When Cleaning Products Are Pesticides1
It might never occur to many people that cleaning products, such as bleach and disinfectants, can be considered pesticides. Custodial staff and homemakers who routinely use cleaning products within the indoor environment may or may not actually be handling pesticides—it depends. This document describes the US Environmental Protection Agency's (EPA) interpretation of cleaning product label language that constitutes which products are marketed as pesticides and must be registered as such. The document includes examples of cleaning product claims that are considered pesticidal, that are considered not pesticidal, and that may or may not be pesticidal depending on the context in which they are presented.
Introduction and Overview
The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) defines a “pesticide” as “any substance or mixture of substances intended for preventing, destroying, repelling, or mitigating any pest.” Some substances might appear at first to be classified by FIFRA as pesticides, but this is not necessarily the case. Unless otherwise exempted from registration, pesticide products intended for a pesticidal purpose, including some cleaning agents, must be registered.
A product is considered intended for a pesticidal purpose if, among other things, the person who distributes or sells it claims, states, or implies that the product prevents, destroys, repels, or mitigates a pest.Therefore, once a product label or other statement made in connection with the sale or distribution of the product includes any claim of pest mitigation, the product becomes subject to the registration provisions of FIFRA.
A product doesn't necessarily have to act directly on a pest in order for it to mitigate the pest and be considered a pesticide. For example, claims that a product affects the habitat or food source of a pest are considered “mitigation” claims against that pest. Such claims are in contrast with statements about a product's use that merely claim to remove dirt or other debris without its association to mitigating a pest, its food source, or its habitat. Thus “mitigation” claims against a pest, its habitat, or its food source subject the product to the requirements of FIFRA.
Certain products may have effects that mitigate pests without being intended for a pesticidal purpose. One such group of these products includes deodorizers, bleaches, and cleaning agents that are not pesticides because they are not intended to prevent, destroy, repel, or mitigate a pest. However, FIFRA provides, and EPA considers, that these types of products are not pesticides only if no pesticidal claim is made on their labeling or in connection with their sale and distribution. In other words, where a claim or implication is made in connection with the sale or distribution of a cleaning product that its use will mitigate a pest, either by itself or in combination with any other substance, the product is considered a pesticide and therefore requires registration and regulation as such.
In this document, the term “cleaning product” means a substance or mixture of substances, such as chemical or biological substances, intended to clean away or remove material from a surface, water, or air, and that makes no pesticidal claims.
Cleaning Products Considered Pesticides by the EPA
Cleaning products are considered pesticides if their claims imply or express that the product mitigates a pest, directly or indirectly, either by itself or by removing the pest's food, food source or its habitat.The following are example claims, or types of claims, for cleaning products that the EPA deems to have pesticidal intent:
Cleans away, washes away, or removes any pest covered by FIFRA.
Cleans away, washes away, or removes biofilm or scum (unqualified).
Cleans away, washes away, or removes allergens (unqualified).
Cleans away or removes allergens associated with a pest; for example, dust mite allergens and cockroach allergens.
Removes pests by suffocating or drowning.
Cleans or removes pest habitats or breeding sites.
Cleans, precipitates, or removes contaminants, nutrients or matter that provide food or habitat for pests.
Cleans, reduces, or removes scum or sludge where pests breed, feed or live.
Out-competes or displaces a pest for nutrition or habitat.
Cleans or removes the habitat where biofilm, germs, allergens, or microorganisms can hide, thrive, or grow.
Prevents, blocks, removes, neutralizes, or controls bacteria or other pests that cause odors.
Sanitizes, disinfects, or sterilizes.
Images of pests or pest habitats on product labels, labeling, or other advertising media, such as nests, hives, or webs, that imply cleaning or removal of pest habitats, or of nutrition or sources of nutrition for pests.
A banner, logo, design, header, or any claim on a label or labeling, or through other means such as websites, advertising, etc., that specifically links the cleaning product to pest control, Integrated Pest Management (IPM), pests or a specific kind of pest.
Cleaning Products Not Considered Pesticides by the EPA
These cleaning products claim to remove dirt or other debris without any linkage to mitigating a pest, its food, food source, or its habitat.Many of these examples are similar to the examples in the previous section with the explicit linkage to a pest removed.
When not used in connection with other pesticidal claims or in a context where they imply pesticidal purposes, these examples represent claims, or types of claims, for a cleaning product that would not trigger a requirement to register the product under FIFRA. EPA generally considers cleaning products with the claims such as those described below as not intended for a pesticidal purpose.
Cleans or removes stains.
Cleans or removes stains from algae, mold, mildew, or other non-public health organisms.
Cleans or removes dirt, soil, dust, or debris.
Nonliving scum, nutrients, organic particulates, or contaminants.
Cleans a site, such as ponds and aquariums.
Prevents, blocks, neutralizes, reduces, eliminates, encapsulates, or removes odors; deodorizes.
Cleans, reduces, or removes sludge.
Cleans or removes inanimate scum such as “soap scum.”
Cleans, washes, or prepares the surface for application of a registered disinfectant intended to kill biofilm.
Combines suspended inanimate particulates for easy removal by a filtration system.
Cleans away or removes nonliving dust mite matter, nonliving matter, or allergens from nonliving sources. Examples would include pet dander allergens, cockroach matter allergens, and dust mite matter allergens. These examples differ from the examples in the previous section in that these indicate that the allergens come from nonliving matter.
Fishel, F.M. 2006. Federal regulations affecting use of pesticides. PI-131. Gainesville: University of Florida Institute of Food and Agricultural Sciences. http://edis.ifas.ufl.edu/pi168 (accessed January 2011)
Fishel, F.M. 2006. What is and isn't a pesticide. PI-96. Gainesville: University of Florida Institute of Food and Agricultural Sciences. http://edis.ifas.ufl.edu/pi133 (accessed January 2011)
This document is PI233, one of a series of the Agronomy Department, UF/IFAS Extension. Original publication date January 2011. Reviewed March 2017. Visit the EDIS website at http://edis.ifas.ufl.edu.
Frederick Fishel, professor, Department of Agronomy and director, Pesticide Information Office; UF/IFAS Extension, Gainesville, FL 32611.
Use pesticides safely. Read and follow directions on the manufacturer's label.
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U.S. Department of Agriculture, UF/IFAS Extension Service, University of Florida, IFAS, Florida A & M University Cooperative Extension Program, and Boards of County Commissioners Cooperating. Nick T. Place, dean for UF/IFAS Extension.