Antimicrobials are Pesticides
The U.S. Environmental Protection Agency (EPA) and California Environmental Protection Agency (CalEPA) define antimicrobials as pesticides. Antimicrobials are commonly called disinfectants and include chlorine bleach, iodophores, sanitizers and bacteriostats. Worker safety requirements for pesticides closely parallel those for other hazardous materials administered by the California Occupational Health and Safety Administration (Cal/OSHA). These requirements include container labeling, hazard communication, exposure and training record retention, availability and use of personal protective equipment (e.g., respirator, chemical splash goggles, gloves, protective clothing) and safety equipment, adequate lighting, and equipment maintenance. These pesticide regulations cover and apply to any employee who handles (e.g., mixes, applies, maintains, services, or cleans contaminated equipment, etc.) antimicrobial products.
The following safety guidelines must be followed when using antimicrobials:
- All requirements on the pesticide product label must be followed, including directions for container disposal.
- Materials should be kept in the original, labeled containers; dilute solutions (e.g. 10% bleach) must be clearly labeled containers identifying contents and associated hazard information.
- All employees handling pesticides must have available the handling instructions for the materials, necessary personal protective equipment, and the material safety data sheets (SDS).
- The laboratory supervisor must have a written training program for employees. Training must be completed before the employee handles an antimicrobial and provided annually thereafter. Training documentation must be kept in the employee's record for two years. At a minimum, employees must be instructed on the following items:
- Immediate and long-term hazards involved.
- Procedures for safe use including application and storage.
- Protective clothing and equipment to use.
- Safety procedures including those for handling emergency situations.
- Common symptoms of poisoning and ways poisoning can occur.
- Where and how to obtain emergency medical treatment.
- Applicable laws, regulations, labeling requirements and SDS information.
- Decontamination procedures.
- Location of the Hazard Communication Program information.
- When the product label states the requirement for respiratory protection, the employer must provide the proper respirator. Employees requiring respiratory protection must be evaluated by Occupational Health Services, then fit-tested and trained by EH&S in the proper use, care, and limitations of respiration protection. See SafetyNet #88, “Respiratory Protection Program” for further information.
- All required safety equipment listed on the product labeling, must be provided and maintained (i.e., cleaned, repaired, etc.).
- Adequate light must be available to allow the employee to perform work activities in a safe manner.
- Disposal of pesticides, pesticide containers and pesticide solutions is strictly regulated; submit to EH&S as hazardous waste.