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  antibacterial (household cleaners)
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LABEL REPORT CARD
How meaningful is the label? Is the label verified? Is the meaning of the label consistent? Are the label standards publicly available? Is information about the organization publicly available? Is the organization free from conflict of interest? Was the label developed with broad public and industry input?
Somewhat1 Yes2 No3 Yes Yes Yes Yes
1. The label is somewhat meaningful for Household Cleaners but not meaningful for Kitchen, Children and Recreational Products.
2. The EPA does require cleaning product manufacturers to submit safety and efficacy testing results to EPA for approval in order to use the antibacterial claim.
3. Different antibacterial agents could be used that have varying levels of safety and effectiveness against variable numbers or types of microbes.
 
LABEL CATEGORY:
General Claims
 
WHERE YOU'LL FIND THIS GENERAL CLAIM:

 CLEANING
 
 
WHAT THIS GENERAL CLAIM MEANS:
Generally speaking, "antibacterial" or "antimicrobial" describe a substance(s) or product that kills or inhibits the growth of bacteria, generally in/on foods, inanimate surfaces, or hands. EPA regulates the use of this claim on household cleaning products, kitchen products such as sponges and cutting boards, children's products and recreational products such as tents. Antimicrobial/antibacterial claims mean different things on different products (discussion of this term on personal care products).

Technically, antibacterials (similar to antibiotics) are considered by EPA and FDA to be a subset of antimicrobials, although EPA states that in the US consumer marketplace, "antimicrobial" has typically been associated with the protection of articles (e.g., tents) and “antibacterial” has been more frequently associated with products designed to control human disease-causing microorganisms.

HOUSEHOLD CLEANERS
EPA regulates all household cleaning products and laundry detergents that claim to have antibacterial or antimicrobial properties except dishwashing soap is an exception to this general rule (see below). EPA classifies the active ingredient—that is, the ingredient that works to kill or reduce the microorganisms—as a pesticide and requires it to undergo safety and effectiveness testing prior to marketing, and the active ingredient to be identified on the label. EPA considers additional claims on antibacterial labeled products such as "non-toxic" or "all natural" to be false or misleading. In addition, EPA does not routinely review efficacy (effectiveness) data for products that make odor-resistant claims, although the manufacturer is supposed to generate this information and keep it on file.

EPA also regulates household cleaners that make antibacterial claims and also claim to be disinfectants or sanitizers. The label of household disinfectants must indicate whether the product is effective only against one specific group of microorganisms or against a broad spectrum of microorganisms (in which case it may be called a “general” disinfectant).

Dishwashing soaps that claim to be "antibacterial" would normally be considered to be household cleaners and therefore be regulated by EPA. However, to date, EPA has not registered nor reviewed any antibacterial dishwashing soaps even though there are many "antibacterial" dish soaps on the market. Based on our research, it appears that these antibacterial dishwashing soaps are actually classified and labeled by the manufacturer as hand soaps, which means they are personal hygiene products and fall under the authority of the FDA. Since FDA has no current testing requirement in place for antibacterial active ingredients, these "antibacterial" labeled dishwashing products are not tested for safety or effectiveness.

Detergents, including laundry detergents, that make antibacterial claims are regulated by EPA and must display the EPA registration number.

KITCHEN, CHILDREN'S, AND RECREATIONAL PRODUCTS
Antibacterial/antimicrobial claims are also increasingly appearing on products such as sponges, cutting boards, and toys. EPA theoretically regulates these kinds of products where the product itself is treated with substances designed to kill bacteria or other microbes in the product and where the products that claim to protect more than the product itself. However, EPA has not approved any treated products to make any public health claims, to date, since according to EPA, there is no evidence that these products prevent the spread of germs and bacteria in people. Nevertheless, these types of unauthorized claims are being made. Besides being unlawful, EPA is concerned that they may be potentially harmful to the public, since if people believe that a product has a self-sanitizing quality, they may not wash or follow proper hygienic practices to prevent the transmission of harmful germs.

If you see a sponge, toy, or other kitchen or children's products that makes any of the following “antibacterial” claims, these claims are illegal. You can report this to the Federal Trade Commission (see below for how):
-- Antibacterial
-- Bactericidal
-- Germicidal
-- Kills pathogenic bacteria.
-- Effective against E. coli and Staphylococcus.
-- Reduces the risk of food-borne illness from bacteria.
-- Provides a germ-resistant surface.
-- Provides a bacteria-resistant surface.
-- Surface kills common gram positive and negative bacteria.
-- Surface controls both gram positive and negative bacteria.
-- Surface minimizes the growth of both gram positive and negative bacteria.
-- Reduces risk of cross-contamination from bacteria.
-- Controls allergy causing microorganisms.
-- Improves indoor air quality through the reduction of microorganisms.

EPA does allow some treated products to be labeled as “resists the growth of mold/mildew,” or “kills germs that cause odor.” However, EPA is concerned that some products such as sponges, that are used in the kitchen, bathroom, or other areas where disease-causing organisms may be present can give the false impression that the sponge or other article provides protection against food-borne and disease-causing bacteria. According to EPA, this potential for a false impression should be addressed through additional labeling such as “This product does not protect users or others against bacteria, viruses, germs or other disease organisms. Always clean this product thoroughly after each use.”

Some critics think that antibacterial / antimicrobial claims even when truthful are playing on consumers' fears. They advise consumers not to buy these products except in unusual circumstances. Stuart Levy, M.D., president of the Alliance for the Prudent Use of Antibiotics and a researcher in the field, believes that antibacterial products should only be used by hospitals, sick people coming home from the hospital, and those with compromised immune systems. “Good soap and water is sufficient in most cases,” Levy says. Overuse of antibacterial substances can lead to bacteria becoming resistant to them, which is a problem for public health.

The long-term safety of triclosan, a widely used antibacterial in personal care products, and its effectiveness in products other than toothpaste is particularly controversial. EPA has registered triclosan as a pesticide, but Lester Crawford, Deputy Commissioner of the FDA, stated in October 2002, “In 1974, our agency published the recommendations of its advisory panel on over-the-counter antimicrobial drug products. Among other findings the panel … identified triclosan as one of the ingredients of antimicrobial products that lacked sufficient evidence of safety and effectiveness. … The FDA still is looking for data on the long-term health effects of triclosan, and at present there is no joint effort to trace the effect, if any, of antiseptic products on antimicrobial resistance. … consumers and health care professionals are not as fully protected as they deserve, expect, and have the right to be.”

In the meantime, FDA has taken no action against use of Triclosan. Triclosan may also impact the environment. Triclosan has been found in the majority of surface waters tested for pollutants from common household chemical products. There is some evidence that triclosan adversely affects freshwater algae. Other studies indicate that it can be converted by sunlight into into a member of the dioxin family.
 
WHO VERIFIES THIS GENERAL CLAIM?
EPA requires manufacturers of household cleaners that make an antimicrobial, antibacterial, or similar type of “kills germs” claim to meet standards set by the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), which requires that the product will not cause unreasonable adverse effects to human health or the environment. Thus the product must be safe. EPA requires manufacturers to submit detailed and specific information concerning the chemical composition of their product, toxicology data documenting any hazards associated with use of the product, effectiveness data provided by the registrant (manufacturer of the active ingredient) to document their claims against specific microorganisms, and labeling that reflects most of the required elements of safe and effective use.
 
CONSUMERS UNION EVALUATION:
How meaningful is the label?
An antibacterial claim on Household Cleaners is somewhat meaningful. EPA requires companies to submit information on household cleaners (including disinfectants and sanitizers, excluding dishwashing detergent) that make an antibacterial claim, and EPA reviews the information, to ensure that the active ingredient (the one that works against bacteria) meets required safety and effectiveness tests, and that the product is labeled properly. However, there have been reports of products not working as claimed, so the system is not foolproof. In response, EPA has tested products used in hospitals, but has not tested products used in the home.

An antibacterial claim on Kitchen, Children and Recreational Products is not meaningful. In fact, such claims are not permitted. Contact the EPA and FTC if you encounter an “antibacterial” claim on sponges, toilet seats, toys, or other treated articles.

Foods, drugs, and cosmetics are required to list their ingredients (with a few exceptions, such as fragrances in cosmetics), but household cleaning products are not required to disclose their ingredients (except for disinfectants or other ingredients considered to be antimicrobial pesticides).

Does an organization verify that the label standards are met?
Yes. The EPA does require testing of active ingredients prior to marketing before cleaning products can make an “antibacterial” claim to ensure that are safe and efficacious. The EPA, and the FTC have taken action against some products, in some cases involving fines of $100,000. However, their ability to do so is significantly limited by legal and resource constraints, and numerous products (particularly treated articles) are on the market that make improper claims.

Is the meaning of the label consistent?
No, since different antibacterial agents in household cleaners could be used that have varying levels of safety and effectiveness against variable numbers or types of microbes. While antibacterial claims for Kitchen, Children and Recreational Products exist, none have been approved at this time.

Are the label standards publicly available?
Yes, all laws and government standards and policies are publicly available.

Is information about the standard organization publicly available?
Yes, information about government agencies is available (by phone, through publications, and through their websites).

Is the organization behind the label free from conflict of public interest?
Yes, in that it is a government agency

Was the label developed with broad public and industry input?
Yes.
 
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