Issue View | Council III | 2023 Biennial Meeting

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Report - Disinfectant Committee (DC)

The Disinfectant Committee requests acknowledgement of their final report, thanking the committee members for their hard work, and that the committee be disbanded.

The FDA Food Code is relied upon by food facilities and local and state regulatory agencies as the primary guidance for food safety requirements. The lack of clear guidance in the Food Code on use of disinfectants has led to inconsistent interpretations from regulators and industry, potentially leading to misuse. As a result, the residue of the product could negatively impact human health, contaminate food, or be ineffective for control of the microorganisms of concern.

Retail food facility disinfection to stop the spread of norovirus has been a challenge for many years. The global SARS-CoV-2 pandemic has underscored the need to ensure the correct use of chemical antimicrobials to inactivate viruses in addition to bacteria commonly targeted by sanitizers. When a norovirus or other viral pathogen outbreak occurs, local and state regulatory agencies require or recommend disinfection within a food facility to inactivate viral pathogens on food-contact surfaces and throughout the facility. During the SARS-CoV-2 pandemic, regulatory agencies across the country have recommended disinfection in retail food facilities as a preventive measure and/or in the event of any confirmed COVID-19 diagnosis(es) on the premises.

COVID-19 has shown that there is a lack of understanding of the differences between sanitization and disinfection. The differences include, but are not limited to efficacy testing requirements, patterns of use, formulations of these products, etc. For example, efficacy tests for most sanitizers are performed against bacteria, not other microorganisms (e.g., viruses, fungi, and parasites). Therefore, most sanitizers should be used only to control bacteria (unless viruses are listed on EPA registered label or EPA regulations are changed).

The Code of Federal Regulations (40 CFR 158.2203) states, "Disinfectant means a substance, or mixture of substances, that destroys or irreversibly inactivates bacteria, fungi and viruses, but not necessarily bacterial spores, in the inanimate environment."

Currently, there are two types of EPA-registered disinfectants which are used on food-contact surfaces in retail food facilities:

1) Disinfectants that require a rinse step prior to resuming regular operations; and

2) Disinfectants that do not require a post-rinse step. This group of disinfectants meets food-contact tolerance levels and, similar to food-contact sanitizers, do not require a rinse step prior to further use due to their conformity to 40 CFR 180 Tolerances and Exemptions for Pesticide Chemical Residues in Food.

Below are examples of FDA's Food Code sections and current guidance from the CDC which can lead to a misunderstanding of how retail food facilities should use disinfectants on food-contact surfaces.

Example #1

Section 4-702.11 of the 2017 Food Code states, "Utensils and food-contact surfaces of equipment shall be sanitized before use after cleaning." There are no similar sections in the Food Code covering disinfection and it is unclear how to use disinfectants in retail and which steps (e.g., washing, rinsing, sanitizing, and air-drying) are required following the use of a disinfectant.

Example #2

In the 2017 Food Code Annex 3, in Hand Antiseptics Section 2-301.16, there is a statement, regarding the efficacy of these products: "Sanitizers used to disinfect food-contact equipment and utensils can easily achieve the 5-log reduction of microorganisms and often far exceed this minimum requirement." This statement indicates that hand sanitizers are used to disinfect food-contact surfaces, causing further confusion about the terms "sanitization", "disinfection", "hand antiseptics" and "hard surface sanitizers".

Updates to the Food Code to address the use of disinfectants in food establishments along with a guidance document to provide detailed information on disinfectants and how they should be used would alleviate confusion and potential misuse of disinfectants in such settings.

This Issue submission does not include a request for scientific review, analysis, or approval of disinfectants or no-rinse disinfectants on food-contact surfaces since this evaluation by EPA is part of their registration process.

1. Acknowledgement of the Disinfectant Committee Report.

2. Thanking the members of the Committee for their work.

3. The Committee be disbanded; all assigned charges have been completed.