21
Oct
While Allowing Indoor Pesticide Spray for Covid, EPA Seeks Advice on Improving Indoor Air Quality
(Beyond Pesticides, October 21, 2022) The U.S. Environmental Protection Agency (EPA) has just made two announcements, related to the quest for improved indoor air quality in buildings, that address mitigation of disease transmission — and that of COVID-19, in particular. Related to enactment of the National COVID-19 Preparedness Plan, EPA issued guidance on the efficacy of antimicrobial products used on surfaces, and registered a new pesticide product the agency says can be used against influenza and corona viruses (some of the latter cause COVID-19 infections). In addition, EPA opened a 60-day public comment period “to solicit information and recommendations from a broad array of individuals and organizations with knowledge and expertise relating to the built environment and health, indoor air quality, epidemiology, disease transmission, social sciences and other disciplines.” Beyond Pesticides cannot help but note the irony of an intention to improve air quality that EPA couples with registration of a new, airborne pesticide for indoor use.
EPA expands on its RFI (Request for Information) related to indoor air quality, saying that it is “seeking input from a diverse array of stakeholders . . . about actions, strategies, tools and approaches that support ventilation, filtration and air cleaning improvements, and other actions that would promote sustained improvements in indoor air quality in the nation’s building stock to help mitigate disease transmission.”
EPA provided interim guidance in 2020 on products that look to claim residual efficacy (ability to continue killing pathogens beyond immediate application). The new guidance identifies three categories of such products: (1) residual disinfectants, (2) antimicrobial surface coatings and films, and (3) fixed/solid surfaces, such as copper, or other impregnated materials. The “residuals” are fairly standard disinfectants that generally show efficacy for up to 24 hours after application; the other two categories represent newer approaches for which EPA now requires a “stewardship plan” in order to gain (conditional) registration. In addition, the agency has issued guidance on new antimicrobial testing methods and standard procedures for evaluation of efficacy of disinfectants on hard surfaces again specific viruses and bacteria.
EPA’s October 6 registration announcement asserts that the newly registered pesticide, Lysol Air Sanitizer spray, is the first registered antimicrobial product that can kill both viruses and bacteria. EPA explains the utility of the new product: “When users spray the aerosol product in a closed, unoccupied room in accordance with the label use-directions, Lysol Air Sanitizer can kill bacteria and viruses in the air.” The product will reportedly kill 99.9% of airborne viruses when all doors, windows, air vents, and air returns in the room are closed, the product is sprayed for 30 seconds, and the room left empty and closed up for 12 minutes. Product instruction do note that there is “no residual effect after room is reopened.” Given that last proviso, the practicality of such a product may be somewhat limited, but Inside Energy and Environment opines that it “may pave the way for other types of registered pesticides that kill airborne viruses and bacteria.” EPA has a history of registering fumigants, such as sulfuryl fluoride, and indoor sprays that leave residues in closed spaces and structural voids in the indoor environment, despite claims that ventilation clears the poison. In terms of efficacy, airborne viruses are being constantly introduced and reintroduced in public spaces, such as stores, schools, restaurants, and public spaces. So, in this public context, a sanitizer application to an indoor space only protects against the target virus as long as the building is not used by the public.
The active ingredient in Lysol Air Sanitizer spray is dipropylene glycol (DPG), an ingredient used in some cosmetics. The Environmental Working Group’s Skin Deep database considers it a generally low-risk compound, but has limited data available on the chemical; the web page also indicates that health risks can be greater if DPG is used in an inhalable form, which the Lysol product obviously deploys. EPA’s review finds low acute inhalation toxicity of DPG, but that assessment is based on studies of mostly acute, not chronic or subchronic inhalation.
The agency announcement adds that EPA “conducted a robust risk assessment on exposure from both household and commercial use. When used following label directions, this product poses no unreasonable adverse risks to human health or the environment.” This may be true for some people, but Beyond Pesticides emphasizes two points:
- EPA’s track record on what pesticides constitute a human health threat, and to what degree, is not stellar; consider our reporting on, among other considerations, risks even with low-level exposures, potential synergistic impacts of multiple chemical exposures, and industry influence on agency risk assessments, among other shortcomings.
- Increasing numbers of people in the U.S. are reporting “chemical intolerance (CI)” — extreme sensitivity to one or more chemicals. A 2021 research study on CI reported that 15–36% of the population reports this experience. The phenomenon has been called numerous things over the years — among them, Multiple Chemical Sensitivity and Idiopathic Environmental Illness. EPA reassurance of “no unreasonable adverse risks” may be cold comfort to people dealing with this condition.
A more-recent and -comprehensive concept (and moniker) is Toxicant-Induced Loss of Tolerance, or TILT — a disease theory that joins germ theory and immune theory to describe and explain what CI people may experience. A leading researcher on TILT is Dr. Claudia Miller, an allergist/immunologist, professor emerita in the Department of Family and Community Medicine at The University of Texas Health Science Center (San Antonio), and leader of its Hoffman TILT Program. She was also a co-author of the paper on the 2021 study referenced above, Toxicant-induced loss of tolerance for chemicals, foods, and drugs: assessing patterns of exposure behind a global phenomenon.
That work examined eight major exposure events that preceded the onset of CI in groups of people who shared the same exposure experience. Those groups comprised, respectively: workers at EPA headquarters during renovations; Gulf War veterans; casino workers with pesticide exposures; workers with exposures to aircraft oil fumes; people who experienced the 2001 World Trade Center tragedy; people with surgical implants; those exposed to moldy environments; and tunnel workers exposed to solvents. Study findings were that “mixed volatile and semi-volatile organic compounds (VOCs and SVOCs), followed by pesticides and combustion products, were most prevalent across TILT initiation events. As a broader category, synthetic organic chemicals and their combustion products were the primary exposures associated with chemical intolerance. Such chemicals included pesticides, peroxides, nerve agents, anti-nerve agent drugs, lubricants and additives, xylene, benzene, and acetone.”
Dr. Miller describes TILT: “It is a two-step process. First, initiation involves acute or chronic exposure to environmental agents such as pesticides, solvents, or indoor air contaminants, followed by triggering of multi-system symptoms by exposure to small quantities of previously tolerated substances such as traffic exhaust, cleaning products, fragrances, foods, drugs, or food-drug combinations.” The 2021 study identified that, for the initiation to occur, the exposure must “interact” with the human nervous system or immune system (or both) in such a way that the individual is rendered intolerant to later triggering events. The co-authors assert that too little is yet known about the nature of that requisite “interaction,” but clearly point to synthetic organics (e.g., pesticides) as one of several primary exposure sources.
In its coverage, Beyond Pesticides notes that, “In the second stage, affected individuals are ‘triggered’ even by minute exposures, not only to the chemical that affected them in the first place, but also to other chemicals that did not affect them previously.” These post-acute trigger exposures can result in a range of symptoms, some fairly debilitating: chronic fatigue; gastrointestinal (GI) issues; problems with memory, attention, and/or mood; headaches or migraines; asthma; rashes; muscle pain; and/or allergy-like symptoms.
Beyond Pesticides adds, “TILT sufferers are often bounced from doctor to doctor based on individual symptoms, have significant difficulties receiving a diagnosis, and must navigate a world filled with triggering compounds, ranging from pesticides, to fragrances, molds, and other indoor air contaminants, traffic exhaust, pharmaceutical drugs, certain food, or food and drug combinations, or other volatile compounds. . . . The [fact] of TILT undermines [the] classical toxicological concept that ‘the dose makes the poison.’ . . . a better phrase may be that ‘[the] dose plus host makes the poison,’ with an understanding that past exposures and various genetic factors are likely at play in terms of individual tolerance to environmental pollutants. These factors play into why it is so difficult for affected individuals to receive treatment, let alone a diagnosis.”
About these triggers, Dr. Miller points out that the tens of thousands of pesticides, petrochemicals, and plastics in our materials stream broadly expose humans in industrialized countries to compounds with which humans did not co-evolve, and that roughly 20% of the populations of such countries exhibit chemical intolerances. Dr. Miller has developed diagnostic instruments to help identify patients suffering from TILT-related intolerances, including the Chemical Intolerance Self-Assessment (QEESI). For more information on TILT, read a transcript of a talk given by Doris Rapp, MD, and published in Beyond Pesticides’ Pesticides and You newsletter, and visit the UT San Antonio website on the Hoffman TILT program. See Dr. Miller’s talk at Beyond Pesticides National Forum Series, Health, Biodiversity, and Climate: A Path for a Livable Future.
The Hoffman program page lists, among other information, common triggers and alternatives to them. Among those triggers is the category “bleach, ammonia, disinfectants, and strong cleaning products.” The alternatives offered are “elbow grease, non-toxic soap and water, baking soda, and vinegar.” Great advice for general cleaning, but unlikely to seem sufficient to those looking for anti-COVID-19 “magic bullets” — an understandable desire, given the havoc this pandemic has wreaked. That said, EPA should be paying more, and more-granular, attention to vulnerable, chemically intolerant segments of the population in its review of, and risk assessments for, new pesticide products, such as this new Lysol spray. Chemically intolerant people, as individuals and as a cohort, are given far too little consideration in this regard.
Beyond Pesticides has previously published articles and fact sheets on COVID-19 protective strategies (some from early in the pandemic), including: EPA-allowed disinfectants increase vulnerability; safer personal protection: a disinfectants factsheet; and a Q&A on sanitizers and disinfectants.
Beyond Pesticides encourages response to EPA’s Request for Information/public comment invitation; comments are due no later than December 5, 2022. Instructions for submitting them are listed under the “Addresses” section of the Federal Register webpage: https://www.federalregister.gov/documents/2022/10/05/2022-21590/request-for-information-better-indoor-air-quality-management-to-help-reduce-covid-19-and-other.
Sources: https://www.insideenergyandenvironment.com/2022/10/epa-provides-guidance-regarding-novel-antimicrobial-pesticides-and-seeks-comment-on-indoor-air-quality-issues/#page=1\ and https://enveurope.springeropen.com/articles/10.1186/s12302-021-00504-z
All unattributed positions and opinions in this piece are those of Beyond Pesticides.
