Comment submitted by Melisa George
AnonymousSupportIndividual
Summary: The commenter supports the EPA's goal of increasing access to effective products against viruses but argues that the guidance must require more rigorous, use-specific evidence. They emphasize that virucidal claims should only be granted when testing demonstrates efficacy under real-world conditions and at specific labeled concentrations to ensure public safety and environmental protection.
I support the goal of increasing access to products effective against viruses such as SARS-CoV-2; however, expanding virucidal claims without stronger, use-specific evidence risks eroding public health protections and public trust.
Virucidal claims should be supported by rigorous testing that reflects real-world conditions, particularly in high-risk environments such as clinical and hospital settings. EPA has historically approved virucidal claims based on efficacy against pathogens considered “hard to kill.” However, this assumption does not always translate to real-world viral inactivation. For example, sodium hypochlorite at 1,000 ppm for 1 minute, which is a recommended concentration and contact time, has been shown to be ineffective and to require up to 10 minutes of contact time for effective viral inactivation (Morris & Esseili, 2023). Inconsistencies between labeled virucidal claims and actual performance may contribute to disease transmission, particularly in settings where rapid surface turnover is required. Products should only bear virucidal claims when testing demonstrates efficacy against relevant viruses at the labeled concentrations and contact times.
Expanded use of antimicrobial pesticides also raises concerns related to user safety and environmental impact. Products labeled as food-safe should be evaluated to ensure they do not pose risks in food-contact environments. In addition, clear guidance on proper use and safe disposal is essential to prevent contamination of water sources and unintended environmental harm.
In conclusion, while I support EPA’s efforts to improve access to virus-effective products, virucidal claims should only be granted when supported by realistic, virus-specific efficacy testing. Strengthening these requirements will better protect public health, maintain trust in product labeling, and reduce potential environmental consequences.
Morris, J. N., & Esseili, M. A. (2023). Efficacy of Peracetic Acid and Sodium Hypochlorite against SARS-CoV-2 on Contaminated Surfaces. Applied and Environmental Microbiology, 89(7), e0062223. https://doi.org/10.1128/aem.00622-23