DUWL ‘Cleaners’ must be Registered with EPA

Chemical cleaners on the market to remove and clean biofilm from dental unit waterlines (DUWLs) must be registered with the US Environmental Protection Agency (EPA). EPA requires regulatory oversight because chemical treatment regimens on the market claiming to control biofilm in DUWLs are actually considered antimicrobial pesticides, and must be regulated as such.

One purpose of EPA is to protect human health and the environment by regulating pesticide sales and use in the United States. The term “pesticide” is broad, encompassing any chemical intended to destroy pests, control their activity, or prevent them from causing damage. Pesticides used in dentistry are antimicrobials, such as surface disinfectants, sanitizers, and DUWL cleaners, designed to destroy or inactivate disease-producing bacteria and other microorganisms.

As stated above, before an antimicrobial can be sold or used in the US, it must be registered with EPA. Pesticide manufacturers and/or distributors must submit scientific data that documents the product’s effectiveness and the potential health and environmental effects. Before registration, EPA scientific and technical personnel review the data on the product to ensure that it is properly labeled and will not cause adverse effects on human health and/or the environment.

Unregistered products that have not undergone this scientific scrutiny may pose unrecognized hazards to human health and/or the environment. Additionally, companies that break the law by selling unregistered products and failing to pay the required environmental taxes have an unfair competitive edge over law-abiding companies.

OSHA Review, Inc. recommends that dentists use chemical cleaners for DUWLs that are properly labeled with an EPA registration number, indicating proper regulatory oversight. To determine if a product is properly registered, you can check EPA’s Product Label and System Database.

OSHA Review, Inc. a registered continuing education provider in the State of California, specializing in Dental Practice Act, infection control, and Cal/OSHA training. OSHA Review subscribers in California receive updated regulatory compliance and infection control training thorough our bi-monthly newsletter.