Food Protection Trends - May/June 2021 - 365

water up to 500 ppm hardness. The efficacy of the product will be negatively impacted if the product is used
in water above the hardness stated on the product label.
Water hardness varies throughout the United States. For
information about a specific location, one should contact
the local health agency or local water utility.
* Contact time. Antimicrobial products have minimum
contact times listed on their product labels. These
contact times can vary based on the product type, the
target organism, or a specific use. The required contact
time for food-contact hard surface sanitizers is typically
1 minute, with the exception of sanitizing in a dish
machine (see FDA Food Code), and for non-foodcontact sanitizers, it can be up to 5 minutes. Disinfectants can list various contact times for different bacteria,
viruses, or fungi but generally do not exceed 10 minutes. If a product has multiple contact times for the
same application, it is recommended to use the most
conservative contact time for routine disinfection,
meaning the longest contact time and the strongest
dilution. In cases when a specific organism is targeted,
the contact time for that organism listed on the label
should be used. Note that for a disinfectant to be
effective, the surface must be wet with the disinfectant
for the full duration of the contact time. It is important
to note that some disinfectants with longer contact times
might need to be applied more than once to achieve the
full required contact time.
* Claims. A claim is a statement about a product
supported by evidence or data and has been approved
by the EPA. Claims can range from simply naming a
product as a sanitizer or disinfectant to specifics about
its ability to kill a particular virus or bacterium or claims
that it will sanitize a particular surface type. An example
is an efficacy claim, which lists organisms for which the
product has been shown to have efficacy.
* These claims are specific to the intended use as a
sanitizer or disinfectant, and they are also specific to
the concentration and a contact time. Any product
marketing materials or associated literature are regarded
as " labelling " by the EPA, and therefore, claims listed on
these materials are subject to the same rules as claims on
product packaging and physical labels. Another type of
claim to note is an emerging viral pathogen claim, used
during a pandemic, such as the COVID-19 pandemic.
This type of claim will only appear on a master label (this
will be discussed below in Emerging Issues).
* Surface type and compatibility. Some products may
have information about surfaces for which the product
is intended (e.g., stainless steel, glazed tile, cabinets, or
floors). Product labels may also mention the surfaces
that may become damaged through use of the product;
for example, peracid products should not be used on soft
metals like copper.

* Shelf life. The EPA requires that shelf life (expiration
date) be listed on the label of a product only when the
shelf life is less than 1 year. The shelf life is determined
for an unopened container by the product manufacturer.
For products that are in use (e.g., wiping cloth solution),
the concentration must be checked according to Section
4-302.14 in the FDA Food Code.
* Storage and disposal. Any specific instructions
regarding storage or disposal are listed on the EPAregistered product label.
* Statutory precautionary statements. These statements
alert the user to the hazards associated with misuse of
the product and necessary first aid procedures if injury
should occur.
* Phone number. A phone number must be listed for the
user in order to access additional information or file a
complaint about the product.
EMERGING ISSUES
Antimicrobial resistance
Discussions about the increased use of antimicrobial
products, such as disinfectants and sanitizers, have centered
around the potential risks associated with the misuse of
these products. In particular, concerns have been raised
about the possibility of the development of reduced
antimicrobial susceptibility, often described in the scientific
literature or media as antimicrobial resistance. The current
research evaluating antimicrobial resistance of bacterial
isolates recovered from food environments has focused on
methodology and concentrations which are not relevant
to the food industry (3). These studies are typically run
following test methods common in antibiotic research, where
use concentrations are very low and close to the minimum
inhibitory concentration (MIC). The concentrations of
sanitizers and disinfectants used in the food industry are
typically hundreds of times higher than the MIC. Currently,
no empirical data exist to indicate that the proper use of
sanitizers or disinfectants leads to antimicrobial resistance
under conditions present in food handling environments as
part of a comprehensive sanitation program (4).
It is imperative that sanitization or disinfection processes
be easy to follow. Sanitizer rotation has been discussed
as a way to mitigate resistance development, without
consideration of whether it is truly needed. This could bring
additional challenges to an already complicated world of
sanitizers, which may in turn further reduce cleaning and
sanitization compliance.
Emerging viral pathogens
In August 2016, the EPA released guidance on disinfectant
claims against emerging viral pathogens (EVP). The
guidance allows companies to make EVP claims against
new and emerging viruses during an outbreak by relying
on historical data on similar or harder-to-kill viruses. In the

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