Guidance on efficacy requirements for biocides: Other types of claims

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Biofilms

To add claims against biofilms on the biocide label (for example, destroying or controlling), the biocide must meet the performance criteria for a general (broad-spectrum) or hospital disinfectant and demonstrate efficacy against P. aeruginosa and S. aureus biofilms. The biofilm test methods are not suitable for hard surfaces of water systems due to differences in environmental conditions found in these systems (for example, drinking water distribution systems, cooling tower systems). For this reason, we do not expect that the biofilm test methods would accurately demonstrate the efficacy of antimicrobial products against public health biofilm in water systems. You may wish to also consult the most recent version of:

Table 21: Biofilm disinfection
Claim Physical form, method of application Recommended test methods Test organisms Number of batches per organism, replication of carrier surfaces per batch Inoculum or carrier count Performance criteria for efficacy
Core bacteria test requirements for biofilms
Biofilm kill claim

Water-soluble powder or liquid – dilutableFootnote 1 or RTU spray – test as liquid

Method not applicable for towelettes

ASTM E3161 Standard Practice for Preparing a Pseudomonas aeruginosa or Staphylococcus aureus Biofilm using the CDC Biofilm Reactor and ASTM E2871 Standard Test Method for Determining Disinfectant Efficacy Against Biofilm Grown in the CDC Biofilm Reactor using the Single Tube MethodFootnote 3

US EPA's standard operating procedures MB-19: Preparing a Pseudomonas aeruginosa or Staphylococcus aureus Biofilm using the CDC Biofilm Reactor and MB-20 Single Tube Method for Determining the Efficacy of Disinfectants against Bacterial Biofilm

Pseudomonas aeruginosa (ATCC 15442) and Staphylococcus aureus (ATCC 6538)

3 batches at LCL per organism

Conduct each of the 3 tests per organism on different test days (P. aeruginosa and S. aureus testing may be on same day)

Evaluate a minimum of 5 coupons against the biocide and 3 coupons as controls per organism per batch

Testing should be done on Borosilicate glass coupons

S. aureus: Mean log density of 7.5 to 9.0 CFU per couponFootnote 2

P. aeruginosa: mean log density of 8.0 to 9.5 CFU per couponFootnote 2

Minimum mean 6.0 log10 reduction (CFU per coupon) across 5 coupons for each batch within or equal to 10 min
Additional bacteria test requirements for biofilms
Biofilm kill claims for additional biofilm bacteria

Contact us about:

  • adding claims against additional biofilm bacteria (accepted case by case)
  • developing an alternative biofilm growth protocol or efficacy data to support approval of such claims
Confirmatory data bacteria test requirements for biofilms
Biofilm kill claim

Same as core bacteria requirements

Testing against additional bacteria not required

2 batches at the LCL per organism

Evaluate a minimum of 5 coupons against the biocide and 3 coupons as controls per organism per batch

Testing should be done on Borosilicate glass coupons

Same as core bacteria requirements

Abbreviation

  • LCL: lower certified limit
  • CFU: colony-forming unit
Footnote 1

The diluent used to dilute the biocide should be consistent for all tested micro-organisms.

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Footnote 2

Each individual coupon must fall within this range.

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Footnote 3

Additionally, see US EPA's standard operating procedures MB-19: Preparing a Pseudomonas aeruginosa or Staphylococcus aureus Biofilm using the CDC Biofilm Reactor and MB-20: Single Tube Method for Determining the Efficacy of Disinfectants against Bacterial Biofilm. These SOPs are the US EPA's interpretation of ASTM E3161 and ASTM E2871, respectively. They are available on the Antimicrobial Testing Methods & Procedures Developed by EPA's Microbiology Laboratory webpage.

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Prions

For information on general efficacy in reducing the infectivity of prions, consult:

Mould, mildew and odour control

You do not need to include efficacy data for general mould, mildew and odour control claims, which are considered non-therapeutic, such as:

However, for claims against specific bacteria or fungi, you should:

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