ICS Magazine

Headline: EPA considers extension of antimicrobial application training; ISSA opposes move

November 12, 2006
The Environmental Protection Agency is considering extending training and certification requirements of some sort to all occupational users of "pesticides," including, but not limited to, employees who apply disinfectants, sanitizers and other antimicrobial products in the course of their employment. Conference calls have confirmed that the EPA is considering extending training requirements to workers who apply antimicrobial pesticides in institutional settings.

The ISSA opposes the extension of additional training requirements in this context for the following reasons:

"Pursuant to the OSHA Hazard Communication Standard, institutional users of antimicrobial products are already required to be provided with education and training on the use of all "hazardous chemicals" including disinfectants, sanitizers, and other antimicrobials. Additional training is not necessary.

"EPA has failed to establish a rational basis to support the need for additional training above and beyond what is already required under the OSHA Hazard Communication Standard. In fact, statistics from the Bureau of Labor and Statistics cover the years 2002, 2003 and 2004 indicate that there has been a decline in workplace injuries involving exposure to disinfectants.

"The inherent nature of general purpose disinfectants and sanitizers does not suggest that additional training is warranted.

"The Food Quality Protection Act amended FIFRA to exclude workers who apply antimicrobial products from the minimum training requirements of the federal pesticide standard."