Apr 152021

U.S. Environmental Protection Agency and Centers for Disease Control Update Surface Cleaning Guidance Amid the COVID-19 Pandemic

Samuel B. Boxerman and Joseph T. Zaleski
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In a recent science brief regarding surface transmission of SARS-CoV-2, the novel coronavirus that causes COVID-19, the U.S. Centers of Disease Control and Prevention (CDC) concluded that while it is possible for people to be infected through contact with contaminated surfaces or objects, “the risk is generally considered to be low.” The principal mode by which people are infected by SARS-CoV-2 is through exposure to respiratory droplets in the air that contain the virus.

In response, the Environmental Protection Agency (EPA or Agency) has issued new surface cleaning and disinfection best practices that revise previous guidelines. The Agency now recommends routine cleaning of surfaces with soap and water, because in most situations that is sufficient. EPA does still recommend using EPA-registered disinfectants for use against the novel coronavirus or those featured on List N on those high-touch surfaces “when you know or suspect someone around you is sick with COVID-19” to “further lower the risk of spreading” the virus.

EPA cautions against deploying disinfectants around people with asthma (while advocating for taking certain precautions such as making sure the space is well ventilated). The Agency specifically reminds users that only those products specifically labeled for such application methods should be used for fogging, fumigating, or deploying wide-area electrostatic spraying. EPA suggests caution when using ultraviolet lights or ozone generators, which “may be risky or ineffective,” because EPA “cannot verify if or when it is appropriate to use” these pesticidal devices (which do not appear on List N).

Finally, EPA reminds users of disinfectant products that it regulates these as pesticides and they must be reviewed and registered with EPA prior to sale or distribution. The Agency also admonishes users to always review disinfectant product labeling and application directions and that children and students should not be asked to apply disinfectants.

As for air quality, the main infection pathway identified by the CDC, the Agency continues to focus its guidance on indoor air ventilation, air filtration, and such social practices as mask wearing, physical distancing, and hand washing to reduce the risk of exposure. EPA’s review and registration of antiviral air treatments remains limited, however. In January 2021 the Agency issued an emergency exemption to a specific antiviral air product for use in Georgia and Tennessee in a variety of use sites. It has neither expanded this emergency exemption nor provided similar full registrations to other antiviral air treatment products.

EPA’s collection of guidance and best practices is available at its “Coronavirus” webpage.

This post is as of the posting date stated above. Sidley Austin LLP assumes no duty to update this post or post about any subsequent developments having a bearing on this post.

Samuel B. Boxerman

Washington, D.C.

sboxerman@sidley.com

Joseph T. Zaleski

jzaleski@sidley.com

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