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-11-06

Date Revised: 07-08-19


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SOP No. MB-11-06
Date Revised 07-08-19
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SOP Number

MB-11-06

Title

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

Revisions Made

•	Added requirement to document on the results sheet any observed
interactions between a product's active ingredient(s) and the
neutralizer can interfere with the reading of results.

•	Minor editorial changes.


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SOP No. MB-11-06
Date Revised 07-08-19
Page 1 of 11

SOP Number

MB-11-06

Title

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

Scope

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

Application

For official product testing, 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Date SOP withdrawn: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-11-06
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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

9


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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.	"Unexposed" 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 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 (pH meters), EQ-02 (thermometers), EQ-03 (weigh
balances), EQ-04 (spectrophotometers), 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, Disinfectant Sample Preparation, and SOP COC-01,
Chain of Custody Procedures.

6. Quality Control

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

7. Interferences

1.	An interaction between a product's active ingredient(s) and the
neutralizer can interfere with the reading of results; if this is observed,
record the observations on the results sheet (see section 14).

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

8. Non-
conforming
Data

1.	Management of non-conforming data will be consistent with SOP
ADM-07, Non-Conformance Reports.

2.	Media performance (Subculture Media Control) must be acceptable to
interpret the neutralization results.

9. Data

Management

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

10. Cautions

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

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

3.	Verify the volume of dilution blanks, neutralizer tubes, and subculture


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tubes in advance of testing and adjust accordingly.

4. Interactions between the media and neutralizer may result in growth in
some media and not others; if this occurs, a more suitable neutralizer
should be selected.

11. Special

Apparatus and
Materials

1. For the neutralization assay, use carriers specified in section 11
(Special Apparatus and Materials) of the appropriate tuberculocidal
activity of disinfectants SOP (MB-07, MB-23, orMB-24).

12. Procedure and
Analysis

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

2.	Sterile carriers are used for this assay. Sterile growth medium with or
without soil load is applied to the test carriers (via carrier submersion
or application using a pipette) in advance of testing to simulate
inoculation.

3.	Perform the neutralization assay in advance of or concurrently with
product testing to verify that the prescribed neutralizer is suitable for
the efficacy evaluation. It is preferable to use the same preparation of
media to conduct the neutralization and efficacy assays.

4.	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, soil load, neutralizer,
contact time, temperature) for the neutralization confirmation assay.

5.	Use the Neutralization Confirmation Assay for M bovis (BCG):
Processing Sheet (see section 14) for tracking testing activities.

12.1 Preparation of
Inoculum

a. Prepare standardized inoculum per section 12.1 or 12.2 of MB-
07, MB-23, or MB-24.

12.2 Preparation of
inoculum
dilutions and
enumeration

a.	Prepare serial ten-fold dilutions of the standardized inoculum in 9
mL of Modified Proskauer Beck medium (MPB) or phosphate
buffered dilution water (PBDW). Use four dilutions (e.g., 10"2,
10"3, 10"4, and 10"5) to inoculate the subculture media described in
sections 12.5-12.7. 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 aliquots of each of the four
dilutions in duplicate on M7H11 agar using spread plating.

Briefly mix each serial dilution tube prior to plating. Spread
inoculum evenly over the surface of the agar. Plates must be dry
prior to incubation.


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

d.	Incubate plates (inverted) concurrently with the neutralization test
subculture tubes at 36±1°C for 17-21 days. An evaluation prior to
17 days may be made for plates with high colony counts.

e.	Count colonies. Record plates that have colony counts over 300
CFU as TNTC. Record the counts on the Neutralization
Confirmation Assay for M bovis (BCG): Inoculum Enumeration
Form (see section 14).

12.3 Product
Sample
Preparation

a. Prepare the product according to the test parameters; follow
guidelines provided in SOP MB-22, Disinfectant Sample
Preparation, and SOP COC-01, Chain of Custody Procedures.

12.4 Carrier

Preparation

a.	Use carrier type required for the specific test.

b.	Application of sterile medium with or without soil load.

i.	For CTB: Add 10 sterile carriers to a tube containing 15-
20 mL of either MPB or Middlebrook 7H9 broth with
0.1% (v/v) polysorbate 80 (M7H9/P80); use the same
sterile medium used to grow the test culture. Add soil load
to the sterile medium as necessary per the test parameters.

ii.	For GSPT: Using a calibrated positive displacement
pipette, transfer 10 |iL of either MPB or M7H9/P80 onto
approximately 1 square inch of the sterile test carrier in
the Petri dish; use the same sterile medium used to grow
the test culture. Add soil load to the sterile medium as
necessary per the test parameters. Immediately spread the
medium uniformly over the majority of the carrier surface
using a sterile loop. Cover dish immediately. Prepare at
least 10 carriers.

iii.	For DTT: Using a calibrated positive displacement
pipette, transfer 10 |iL of either MPB or M7H9/P80 onto
the sterile test carrier in the Petri dish at one end of the
slide; use the same sterile medium used to grow the test
culture. Add soil load to the sterile medium as necessary
per the test parameters. Immediately spread the medium
uniformly over one third of the carrier surface using a
sterile loop. Cover dish immediately. Prepare at least 10
carriers.


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c. Dry carriers in incubator at 36±1°C for 30±2 min.

12.5 Subculture
Media +
Exposed
Neutralizer
Treatment

a.	Requires four dried carriers (with medium added). Each carrier
will be associated with one dilution of inoculum.

b.	Apply the product to the carriers according to the efficacy method
SOP and the specific instructions provided in the test parameters.
Record the carrier transfer information on the Neutralization
Confirmation Assay for M. bovis (BCG): Time Recording Sheet
for Carrier Transfers (see section 14).

c.	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.

Note: For spray and towelette products, use 20 mL neutralizer
per 38x100 mm tube. For liquid products use 10 mL neutralizer
per 25x100 mm tube.

d.	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.

e.	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. Do not add neutralizer to the MPB tube. This
portion of the assay is not timed, but the aliquots should be
transferred to the subculture media within approximately 30
minutes. Inoculate one tube of each medium with one of the four
inoculum dilutions prepared in section 12.2.

f.	For spray and towelette products, sequentially 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)
specified by the test parameters. Inoculate two tubes of each
medium with one of the four inoculum dilutions prepared in
section 12.2.

12.6 Subculture
Media +
Unexposed
Neutralizer
Treatment

a.	Requires four dried carriers (with medium added). Each carrier
will be associated with one dilution of inoculum.

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


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c.	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.

d.	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. Do not add neutralizer to the MPB tube. This
portion of the assay is not timed, but the aliquots should be
transferred to the subculture media within approximately 30
minutes. Inoculate one tube of each subculture media with one of
the four inoculum dilutions prepared in section 12.2.

e.	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). Inoculate two
tubes of each subculture media with one of the four inoculum
dilutions prepared in section 12.2.

12.7 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. Inoculate each tube of
each medium with one of the four inoculum dilutions prepared in
section 12.2.

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

12.8 Inoculating
Subculture
Media

a. Within 30 minutes after all carriers and neutralizer aliquots have
been transferred, inoculate the Subculture Media + Exposed
Neutralizer treatment, the Subculture Media + Unexposed
Neutralizer treatment, and the Subculture Media Control with
0.1 mL of the diluted M bo vis (BCG) inoculum (dilution tubes
10"2 through 10"5), beginning with the least concentrated dilution.

12.9 Incubation and
Presumptive
Confirmation
Testing

a.	Incubate tubes at 36±1°C for up to 60 days; tubes may be
monitored for growth prior to 60 days.

b.	Record results between 45-60 days as positive (+) or negative (0)
as indicated by the presence or absence of growth.

c.	For each medium in the Subculture Media + Exposed
Neutralizer treatment, the Subculture Media + Unexposed
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


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a sample of the growth. Acid fast rods are typical forM bo vis
(BCG).

d.	If necessary, conduct additional confirmation to include isolation
streaks on selective media such as M7H11 agar plates. Following
the 17-21 day incubation period, evaluate the colony morphology
of the organism on M7H11 agar. On 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).

12.1 ©Interpretation
of Results

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

b.	Growth in the Subculture Media Control (media performance)
verifies the presence of the test microbe, performance of the
media, and provides a basis for comparing growth in the
subculture tubes to growth in the Subculture Media + Exposed
Neutralizer treatment and the Subculture Media + Unexposed
Neutralizer treatment.

c.	The occurrence of growth in the Subculture Media +

Unexposed 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.

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.

e.	Verification of neutralizer effectiveness.

i.	Growth in tubes that were inoculated with dilutions
yielding plate counts ranging from TNTC to 5-100 CFU;
growth in at least one tube receiving a desired target of 5-
100 CFU is required.

ii.	Growth in the Subculture Media + Unexposed
Neutralizer treatment and Subculture Media + Exposed
Neutralizer treatment should be comparable to the
Subculture Media Control.


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f.	Lack of verification of neutralizer effectiveness.

i.	Growth in tubes that were inoculated with dilutions
yielding plate counts of TNTC and no growth in tubes that
were inoculated with dilutions yielding plate counts with a
desired target of 5-100 CFU.

ii.	No growth in any tubes.

g.	For the data to be deemed valid, each Negative (uninoculated)

Media Control tube must show no microbial growth.

13. Data Analysis/
Calculations

None.

14. Forms and Data
Sheets

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

Neutralization Confirmation Assay for M MB-11-06F1 .docx
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
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 for M
bovis (BCG): Processing Sheet

MB-11-06F2.docx
MB-11-06F3. docx
MB-11-06F4.docx

MB-11-06F5. docx
MB-11-06F6.docx

MB-11-06 F7.docx

15. References

Official Methods of Analysis. Revised 2013. 18th Ed., AO AC
INTERNATIONAL, Gaithersburg, MD, (Method 965.12 In vitro Test for
Determining Tuberculocidal Activity).


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Table 1: Components of the Neutralization Confirmation Assay for Liquid
Products

1 iv;ilim-nl/( onirol

M. bovis (lii ii)
1 iiocii In in Dilution
(0.1 ml. iiddod per luhc)

Modiii (O = l ulKM.r Mcdiii)

M P IS

(20 ml.)

\ni')

(20 ml.)

k or 11}
(20 ml.)

Subculture Media +
Exposed Neutralizer

lO"2

O/Carrier

O

O

lO"3

O/Carrier

O

O

10"4

O/Carrier

o

o

10"5

O/Carrier

o

o

Subculture Media +
Unexposed Neutralizer

10"2

O/Carrier

o

o

10"3

O/Carrier

o

o

10-4

O/Carrier

o

o

10-5

O/Carrier

o

o

Subculture Media Control

10-2

O

o

o

10-3

O

o

o

10"4

O

o

o

10"5

O

o

o

Negative Uninoculatcd
Control

Not inoculated

O

o

o


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

Tiv;iIiik*iiI/( nniml

M. bovis (lii ii)
1 iiocii In in Dilution
(0.1 ml. iiddod per luho)

Medhi (O = Tiihe of Mrdi.i)

M P IS

(20 ml.)

\ni«>

(20 ml.)

K or 11$
(20 ml.)

Subculture Media +
Exposed Neutralizer

lO"2

O/Carrier

OO

OO

lO"3

O/Carrier

oo

OO

10"4

O/Carrier

OO

oo

10"5

O/Carrier

oo

oo

Subculture Media +
Unexposed Neutralizer

lO"2

O/Carrier

oo

oo

to-3

O/Carrier

oo

oo

10-4

O/Carrier

oo

oo

10-5

O/Carrier

oo

oo

Subculture Media Control

10-2

O

o

o

10-3

O

o

o

10"4

O

o

o

10"5

O

o

o

Negative Uninoculaled
Control

Not inoculated

O

o

o


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