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 Procedure for Products
Evaluated with the AO AC Use Dilution Method (UDM),
the AO AC Germicidal Spray Products as Disinfectants
Test (GSPT), and the Disinfectant Towelette Test (DTT)

SOP Number: MB-17-04

Date Revised: 09-21-17


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SOP No. MB-17-04
Date Revised 09-21-17
Page 1 of 10

SOP Number

MB-17-04

Title

Neutralization Confirmation Procedure for Products Evaluated with
the AO AC Use Dilution Method (UDM), the AO AC Germicidal
Spray Products as Disinfectants Test (GSPT), and the Disinfectant
Towelette Test (DTT)

Scope

This SOP describes methodology used to determine the effectiveness
of neutralizers specified for disinfectant testing (UDM, GSPT, and
DTT). A quantitative approach is used to assess the effectiveness of
the neutralizer and any bacteriostatic action resulting from the
neutralizer itself or neutralizer/disinfectant interactions across a
range of microbe concentrations. This SOP can be modified to
accommodate other test methods.

Application

This assay is designed to simulate the conditions of the UDM,
GSPT, and DTT; however, sterile carriers are used instead of
inoculated carriers. The test conditions specified for product testing
(e.g., water hardness, use-dilution, pH, organic soil, neutralizer,
contact time, temperature) are used.





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Date SOP withdrawn: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-17-04
Date Revised 09-21-17
Page 2 of 10

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

3

12.

PROCEDURE AND ANALYSIS

4

13.

DATA ANALYSIS/CALCULATIONS

10

14.

FORMS AND DATA SHEETS

10

15.

REFERENCES

10


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SOP No. MB-17-04
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1. Definitions

Additional abbreviations/definitions are provided in the text.

1.	Bacteriostatic = Capable of inhibiting or controlling the growth or
reproduction of bacteria without killing the cells

2.	CFU = Colony Forming Unit

2. Health and
Safety

Follow procedures specified in SOP MB-01, Laboratory Biosafety. The
Study Director and/or lead analyst should consult the 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-02 (thermometers), EQ-03 (weigh balances), EQ-04
(spectrophotometer), EQ-05 (timers), and QC-19 (pipettes) for details on
method and frequency of calibration.

5. Sample

Handling and
Storage

Refer to SOP MB-22, Preparation and Sampling Procedures for
Antimicrobial Test Substances, and SOP COC-01, Chain of Custody
Procedures.

6. Quality
Control

For quality control purposes, the required information is documented on the
appropriate form(s) (see section 14).

7. Interferences

For each neutralizer and subculture medium tested per study, use one batch
(preparation) of neutralizer and medium for all treatment and control
groups. Differences in performance (quality) between batches of media
may lead to misleading neutralization results.

8. Non-
conforming
Data

Management of non-conforming data will be specified; 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.	To ensure the stability of the test disinfectant solution, perform testing
within 3 hours of preparation.

2.	Strict adherence to the procedure is necessary for validity of test results.

3.	Use appropriate aseptic techniques for all test procedures involving the
manipulation of test organisms and associated test components.

11. Special
Apparatus
and Materials

Refer to section 11 of MB-05 (UDM), MB-06 (GSPT), and MB-09 (DTT)
for required apparatus and materials.


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12. Procedure and
Analysis

a.	Sterile carriers are used for this assay (see section 12.4).

b.	Perform the neutralization assay in advance of product testing to
verify that the prescribed neutralizer is suitable for the efficacy
evaluation. Concurrently conduct two test scenarios to determine
an appropriate approach for performing the product efficacy
evaluation:

i.	First Scenario: expose carriers to the disinfectant and
transfer them into the neutralizer subculture medium
(primary tube). No secondary subculture medium transfers
are conducted. Inoculate the neutralizer tubes containing
the carrier with a test organism suspension to deliver 5-100
CFU/mL.

ii.	Second Scenario: expose carriers to the disinfectant and
transfer them into the neutralizer subculture medium
(primary tube); in addition, subsequently transfer the
carriers to a secondary subculture medium (secondary
tube). Inoculate tubes with a test organism suspension to
deliver 5-100 CFU/mL.

c.	The purpose of the two scenario approach is to determine if the
prescribed neutralizer for the disinfectant is sufficient to support
growth.

12.1 Inoculum
Preparation

a. Prepare the inoculum according to SOP MB-05, AO AC UDM,
sections 12.1 through 12.2b.

12.2 Inoculum
Enumeration

a.	Prepare serial ten-fold dilutions of the inoculum by pipetting 1 mL
of the final test culture into 9 mL of PBDW (see section 12.1).
Use four dilutions, (e.g., 10"4, 10"5, 10"6, and 10"7) to inoculate the
neutralizer (primary tubes) and subculture medium (secondary
tubes). The target number of cells is 5-100 CFU/mL; this level
should be seen in one of the two highest dilutions.

b.	To estimate CFU/mL, plate 0.1 mL of each of the four dilutions in
duplicate on TSA or blood agar plates (BAP). Briefly vortex each
dilution tube prior to plating. Plates must be dry prior to
incubation.

c.	Record the dilution and plating information on the Neutralization
Confirmation Assay: Enumeration Form (see section 14).

d.	Incubate plates (inverted) at 36±1°C for up to 48±2 h and record
colony counts. Plates that have colony counts over 300 are
labeled as too numerous to count (TNTC). Record the counts on


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SOP No. MB-17-04
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the Neutralization Confirmation Assay: Enumeration Form (see
section 14).

12.3 Product
Sample
Preparation

a. Prepare the product according to the test parameters; follow
guidelines for disinfectant sample preparation provided in SOP
MB-22, Preparation and Sampling Procedures for Antimicrobial
Test Substances.

12.4 Carrier

Preparation

a. Prepare carriers according to the applicable SOP: for the UDM,
SOP MB-05 (stainless steel penicylinders), for the GSPT, SOP
MB-06 (25x25 mm glass slide carriers), and for the DTT, SOP
MB-09 (25x75 mm glass slide carriers).

i.	UDM: Follow carrier inoculation (SOP MB-05, section
12.2) except use sterile broth. Add organic soil to the
sterile broth as necessary per the test parameters.

ii.	GSPT and DTT: Follow carrier inoculation (SOP MB-06
and SOP MB-09, section 12.2) except use sterile broth.
Add organic soil to the sterile broth as necessary per the
test parameters.

12.5 First

Scenario:

Neutralizer -

Primary

Subculture

Treatment

Only

a.	Requires four dried carriers (with broth culture added) per
organism. Use the carrier type required for the specific test.

b.	Apply the product to the carriers according to specific instruction
provided in the test parameters (e.g., use dilution, spray distance,
spray period, wipe pattern, and contact time).

c.	Per test, per one test organism, expose four of the carriers to the
disinfectant for the specified contact time in the same manner as
product efficacy testing. Record the carrier transfer information
on the Neutralization Confirmation Assay: Time Recording Sheet
for Carrier Transfers (see section 14).

d.	After the last carrier of a set (4 total carriers) has been treated with
the disinfectant, and the contact time is complete, aseptically
transfer carriers in order in a timed fashion into tubes containing
the specified neutralizer, in the same manner as product efficacy
testing. Drain excess liquid from the carrier prior to the transfer.
This set of neutralizer tubes (4 total tubes) represents the
Neutralizer-Primary Subculture Treatment. Refer to section
12.8 for treatment inoculation (Table 1).

Note: For GSPT and DTT, the amount of neutralizer is 20 mL per
tube (38x 100 mm tubes) compared to 10 mL (20x 150 mm tubes)
used in the UDM.


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e. Proceed immediately with the Second Scenario.

12.6 Second
Scenario:
Neutralizer
Subculture
Treatment
Plus

Secondary
Subculture
Treatment

a.	Requires four dried carriers (with broth culture added) per
organism. Use the carrier type required for the specific test.

b.	Apply the product to the carriers according to specific instruction
provided in the test parameters (e.g., use dilution, spray distance,
spray period, wipe pattern, and contact time).

c.	Per test, per one test organism, expose four of the carriers to the
disinfectant for the specified contact time in the same manner as
product efficacy testing. Record the carrier transfer information
on the Neutralization Confirmation Assay: Time Recording Sheet
for Carrier Transfers.

d.	After the last carrier of a set (4 total carriers) has been treated with
the disinfectant, and the contact time is complete, aseptically
transfer carriers in order in a timed fashion into tubes containing
the specified neutralizer, in the same manner as product efficacy
testing. Drain excess liquid from the carrier prior to the transfer.
This set of neutralizer tubes (4 total tubes) will represent the
Neutralizer-Primary Subculture Treatment.

Note: For GSPT and DTT, the amount of neutralizer is 20 mL per
tube (38x 100 mm tubes) compared to 10 mL (20x 150 mm tubes)
used in the test method for liquid products.

e.	Following the last carrier transfer into the neutralizer tube,
incubate both First and Second Scenario neutralizer tubes at room
temperature for 30-45 min. Then, for the Second Scenario,
transfer each carrier in order into a culture tube containing the
secondary subculture medium. This portion of the assay is not
timed. This set of tubes (4 total tubes) represents the Secondary
Subculture Treatment. Refer to section 12.8 for treatment
inoculation (Table 2).

f.	Repeat the assay for the second test organism, if required.

12.7 Controls

a. Inoculated controls

i.	The Neutralizer-Primary Inoculated Control contains
four tubes of fresh, unexposed (to disinfectant) neutralizer-
primary media.

ii.	The Secondary Subculture Inoculated Control contains
four tubes of secondary subculture media.

iii.	It is highly desirable that the preparation (media
preparation number) of each medium be the same as used


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in the treatments. Refer to section 12.8 for treatment
inoculation (Table 3).

b.	Uninoculated controls

i. Neutralizer-Primary and Secondary Subculture
Uninoculated Controls. Incubate one tube each of
uninoculated neutralizer and secondary subculture media
with the other tubes.

c.	Confirm sterility of carriers in advance or concurrently with
testing: add an uninoculated carrier to a tube of 10-20 mL fluid
thioglycollate medium or letheen broth and incubate at 36±1°C for
3-10 days.

12.8 Treatment
Inoculation

a. After step 12.6e, inoculate all tubes concurrently using Tables 1,
2, and 3.

Table 1. First Scenario: Inoculation of Treatment Group with Dilutions of
the Test Organism*

Trc



Dilutions Added

almcnl

10-1

10 s

10-"

10"7

Nculrali/.cr-Primary Subculture
T real merit

0.1 mL

0.1 mL

0.1 mL

0.1 mL

* 1 x lO 4 through 1 x lO 7; based on an approx. starting suspension of 108 to 109 CFU/mL

Table 2. Second Scenario: Inoculation of Treatment Groups with Dilutions
of the Test Organism*

Trc;



Dilutions Added

Hmcnts

10"4

10"5

10"6

10"7

Nculralizcr-Primary Subculture
Treatment

0.1 mL

0.1 mL

0.1 mL

0.1 mL

Secondary Subculture Treatment

0.1 mL

0.1 mL

0.1 mL

0.1 mL

* 1 x 10"4 through 1 x 10"7; based on an approx. starting suspension of 108 to 109 CFU/mL

Table 3. Controls: Inoculation of Control Groups with Dilutions of the
Test Organism*

Controls

Dilutions Added

10"4

lO"5

10"6

lO"7

Inoculated
Controls
(media
performance)

Ncutralizcr-
Primarv

0.1 mL

0.1 mL

0.1 mL

0.1 mL

Secondary
Subculture

0.1 mL

0.1 mL

0.1 mL

0.1 mL

Stcrililv
Controls

Ncutralizcr-
Primarv

N/A

N/A

N/A

N/A

Secondary
Subculture

N/A

N/A

N/A

N/A


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SOP No. MB-17-04
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* 1 x lO 4 through 1 x lO 7; based on an approx. starting suspension of 108 to 109 CFU/mL

b. Shake tubes thoroughly. Incubate all tubes for up to 48±2 h at
36±1°C.

12.9 Recording
Results and
Confirmation
Testing

a.	Record results as + (growth/turbidity) or 0 (no growth) on the
Neutralization Confirmation Assay Results Form (see section 14).

b.	For each treatment and control group, Gram stain a minimum of
one positive tube per treatment. Select the tube with the highest
dilution showing growth (inoculated with the dilution with fewest
CFU/mL delivered).

c.	Record confirmation results on the Neutralization Confirmation
Assay: Microbe Confirmation Sheet (see section 14).

12.1 ©Interpretation
of Results

a.	Plate count data. One of the four dilutions plated should provide
counts within the approximate target range, 5-100 CFU/mL.

i. Note: The lack of complete neutralization of the

disinfectant or bacteriostatic activity of the neutralizer
itself may be masked when a high level of inoculum is
added to the subculture tubes.

b.	Controls. Growth in the Secondary Subculture Inoculated

Control verifies the presence of the test microbe, performance of
the media, and provides a basis for comparison of growth in the
neutralizer and subculture treatment tubes. No growth or only
growth in tubes which received high levels of inoculum (e.g., a
dilution with plate counts which are TNTC) indicates poor media
performance. Growth in the Neutralizer-Primary Inoculated
Control should be comparable to the Secondary Subculture
Inoculated Control if the neutralizer is the same as the secondary
subculture media.

i.	There may be cases when the neutralizer (primary tubes) is
significantly different from the secondary subculture
media. In these cases, growth may not be comparable to
the Secondary Subculture inoculated Control.

ii.	The Neutralizer-Primary Uninoculated Control and
Secondary Subculture Uninoculated Control tubes are
used to determine sterility and must show no growth for
the test to be valid.

c.	Treatments. The occurrence of growth in the Neutralizer-
Primary Subculture and Secondary Subculture Treatment

tubes are used to assess the effectiveness of the neutralizer.


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SOP No. MB-17-04
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i.	First Scenario: The neutralizer itself mav exhibit
bacteriostatic activity against the test microbe. No growth
or growth only in tubes which received a high titer of
inoculum (e.g., the dilution with plate counts which are
TNTC) indicates poor neutralization and/or presence of
bacteriostatic properties of the neutralizer or neutralizer-
disinfectant interactions. For the neutralizer to be deemed
effective, growth must occur in the Neutralizer Primary
Subculture Treatment tubes which received a lower titer
of inoculum (e.g., 5-100 CFU/mL).

ii.	Second Scenario: The neutralizer itself or in combination
with the recovery (subculture) medium may exhibit
bacteriostatic activity against the test microbe. No growth
or growth only in tubes which received a high titer of
inoculum (e.g., the dilution with plate counts which are
TNTC) indicates poor neutralization and/or presence of
bacteriostatic properties of the neutralizer or neutralizer-
disinfectant interactions. For the neutralizer to be deemed
effective, growth must occur in the Secondary Subculture
Treatment tubes which received a lower titer of inoculum
(e.g., 5-100 CFU/mL).

12.11Efficacy
Evaluation
based on
Neutral-
ization
Results

a.	If results from the First Scenario indicate effective neutralization,
conduct the efficacy evaluation using only the neutralizer
subculture tubes (i.e., primary tubes).

b.	If results from the First Scenario (Neutralizer-Primary Subculture
Treatment only) are inconclusive and/or indicate that a
bacteriostatic effect from the neutralizer or neutralizer-disinfectant
interaction is present, evaluate results from the Second Scenario to
determine if the Secondary Subculture tube provide appropriate
neutralization.

c.	If the Second Scenario is deemed effective, conduct the efficacy
evaluation using both subculture media tubes (i.e., primary and
secondary tubes).

d.	If results from the Second Scenario (Neutralizer-Primary
Subculture Treatment tubes and Secondary Subculture Treatment
tubes) are inconclusive and/or indicate that a bacteriostatic effect
from the neutralizer or neutralizer-disinfectant interaction is
present, assay an alternative neutralizer prior to conducting the
efficacy evaluation. The alternative neutralizer may not be
specified in the test parameters.


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SOP No. MB-17-04
Date Revised 09-21-17
Page 10 of 10

13. Data Analysis/
Calculations

1.	Enumerate plate counts and calculate CFU/mL added to each tube
based on the average of countable plates. Apply TNTC for counts
above 300 CFU.

2.	To calculate the average CFU/mL per dilution added to each tube, add
the plate counts for each plate within the dilution and divide by two.

3.	Use counts from 0 through 300 in the calculations.

14. Forms and
Data Sheets

Test Sheets. Test sheets are stored separately from the SOP under the
following file names:

Neutralization Confirmation Assay: Time , _ , „ „, .
Recording Sheet for Carrier Transfers MB-17-04_F1 docx

Neutralization Confirmation Assay: Test , _ , „ „, .
T r cu * MB-17-04 F2.docx
information Sheet -

Neutralization Confirmation Assay: Results , _ , „ „, .
„ J MB-17-04 F3.docx
Form -

Neutralization Confirmation Assay: Test A ,
Microbe Confirmation Sheet - ' 0CX

Neutralization Confirmation Assay: , _ , „ „, .
_ 4. _ J MB-17-04 F5.docx
Enumerati on F orm -

Neutralization Confirmation Assay: Processing - „ , „ „, .

A J & MB-17-04 F6.docx
Sheet -

15. References

1.	Official Methods of Analysis. Methods 955.14, 955.15, and 964.02.
Posted September 2013. AO AC INTERNATIONAL, Gaithersburg,
MD.

2.	Official Methods of Analysis. Method 961.02. Posted March 2013.
AOAC INTERNATIONAL, Gaithersburg, MD.


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