This chapter deals with the evaluation methodology of efficacy tests for disinfectants for the national authorisation of products under the EU Biocidal Products Directive 98/8/EC (BPD) and the EU Biocidal Products Regulation 528/2012 (BPR).

The general introduction is written for disinfectants in Main Group 1 (PT 1 to 5). Detailed guidance is currently only available for PT2, and guidance on the other PTs will be included at a later date. This guidance is a “living document”, which will be revised regularly.

1. General Introduction

1.1 Introduction

This chapter describes the nature and extent of data which should be available to support the label claims for biocidal products within the Main Group 1: Disinfectants. This group covers 5 product types[1]:

Product type 1: Human hygiene

Products in this group are biocidal products used for human hygiene purposes, applied on or in contact with human skin or scalps for the primary purpose of disinfecting the skin or scalp.

Product type 2: Disinfectants and algaecides not intended for direct application to humans or animals

Products used for the disinfection of surfaces, materials, equipment and furniture which are not used for direct contact with food or feeding stuffs.

Usage areas include, inter alia, swimming pools, aquariums, bathing and other waters; air-conditioning systems; and walls and floors in private, public, and industrial areas and in other areas for professional activities.

Products used for disinfection of air[2], water not used for human or animal consumption, chemical toilets, waste water, hospital waste and soil.

Products used as algaecides for treatment of swimming pools, aquariums and other waters and for remedial treatment of construction materials.

Products used to be incorporated in textiles, tissues, masks, paints and other articles or materials with the purpose of producing treated articles with disinfecting properties.

Product type 3: Veterinary hygiene

Products used for veterinary hygiene purposes such as disinfectants, disinfecting soaps, oral or corporal hygiene products or with anti-microbial function. Products used to disinfect the materials and surfaces associated with the housing or transportation of animals.

Product type 4: Food and feed area

Products used for the disinfection of equipment, containers, consumption utensils, surfaces or pipework associated with the production, transport, storage or consumption of food or feed (including drinking water) for humans and animals.

Product type 5: Drinking water

Products used for the disinfection of drinking water for both humans and animals.

Products in this main group are meant for the control of micro-organisms, such as bacteria (including vegetative cells, spores and mycobacteria), fungi (including moulds and yeasts), and viruses (including bacteriophages), algae and protozoa. Control may be carried out on inanimate surfaces or skin or in liquids.

The most important fields of use include the medical, veterinary, and food and drinking water sectors. Applications in public, commercial and industrial areas, where application is to surfaces without direct contact with food are included in Product type 2. If contact between disinfected surfaces and food is possible (e.g. food industry, private and restaurant kitchens), applications are included in Product type 4.

Disinfectants for medical instruments and medical equipment that are considered medical devices are covered under the Medical Device Directive 93/42/EEC. However, disinfectants with a broader claim, e.g. disinfection of instruments and surfaces, are under the BPD or BPR.

Cleaning products which are not intended as biocides, including liquid detergents, washing powders etc., are excluded from these product types.

Treated articles with claimed disinfecting or biostatic properties or function also fall within PTs 1 to 5, when they have a primary biocidal function. These articles can include a wide variety of products, with different applications, matrices etc..

There is currently little guidance on data requirements and acceptance criteria available for treated articles. A chapter on treated articles will be included in this guidance at a later date.

A “Glossary of Terms” is included as Appendix 1 of this chapter.

1.2 Dossier requirements

The following aspects are relevant for the evaluation of the efficacy of disinfectants:

1. The label claim and instructions for use

2. Efficacy data of the product

3. The possible occurrence of resistance, cross resistance or tolerance.

1.3 Label claim

For each product, clear label claims should be provided. When the label itself cannot contain all the necessary information, any accompanying leaflet containing instructions for use should also be considered. To simplify the text only the term "label claim" will be used below.

The types of efficacy claims made for a disinfectant depend upon, among other things, the types of micro-organisms the disinfectant targets (e.g. fungi, yeasts, (myco)bacteria or bacterial spores) and the disinfectant’s intended use (e.g. in hospitals, in contact with food, in stables). Label claims and recommendations for use, including concentration and contact time, must be supported by the results of bactericidal, fungicidal, etc. tests appropriate to the area of application, which are normally performed on the basis of the specific standards.

Applicants must clearly indicate the spectrum of antimicrobial activity claimed for the proposed product on the product label.

Examples of the common fields of applications are presented in Appendix 2: Claim matrix (note: this list is not intended to be exhaustive).

1.3.1 Target organisms

The target organisms for which claims are made should be specified on the product label.

As the claimed antimicrobial efficacy for disinfectant products will encompass a large spectrum of potential target organisms, it is not necessary or indeed feasible to include all the possible micro-organisms in an efficacy test designed to support a label claim.
Instead the types of target organism the product is intended for are mentioned, e.g. fungi, yeasts, viruses, algae, protozoa, (myco)bacteria or spore forming bacteria. Specifying the groups of organisms (e.g. bacteria, fungi) is also relevant as products are not normally specific to single species.

Specific species are mentioned on the label where they are the only or most relevant organism, or where they have a different susceptibility to biocides than the rest of the group. For instance, mycobacteria are less susceptible then other bacteria and it is only relevant to control them in certain situations such as tuberculosis wards.

In general it is not possible to claim against specific single species without claiming (and demonstrating) efficacy against the group of organisms (e.g. no claim against Mycobacterium tuberculosis without also making a general bactericidal claim, no claims against Rotavirus without a general virucidal claim). However, there are some cases in which it can be justified that a single or a small number of species are relevant (for instance bacteriophages in milk industry).

Standard test methods normally specify one or more representative species that should be tested per group of organisms claimed. For instance, a bactericidal product should be tested on gram-positive and gram-negative bacteria, a fungicidal product should be tested on yeast and fungi. The species used are representative species that take into account their relevance to practical use, susceptibility for disinfectants and adequacy for laboratory testing.

The test organisms and strains which should be used are normally stated in standard efficacy test methods, i.e. according to EN 14885 or OECD-guidance and guidelines.

When it is not possible to use standard test methods for efficacy testing and other tests are used, the test organisms listed in Appendix 4 should be employed. If test organisms other than those listed in Appendix 4 are used, their relevance should be justified.

Wherever possible strains should be selected from international collections (their genetic stability should be checked regularly). The preservation procedures must be clearly described (EN12353).

Other test organisms, in addition to those specified in the test standards, can also be tested. When efficacy against specific additional species is claimed, efficacy tests with those species should also be performed. In general, claims should not be made against the specific reference species used in a standard test as this can give a misleading impression that the product shows activity beyond that covered by the general (e.g. bactericidal, fungicidal) claim.

Mentioning specific organisms on the label is still subject of discussion between Member States. The above paragraphs reflect the position at the time this guidance is written.

1.3.2 Areas of Use

Disinfectants are used almost everywhere people want to “eliminate” micro-organisms. They are used to kill or irreversibly inactivate bacteria, fungi and viruses on animate and in-animate surfaces and matrices, in hospitals, households, schools, restaurants, offices, swimming pools, kitchens, bathrooms, dairy farms, on medical and dental instruments, eating utensils and at many other locations.

Applicants should clearly indicate the intended areas of use for the product on the label e.g. areas of use could include (not exhaustive):

Hospital and other medical areas

Domestic use

Institutional use (offices, schools etc.)

Industrial applications, e.g. food, cosmetic, pharmaceutical industry etc.

Veterinary areas (animal housing, animal health care etc.)

Recreational areas

1.3.3 Sites of Application

In addition to the types of efficacy claimed (e.g. bactericidal, fungicidal, tuberculocidal) and the intended area of use, the applicant must specify the use patterns for which the disinfectant is recommended on the label.

Broad examples of use patterns (not exhaustive) could include areas such as:

· Use on intact skin

· Use in hospitals, operating theatres, isolation wards, use on instruments etc.

· Use in food manufacturing, retailing, processing areas etc.

· Use in animal housing and equipment, e.g. pigs, sheep, poultry etc.

· Use on work surfaces, cutting boards etc.

· Use on fabrics or textiles

· Use on toilets, bathrooms, sinks, etc.

· Use against micro-organisms associated with human or animal wastes

· Use in air conditioning systems

· Use in swimming pools, spas, aquariums and bathing waters

· Use in tanks, pipelines, equipment soak or bottle wash

1.3.4 Directions for use (Methods of application)

The label claim must specify the application method of the product. For disinfectants there is a broad range of application methods (e.g. aerosol, wiping, spraying). The in-use concentration of the solution and the contact time, which are essential for safe and effective use, should be described on the label. Any other directions for use should also be specified, such as whether the surface should be cleaned first, and claims regarding the number of times a prepared use solution of an antimicrobial product can be used (or re-used) before a fresh solution must be prepared.

The application method can have a strong influence on the efficacy of a product, therefore the testing of a product should be appropriate for the application method. If specific equipment is used for application of the product (e.g. vaporisers) this should be taken into account when testing the product for efficacy.

1.3.5 Other interfering parameters

Any other circumstances that can effect the efficacy of a product should be mentioned on the label (e.g. temperature or pH requirements). For example, when a surface should be cleaned before applying the biocide and no rinsing step is involved, alkaline cleaning fluids should not be used with acidic biocides, and vice versa.

1.4 Efficacy testing of the product

For efficacy testing of disinfectants in general only quantitative tests methods should be used.

1.4.1 Tiered approach

For efficacy testing of disinfectants a tiered approach is recommended. The following tiers can be distinguished (in accordance with EN 14885: 2006):

Phase 1 tests are quantitative suspension tests to establish that a product has bactericidal, fungicidal, virucidal etc. activity without regard to specific conditions of intended use.

Phase 2 comprises two steps:

Phase 2 step 1 tests are quantitative suspension tests to establish that a product has bactericidal, fungicidal, virucidal etc. activity, simulating practical conditions appropriate to its intended use.

Phase 2 step 2 tests are quantitative laboratory tests, often using carriers or living tissues with dried-on micro-organisms, simulating practical conditions to establish that the product has bactericidal, fungicidal, virucidal etc. activity.

Phase 3 tests are field tests under practical conditions.

1.4.1.1 Phase 1

Phase 1 tests are laboratory suspension tests to establish the basic activity of the product or active substance. These tests may be used during the development of the product, but are not accepted for product authorisation. However, a phase 1 test can be used to demonstrate that a co-formulant does not have any biocidal activity in the product.

1.4.1.2 Phase 2 step 1

Phase 2 step 1 tests are laboratory suspension tests in which the ultimate purpose is to establish at what concentrations the product meets specified requirements under “in-use” conditions. In these tests in-use conditions (e.g. temperature, contact time, interfering substances) are considered in the test method.

Various laboratory methods have been developed for biocide activity testing.
Although these experiments differ in their design and experimental detail, they are all based on the principle of adding a test inoculum to disinfectant (or vice versa) and taking samples at specified times. The biocide in each sample is then neutralised and the survival of the organisms assessed. In practice the methods can be classified into 2 groups, according to how the end-point of the test is determined:

Quantitative tests

Samples of untreated and biocide-treated cells are plated on nutrient medium after neutralisation. After incubation, the number of colony forming units is determined and the log reduction in viable counts determined.

Capacity tests

The biocide is challenged successively with the test organism at defined time intervals. This type of test can be used for instance for swimming pools and toilet disinfectants which are challenged by new bacteria periodically.
Following each inoculation samples are taken, and after a suitable contact period has elapsed, the biocide is neutralised and the sample incubated in a suitable growth medium to determine the surviving micro-organisms. The result is expressed as the amount of the accumulated inoculum that was required to produce the “failure”.

1.4.1.3 Phase 2 step 2

Phase 2 step 2 tests are simulated use or practical tests, which mimic real-life conditions, for instance by pre-drying the micro-organisms onto surfaces. These tests are used in a second testing stage. After measuring the time-concentration relationship of the disinfectant in an in-vitro test (phase 2 step 1), these practical tests are performed to verify that the proposed use dilution is likely to be adequate in real life conditions. For several uses standardised simulated use tests exist (surface disinfection, hand wash or rub, instrument disinfection) but there are no standard tests available for many others.

Longer-lasting activity is claimed for some products. When these products are applied to surfaces, it is common that they will not be completely removed or rinsed off after application. This might lead to longer-lasting activity of the biocide on the surface, which can be determined by modified efficacy tests.

1.4.1.4 Phase 3 Field or in-use tests

In-use testing involves the antimicrobial evaluation of the product under actual conditions of use on specified surfaces or materials in a specified environment. As with standard and non-standard laboratory methods, representative organisms or actual organisms of concern may be used.

Validated methodologies for these types of tests are not currently available, although some are in development.

The practical use conditions under which a product can be used can be very variable and are therefore difficult to standardise. Field tests, although not standardised, can however give valuable additional information on the efficacy of the product, provided that the studies are scientifically robust, well reported and provide a clear answer to the question. In these types of test, a control treatment without biocide should be included. Where this is not possible, efficacy should be judged on a comparison of the situation before and after application.

Until validated standards are prepared, the responsibility for determining the acceptability of data derived from field trials in support of the claim will lie with the Competent Authority.

1.4.2 Standard test methods

Ideally, data should be generated using international or national recognised testing methods (CEN, OECD, ISO, etc.). Several international standard test methods currently exist for disinfectant products. A list of recommended standard tests is presented in Appendix 3 to this document.

If there are no guidelines available for the specific use of a product or guidelines are not suitable, the applicant may use other methods (such as intra-company Standard Operating Procedures), where the studies are scientifically robust, well reported and provide a clear answer to the question. In addition, the test methods used, together with the test conditions, should be clearly and fully described and must address the efficacy claim that appears on the product label. The use of existing guidelines, with revisions to make the guideline more suitable for the specific product or use conditions, is also possible.

At the time of production of this guidance document, a broad range of CEN methods is available, as described in Appendix 3. Further the development of a series of phase 2 / step 2 methods for the disinfection on hard surfaces is under progress by the CEN and OECD. The use of CEN or OECD test methods is highly recommended, where these are available and relevant.

These methods described below typically give a standard set of test parameters, test organisms and pass criteria. Where specific conditions apply for a field of use, such as high/low level soiling, high/low temperatures, relevant contact times etc., these conditions should be included in the efficacy tests.

1.4.2.1 CEN Standard Test Methods

A Technical Committee (TC 216) was established in the European Committee for Standardisation (CEN), to produce harmonised European methods for testing the activity of disinfectants used in medical, veterinary, food, industrial, domestic and institutional areas. The standards are based on suspension tests (phase 1 and phase 2/step 1) and some simulated use tests like surface tests (phase 2/step 2).

European standard EN 14885 gives information on the application and interpretation of European Standards for the testing of chemical disinfectants within product types 1, 2, 3 and 4 of the Directive / Regulation.
This document outlines the various standards currently available and provides guidance as to the choice[3] of available standards that may be used to demonstrate the effectiveness of disinfectants in particular situations (such as medical, veterinary and food hygiene) and on the interpretation of results from such tests in making and supporting efficacy claims.

In EN14885 products intended for domestic use are grouped with products for use in food and industrial areas, and therefore the tests specified are not always relevant to domestic areas. For instance, the virus test EN13610 only tests on phages. In these cases the test from the medical area should be used where relevant. In cases where no test method is available for one area of use (e.g. sporicidal test in medical area), a test from another area can be used instead, provided that the test parameters (soiling, temperature, etc.) are adapted to the intended use area.

The application of disinfectants to water systems such as swimming pools, spas, and drinking water is not addressed in EN 14885 (2006). For the evaluation of activity against Legionella in aqueous systems (water used in cooling towers and water for general purposes, like spas, pools, showers and other uses) a quantitative suspension test is available (EN 13623).

CEN TC 216 is revising EN 14885 and the new version will include guidance on how a field trial shall be conducted. This guidance is intended to advise on the factors to be taken into account and controlled when carrying out a field trial.

The use of CEN test methods is highly recommended, provided that the methods are applicable for the use of a product. In some cases, the method can be adapted (other contact time, soiling, etc.) to fit the use conditions. Any deviation from a standard must be clearly described and a justification for any deviations provided.

1.4.2.2 OECD Standard Test Methods

OECD has several draft phase 2/step 2 test methods for the efficacy testing of disinfectants to be used on hard surfaces under development, although it is currently uncertain if they will be accepted as Test Guidelines or as Guidance Documents. Guidelines on the testing of disinfectants used in treated articles are also in preparation.

An OECD guidance document “Guidance document on the evaluation of the efficacy of antimicrobial treated articles with claims for external effects” and an OECD Guidance Document for pool and spa disinfectants have been published.

As with the CEN test methods, the use of OECD test methods is also highly recommended, provided that the methods are relevant to the use of a product. Again, the methods can be adapted (other contact time, soiling, etc.) to better fit the use conditions, provided that any deviations from the standard are clearly described and justified.

1.4.2.3 Other Standard Test Methods

While CEN and OECD standards are highly recommended, there are circumstances in which these tests cannot be applied, i.e. they are not available, or relevant to a particular product or use pattern. In those cases other test methods can be used.

Other test methods, e.g. DGHM, EPA, AOAC or ASTM methods, are available and might be used when no international standard is available for a specific application. Where these methods lack predefined test parameters, target organisms or pass criteria, the applicant has to provide evidence why the chosen parameters are appropriate for the intended application.

Where no standard tests are available, suitable test protocols may be designed (and justified) by the applicant, but these should be discussed with and agreed by the Competent Authority before testing takes place.

1.4.3 Data requirements

Label claims and recommendations must be supported by the results of tests appropriate to the area of application.

In each test the composition of the tested product should be clearly described: including the identity of the active substances and co-formulants, and their concentrations in the tested formulation. As the formulation may affect the efficacy of the product, the composition of the product tested should be the same as the product under consideration. If not, justifications should be provided for any differences, and these will be assessed on a case by case basis. In cases where the test report does not report the formulation of the test product (e.g. it may only state a code for the product for the purposes of confidentiality with the testing organisation), the full composition of the product should also be provided.

As Phase 1 tests do not take practical use conditions into account, they are not considered acceptable to support claims during product authorisation. In general phase 1 tests are used during the development of the product, for inclusion of an active substances on Annex I of the BPD or “Union list of approved substances” under the BPR or to prove that a co-formulant has no biocidal activity.

In general at least phase 2 step 1 and step 2 tests are required to support label claims during product authorisation. The phase 2 step 1 test will provide basic information on the efficacy of the product (in a standard test) that can be compared to similar biocides, while phase 2 step 2 tests investigate the effects of more in-use factors (such as interfering substances). The combination of phase 2 step 1 and step 2 tests will generally provide a robust data package to demonstrate the efficacy of a product. Deviations from the tiered approach should be justified.

In some cases, e.g. when disinfection is done in suspension under real use conditions, a phase 2 step 1 test is sufficient on its own, as this already simulates practical conditions.

A phase 2 step 2 test may be replaced by a phase 3 test where a phase 2 step 2 tests is not appropriate. In general, a phase 3 test will be done in combination with a standard phase 2 step 1 test, as phase 3 tests are often variable.

Where in-use conditions cannot be simulated, phase 3 tests are required (e.g. drinking water disinfection with ionisation equipment).

If more than one test method is available and applicable in phase 2, step 2 to substantiate a label claim for efficacy, it is sufficient to provide data from only one of the test methods. The test method selected should be one which best represents the way in which the product is used. For example, in the case of a disinfectant used for “hard, non-porous surfaces by spraying”, the test method should be one for such surfaces without mechanical action and with representative conditions of use, such as contact time, soiling, temperature and test organisms.

Tests have to be performed with relevant target organisms, which are selected in accordance with the standard and the intended use of the product. This is further discussed in Section 1.3.1. A list of standard test organisms in given in Appendix 4.

The concentrations used in testing should be selected to demonstrate the threshold of product efficacy. Suspension test should be performed with several dose rates, including at least one rate lower than the effective rate. Competent Authorities will evaluate dose response data generated in these tests in order to assess if the recommended dose is appropriate (i.e. the concentration is not too high, or at the minimum) to achieve the desired effect.

For biocidal products which claim a biostatic effect (bacteriostatic, fungistatic, etc. i.e. the ability to inhibit growth of bacteria, fungi etc. without killing them) both suspension and surface tests should be performed. The suspension test should be performed with and without neutralisation and with a water control (where water is tested instead of the product). The results from this testing should show that the product prevents growth of the test micro-organism (i.e. a lower level of test organism compared to the water control) but does not necessarily inactivate them (the micro-organism survive in the test without neutralisation).

Biocidal products that claim a biostatic effect bear the risk of development of resistant organisms. For this reason, efficacy of these types of products has to be examined carefully.

Other products, which do not have biocidal or biostatic activity, might fall within the scope of BPD or BPR, i.e. which “deter, render harmless, prevent the action or otherwise exert a controlling effect on any harmful micro-organism”. No EU standards are available for these types of product yet, so applicants should provide a method following the principles of this guidance and based on scientific evidence. During development of new tests, or when an applicant is considering using a non-standard test or using novel testing methods, they should discuss this with the Competent Authority as to the acceptability and applicability of the test.

In the following sections, guidance on the requirements per product type and use will be given.

A detailed but non-exhaustive list of most relevant product applications and uses of biocides, together with the required test methodology, is given in Appendix 2 (Claims matrix).

1.4.4 Relevant factors of the test procedure

1.4.4.1 Formulation of the tested product[4]

A product authorisation is given to a specific product with a defined composition, and the efficacy of this specific formulation should be demonstrated. Therefore it is important that the formulation tested is clearly reported in each test report (or provided alongside the test report with a statement that it is the formulation which has been tested). The formulation details should specify the active substances and co-formulants present, together with their respective concentrations, and should confirm that all tested formulations contain the same co-formulants and concentrations. Any deviations should be mentioned and justified in a statement or in the relevant efficacy reports. Where there are deviations in the formulation from that in the product for which authorisation is sought, the tests will only be considered relevant where it is evident that the deviations have no effect on efficacy.

1.4.4.2 Hard Water Claims

The degree of hardness of the water used to dilute the disinfectant may affect its performance (by the presence of metal ions such as Ca2+ and Mg2+). Generally the harder the water is, the less effective the diluted disinfectant will be. Therefore, test programmes which require that products are diluted with potable water must be diluted in water of standard hardness for the purpose of efficacy testing.

It follows that any product that carries label claims for effectiveness in hard water must be tested by the appropriate method in water with defined hardness at the level claimed.

1.4.4.3 Presence of Interfering Substances

Where disinfectants are applied to either inanimate surfaces or the hands, substances may be present on the surface which may affect the disinfectant’s activity.

The nature, amount and condition of the soiling present will affect the efficacy of a disinfectant.

In many cases, however, residual contamination must be expected, and in some situations (e.g. in the treatment of blood spillages) disinfectants are specifically used to decontaminate soiling, to prevent infection transfer and to assist in safe disposal.

Blood, urine, faeces, food debris, fats and oils, dust and proteinaceous materials are the most likely organic soils to be encountered. Limescale, milkstone and soil are the most common inorganic soils.

Where claims are made for use under soiled or dirty conditions, the use concentrations of the product must be determined from tests carried out in the presence of suitable soil. Soiling materials commonly used in efficacy test methods include albumin serum, blood, yeast and yeast extract.

In practice, with exception of a few situations (e.g., clean rooms) the presence of soiling on surfaces or in liquids to be disinfected can not be ruled out. For this reason, a small amount of interfering substance should always be added in testing the product. In the CEN methods this is called "under clean conditions". Tests under clean conditions can be used when the surface is clean before disinfection. When a product claims combined cleaning and disinfection the product should be tested under dirty conditions.

When a product is to be recommended for certain uses where the soiling is of a specific type (such as soap film residue or hard water scum), the product must be tested in the presence of that specific soil.

Generally, soiling will reduce the efficacy of the disinfectant, and where soiling is present, longer contact times, higher concentrations, pre-cleaning or a combination of these elements may be necessary.

1.4.4.4 Temperature

Generally, disinfection performance increases with temperature, although this depends on the active substances and the effect on individual species may vary depending on the specific properties. Therefore, the test temperature should be representative of the intended use of the product (e.g. low temperature in stables, high temperature in contact with skin).

1.4.4.5 Contact Time

The contact time of a product on a surface etc. is an important aspect in the evaluation of the efficacy of disinfectants. In general, the longer the contact time, the more effective the disinfectant is.
In trials where test organisms are taken from treated samples for further analysis, the contact time between the biocide and the test organisms should be stopped. Neutralisers, membrane filtration or subculture techniques are used to prevent residual carry over of active substances. Neutralisation is discussed further in section 1.4.4.6 below.

Some disinfectants act very quickly, whereas others require an extended contact time to achieve adequate performance. Mycobacteria, bacterial spores, fungal spores and non-enveloped viruses take longer to be irreversibly inactivated than most vegetative micro-organisms.

The contact time that is practical in real life use should be taken into consideration when testing. In phase 2 and phase 3 tests the product should pass the test at the contact time recommended on the product label.

1.4.4.6 Neutralisation

Neutralisers are used to stop the product’s activity in trials where the test organisms are taken from treated samples for further analysis, such as plate count following biocidal treatment. An effective neutraliser for the test product should be identified, and evidence demonstrating the effectiveness of the neutraliser against the active ingredient, and showing that the neutraliser itself does not have antimicrobial activity, must be included in a test report. Appropriate controls for determining the efficacy of the neutraliser should be performed.

Membrane filtration or subculture techniques can be used to neutralise the product’s activity, in combination with or instead of chemical neutralisation.

1.4.4.7 pH

The prevailing degree of acidity or alkalinity during disinfection can also affect the performance and choice of disinfectant, and must be included in the test report.

1.4.4.8 Texture of Surfaces

Smooth impervious surfaces are easier to disinfect (and also to clean) than rough or pitted ones. In some circumstances the micro-organisms might be protected from the action of disinfectants by being protected in porous surfaces. Clumps of micro-organisms may also be more difficult to inactivate, as cells inside are protected by dead micro-organisms on the outside.

Bacteria and fungi can adhere to surfaces forming biofilms. In biofilms, the cell resistance is increased (the bacteria are in a different physical state) and penetration of biocide can be difficult to achieve due to the matrix surrounding the bacteria. This makes bacteria in biofilm more difficult to inactivate.

1.5 Resistance

The topic of resistance is discussed in the general part of the TNsG on Product Evaluation (Chapter 6). Additionally, in support of the review for each active substance information on resistance is given in the Competent Authority Report of this active substance.

Resistance will be assessed on the basis of expert judgement.

1.6 Assessment of authorisation

1.6.1 Decision making

The Biocides Product Directive 98/8/EC (Annex VI 90-93) and Biocidal Product Regulation 528/2012 (Annex VI) stipulates rules for decision making for biocides (see Biocides chapter Efficacy General).

The test results shall meet the requirements of the standards or other criteria for acceptance which are described below per type of use. Where a product does not perform to these criteria, the applicant should provide a justification in the application as to why the product should still be recommended for authorisation.

1.6.2 Assessment

The CA assessor/expert assesses the performance of the product as demonstrated in the submitted efficacy tests against the label claims made for the product and the above criteria. If the product is judged to be sufficiently effective in laboratory (and, where relevant, field) tests, the product will be recommended for authorisation as far as efficacy is concerned.

In exceptional cases the applicant can provide justification why the specified acceptance criteria are not met but the product is still acceptable. The Competent Authority will evaluate the justification on a case by case basis, possibly in consultation with the other Competent Authorities, and decide whether it is acceptable or not.

The following sections give more specific dossier requirements per type of disinfectant.

2 PT 1 Human hygiene biocidal products

Will be added later.

3 PT 2 disinfectants and algaecides not intended for direct application to humans or animals

3.1 General Introduction PT2

Product type 2 contains disinfectants and algaecides not intended for direct application to humans or animals. This includes inter alia:

- products used for the disinfection of surfaces, materials, equipment and furniture which are not used for direct contact with food or feeding stuffs,

- usage areas like swimming pools, aquariums, bathing and other waters; air-conditioning systems; and walls and floors in private, public, and industrial areas and in other areas for professional activities.

- products used for disinfection of air[5], water not used for human or animal consumption, chemical toilets, waste water, hospital waste and soil.

- products used as algaecides for treatment of swimming pools, aquariums and other waters and for remedial treatment of construction materials.

- products used to be incorporated in textiles, tissues, masks, paints and other articles or materials with the purpose of producing treated articles with disinfecting properties.

The data requirements (test standards and test organisms) and assessment criteria for the most common uses are specified below. A detailed but non-exhaustive list of most relevant product applications and uses of disinfectants within PT2, together with the relevant test methodologies is given in Appendix 2 (Claims matrix).

All of the possible uses in this PT cannot be covered in the Appendix. For less common uses, there is often no international standard test available. Where this is the case, the applicant should provide tests that show the efficacy of the product and a justification for the use of these tests. The assessment of these products will be based on expert judgement and will be handled case by case.

3.2 General data requirements PT2

There are some general data requirements which apply to all uses in PT2, and these are described below. There are also specific data requirements which apply to different types of use, and these are described in the sections covering those uses.

The intended uses of the disinfectant determine which tests will be required to support the product. Tests which most closely reproduce the practical application conditions should be selected.

In general it is not known which organisms are present on a surface or matrix to be disinfected. Therefore a disinfectant must have a broad spectrum of activity, in order to control all of the organisms which may be present.

3.2.1 Use in health care

For general applications in the medical sector, products should be at least sufficiently effective against bacteria and yeasts (which are responsible for most common nosocomial infections). Additionally efficacy against other organisms can be claimed.

3.2.2 Tuberculosis departments

If the product is to be used on tuberculosis departments, the product should be efficacious as general disinfectant used in health care (efficacy against bacteria and yeast), but efficacy against mycobacteria (representative for M. tuberculosis) must also be demonstrated.

3.2.3 Products against viruses

Products against viruses must be effective against viruses with and without an “envelope” (protein or lipid mantle). Products can claim virucidal efficacy if efficacy against non-enveloped viruses has been proven. Such products can be regarded as efficacious against enveloped and non-enveloped viruses.

The virus test EN13610, which is recommended in EN14885 for food, domestic and industrial areas, is not relevant for use in domestic areas, as it only tests on phages. Instead, the test specified for the medical area, EN14476, should be used for products against viruses used in domestic areas.

3.2.4 Biocidal products with biostatic effect

For biocidal products with a biostatic effect (bacteriostatic, fungistatic, etc.), both suspension and surface tests should be performed. The suspension test should be performed with and without neutralisation. The results from this test should show that the product prevents growth of the test organism (a reduction in numbers compared to the negative control) but does not kill them (survival of the test organism in the test without neutralisation).

3.2.5 Malodour control

There are specific requirements for products claiming control of organisms which cause malodour. Phase 2/step1 and step 2 tests should be performed with odour producing micro-organisms. A justification for which bacteria, fungi, etc. are relevant to the intended use should be provided. Next to these laboratory tests an odour test can be performed.

3.2.6 Test range

Tests (phase 2, step 1) should be carried out at a range of concentrations in order to verify that the use concentration is suitable for the desired effect (e.g. not too high or not at the minimum effective level).

3.2.7 Changes in ingredients [6]

When small changes are made to the non-active ingredients in a product, it is not always necessary to redo all the tests with the new formulation. The applicant may provide a justification for changes and the effects they have on the efficacy of the product. In case of a minor change, a robust justification might be sufficient (to be decided by the Competent Authority). In other cases, new efficacy tests will have to be provided. This can be a full set of efficacy tests or a test with the most resistant organism in the former test.

3.3 Disinfectants for hard surfaces

3.3.1 Introduction

Biocides can be used to disinfect hard surfaces in areas such as hospitals, industry, institutions or private homes. These surfaces can be tables, floors, walls, the outsides of machinery and hard furniture, etc.. Products are often wiped or sprayed onto the surfaces, and may be washed or wiped off after a certain contact time.

The testing requirements for some specific uses of hard surface disinfectants are discussed in separate sections e.g. toilets, room disinfection with vaporised biocide, immersion of equipment into the product, etc.. As the areas of use can be as diverse as private homes, operating theatres etc., the test requirements might vary depending on the area of use.

3.3.2 Data requirements

See general data requirements PT2 (section 3.2). A detailed, but non-exhaustive list of most relevant product applications and uses of hard surface disinfectants and the required test methodologies is given in Appendix 2 (Claims matrix, table Hard surfaces).

3.3.2.1 Test methods

For efficacy testing of hard surface disinfectants, the tiered approach as described in section 1.4.1 is preferred.

The following tests are normally required for a hard surface disinfectant:

- a quantitative suspension test (phase 2/step 1),

- and a quantitative surface test (phase 2/step 2),

both simulating practical conditions appropriate to its intended use (temperature, soiling, different surfaces, contact time, etc.).

Tests in phase 3 are optional, as no validated test methods are available yet.

Several test methods for testing the efficacy of hard surface disinfectants are available.

Appendix 3 gives a list of recommended test methods.

The following documents are recommended for surface disinfection:

· EN 14885: gives an overview of which EN phase2/step1 and step2 tests to use for different uses.

· OECD guidance and guidelines for the testing of chemicals: Quantitative method for evaluating activity of microbiocides used on hard non-porous surfaces. (These are surface tests which would be considered phase 2/step 2 tests)

The use of the specified tests is strongly recommended where they are relevant and appropriate. Where the tests are not appropriate to the product other tests can be used, although a justification for the relevance of the tests used should also be provided.

Preferably, tests should be selected that correspond to the use area of the product (e.g. tests from medical area for use in hospitals and tests for industrial areas for use in cosmetic industry). Where the product is intended for use in several areas it is acceptable to perform the tests specified for only one of the areas, as long as the test with the highest/most stringent pass criteria is used.

A phase 2/step 2 surface test is not yet available for the medical sector. However the surface test for the food/industrial sector can be used, with medical area specific soiling, instead.

Currently only validated surface tests without mechanical action are available (EN and OECD). Validated surface tests with mechanical action are being developed, and should be used for products that are intended to be used with mechanical action when they are available.

Where specific conditions apply for a field of use, such as high/low level soiling, high/low temperatures, relevant contact times etc. (see introduction 1.4.4), these conditions should be included in the efficacy testing.

Disinfectant towels/wipes

For disinfectant towels, the phase 2/1 tests should be done with liquid extracted from the towel. Phase 2/2 tests should be tests with mechanical action (CEN in preparation). Until these tests are available, surface tests can be done with liquid extracted from the towel, although a justification of the volume that is applied per square centimetre will also be required. In additional, a test has to be performed that shows that either the towel will still disinfect if the towel dries out or that the towel stays wet long enough to disinfect according to the claim. Alternatively, the use directions can address these issues, for instance, stating on the label that only wet towels are efficacious, defining the surface area each towel can disinfect (e.g. 0.5 m²), or giving expiry dates for resealable packages.

3.3.2.2 Test organisms

The test organisms used in efficacy tests are normally stated in the applicable standard test methods.

If standard tests are not used (there will normally need to be a justification for this), the test organisms used to support a general claim should be demonstrated to be equivalent to the reference organisms given in Appendix 4.

Tests with test organisms other than those mentioned in Appendix 4 are acceptable, if adequate scientific evidence is submitted on which the relevance of the test organism to the field of use can be judged.

Also see the general data requirements PT2 for specific claims and minimum requirements in health care.

3.3.3 Acceptance criteria

A product will be assessed to be sufficiently effective if the required laboratory and, where relevant, field tests have been carried out (using the required test organisms and test conditions), and when the pass criteria for the tests have been met.

Where pass criteria are available in the standard test these should be met.

If the test doesn’t provide these criteria, the general criteria in Appendix 5 can be taken as guidance for the level of reduction required. Deviations from the pass criteria are possible, but must be justified in the application. The Competent Authority will evaluate any justification on a case by case basis, consulting the other Competent Authorities where appropriate, and decide whether it is acceptable or not.

3.4 Soft furnishings

3.4.1 Introduction

Disinfectants for use on soft furnishings are intended to be used on fabrics in the home, institutional environment, healthcare and healthcare facilities. These can be used to treat porous soft surfaces such as curtains, sofas, upholstery, mattresses and carpets. The products are often sprayed onto the surfaces.

3.4.2 Data requirements

See PT2 general data requirements. A detailed, but non-exhaustive list of most relevant product applications and uses of hard surface disinfectants and the required test methodology is given in Appendix 2 (Claims matrix, table “Soft furnishings”).

3.4.2.1 Test methods

For efficacy testing of surface disinfectants for use on soft furnishing the tiered approach as described in section 1.4.1 is preferred.

The following tests are normally required for a these surface disinfectant:

- a quantitative suspension test (phase 2/step 1),

- and a quantitative surface test (phase 2/step 2),

both simulating practical conditions appropriate to its intended use (temperature, soiling, different surfaces, contact time, etc.).

Tests in phase 3 are optional as no validated test methods are available yet.

Where possible, the phase 2 step 1 test should be selected from EN14885 from the table that corresponds to the use area of the product (e.g. test from medical area for use in hospitals and test for domestic areas for use in private homes). In case the product is intended for several areas, it is acceptable to perform the tests from only one area, as long as the test with the highest pass criteria is used.

For the phase 2 step 2 test it is suggested that EN13697 be modified to include suitable fabric types in place of the standard stainless steel carriers. ISO 20743 can also be used, or other quantitative methods including textile as carrier.

3.4.2.2 Test organisms

The same test organisms as given for hard surfaces should be tested. See section 3.3.2.2 and Appendix 4.

3.4.3 Acceptance criteria

Where pass criteria are available in the standard tests these should be met.

3.5 Room disinfection with vaporised biocide

3.5.1 Introduction

Room disinfection involves the reduction and inactivation of micro-organisms on the surfaces of the walls, floor and ceiling of the room, as well as on external surfaces of the furniture and equipment present in the treated room. The product is applied by airborne diffusion of an aerosol, a smoke, a vapour or a gas. The technical characteristics of the diffuser equipment play a central role, ensuring an homogeneous distribution of the biocide product in the volume of the room and reaching all surfaces (including ceilings and the undersides of horizontal surfaces), therefore the diffuser equipment contributes in a decisive way to the efficacy of the product. Manual spraying is not covered in this section, but under hard surface disinfection (section 3.3).

Room disinfection may not disinfect the inside parts of furniture, and will not disinfect the air itself, so these uses are not considered in this chapter. Room disinfection is therefore closely related to surface disinfection without mechanical action. As this causes complications in cases of organic contamination, cleaning of surfaces is necessary prior to room disinfection.

3.5.1.1 Process:

The application of the product consists of four phases:

(1) The preparation phase (required depending on type of active substance and application procedure), during which the environmental conditions (relative humidity, temperature) are modified to an optimal level for the product,

(2) The conditioning phase, during which the product is diffused into the room, in order to reach the desired effective concentration,

(3) The disinfection phase, which corresponds to the contact time required to obtain the expected level of efficacy, and

(4) The terminal phase, which includes aeration of the room to remove any disinfectant present in the air, or other procedures for inactivation of the active substance, before access of people or animals into the room can be permitted (figure 5.1).

Particular attention must given to the dispersal time and contact time. The dispersal time is the time necessary to reach a target concentration of the product on the surfaces to be disinfected in a given volume, while the contact time is the time necessary to reach the expected efficacy.

Note: the various phases of the cycle presented are theoretical and can be adapted according to the process. The maintenance of a concentration of biocide in the atmosphere may be achieved by the regular introduction of additional biocide during the contact phase.

3.5.2 Data requirements

3.5.2.1 Test methods

Airborne disinfection differs from direct application of liquids to surfaces. Therefore the EN phase 2/ step 2 standards for surface disinfection are not applicable for room disinfection. The tiered approach is still possible, however, by using different test methods.

The following tests are normally required for a room disinfectants:

- when applicable a quantitative suspension test (phase 2/step 1),

- semi-field trial such as NF T 72-281 or European standard (EN standard in preparation) for disinfection using airborne application (phase 2/step 2).

The CEN phase 2/step 1 tests are suitable as suspension tests under clean or dirty conditions, although only applicable for products that can be tested in suspension (e.g. not for gasses). These tests are not sufficient on their own, and should be combined with a semi-field trial, such as NF T 72-281 for disinfection using airborne application. Where it is not possible to test the product in a suspension test, the semi-field trial will be sufficient.

NF T 72-281 was developed by AFNOR (the French standardisation body) in 1986, updated in 2009, and proposed as new item within the framework of TC 216 in November 2010. This semi-field method evaluates the efficacy of disinfectants when vaporised in a room (automatic diffusion process) or when sprayed into the direction of a surface (manual application). Only application by vaporisation is discussed in this section. Once this method has been finalised and adopted at European level, any method variations should be taken into account.

3.5.2.1.1 Basic principles of room disinfection

Inert and dry carriers infected with a known number of micro-organisms (bacteria, yeast, fungi or bacterial spores) are placed in a room of defined volume, temperature and relative humidity. The size of the test room should be relevant to the claims for the product. The carriers used are often stainless steel, but other relevant (generally non-porous) materials can also be used, for instance, glass, filter paper, or plastic.

When the disinfection of textiles (curtains etc.) and other materials (e.g. wallpaper. filters in flow cabinets, etc.) is claimed, appropriate carriers should be used to demonstrate efficacy.

The standard NF T 72-281 does not include tests against viruses. Inoculation of carriers with viruses according to the protocols of CEN or OECD surface tests and exposure to the airborne disinfection process as according NF T 72-281 is acceptable.

The inoculated carriers must be placed in a vertical position with inocula facing away from the diffuser. Their distance to diffuser depends on the room dimensions (for instance: see Appendix B of NF T 72-281). The test method defines obligatory conditions for parameters that may influence the success of the disinfection.

This test includes the use of milk as interfering substances in order to maintain viability of the micro-organisms on the carriers during the test. Depending on the area of use, other suitable interfering substances should be tested (e.g. blood for use in hospitals).

Similar carriers are placed in a second room nearby, which is not treated with diffused product, as controls.

Additional tests can be performed to simulate specific conditions that are encountered in the practice and to fit with label instructions. In that case, all experimental conditions should be clearly described in the test reports. The standard lists the information that must be included in the final report.

3.5.2.1.2 Diffuser

As mentioned earlier, the disinfection efficacy is closely related to the technical characteristics of the diffuser. Chapter 5 “intended uses and efficacy” of the “Guidance on data requirements for active substances and biocide products” requires applicants to take into account the technical equipment used together with the product to be authorised.

A detailed description of the equipment and its characteristics must be provided in sufficient detail to distinguish it from other equipment:

Ø equipment name and model,

Ø diffusion principles (fogging, vapour, fumigation, …) and particles size distribution of aerosols or powder,

Ø description of the diffusion performance of the equipment (volume to disinfect, diffusion speed…),

Ø description of the ambient conditions (humidity, temperature, …) in which the process can be used,

Ø diffusion time for a specific volume

Ø precautions for over- and under-dosing.

The product authorisation will only be granted for use with the equipment described in the application. After authorisation, any modification to the equipment should be validated and reported to the Competent Authority for evaluation.

For major modifications which can affect the efficacy (pipe, pump, nozzles…), it should be demonstrated that the efficacy of the process has not been affected (for example: by a new study on the most resistant organism).

For minor modifications which do not change the efficacy of the process, only a notification of the modifications to the equipment must be provided.

3.5.2.1.3 Contact time

As room disinfection may necessitate a long period of treatment, the contact time to be tested is not defined. The testing should demonstrate efficacy at contact time proposed for the intended use. This should be relevant to practical use and depends on substance concentration, volume of room, power of the diffuser equipment, etc... All of these parameters should be stated on the product label or in a technical information sheet.

3.5.2.2 Test organisms

Since room diffusion is used to disinfect hard (and soft) surfaces the same organisms should be tested as for hard surface disinfection (section 3.3). Appendix 4 contains a table of reference organisms.

The general data requirements for PT2 for specific claims and minimal requirements in health care also apply for room disinfection with vaporised biocide.

3.5.3 Acceptance criteria

Where pass criteria are available in the standard tests these should be met.

3.5.4 Notes

3.5.4.1 Limitations

Any limitations of the procedure should be specified in the application.

Literature has shown that disinfection by vaporised biocide may not be as effective on wet surfaces (lower concentration of the product) or inside closed cupboards and closets (where the vapour cannot penetrate). Therefore carriers should be tested under these conditions, and if efficacy is not proven, the label instructions should provide appropriate information (such as stating that cupboard doors should be opened, surfaces should be dried and wet areas (such as sinks and toilet bowls) should be disinfected with suitable alternative products.

Other factors which may influence the efficacy of the process in the practical use (such as the equipment, furniture, special structures (e.g. bumps on the walls) or special materials (copper in hydrogen peroxide procedures) including environmental conditions (e.g. temperature, relative humidity) which may affect the success of the disinfection have also to be considered. The conditions of a sufficient vaporisation should also be specified.

3.6 Swimming pools, spas and hot tubs

3.6.1 Introduction

Disinfectants can be used to disinfect water in swimming pools, spas and hot tubs. These may be public pools (which may be used by many people daily) or household pools or tubs (which might be used only occasionally). An intermediate situation consists of facilities in hotels, housing complexes or sports clubs, where the bather load may be lower than in a fully public facility, but still high compared to private, domestic facilities.

Disinfectant products can be added to a pool continuously, intermittently, by shock dosing or through generation in situ. Large public facilities may have dedicated staff to maintain the pool using automated control systems, whereas smaller pools may be treated using manual methods by janitorial staff. Private pools may be treated by individual householders, supplemented in some cases by professional pool treatment personnel. Disinfection is only one aspect of pool maintenance and other activities, such as ensuring the correct pH and the removal of pollutants by oxidation, flocculation and filtration, are essential to ensure adequate water quality.

The principal purpose of disinfection is to disinfect the water to prevent the water-borne transmission of pathogens between pool users. Supplementary purposes are to ensure the aesthetic quality of a pool (by ensuring that algae do not result in turbid water or unsightly microbial growth on pool surfaces, such as the floor and walls of the pool) and to prevent microbial slime and biofilm formation in pipework and related equipment.

This section only deals with disinfection of the pool water and the pipework and related equipment containing pool water. The disinfection of hard surfaces surrounding the pool is covered in section 3.3.

3.6.2 Data requirements

See PT2 general data requirements.

A detailed, non-exhaustive list of the most relevant applications and of appropriate test methodology is given in Appendix 2 (Claims matrix, table “Swimming pools”).

3.6.2.1 Test methods

For efficacy testing of pool disinfectants the tiered approach as described in section 1.4.1 is preferred.

The following tests are normally required for a pool disinfectant following a tiered approach:

- a quantitative suspension test (phase 2/step 1),

- simulated-use tests with pool water or a surface test (phase 2/step 2)*

- and a field test (phase 3)**,

all simulating practical conditions appropriate to its intended use (temperature, contact time, soiling/bather load etc.).

* A phase 2/step 2 test may be appropriate in cases where a product has a specific use in surface disinfection. Otherwise, a simulated use test is appropriate for products intended to disinfect the water in a pool or spa.

** In some cases the field trial can be waived. The OECD guidance document (described below) is based on experience with hypochlorous acid/hypochlorite. Therefore, it is acceptable that for products based on hypochlorous acid/ hypochlorite the field test is waived and only laboratory test data are provided. In some other cases, waiving the phase 3 test can also be justified.

The OECD ”Guidance Document for Demonstrating Efficacy of Pool and Spa Disinfectants in Laboratory and Field testing” (OECD Series of Testing and Assessment No 170, version dated 08 October 2012) describes laboratory and field test methods, conditions and criteria needed to demonstrate efficacy of a pool disinfectant. The protocol for field tests should be agreed between the applicant and Competent Authority before a field test is initiated.

For products that are used for specific purposes such as disinfecting pipework, filters and filter media, it may be more appropriate to test using the EN 14885 methods for the disinfection of surfaces in institutional applications.

3.6.2.2 Test organisms

Besides bacteria and viruses, protozoa can also be of importance in swimming pools. Fungi may pose a health hazard on wet surfaces surrounding the pool and can cause slime build up in pipework. Table 6.1 lists the organisms that normally should be tested. Although algae and protozoa in pools are in general only a problem when maintenance of the pool is not carried out properly, data against algae and/or protozoa should be provided where claims against these targets are made.

3.6.3 Acceptance criteria

When pass criteria are available in the standard tests these should be met.

The OECD guidance document sets out criteria for laboratory and field tests. Table 6.1 and 6.2 show these default criteria.

Table 6.1 Criteria for laboratory tests

Test Organisms for both swimming & spa pools	Number of log₁₀ reductions to be achieved	Time of exposure to test disinfectant at normal concentration during which reduction is to be achieved
Bacteria
Escherichia coli	4	30 seconds
Enterococcus faecium	4	2 minutes
Pseudomonas aeruginosa	4	30 seconds
Legionella pneumophila	4	30 seconds
Staphylococcus aureus	4	30 seconds
Viruses ^a
Adenovirus (disaggregated) ^b	3	10 minutes
Rotavirus (disaggregated) ^b	3	2 minutes
Protozoa ^c
Naegleria fowleri - (cysts)	4	30 minutes
cGiardia intestinalis ^d or Giardia muris ^e- (cysts)	3	45 minutes
Algae
None specified ^f

a Among viruses, Enterovirus can be added to the above list, but the performance characteristics against free chlorine are not known.

b Prior to the test exposure, virus suspensions should be treated to disassociate aggregated clusters of virus particles

c Among protozoa, Cryptosporidium can be added to the above list, but the performance characteristics against free chlorine are not known

d Giardia intestinalis is the human pathogen – in the literature this species may also be referred to as Gardia lamblia and the more general mammal parasite Giardia duodenalis.

e The rodent pathogen Giardia muris can be used as a surrogate for the human pathogen

f There are no European or international standardised test methods for activity against algae; species selected should be representative of those that require control. Algaecidal properties are not covered by the OECD guidance document

Table 6.2. Criteria for field tests

Test Organisms	Test Method	Maximum Count Allowable
Culturable micro-organisms colony count (also called „aerobic” colony count or „heterotrophic” colony count)	ISO 6222:1999 – Enumeration of culturable micro-organisms – Colony count by inoculation in a nutrient agar culture medium.	100 Colony Forming Units (CFU) per ml
Thermotolerant coliforms	ISO 9308-1 – Detection and enumeration of E. Coli and coliforms – Part 2: Membrane filtration method.	Not detectable in 100 ml
Pseudomonas aeruginosa	ISO 16266 – Detection and enumeration of Pseudomonas aeruginosa – Method by membrane filtration.	Not detectable in 100 ml

Where these criteria are not met, the applicant can provide a justification as to why the product should still be considered acceptable. However, the Competent Authority will evaluate any justifications on a case-by-case basis, consulting the other Competent Authorities as necessary, and will decide whether it is acceptable or not.

The OECD guidance document contains more details on factors to be considered.

3.7 Toilets

3.7.1 Introduction

Biocides can be used to disinfect toilet bowl surfaces in diverse environments including; hospitals, industry, institutions or households. Toilet bowl biocides are available in a wide variety of forms, including liquids, foams, powders, and tablets. These products are often applied via pouring around the inside rim of the toilet bowl surfaces, with the area scrubbed after a minimum contact time.

Toilet rim block biocides are used in flush toilets, are attached over the rim of a toilet, hanging down into the bowl. The block slowly dissolves in water as the toilet gets flushed. These biocides also come loose for placement directly in the cistern (water reservoir), and these variants usually dissolve slower with the constant contact with water.

Hard surfaces on the inside of toilets are covered by this section. Surfaces on the outside and toilet seats, lids etc. are covered by section 3.3 “hard surfaces”.

The use of biocides in chemical toilets, most commonly found on airplanes, trains, and in portable toilets is not covered in this section.

3.7.2 Data requirements

See PT2 general data requirements.

A detailed, non-exhaustive list of the most relevant applications and of appropriate test methodology for is given in Appendix 2 (Claims matrix, table “Toilet bowls”).

3.7.2.1 Test methods

For efficacy testing of toilet disinfectants the tiered approach as described in section 1.4.1 is preferred.

The following tests are normally required for a hard surface disinfectant:

- a quantitative suspension test (phase 2/step 1),

- and a quantitative surface test (phase 2/step 2),

both simulating practical conditions appropriate to its intended use (temperature, soiling, contact time, etc.).

Several test methods for quantitative suspension and surface tests are available.

Appendix 3 gives a list of recommended test methods. The following documents are recommended for surface disinfection:

· EN 14885: gives an overview of what EN phase2/step1 and step2 test to use for different uses.

· OECD guidance and guidelines for the testing of chemicals: Quantitative method for evaluating activity of microbiocides used on hard non-porous surfaces. These are surface tests which would be considered phase 2/step 2 tests.

The use of the specified tests is strongly recommended where they are relevant and appropriate. Where tests are not appropriate to the product other tests can be used, although a justification for the relevance of the tests used should also be provided.

For products intended to be added to the water reservoir or hanging down from to the rim of the bowl, the concentration of the product (or at least the active substance) in the water before, in between and after flushing should be determined. This can be done by an analysis of the water under in-use conditions or, for products were all parameters are defined, by calculation. The laboratory efficacy tests should be performed with these concentrations.

Tests in phase 3 are optional.

3.7.2.2 Test organisms

The same test organisms as for hard surfaces should be tested. See section 3.3.2.2 and Appendix 4.

Fungi are not relevant to target in toilets, so products will normally only target bacteria and yeasts (and optionally viruses).

3.7.3 Acceptance criteria

Where pass criteria are available in the standard tests these should be met.

3.8 Air-conditioning systems

3.8.1 Introduction

Disinfection of air-conditioning systems is similar to hard surface disinfection since only the surfaces in the system are disinfected and not the air itself. The difference with general surface disinfection is that the surfaces are mostly hidden inside the system and cannot be reached easily without taking it apart (for instance for air-conditioning systems in cars, dismantling the system would not be desirable).

In general disinfectants for air-conditioning systems are applied by airborne diffusion of an aerosol, a smoke, a vapour or a gas. The biocide is applied to an operating air-conditioning system at the inlet of the system. This way the biocide is sucked into and passes through the whole system.

Preservation of cooling liquids is not covered under PT2 but rather within PT11 (preservatives for liquid cooling and processing systems).

3.8.1.1 Data requirements

For products that are applied by airborne diffusion of an aerosol, smoke, vapour or gas the same test methods and test organisms should be used as for room disinfection. Therefore, the same data requirements as for section 3.5 (Room disinfection with vaporised biocide) are applicable here.

The following tests are normally required for a disinfectant for air-conditioning systems:

- when applicable a quantitative suspension test (phase 2/step 1),

- semi-field trial such as NF T 72-281 for disinfection using airborne application (phase 2/step 2).

See section 3.5 for specifications.

In the semi-field test the carriers with test organisms are placed in the air-conditioning system at the beginning and at the end of the system. When it is not possible to put carriers in the system they should be between the biocide application site and the inlet of the system and at the end of the system, in the out flowing air. If carriers at both sides full fill the criteria it can be assumed that the surfaces in between are also disinfected sufficiently.

For products that are applied by manual spray the test methods and test organisms should be used as for hard surface disinfection. See section 3.3 (Hard surface disinfection) for data requirements.

In addition to these data, the applicant should provide a justification that the spray apparatus is capable of reaching all (hidden) surfaces of the air conditioning system.

3.8.2 Acceptance criteria

The same pass criteria can be used as for other surface disinfection (section 3.3.3). The criteria in Appendix 5 can be taken as guidance for what level of log reduction is normally required. Deviations from the norm are possible, but have to be justified in the application.

3.9 Equipment disinfection by immersion

3.9.1 Introduction

Although instrument or equipment disinfection can be considered equal to hard surface disinfection, it differs from the intended use in section 3.3 because it is mainly applied by immersion of the instruments in the biocide solution or by filling equipment with the solution (disinfection of inner surfaces). The products are intended for instruments used in health care facilities, laboratories and industry.

Some of the products used for disinfection of medical instruments, which are to be used specifically for diagnostic and/or therapeutic purposes for human beings, are not under the scope of the BPD. Disinfectants that are specifically used for disinfection of medical devices or a group of medical devices (anaesthetic equipment, endoscopes, surgical instruments, incubators) are covered under the Medical Device Directive 93/42/EEC. However, disinfectants with a broader claim, e.g. disinfection of instruments and surfaces, are under the BPD. The BPR states that such biocidal products should comply, in addition to the requirements laid down in this Regulation, with the relevant essential requirements set out in Annex I to Council Directive 90/385/EEC of 20 June 1990 on the approximation of the laws of the Member States relating to active implantable medical devices, Council Directive 93/42/EEC of 14 June 1993 concerning medical devices and Directive 98/79/EC of the European Parliament and of the Council of 27 October 1998 on in vitro diagnostic medical devices.

3.9.2 Data requirements

3.9.2.1 Test methods

For efficacy testing of equipment disinfectants the tiered approach as described in section 1.4.1 is preferred.

The following tests are normally required for a instrument disinfectant:

- a quantitative suspension test (phase 2/step 1),

- and a quantitative carrier test (phase 2/step 2),

both simulating practical conditions appropriate to its intended use (temperature, soiling, different surfaces, contact time, etc.).

Methods for testing efficacy of instrument disinfectants are available.

Appendix 3 gives a list of recommended test methods. The following document is recommended for instrument disinfection:

· EN 14885: gives an overview of which EN phase2/step1 and step2 test to use for different uses.

The use of the specified tests is strongly recommended where they are relevant and appropriate.

For use in industry and institutional areas, no specific tests for instrument disinfection are given in EN14885. While these tests are not available for the phase 2/step 1, either the surface disinfectants test from the industry and institutional areas or the instrument tests for medical areas can be used, by employing area specific soiling. For phase 2/step 2 the instrument tests for medical areas are most appropriate, also with area specific soiling.

3.9.2.2 Test organisms

For general disinfection of medical instruments, efficacy against bacteria, yeasts, viruses and fungi must be demonstrated. For all other uses the test organisms specified for hard surfaces should be tested. See section 3.3.2.2 and Appendix 4.

3.9.3 Acceptance criteria

Where pass criteria are available in the standard tests these should be met.

3.10 Textile

3.10.1 Introduction

Biocides can be used to treat textiles and fabrics in hospitals, health care facilities, industry, institutions or private homes, when relevant micro-organisms (pathogenic, spoiling) in the textiles have to be reduced. These products can be in the form of laundry products which combine detergent and biocide or can be specialised products in the form of laundry additives which are added to the wash cycle or as finishing products (e.g. fabric softeners) which are added in the last rinsing step or as pre-treatment.

Typically contaminated clothes, linen or other washable textiles are treated in an appropriate washing machine. The biocide is added in concentrated form and diluted in the machine with water according to the specification of the manufacturer to get a defined concentration in the machine. The automated chemical-thermal process normally comprises an (optional) initial pre-treatment step for heavily soiled laundry, followed by the main washing step (at a defined temperature and defined contact time) and 3 to 4 rinsing steps with cold water.

In some cases laundry can be treated through a hand-wash process in diluted biocide, which can be as pre-soak (after which machine washing is used), as a hand wash only, or through soaking to disinfect textiles before they are destroyed (for example, in an infectious disease outbreak situation).

Biocidal laundry products, either as combined biocide/detergent/conditioner or as special additives, are available for either targeted pre-treatment of contaminated articles or for whole-wash use.

3.10.2 Data requirements

See PT2 general data requirements. A detailed, non- exhaustive list of the most relevant applications and of appropriate test methodology for is given in Appendix 2 (Claims matrix, table Laundry products).

3.10.2.1 Test methods

For efficacy testing of textile disinfectants the tiered approach as described in section 1.4.1 is preferred.

The following tests are normally required for a textile disinfectant:

- a quantitative suspension test (phase 2/step 1),

- a quantitative carrier test involving carriers made of test fabric (cotton, polyester) (phase 2/step 2),

Both should simulate practical conditions relevant to its intended use (concentration of the product, temperature, soiling, different fabrics, contact time, etc.).

At this moment three types of test are available:

- phase 2/step 1 suspension tests as described in EN14885,

- phase 2/ step 2 tests involving test fabrics in a small scale laboratory setting (e.g. ASTM E2406) or a full-scale laundry machine test (as a CEN draft TC 216/N 472, or DGHM).

In the phase 2/step 2 tests fabric is contaminated with test organisms and then exposed to the disinfectant.

The EN tests are strongly recommended where available and appropriate.

3.10.2.1.1 Test conditions

For products intended to be added to washing machines, information on the following in-use conditions should be provided:

- the concentration of the product (or at least the active substance) in the water during disinfecting process (i.e. washing or rinsing). The water volume used can differ between wash and rinse cycle and different washing programmes, but also between washing machines

- the water to textile ratio in the test is an important factor that should reflect the in-use conditions

- the temperature during the disinfection process (high when added in wash process, low in rinse process)

- the contact time (differs between various washing programmes and washing machines)

The laboratory tests should be performed under these conditions. The identified conditions of effective disinfection can normally only be carried out in professional washing machines.

If the exact conditions cannot be met, e.g. in household machines, reasonable worst case conditions shall be tested.

Worst case conditions:

- the lowest temperature

- the highest volume of water (i.e. maximum dilution of the product)

- the shortest contact time

- the maximum load of laundry (i.e. smallest water to textile ratio).

When phase 2, step 2 tests involving fabric test carriers are performed, both the micro-organisms remaining on the test carriers, those released into the washing liquid and those transferred to previously uncontaminated control carriers should be assessed.

Manual soaking or pre-soaking can be done at room temperature but for some intended uses the temperature might start high and will cool down during the contact time (e.g. where hot water is used, which cools naturally). This should also be taken into account in the tests.

3.10.2.1.2 Soiling:

The interfering substance most appropriate for the in-use conditions should be used. For instance, blood for products used in the medical area and protein for products used in industry, institutional and domestic areas is recommended. The soiling on a domestic product for use in pre-soak (dirty clothes) will be very higher than the soil for a post-wash rinse additive (clean clothes). For products used during pre-soak and wash tests should be done under dirty conditions. For products used during post-wash rinse test should be done under clean conditions.

3.10.3 Acceptance criteria

EN and DGMH tests provide pass criteria.

No acceptance criteria have been specified in the ASTM standards for laundry (ASTM E 2406-04).

If the test doesn’t provide pass criteria, the general criteria in Appendix 5 can be taken as guidance for the level of reduction required. Deviations from the pass criteria are possible, but must be justified in the application. The Competent Authority will evaluate any justification on a case by case basis, consulting the other Competent Authorities where appropriate, and decide whether it is acceptable or not.

3.11 Biofilm

3.11.1 Introduction

A biofilm is a complex aggregation of micro-organisms distinguished by the excretion of a protective and adhesive matrix attached to a solid surface in contact with a fluid. The matrix may incorporate other components derived from the environment.

Once the first cell succeeds to attach to the solid surface and biofilm starts to form, growth of the biofilm may become very fast, as subsequent free floating bacteria find it much easier to attach to the developing matrix.

Biofilms can grow in areas such as inside water tanks and distribution pipelines of hospitals, hotels, industries and in general in all those water systems which have adequate temperature and nutrients for the microbial growth.

The consequences of biofilm formation into a water system or facility may be severe depending on environmental conditions and any safety and performance requirements.

In healthcare facilities, biofilm contamination of medical equipment or water systems may increase the risk of nosocomial infections; in industrial facilities biofilm may cause microbial contamination of production (pharmaceuticals, cosmetics, etc.); in other situations biofilms may be responsible for significant reduction of the performance of water systems by obstructing normal water flow or they may induce corrosion of the pipelines.

Several factors may contribute to biofilm formation, with important factors including the chemical composition and roughness characteristics of the pipe, tank or tube circuit.

Bacteria in biofilms are more resistant to disinfection than free floating bacteria of the same species, as the presence of extracellular polymeric substances acts as a physical barrier to the biocide. This matrix may hamper biocidal penetration to the lower layers of the biofilm or may interact with the biocide and neutralise it. Additionally, the physiological state of the bacteria in the biofilm differs from bacteria in suspension, which can also influence the susceptibility of the bacteria to biocides.

Two types of activities of biocides against biofilm can be identified:

a) Prevention of biofilm formation: the biocide acts on biofilm formation (i.e. in this case the biocide is present before the biofilm is formed and may affect the early adhesion of cells to the surface or the viability of the cells).

b) Biofilm disinfection (“curative”): the biocide acts on a mature biofilm (i.e. when the biofilm is already present on a surface and the biocide interacts with the biofilm-embedded cells, with a -cidal effect). Biocidal products of this type may also achieve detachment of the biofilm (possibly in conjunction with physical action).

In case where the biofilm is not removed as a result of the biocide treatment, it should be followed by mechanical removal of the biofilm.

Industry is increasingly developing new technologies for prevention, inactivation and/or detachment of biofilms and/or inactivation of biofilm embedded organisms, for example through the use of UV light, water ionization or impregnated or coated materials and new biocides which claim specific efficacy against biofilms.

3.11.2 Data requirements

There are currently no standard laboratory tests available to verify the efficacy of biocides against biofilms. As this is an area in which the science is developing rapidly, the information below should be considered as general guidance reflecting the state of knowledge at the time of writing.

Tests to demonstrate the efficacy of disinfectants according to EN and OECD are based on simpler models than are found in biofilms. The available surface/carrier tests are not representative of biofilm models, as they do not consider the presence of extra cellular polymeric substances which act as a physical barrier to the biocide.

Other characteristics of the biofilm and biocidal product should be taken into account. For example, if biocide impregnated materials claim a preventive effect on biofilm formation, the prevention of biofilm formation should be demonstrated, taking into consideration the half-life of the impregnating substance which may differ depending on the material characteristics. The active substance may be released from the surface and/or may be inactivated by environmental factors.

A standard suspension test can only be used to confirm basic activity of the product against the claimed organisms in a tiered approach.

A suggested general approach could be:

1) a suspension test: any biocide claiming to act on biofilm, has to be first evaluated in standard suspension test (preferably EN)

2) a simulated use efficacy test to demonstrate the ability of the product to exert a controlling effect on the biofilm under either static condition or under flow conditions depending on the use pattern (claim). This controlling effect can be to destroy and detach, inhibit or prevent the formation of a biofilm

3) a field trial, where the biofilm is formed under (simulated) use conditions.

These tests should be performed in sequence to obtain more complete information on the activity of the product on biofilm.

For biofilm disinfection (curative) a suspension test (as for (1) above) and suitable robust data from either a simulated use test (2) or field trial (3) should be performed. If there are no robust data from a simulated use test (2), a field test (3) is mandatory.

For biofilm prevention the approach is different to that for biofilm disinfection, as the biocide is present before the biofilm is formed and may affect the early adhesion of cells to the surface or the viability of the cells. In this case the suspension test (1) may not be useful since the product might not have a –cidal effect.

3.11.2.1 Test Methodologies

3.11.2.1.1 Suspension tests

The first step in the tiered approach is a suspension test. The CEN phase 2/step 1 tests are suitable as suspension tests. This test is only applicable for products that can be tested in suspension and which have a –cidal effect.

3.11.2.1.2 Simulated use tests

Standard laboratory tests to verify the efficacy of biocides against biofilms are not currently available. Therefore, before carrying out a biofilm test, any test methods should be agreed with the Competent Authority.

Applicants should provide a method following the principles in this guidance and based on scientific evidence. During development of the tests Competent Authorities of member states should be consulted to make sure that the tests are acceptable.

Biofilms can be formed and evaluated in static or flow conditions. The way the biofilm is formed has an effect on the susceptibility of the biofilm to biocides: biofilms formed under flow conditions are generally more resistant to biocides than biofilm formed under static conditions.

The conditions under which the biocidal products will have to operate should also be taken into account. Under static conditions the disinfectant operates without the aid of the removal effect of a fluid flow or shear stress. Under flow conditions the contact time might be shorter when shock dosing is used.

Static tests are less expensive and easier to standardise, but flow tests are generally closer to the real use scenarios.

In both cases, the reproducibility and repeatability of results over time should be ensured; so a method that allows a series of observations, rather than a single one, should be employed.

Laboratory for testing the efficacy of biofilm disinfectants should emulate the critical factors of a real-world environment.

In cases where only efficacy against biofilm formed under static conditions is claimed (e.g. use in tanks without flow) it is sufficient to only test against these biofilms.

Examples of methods for testing under flow and static conditions are described below, but other protocols are available in literature or may be under development.

3.11.2.2 Static condition assay

Standard laboratory tests to verify the efficacy of biocides against biofilms formed under static conditions are not currently available. However, literature describes several methods of how to create a biofilm in the laboratory under static conditions.

An example of a semi-quantitative method for biofilm evaluation is the microplate test, where biofilm is formed in static conditions and the amount of biofilm can be quantified by spectrophotometric measurements. The amount of living cells in the biofilm before and after treatment can also be determined. In this case, the disinfectant operates without the aid of the removal effect of a fluid flow or shear stress.

A positive aspect of such assay is that it is a low cost, easy-to-conduct test, that allows several replicates and/or testing of several conditions (several biocide concentrations, more species, etc) to be carried out, which would provide the basis for a more accurate and closer-to-reality test.

This method consists of the formation of a biofilm by the species of interest on the bottom of 96 well plates (the material and coating of the plates should be specified); the disinfectant may be present before (preventive effect) or after (inhibition/removal effect) the biofilm is formed. The amount of biofilm (biomass) is quantified after staining of the adherent material and spectrophotometric measurement. Detecting agents such as ATP to measure bacterial viability may also be used.

3.11.2.3 Flow condition assay

Standard laboratory tests to verify the efficacy of biocides against biofilm formed under flow conditions are not currently available. However, systems to generate a standard biofilm have been developed by CEN (CEN ISO/TS 15883-5:2005 Annex F) and ASTM (ASTM E2196 and ASTM E2562). Using either of these reproducible biofilms, a method for the assessment of prevention and/or elimination of biofilm in terms of viable cells reduction and bacterial biomass reduction can be carried out.

The CEN method consists of the production of a standard Pseudomonas aeruginosa biofilm inside a Teflon tube, using a flowing system to simulate a real world situation.

ASTM E2196 and ASTM E2562 standards use biofilm rotating disc reactors, which are especially suited for high shear forces.

The biofilm is then treated with a disinfectant to evaluate the biocidal capacity to remove or to reduce the biofilm.

Other carrier types (e.g. silicon, steel, PVC, etc.) can be selected and used depending on the biofilm development system, and the experimental conditions can be adapted to compare the efficacy of different treatments in preventing biofilm formation.

A reference substance of known activity shall be tested in parallel (e.g. chlorine dioxide, sodium hypochlorite).

3.11.2.4 Field trials

As for other situations in which biocides are used, only field tests (phase 3 tests) would be fully representative of the activity of the biocide on biofilms, but these tests are difficult to standardise, and such tests, if used, should be complemented by laboratory suspension or simulated use tests, which have a higher degree of robustness and reproducibility.

A field trail should reproduce the in-use conditions of the worst case situation of the intended uses.

Prevention and/or elimination of biofilm (in terms of viable cells reduction and bacterial biomass reduction) should be demonstrated by sampling before and after disinfection.

A field test can be waived if a suitably robust simulated use test, which adequately mimics the in-use conditions is provided. A robust test could for instance be a complex pipe system, in which natural biofilm formation takes place, either in combination with the addition of standard organisms or not.

3.11.2.5 Test organisms

The choice of micro-organisms for a test is relevant, since the use of only one organism per test is limitating and may not be fully representative of the real events leading to micro-organism aggregation (biofilms in settings where disinfectants are used, are normally multi-microbial, i.e. composed by several different species). Moreover contaminants from environmental sources may be embedded in the biofilm matrix which may reduce the disinfectant’s efficacy.

Bacteria are not the only inhabitants of biofilms, as both fungi and algae may also inhabit biofilms. Protozoans that consume bacteria may feed on biofilms. Protozoan oocysts and virus particles can become entrapped in a biofilm and later detach, returning to the environment.

In a suspension test, the standard organisms per claimed group (bacteria, fungi, etc.) should be tested.

For a general claim of efficacy against biofilm, as a minimum bacteria should be tested in laboratory biofilm tests. When action against other groups of organisms (e.g. fungi, algae) is claimed these should be tested too.

In suspension tests the standard organisms should be tested (see Appendix 4).

Pseudomonas aeruginosa and Staphylococcus aureus are acceptable test organisms for the laboratory biofilm tests. Mixtures of test organisms for producing biofilms are only acceptable as additionally testing, as it is difficult to standardise these tests.

In simulated use or field trials the biofilm may be formed in vivo with naturally occurring micro-organisms.

3.11.3 Acceptability criteria

Where pass criteria are available in the standard tests these should be met.

3.12 Soil

Disinfection of soil and other substrates (in playgrounds) with biocides is not common (and so far not claimed for Annex I of the BPD). This is more often done for plant protection. Therefore, plant protection guidelines and EPPO standards on soil treatments should be referred to for test methods. The use of the test methods should be justified with the application.

3.13 Treated articles

A treated article within PT2 is any article which has been treated with or intentionally incorporates one or more biocidal products and which claims disinfecting or biostatic properties or function, when they have a primary biocidal function.

For PT2 this includes for instance self-disinfecting surfaces, surfaces which prevent biofilm formation, etc..

There is currently little guidance on data requirements and acceptance criteria available for treated articles, although OECD test methods are in development.

A chapter on treated articles will be included in this guidance at a later date.

3.14 Other uses

Several other uses are mentioned in the description of PT2: waste water and hospital waste disinfection, algaecides for swimming pools and indoor/outdoor aquatic area (aquaria / garden ponds). No data requirements and acceptance criteria for these uses are currently available.

Guidance on the requirements for testing “clean-in-place” products is not currently included.

The guidance will be updated when methods are available.

4 PT 3 Veterinary hygiene biocidal products

Will be added later.

5 PT 4 Food and feed area disinfectants

Will be added later.

6 PT 5 Drinking water disinfectants

Will be added later.

7 Appendices

Appendix 1. Glossary of terms

Appendix 2. Claims Matrix

Appendix 3. List of currently available standard test methods for disinfectant biocides within product type 1 to 5

Appendix 4. Table of Reference Organisms

Appendix 5. EN norms pass criteria

Appendix 6. Introduction CEN methods

[1] These definitions are taken from the Biocidal Products Regulation.

[2] This is taken to mean the disinfection of air itself. Disinfectants sprayed or vaporised into the air (e.g. room disinfection by vaporised biocide) are normally for the purpose of disinfecting surfaces and not the air itself.

[3] Remark: paragraph 5.5 of EN14885: 2006 is not applicable for disinfectants in Europe.

[4] This paragraph is based on the BPD. The product family concept of the BPR is not yet taken into account.

[5] This is taken to mean disinfection of air itself. Disinfectants sprayed or vaporised into the air (e.g. room disinfection by vaporised biocide) are generally for the purpose of disinfecting surfaces and not the air itself. Disinfectants for air conditioning systems disinfect the surfaces in these systems, not the air coming out of it.

[6] This paragraph is based on the BPD. The product family concept of the BPR is not yet taken into account.

Donnerstag, 27. August 2015

0006-Guidance document on the evaluation of efficacy of disinfectants PT2

1.1 Introduction

1.3 Label claim

1.3.1 Target organisms

1.3.5 Other interfering parameters

1.4.1.1 Phase 1

1.4.1.2 Phase 2 step 1

1.4.1.3 Phase 2 step 2

1.4.1.4 Phase 3 Field or in-use tests

1.4.2.1 CEN Standard Test Methods

1.4.2.2 OECD Standard Test Methods

1.4.2.3 Other Standard Test Methods

1.4.4 Relevant factors of the test procedure

1.4.4.1 Formulation of the tested product[4]

1.4.4.2 Hard Water Claims

1.4.4.3 Presence of Interfering Substances

1.4.4.4 Temperature

1.4.4.5 Contact Time

1.4.4.6 Neutralisation

1.4.4.7 pH

1.4.4.8 Texture of Surfaces

1.6 Assessment of authorisation

3.3.2.1 Test methods

3.3.2.2 Test organisms

3.4.2.1 Test methods

3.4.2.2 Test organisms

3.5.1.1 Process:

3.5.2.1.3 Contact time

3.5.4.1 Limitations

3.6.2.2 Test organisms

3.7.2.1 Test methods

3.7.2.2 Test organisms

3.8.1.1 Data requirements

3.8.2 Acceptance criteria

3.9.2.1 Test methods

3.9.2.2 Test organisms

3.10.2.1 Test methods

3.10.2.1.1 Test conditions

3.10.2.1.2 Soiling:

3.11.2.1 Test Methodologies

3.11.2.1.1 Suspension tests

3.11.2.1.2 Simulated use tests

3.11.2.2 Static condition assay

3.11.2.3 Flow condition assay

3.11.2.4 Field trials

3.11.2.5 Test organisms

7 Appendices

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