Child Care Facilities Presented by Amy Gammel Overview of Department General Review of Sanitizing and Disinfecting History of Bleach Use Using Bleach to Sanitize Using Bleach to Disinfect Alternate Solutions Determining Approval for Disinfectants Determining Approval for Sanitizers FAQ’s Questions Colorado Department of Public Health and Environment (CDPHE) “The Department” is the regulatory authority for the Rules and Regulations Governing Health and Sanitation of Child Care Facilities. The child care program is housed in the Division of Environmental Health and Sustainability (DEHS), Delegated Programs Unit (DPU). Therese Pilonetti is the program manager. Amy Gammel is the lead Environmental Protection Specialist. The DPU unit also implements the retail food establishment and schools programs. CDPHE delegates authority to local public health agencies to enforce regulations with the exception of counties where the local program does not do inspections. Child Care Facilities in these counties are inspected by CDPHE and not the local agency. Sanitization: reduces bacterial count, including pathogens, to a safe level. ◦ Use on food contact surfaces, tables, toys etc. Disinfecting: eliminates most or all pathogenic microorganisms. ◦ Use on diaper tables, surfaces contaminated with high hazard body fluids (urine, feces, blood, vomit, sputum, mucus) Sanitizing Toys: Weekly* Bedding, Mattresses etc.: Weekly* or between use of another child Water Tables: Daily and between groups of children Food Contact Surfaces: per RFE regulations Disinfecting Diaper Tables: after each use Toilet Seat Inserts: after each use Surfaces Contaminated w/ HHBF: immediately *When items are placed in mouth or contaminated, they shall be sanitized prior to use by another child. If contaminated with a HHBF, item shall be disinfected. RFE: Retail Food Establishment HHBF: High Hazard Body Fluid Sanitizers Test strips are required for sanitizing solutions Sanitizing solutions shall be made and/or tested daily Sanitizing solutions obtained in a ready to use solution do not require testing Disinfectants Disinfectants shall be mixed daily in facilities that have children in diapers, unless obtained in a ready to use solution Daily testing is acceptable in lieu of daily mixing In other facilities that do not have children in diapers, disinfectants can be made as needed All secondary containers of sanitizers & Disinfectants must be labeled with the content and intended use: ◦ Sanitizer/chemical name for Tables/Toys ◦ Disinfectant/chemical name for bathrooms ** Solutions shall be readily accessible to caregivers and inaccessible to children Historically most child care providers have used household bleach as a sanitizer and disinfectant. Before Clorox was a registered pesticide, it was still acceptable as a sanitizer and disinfectant because it was deemed as safe and effective. This was the only chemical sanitizer/disinfectant that did not need to be EPA approved. Providers wanting an alternative to bleach have typically used a quaternary ammonium solution for a sanitizer. Providers have rarely used any bleach alternates for disinfecting due to long contact times of products. When Clorox registered household bleach with EPA, the instructions for use as a disinfectant conflicted with previous guidance issued and what is stated in the regulations. The Department had to issue new guidance because the regulations also state that all products have to be used according to EPA registered labeled instructions. A guidance sheet intended for child care providers was distributed by the Department. An interpretive memo was issued by the Department and distributed to local health agencies. Environmental health inspectors were made aware of changes and are providing education to child care providers. Department is a resource to child care providers in direct service counties, agencies that work with child care providers, and local health agencies. Bleach is an approved sanitizer if mixed and used according to the labeled instructions For sanitizing the solution shall be maintained between 50-200 ppm Most bleach solutions are now manufactured with 8.25% sodium hypochlorite (active ingredient) Determine the % of hypochlorite: Active Ingredient: Sodium Hypochlorite……….…8.25% OTHER INGREDIENTS…….91.75% TOTAL……………………….100% If a bottle contains 5.25% or 6% hypochlorite, refer to label for mixing instructions or previous guidance Most bleach that is sold today contains 8.25% hypochlorite, refer to table below for mixing instructions Concentration Amount of Bleach (8.25%) Amount of Water 100 ppm 1 tsp 1 gallon (128 oz) 100 ppm ¼ tsp 1 quart (32 oz) 100 ppm 1/8 tsp 1 pint (16 oz) Mixing instructions were obtained from EPA registration There were no changes to the USE of bleach as a sanitizer The only change was the amount of bleach to mix if using an 8.25% hypochlorite product Sanitizers are to be tested daily If inspectors see a violation related to the use of bleach as a sanitizer it will be marked as a violation Bleach is an approved disinfectant if mixed and used according to the labeled instructions Refer to labeled instructions on bottle used by facility Contact time and rinsing if required must be followed Most measurements on the label are calculated per gallon Not all establishments mix this quantity and my need help determining mixing instructions for smaller batches Example: Bottle instructs to mix ½ cup bleach to 1 gallon water. Provider may only use 1 quart (32 oz) or 1 pint (16 oz) containers and may need help with the conversion. Amount of Bleach Amount of Water ½ Cup 1 gallon 2 Tbsp 1 quart 1 Tbsp 1 pint **This chart is for example purposes only and not a standardized recipe for disinfecting solutions. Follow instructions on label for mixing instructions. Liquid measurements helpful in making conversions: 1 Tbsp=3 tsp 1 oz= 2 Tbsp 1 cup= 8 oz 1 pint=2 cups= 16 oz 1 quart= 4 cups= 2 pints= 32 oz 1 gallon= 4 quarts= 8 pints= 16 cups= 128 oz Tip: Covert everything into the same measurement (ex. Ounces) At the first inspection, inspectors may take an educational approach If a provider wishes to use bleach, it shall be used according to the labeled instructions moving forward Assistance should be given to providers in determining the % of hypochlorite and reading the label At corresponding inspections if the bleach is not used according to the labeled instructions, it will be marked as a violation Changes to the use of bleach as a disinfectant may not have an impact on child care programs with preschool age children and older This change may have a larger impact on programs with infants and toddlers Program changes can be made to accommodate contact times such as additional diaper tables, scheduling, staffing etc. There are alternate products with lower contact times and no rinse step There are other products approved for use aside from household bleach Most common active ingredients include sodium hypochlorite, hydrogen peroxide and quaternary ammonium More child care providers are moving toward using green products Disinfectants ◦ Is the product EPA registered? What is the number? ◦ Is it a hospital grade disinfectant? Effective against Salmonella choleraesuis(enterica); Staphylococcus aureus; and, Pseudomonas aeruginosa ◦ Is the chemical used in accordance to the EPA labeled instructions including: Concentration Contact Time Method Surfaces Product labels contain valuable information needed to determine approval but do not rely solely on the label Always cross reference the National Pesticide Information Retrieval System: http://state.ceris.purdue.edu/ for the EPA registration Look for key words such as: for use in schools, daycare centers, hospitals etc. Look for keywords such as: use on diaper tables, exam tables, medical devices (items that normally have contact with skin) Note: There is no requirement for contact time, however the product must be used according to the label. Is this contact time practical? Use your judgment, does the use seem practical ? ◦ Examples: product may meet criteria but it is intended for toilet bowls, product has a 10 minute contact time etc. Click on Colorado Search by EPA Reg no, product name, company, or active ingredient. Note, if the product is not registered in Colorado it will not be displayed and is not permitted to be sold in the state. Provides EPA Registration Provides label if submitted to CDA electronically Click on the Company Label ID to view the label. Click on the most recent approval date when viewing registrations This is the cover page of the EPA registration. Scroll through document to find information needed. The document can be printed or saved as a pdf if desired. These products have been evaluated by DEHS and are approved to be used as a disinfectant in child care facilities. The list of products does not represent endorsement by CDPHE. This list is intended as a resource for child care providers inquiring about alternate disinfecting solutions. This is not intended for mass distribution. The instructions on a product label or EPA registration supersedes any information listed here. Sanitizers ◦ Is the product EPA registered? What is the number? ◦ Is the active ingredient listed in 40 CFR 180.940 “Approved Sanitizers”? ◦ Is the chemical used in accordance to the EPA labeled instructions including: Concentration Contact Time Method Surfaces- food contact surfaces Look at the “directions for use” on the label for information needed to determine approval but do not rely solely on the label Cross reference the National Pesticide Information Retrieval System: http://state.ceris.purdue.edu/ for EPA registration Look for key words such as: use in restaurants, food establishments, deli’s etc. Look for keywords such as: use on food contact surfaces Refer to 40 CFR 180.940 (search for electronic copy) to verify the active ingredient is an approved sanitizer Note: A rinse step can not be required for a sanitizing product to be approved Note: Household bleach used can not contain a scent Note: Products intended for residential use only (with the exception of household bleach) are not approved sanitizers for food contact surfaces Quaternary Ammonium (QA): There are several products with the active ingredient of a quaternary ammonium compound that are approved for food contact surfaces. Places to purchase quaternary ammonium products: •Restaurant supply stores •Companies that distribute chemicals to restaurants (Autochlor, Eco Lab etc.) Concentration: It is critical that the concentration on the label is followed because there are different compound variations of this chemical. Example: If the directions state the concentration needs to be 200 ppm, this is what needs to be followed. If the directions state the concentration needs to be between 150-400 ppm, this is what needs to be followed. Test Strips: The test strips can be purchased in the same location as the product. Note: chlorine test strips will not work for QA products. Sanidate Ready To Use is a product that has been evaluated by the Department and meets approval criteria for sanitizers for food contact surfaces. Active Ingredient: Hydrogen Peroxide EPA Registration No: 70299-9 Colorado Registration No: 50465 Testing: This is a ready to use product and does not require testing. Note: There are directions for residential use and commercial use, follow directions for commercial use of food contact surfaces. **Sanitizers not listed in this presentation should be reviewed by the regulatory agency prior to use. Can I purchase 3% hydrogen peroxide and mix it with water to create a sanitizer and/or disinfectant? No. To date over the counter hydrogen peroxide is not EPA registered. Instructions are relevant to first aid. Is ozone an approved sanitizer and/or disinfectant? No. The device that mixes ozone to make an aqueous solution is registered but the solution is not. This product has not gone through efficacy testing and is not listed on 40 CFR 180.940 (approved sanitizers) The only approved use for ozone at this time is as an antimicrobial produce wash. Is the new guidance for disinfectants applicable to norovirus outbreaks in child care facilities? For norovirus outbreaks refer to “Infectious Diseases in Child Care and School Settings.” This document can be found on CDPHE’s website. Is Benefect Decon 30 Disinfectant an approved sanitizer and/or disinfectant? This product meets the approval criteria as a disinfectant but has a 10 minute contact time. For a sanitizer, this has not been determined. The active ingredient Thymol is not listed in 40 CFR 180.940 as an approved sanitizer for food contact surfaces. The directions for use are a little vague. The label and EPA registration have been forwarded to FDA for evaluation. Are household Clorox wipes acceptable for sanitizing? Any product intended for household or residential use is not approved for commercial use. Typically these products have a very high concentration of quaternary ammonium that exceeds the limit for a food contact surface. What qualifies as a secondary rinse after disinfecting? Rinsing with water is sufficient. This could be done by spraying water on surface and allowing it to air dry or wiping with it away with a paper towel. This could also be accomplished by taking a wet paper towel and wiping the surface. A cloth towel would not be acceptable for this use. Do door handles or similar fixtures require a rinse/wipe step? If the direction on the label state a rinse step is required then this would apply to all surfaces the solution is being applied to. Has anyone identified an affordable alternative to bleach as a disinfectant? Boulder County Public Health has done a cost analysis on Oxivir TB (EPA reg. no. 70627-56) and found that it costs .12 per ounce. Household bleach is still an approved chemical, when mixed correctly, for sanitizing and disinfecting. The product label of any chemical used must be followed. Rules and Regulations Governing the Health and Sanitation of Child Care Facilities are scheduled to be revised in 2015. If you would like to be on CDPHE’s stakeholder list please contact Amy Gammel at [email protected] or (303)692-3644 In the message, please indicate what type of stakeholder you would like to be: ◦ Active involvement in process (includes attending meetings and completing assigned work) ◦ Notification list (will receive updates throughout process) Contact Information: Colorado Department of Public Health & Environment Division of Environmental Health & Sustainability 4300 Cherry Creek Drive South Denver, CO 80246 (303)692-3645- Main http://www.colorado.gov/cdphe/dehs Thank you for your participation!
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