x 100 mm tube. For liquid products use 10 mL neutralizer
per 25 x 100 mm tube.

e.	Shake the tube containing the carrier in neutralizer thoroughly
and transfer the carrier to the primary subculture medium tube
containing 20 mL MPB broth within 5-10 minutes.

f.	For liquid products, sequentially transfer 2 mL aliquots from each
of the four neutralizer tubes into one tube of each of the 2
additional subculture media (M7H9, K or TB) specified by the
test parameters. This portion of the assay is not timed, but the
aliquots should be transferred to the subculture media within
approximately 30 ± 5 minutes.

g.	One tube of each medium will be inoculated with one of the four
inoculum dilutions.

Note: For spray and towelette products, transfer 2 mL aliquots
from each of the four neutralizer tubes into two tubes of each of
the 2 additional subculture media (M7H9, K or TB). Two tubes
of each subculture media will be inoculated with one of the four
inoculum dilutions.

12.4 Subculture
Media + Fresh
Neutralizer
Treatment

a.	Expose four sterile carriers to neutralizer, one carrier per tube of
neutralizer (this portion of the assay is not timed).

b.	Shake the tube containing the carrier in neutralizer thoroughly
and transfer the carrier to the primary subculture medium tube
containing 20 mL MPB broth within 5-10 minutes.

c.	For liquid products, sequentially transfer 2 mL aliquots from each
of the four neutralizer tubes into one tube of each of the 2
additional subculture media (M7H9, K or TB) specified by the


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SOP No. MB-11-04
Date Revised 04-29-13
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test parameters. This portion of the assay is not timed, but the
aliquots should be transferred to the subculture media within
approximately 30 ± 5 minutes.

d. One tube of each medium will be inoculated with one of the four
inoculum dilutions.

Note: For spray and towelette products, transfer 2 mL aliquots
from each of the four neutralizer tubes into two tubes of each of
the 2 additional subculture media (M7H9, K or TB). Two tubes
of each subculture media will be inoculated with one of the four
inoculum dilutions.

12.5 Subculture
Media
Controls

a.	Subculture Media Control. This control contains four tubes of
each preparation of subculture media used in the neutralization
assay. Do not add neutralizer to the media. Each tube of each
medium will be inoculated with one of the four inoculum
dilutions.

b.	Negative (uninoculated) Media Control. Incubate one
uninoculated tube of each medium along with the assay.

12.6 Inoculating
Subculture
Media

a. Inoculate the Subculture Media + Exposed Neutralizer

treatment, the Subculture Media + Fresh Neutralizer treatment,
and the Subculture Media Control with 0.1 mL of the diluted M.
bovis (BCG) inoculum (e.g., dilution tubes 10"3 through 10"6).
Inoculate the tubes after all carriers and neutralizer have been
transferred. Refer to Table 1 and Table 2 for organization of
neutralization assays for liquid and spray/towelette products,
respectively.

12.7 Incubation and
Presumptive
Confirmation
Testing

a.	Incubate tubes at 36± 1 °C.

b.	Beginning at 21 days, monitor tubes for evidence of typical
mycobacterial growth. Continue incubating all tubes for 60 days.

c.	Record results at 60 days as positive (+) or negative (0) as
indicated by the presence or absence of growth. If the 60th day of
incubation falls on a weekend or holiday, record the results on the
first workday following the 60th day.

c. For each medium in the Subculture Media + Exposed
Neutralizer treatment, the Subculture Media + Fresh
Neutralizer treatment, and the Subculture Media Control,

select the tube with growth from the highest dilution of inoculum
(i.e., fewest CFU/mL delivered) and perform acid fast staining on
a sample of the growth. Acid fast rods are typical forM bovis


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SOP No. MB-11-04
Date Revised 04-29-13
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(BCG).

d.	If necessary, conduct additional confirmation to include isolation
streaks on selective media such as M7H9 or M7H11 agar plates.
Following the 17-21 day incubation period, evaluate the colony
morphology of the organism on M7H9 or M7H11 agar. On
M7H9 or M7H11 agar, M. bovis (BCG) typically appears as
colorless to buff-colored, raised, rough growth.

e.	Record confirmation results on the Neutralization Confirmation
Assay forM bovis (BCG): Test Microbe Confirmation Sheet (see
section 14).

12.8 Interpretation
of Results

a.	Review the plate count data. One of the four dilutions plated
should provide counts within the target range, 5-100 CFU/mL.
Subculture tubes inoculated from this dilution also received this
low level of challenge, an aspect critical to the determination of
neutralization effectiveness and bacteriostatic activity.

i. The lack of complete neutralization of the disinfectant or
bacteriostatic activity of the neutralizer itself may be
masked when a high level ofM bovis (BCG) is added to
the subculture tubes.

b.	The Subculture Media Control (media performance) provides a
basis for comparing growth in the subculture tubes to growth in
the Subculture Media + Exposed Neutralizer treatment and the
Subculture Media + Fresh Neutralizer treatment. Growth in
Subculture Media Control verifies the performance of the
media and the presence of M. bovis (BCG) in the diluted
inoculum.

Media is considered to be of acceptable quality if growth is
observed when challenged with 5-100 CFU. No growth or only
growth in tubes which received high levels of inoculum (e.g., a
dilution with plate counts which are too numerous to count)
indicates poor media performance.

c.	The occurrence of growth in the Subculture Media + Fresh
Neutralizer treatment as compared to the Subculture Media
Control tubes is used to assess any bacteriostatic effects
attributable to possible interactions between the neutralizer and
subculture media. Interactions between the media and neutralizer
may result in growth in some media and not others.

No growth or growth only in tubes which received a high level of
inoculum (e.g., the dilution with plate counts which are too


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SOP No. MB-11-04
Date Revised 04-29-13
Page 9 of 12

numerous to count) indicates the presence of bacteriostatic
properties as a result of the neutralizer-media interaction.

d.	The occurrence of growth in the Subculture Media + Exposed
Neutralizer treatment tubes as compared to the Subculture
Media Control tubes is used to determine the effectiveness of the
neutralizer to inactivate the disinfectant when used under
simulated test conditions. Interactions between the media and
neutralizer may result in growth in some media and not others.

No growth or growth only in tubes which received a high level of
inoculum (e.g., the dilution with plate counts which are too
numerous to count) indicates ineffective neutralization and/or the
presence of bacteriostatic properties as a result of the
neutralizer-media interaction.

e.	Each Negative (uninoculated) Media Control tube must show no
growth.

13.	Data Analysis/ None.

Calculations

14.	Forms and Data Test Sheets. Test sheets are stored separately from the SOP under the
Sheets	following file names:

Neutralization Confirmation Assay for M
bovis (BCG): Time Recording Sheet for
Carrier Transfers

Neutralization Confirmation Assay for M
bovis (BCG): Information Sheet

Neutralization Confirmation Assay for M
bovis (BCG): Results Sheet - Liquid Products

Neutralization Confirmation Assay for M MB-1 l-04_F4.docx
bovis (BCG): Results Sheet - Spray/Towelette
Products

Neutralization Confirmation Assay for M
bovis (BCG): Inoculum Enumeration Form

Neutralization Confirmation Assay for M
bovis (BCG): Test Microbe Confirmation
Sheet

Neutralization Confirmation Assay forM MB-1 l-04_F7.docx
bovis (BCG): Processing Sheet

MB-11-04F1. docx

MB-1 l-04_F2.docx
MB-11-04 F3.docx

MB-11-04F5. docx
MB-11-04 F6.docx


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SOP No. MB-11-04
Date Revised 04-29-13
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Official Methods of Analysis. Revised 2013. 18* Ed., AO AC
INTERNATIONAL, Gaithersburg, MD, (Method 965.12 In vitro Test for
Determining Tuberculocidal Activity).


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SOP No. MB-11-04
Date Revised 04-29-13
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Table 1: Components of the Neutralization Confirmation Assay for Liquid
Products

TiViilmcnl/( onirol

M. hm-isi IWCi)
Iikiciiliiill Dilution
(0.1 ml. iiddcd per 1 uhe)

Mi'riisi (O = l uho of Modi;i)

M 1*15

(20 ml.)

\ni«>

(20 ml.)

k or 11}

(20 ml.)

Subculture Media +
Exposed Neutralizer

10"3

O/Carrier

O

O

10"4

O/Carrier

O

O

10"5

O/Carrier

o

o

10"6

O/Carrier

o

o

Subculture Media + Fresh
Neutralizer

10"3

O/Carrier

o

o

10"4

O/Carrier

o

o

10"5

O/Carrier

o

o

10"6

O/Carrier

o

o

Subculture Media Control

10"3

O

o

o

to-4

O

o

o

10"5

O

o

o

10"6

O

o

o

Negative Uninoculalcd
Control

Not inoculated

O

o

o


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SOP No. MB-11-04
Date Revised 04-29-13
Page 12 of 12

Table 2: Components of the Neutralization Confirmation Assay for
Spray/To welette Products

TiViilmcnl/( onirol

M. hm-isi IWCi)
Iikiciiliiill Dilution
(0.1 ml. iiddcd per 1 uhe)

Mi'riisi (O = l uho of Modi;i)

M 1*15

(20 ml.)

\ni«)

(20 ml.)

k or 11}
(20 ml.)

Subculture Media +
Exposed Neutralizer

to-3

O/Carrier

OO

OO

10"4

O/Carrier

oo

OO

10"5

O/Carrier

OO

oo

to-6

O/Carrier

oo

oo

Subculture Media + Fresh
Neutralizer

10"3

O/Carrier

oo

oo

10"4

O/Carrier

oo

oo

10"5

O/Carrier

oo

oo

10"6

O/Carrier

oo

oo

Subculture Media Control

to-3

O

o

o

10"4

O

o

o

105

O

o

o

10"6

O

o

o

Negative Uninoculalcd
Control

Not inoculated

O

o

o


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