Efficacy Requirements for Antimicrobial Pesticides
In addition to data requirements that apply to all pesticides, pesticides designed to control microbial pests such as viruses and bacteria must have data proving their ability to kill these pests (known as efficacy).
Each of the guidance documents listed below provides a summary of current efficacy-related requirements and/or policy for a category of antimicrobial pesticide products, claims, or patterns of use. If more detailed guidance is needed, the Antimicrobials Division should be consulted.
If any of the product's use patterns is classified as human-health-related, efficacy data must be submitted for review in order to support the inclusion of that use pattern in the product registration. Regardless of the use pattern, however, product efficacy data is required to be maintained in the registrant's files.
Requirements to develop data on product performance provide a mechanism to ensure that pesticide products will control the pests listed on the label and that unnecessary pesticide exposure to the environment will not occur as a result of the use of ineffective products. Specific performance standards are used to validate the efficacy data in the public health areas, including:
- disinfectants used to control microorganisms infectious to humans in any area of the inanimate environment; and
- those pesticides used to control vertebrates (such as rodents, birds, bats, and skunks) and invertebrates (ticks, mosquitoes, etc.) that may directly or indirectly transmit diseases to humans.
The key set of documents directing efficacy testing is:
In addition, the following documents also provide information relevant to the efficacy process:
- Revisions to the Performance Standard for the AOAC Use-dilution Methods for Staphylococcus aureus (955.15) and Pseudomonas aeruginosa (964.02)
- Standardized Efficacy Study Report and Efficacy Study Summary
- Efficacy Testing Standards for Product Data Call-in Responses
- Fogger-Mister Final Signed Letter (guidance on data requirements for fogging claims)
- Guidance for the Efficacy Evaluation of Products with Sporicidal Claims Against Clostridium difficile (June 2014)
- Guidance for Efficacy Testing at the Lower Certified Limits
- Guidance for Testing and Labeling Claims Against Pandemic 2009 H1N1 Influenza A Virus (formerly called swine flu)
- Protocol for Room Sterilization by Fogger Application
- Protocols for Testing the Effectiveness of Disinfectants Against Hepatitis B Virus (HBV)
- Protocol for Residual Self-Sanitizing Activity of Dried Chemical Residues on Hard, Non-Porous Surfaces
- Using Bovine Viral Diarrhea Virus (BVDV) As Surrogate for Human Hepatitis C Virus
Information about test protocols and related guidance can be found on the Pesticide Analytical Methods site.