PRODUCT PERFORMANCE TESTS AND STANDARDS

Cleaning performance is important for environmental certification. The most

environmentally acceptable household cleaner is cold water, but it doesn't clean very well. If products are certified that do not perform as well as many others on the market, then consumers will quickly lose faith in certified products. Furthermore, the environmental benefits of a "green"

cleaner may be lost if people have to use five times as much of it to clean as well as another brand.

It may be that a little more elbow grease is worth using to protect the environment, but an environmentally superior cleaner should at least perform in the range of other cleaners on the market.

General Purpose Household Cleaners are intended to clean a wide variety of soils on a wide variety of surfaces. As such, a single performance test or standard is difficult to specify.

With so many different types of cleaners on the market with a wide variety of ingredients, it is impossible to predict performance based simply upon product ingredients.

Manufacturers have their own internal standards and internal performance tests, fashioned after long years of market research. None of the manufacturers contacted were willing to share these internal performance tests. Several associations have developed performance tests for comparisons of cleaner performance, but none of these have set standards of performance.

The American Society for Testing and Materials (ASTM) has developed a performance test method for cleaners. Standard D 4488-85 is the Standard Guide for Testing Cleaning

Performance of Products Intended for Use on Resilient Flooring and Washable Walls. This Guide states that it is applicable to testing all types of multipurpose household cleaners, including dissolvable powders, dilutable liquids, and pre-diluted liquids. [ASTM (1989)].

The ASTM Guide, however, does not specify an acceptable level of performance. The purpose of the Guide is to attempt to make performance tests reproducible and consistent. It sets out a series of test methods for different types of surfaces and different types of soils for use in comparing the performance of different cleaners. The tests include the greasy soil/painted

masonite wallboard test method; iron oxide pigment/linoleum test method; mohair cloth/modified Gardner straight-line washability and abrasion apparatus method; and the oil, carbon black and clay/white enamel painted stainless-steel panels test method. Most of these quantify cleaning performance by measuring the reflectance of the material test panel with an optical instrument after cleaning. [ASTM (1989)].

The Chemical Specialties Manufacturers Association (CSMA), a trade association for manufacturers of cleaners, has developed two performance test methods for the performance of some cleaners: CSMA DCC-04 for Hard Surface Cleaners (July 1973) and CSMA DCC-02 for Floor Tile Cleaner (May 1983). The Hard Surface Cleaner performance test method is for evaluating the relative efficiency of aqueous cleaners on painted surfaces. It uses a pencil and a crayon marker as representative soils, a cleaning apparatus that uses a specified number of brush strokes with the cleaner, and a panel of judges to rate the degree of soil removal for each mark made by the pencil and the crayon on a scale of 1 to 7. [CSMA (1973)].

The Floor Tile Cleaner performance test method is for comparing the cleaning efficiency of floor tile cleaners on naturally soiled resilient floor tile (either vinyl asbestos or vinyl tiles).

White tiles are obtained from CSMA and are installed in a pedestrian walkway until they are uniformly soiled. The reflectance of the panels is measured by an electronic instrument called a reflectometer before and after soiling. The panels are then cleaned with the subject cleaner in a cleaning apparatus (called a Gardner Washability Machine) using a sponge for a uniform number of strokes. The reflectance of the panels after cleaning is then measured, and the cleaning

efficiency is calculated as the increase in reflectance after cleaning as compared to the decrease in reflectance from the soiling of the clean panel. [CSMA (1983)].

Consumer Reports has tested General Purpose Household Cleaners using its own cleaning machine test method. It rated 35 products, including some of the best-selling, heavily advertised brands, in cleaning performance on three types of soils on white-painted surfaces: red crayon, black grease compound (lampblack, lanolin, margarine, petroleum jelly), and heavy pencil. Few cleaners performed well on all three of the stains, and the black grease was the most intractable.

[Consumer Reports (1988a)].

Out of the top ten cleaners in performance, seven were formulated with pine oil and

surfactants. Pine oil apparently helps penetrate and loosen greasy dirt. Consumer Reports cautioned, however, about the combustibility of pine oil formulations.

The glycol ether/surfactant-based spray cleaners turned in average performance. The surfactant-based cleaners without pine oil ranged from good to average, and one vegetable oil soap cleaner had average performance. Some of the worst performers in the tests were plain ammonia, a sodium hypochlorite spray, and a cleaner advertised for cleaning grease, that performed worst of all in cleaning the grease stain. [Consumer Reports (1988a)].

2.2.2 Disinfectant Performance

The Environmental Protection Agency has specified test methods for claims of

disinfectancy for household cleaners for registration under the Federal Insecticide Fungicide and Rodenticide Act (FIFRA). Under FIFRA regulations any products bearing claims for control of microorganisms which pose a threat to human health require specific efficacy data to support such claims and patterns of use. [7 U.S.C. § 136a(c)(5); 40 C.F.R. § 162.18-2]. This includes

unqualified claims for products as disinfectants, sanitizers, and for limiting growth of odor-causing bacteria. [EPA Requirements for Antimicrobial Pesticides].

A disinfectant, as that term is used by EPA, is intended to destroy or inactivate one or more species of major bacteria, depending upon whether the disinfectant makes a "limited",

"general", or "hospital" disinfectant claim. There are also tuberculocides, fungicides, virucides, sterilizers (destroy all bacteria and viruses, including spore forms), and sanitizers (reduce number of bacteria and viruses).

Efficacy tests used for general and limited disinfectants, which are most relevant for General Purpose Household Cleaners, include the AOAC Use-Dilution Method and the AOAC Germicidal Spray Products Test, both developed under the auspices of the Association of Official Analytical Chemists, an independent, international standard-setting organization. These tests measure whether a disinfectant kills test bacteria on a standard hard surface. For general disinfectants the test bacteria are Salmonella cholera-suis and Staphylococcus aureus. [GAO (1990)].

EPA's disinfectancy test methods have come under increasing criticism. First, the role of the inanimate environment (e.g., hard surfaces) in transmitting infection has not been completely defined, and controversy particularly exists about whether hard surfaces can transmit infections through contact with intact skin. Second, EPA's test methods have come under fire because they produce highly variable results and may not represent actual conditions of use. This later criticism stems from concerns that the surfaces, number and resistance of microorganisms, presence of organic matter, disinfectant concentration, ambient temperature, and amount of time a disinfectant is exposed to a contaminated surface encountered in actual use conditions may differ significantly from laboratory test conditions. [GAO (1990)].

Industry members have criticized EPA's pass/fail standards based upon the tests as being too stringent. The General Accounting Office found, however, that certain registered disinfectants have failed state and federal enforcement tests by such a wide margin that the disinfectants would be judged ineffective by almost any performance standard. For instance, when EPA was still testing disinfectants, between 1978 and 1982 an average of 42% of all disinfectant samples tested by the lab failed efficacy tests. [GAO (1990)].

Disinfectants in household cleaners do not sterilize a surface, which would require killing all viruses and all living bacteria, fungi, and their spores. Disinfectants destroy specific viruses, bacteria or pathogenic fungi, but not necessarily their spores. Even with prolonged contact time, disinfectants are not effective as sterilizers. [EPA, Letter].

Consumer Reports in a 1988 article on General Purpose Cleaners stated that:

We think it's a waste of money to pay extra for those touted disinfectant properties. A disinfecting cleaner cannot sterilize every surface in the home or sterilize the air. At best, such a cleaner can temporarily reduce populations of some germs in a very limited area for a limited time. Keeping a sickroom clean--with any cleaner--and washing hands after contact with a sick person are usually sufficiently hygienic. If you need stronger germicidal protection, ask your doctor for advice.

[Consumer Reports (1988a)].

In a 1991 article about bathroom cleaners, Consumer Reports stated that:

Many cleaners claim to disinfect, and they may indeed get rid of some microorganisms for a while. But trying to kill microorganisms in an unsterile environment is futile. As soon as you bump off some germs, they're replaced by others.

Consumer Reports ended up recommending General Purpose Household Cleaners for cleaning bathrooms instead of specialized disinfecting bathroom cleaners. [Consumer Reports (1991b)].

We investigated these issues further through literature reviews and through discussions with manufacturers and researchers. The literature reviewed generally supports the argument that disease organisms can thrive on certain hard surfaces in the home, and that some diseases can be transmitted through contact with these surfaces. The surfaces most discussed for such tranmission are food preparation surfaces and hand contact areas in bathrooms, such as water faucet and door handles. In both of these cases the route of exposure is ultimately through ingestion, with

organisms from meat and poultry contaminating other food prepared on the same surfaces, and with hand-to-mouth contact transmitting organisms picked up by hand in bathrooms. [Mendes (1978); Mendes (1975); Zeligs (1992)].

In addition to exposure, the ability of disease organisms on home surfaces to actually cause disease depends upon the size of the organism population and the status of the immune systems of the persons exposed. For most homes and most surfaces, general cleanliness is usually enough to keep organism populations at levels that do not transmit disease, although it is difficult to remove organisms found in raw meat and poultry from rough surfaces such as wood cutting boards by simple cleaning. Persons with weaker immune systems, such as infants, the elderly, and AIDs victims, are more susceptible to infection, and disinfection of surfaces in which they come into frequent contact may reduce organism levels to an extent sufficient to reduce infections.

Manufacturers also believe that disinfectants confer benefits that consumers want by reducing levels of odor-causing bacteria in some areas of the home. No studies were found on this claim, but it seems that general cleaning would have a similar effect and that microorganism populations will return quickly after disinfection on surfaces that are subject to recurring bacterial input, such as toilets. As Consumer Reports concluded, it is impossible to sterilize a home, and some cleaners merely mask odors with their own "disinfectant" odor.

2.3 REGULATIONS FOR GENERAL PURPOSE HOUSEHOLD CLEANERS AND