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There were issues with the manufacturers' labels for killing the fungus. Rather than a detergent (cleanser) they stressed it was being used to kill a pest, and was thus a pesticide and subject to FIFRA (Federal Insecticide Fungicide and Rodenticide Act).

Dueling bureaucracies .

What? The USFWS conjured up a recommendation without checking to see if it was credible, reasonable, or even permissible? Say it isn't so. It's hard to put credibility to ANYTHING the USFWS puts out these days. Maybe they should change their brim hats to dunce caps. I'm sure there are great folks who can use logic and reasoning in the Service....but none of them are doing the talking!

Hi, Cheryl,

Just arrived home from Convention and post-convention travels. I have no idea why the hot water time changed from 15 to 20 minutes. I will inquire.

Peter

It appears that the second row of the chart that lists "Non-porous personal protective safety equipment" does not mean helmets, masks, and rubber boots used only for caving.

FIFRA defines personal protective equipment: http://www.epa.gov/oppfead1/safety/workers/equip.htm

It would be good to get an opinion if possible. Then the table would make sense.

This talk of applying flame to a vessel containing your gear for the warm water treatment is thoughtless. Put your gear in a tub and just add some more hot water if it cools.

At first I had difficulty making sense of the change in which the quaternary ammonium compound -based products were no longer recommended for porous surfaces. The revised USFWS document is not very helpful - there's a mention at the end regarding FIFRA (Federal Insecticide Fungicide and Rodenticide Act) definitions, but no context is provided to explain the rationale for the change.

Then I read the label and MSDS (Material Safety Data Sheet) for one of the products. The Lysol IC Quaternary Disinfectant Cleaner label states:

Virucidal, fungicidal and bactericidal, this multi-purpose, hospital disinfectant cleans and disinfects hard, nonporous surfaces. The economical, concentrated formula makes up to 256 gallons (1:256). Use on floors, walls, glazed porcelain, plastic surfaces (such as polypropylene, polystyrene, etc.) and other hard, nonporous surfaces.

Takeaway: label use - "hard,nonporous surfaces."

And from the Lysol IC MSDS:

It is a violation of Federal law to use this product in a manner inconsistent with its
labeling.

I suspect that the other commercial quaternary ammonium based products named in the USFWS document have similar labeling. Since their labels state that the use is for hard, nonporous surfaces, and since use inconsistent with the label is "a violation of Federal law" (presumably FIFRA), it seems fairly clear that USFWS should not be recommending their use on porous surfaces to kill a fungus (especially not one that's not even listed on the label - I wonder how long till someone notices that problem as well!)

That said, it's amazing that this is only just now coming to light, three years after the USFWS issued the initial WNS decontamination guidance document, given the labyrinth of review that these federal documents supposedly have to go through. It's also surprising that there isn't some form of waiver that USFWS could get, or supplemental product labeling that the manufacturers could get, since the efficacy of these products on porous surfaces against G.d. has actually been demonstrated.

Ron - excellent, clear and concise post, and right on point.

Essentially, the USFWS protocols flew "under the radar" of other federal agencies. The focus was (appropriately, in my opinion) on functionality: i.e. what worked to kill the fungus in question. There is no question that quarternary ammonium compounds in the appropriate concentration kills the fungus. It works. It's just not an approved, labeled use.

USFWS and those working on the protocols, including Hazel Barton, looked at this as cleaning, not through the technical lens of a pesticide. Others felt differently, and have asserted themselves. I don't blame this on USFWS, but they were forced to react.

It is a violation of Federal law to use this product in a manner inconsistent with its labeling.

Seen this many times, and always wondered who gets to make that determination. If I come up with a new cleaning product, can I just throw on a Federal law warning or does my product label have to be voted on by Congress?

It is a violation of Federal law to use this product in a manner inconsistent with its labeling.

I'd like to know how they find out how someone is using a product, and what the arrest rate is! Think neighbors rat each other out?

I bet while they were arresting, the feds would also nab you for having cut off those big "do not remove" tags on your mattress and furniture.


PS: Yes, yes, I know--it's all mostly about liability and what the federal agencies can be seen to be recommending.

Regarding the change in time from 15 minutes to 20 minutes for the hot water treatment, my inquiries have found some potential miscommunication on this issue. I am working with the various parties now in an attempt to get formal clarification.

Having communicated with both USFWS and Dr. Hazel Barton, and read the manuscript of the study on decon strategies and techniques that is currently in press (awaiting publication), the correct time for hot water submersion (>50 degrees C; 122 degrees F) is 20 minutes.

The paper further confirms the necessity to remove mud from cave and research gear, as the presence of mud and other organic materials counteracts the effectiveness of the disinfecting.

Bottom line: wash thoroughly (pressure wash or scrub); then soak using a detergent (surfactant), such as Woolite, to loosen and remove remaining mud and debris; rinse; then use the hot water for 20 minutes or the chemical alternatives for the appropriate amount of time; rinse; dry.

Again, the most current protocols are found here:
http://whitenosesyndrome.org/sites/default/files/resource/national_wns_revise_final_6.25.12.pdf

Did you get or do you have a definition of "Non-porous personal protective safety equipment" as used in row two of the chart?

The second column (under Lysol IC) gives examples: goggles, rubber boots, etc. I'd include rubber gloves, waterproof cave packs, and the like.

PYoungbaer wrote:I'd include rubber gloves, waterproof cave packs, and the like.

Be mindful that the straps on cave packs are porous.

PYoungbaer wrote:The second column (under Lysol IC) gives examples: goggles, rubber boots, etc. I'd include rubber gloves, waterproof cave packs, and the like.

Since when is a waterproof cave pack classified as personal protection safety equipment?

I think row two was added to cover situations where personal protection safety equipment is called for by the product label or MSDS. I do not think row two was meant to include caving gear.

Could you please ask for a clarification?

Crockett,

You're reading the chart headings too literally. The difference is functional - either a hard substance in row one (e.g helmet, carabiner, camera case, tripod, etc.) vs. a soft substance (e.g. rubber boots). The classification on the chart is not intended to be a technical guide, but one for cave bat researchers and cavers. If you look at the earlier, very detailed decon guides for bat researchers, for example, it covers things like harp traps, cameras, and more. There is no chart or list of "non-porous personal protective gear," just the examples - boots, goggles, and I added gloves and wet caving packs as additional examples (to differentiate between cloth packs). The latter, like cave coveralls, have a fabric weave, which traps mud (organic detritus) between the threads, creating additional challenges for cleaning and deconning that soft, non-porous materials don't.

Hope that helps.

(P.S. It is correct that some cave packs have both non-porous bodies and fabric strapping, not to mention hard materials, as well).