By J. Darrel Hicks, Contributing Writer

The U.S. Environmental Protection Agency (EPA) recently combined and updated information from several disinfectant lists to create a new list titled EPA-Registered Antimicrobial Products Effective Against Bloodborne Pathogens (HIV, Hepatitis B, and Hepatitis C) List S. The list includes 524 antimicrobials and combines product information from the agency’s following former disinfectant lists: 

• List C: EPA’s Registered Antimicrobial Products Effective Against Human HIV-1 Virus 
• List D: EPA’s Registered Antimicrobial Products Effective Against Human HIV-1 and Hepatitis B Virus 
• List E: EPA’s Registered Antimicrobial Products Effective Against Mycobacterium tuberculosis, Human HIV-1 and Hepatitis B Virus 
• List F: EPA’s Registered Disinfectants for use Against Hepatitis C. 

These four lists are now retired and will be redirected to the new List S. Not only does the revised list include products that are effective against HIV, Hepatitis B and Hepatitis C, it also specifies products that are not effective against one or more of these viruses. 

OSHA Bloodborne Pathogen Standard 1910.1030(c)(4)(ii)(A) requires the use of EPA-registered tuberculocidal disinfectants or a diluted bleach solution to decontaminate contaminated work surfaces, and it should be expanded to include EPA-registered disinfectants that are effective against both HIV and HBV. 

But wait. OSHA's policy is that EPA-registered disinfectants for HIV and HBV meet the requirement in the bloodborne pathogen standard and are "appropriate" disinfectants to clean contaminated surfaces, provided such surfaces have not become contaminated with agents, volumes or concentrations of agents for which higher level disinfection is recommended. 

Related: 3 Nuances of Cleaning and Disinfection in Healthcare

These List S disinfectant products can be used under limited circumstances, provided the following conditions are met. First, HBV and HIV are the only agents or bloodborne pathogen of concern — for instance, as in a research setting — and second, the products are used in the concentrations approved by the EPA. The product also may be approved to disinfect only certain contaminated surfaces, such as solid versus carpet, so additional instructions on the label must be followed. 

The rationale for requiring tuberculocidal agents is not based on the desire to control Mycobacterium tuberculosis but rather to ensure the disinfectant is effective against a host of bloodborne pathogens. Therefore, when bloodborne pathogens other than HBV or HIV are of concern, OSHA continues to require the use of EPA List B- Registered Antimicrobial Products Effective Against Mycobacterium tuberculosis (TB). 

The general duty clause in the OSHA Act of 1970 requires that in addition to compliance with hazard-specific standards, all employers provide a work environment “free from recognized hazards that are causing or are likely to cause death or serious physical harm.“ The risk of employee exposure to bloodborne diseases is a recognized hazard in the healthcare industry, and as such, employers have the responsibility via the act to abate the hazard. OSHA relies on the general duty clause for enforcement authority. 

J. Darrel Hicks, BA, MESRE, CHESP, Certificate of Mastery in Infection Prevention, is the past president of the Healthcare Surfaces Institute. Hicks is nationally recognized as a subject matter expert in infection prevention and control as it relates to cleaning. He is the owner and principal of Safe, Clean and Disinfected. His enterprise specializes in B2B consulting, webinar presentations, seminars and facility consulting services related to cleaning and disinfection. He can be reached at darrel@darrelhicks.com, or learn more at www.darrelhicks.com.