Debbie Graham
Cleaning and disinfecting can mean different things to different people. However, in a correctional institution, a clear understanding of both terms and implementation of appropriate cleaning and disinfecting practices can be the difference between a healthy environment or an environment where contracting and spreading of disease is not under control.
The past two years of COVID-19 have made us all aware not only of the importance of cleaning and disinfecting our facilities but also setting a “goal” of a healthy environment. While COVID-19 is on everyone’s mind, it is important to remember that COVID-19 is certainly not the only contagious or serious virus. There are bacteria and other pathogens as well that can cause serious illness and even death.
Many times during facility inspections I observe inappropriate practices or practices that won’t meet the “goal” despite a facility’s best efforts. Some of the mistakes include:
• not having a sanitation plan, • lack of sufficient processes, • types of chemicals and supplies used, • failure to follow chemical label instructions, • inappropriate or no personal protective equipment (PPE) used, • failure to clean before disinfecting, and • lack of training.
So, what are the appropriate cleaning and disinfecting practices that can meet the “goal” of a healthy environment? This is the first of several articles in which cleaning and disinfecting in a correctional institution will be covered. Subsequent articles cover topics such as food service and food safety, general housekeeping, laundry, and medical areas.
Sanitation Plan A facility may have limited written instructions for cleaning, disinfecting, and housekeeping functions, most often in the form of a facility policy. However, the policy generally lacks clear instructions, specific procedures, chemicals, and supplies to be used, monitoring and inspections, and required training. An important first step in setting a “goal” for a healthy environment is creating a written plan. In most cases, the written plan is referred to as the “Sanitation Plan” or “Housekeeping Plan.”
Before beginning the process of writing the Sanitation Plan, a needs assessment of the facility should be conducted to identify all areas that have cleaning and disinfecting needs, then determine exactly what those needs are. For example, is only cleaning necessary, or is disinfecting or sanitizing also required? Once the needs assessment is complete, the facility can identify the person responsible for completing the necessary tasks, the chemicals and supplies needed the actual steps necessary to accomplish the tasks and the frequency of the tasks. A facility’s chemical and supply vendor can assist with determining the appropriate chemicals and supplies needed for each task.
Start Your Plan Start your plan with a statement describing what the Sanitation Plan is meant to accomplish. The plan should include definitions of terms that are important for
everyone to understand and a list of the types of chemicals used in the facility. Next, start with each individual area (i.e., housing units) and list the chemicals and supplies needed to complete the tasks in that area. Then, develop a standardized process by providing step-by-step instructions for completing each task in the proper order (i.e., clean from the cleanest surfaces to the dirtiest surfaces) for that area.
The next steps are to: • Utilize chemical labels to include instructions about how to use the chemical, supplies needed, PPE required, and the “dwell time,” the time the chemical needs to stay wet on a surface to be effective.
• Develop cleaning schedules and assign responsibilities for all areas and tasks. Cleaning schedules can be set up in a manner that works best for the facility, such as a schedule by facility area or by frequency (i.e., daily tasks).
• Include in the Sanitation Plan provisions for monitoring, inspections, and corrective actions to ensure the Sanitation Plan is being followed, goals are being met, and corrective actions are implemented.
• Review the Sanitation Plan as necessary, but also on a set interval such as an annual review. The Sanitation Plan should be comprehensive and may include other details based on the facility’s needs. Take ample time to carefully assess the facility and to write the Sanitation Plan. The more comprehensive and complete the plan is, the better staff will be able to understand and follow it.
Implement Your Plan Once the plan is written, the following steps need to be taken: • Review the plan with staff, especially sanitation staff.
• Provide training for staff.
• Implement the Sanitation Plan and monitor progress.
• Complete inspections of all areas of the facility and compare your findings with the requirements outlined in the Sanitation Plan.
• Develop corrective actions for areas found with deficiencies.
• Provide follow-up inspections to ensure corrective actions have been implemented.
• Update the Sanitation Plan as needed, especially if monitoring and inspections reveal that parts of the Sanitation Plan are not assisting the facility in meeting its goals.
At first, these steps may seem cumbersome, especially if your facility is short-staffed. However, once a routine has been established and staff understands how to follow the Sanitation Plan, the benefits will be easy to see.
An important first step in setting a “goal” for a healthy environment is creating a written plan.
Chemicals, Supplies, and Usage During inspections, I see a good number of errors made concerning the use of chemicals. For example, the wrong chemical is used for the task, dilution rates are incorrect, labeling requirements are not met, dwell times are not adhered to, or there is no proper training. In general, chemicals intended for cleaning, sanitizing, or disinfection are in three forms (cleaners, sanitizers, and disinfectants), with some exceptions.
Cleaners are designed for specific cleaning needs. Some are all-purpose cleaners, but these products do not kill pathogens. Cleaners can be in the form of detergents or soaps and remove dirt, dust, and debris from surfaces.
After proper cleaning, sanitizers lower the number of pathogens on a surface to a safe level in accordance with public health standards and requirements. Disinfectants kill pathogens on a surface—except for spores—providing that proper cleaning has occurred prior to the use of the disinfectant. Some products are cleaners and disinfectants in one. These products can be used for cleaning and disinfecting, when the label instructions are followed. Keep in mind these products may have different instructions for use as a cleaner versus as a disinfectant.
Chemicals authorized for use in the U.S. are regulated by the Environmental Protection Agency (EPA) under the Federal Insecticide, Fungicide, and Rodenticide Act. Under this act, chemical disinfectants are considered “antimicrobial pesticides.” Per the EPA, “pesticide product labels provide critical information about how to safely and legally handle and use pesticide products” (EPA, 2021a).
The labels also contain information about the intended use of the chemical (i.e., cleaner, disinfectant, etc.), what microorganisms the product is effective against, safety precautions, the proper dilution ratio, and dwell time. All disinfectants require a certain time they must stay wet on a surface. This is referred to as the “dwell time” to be effective, and the label provides this information.
Some chemicals can be a cleaner and disinfectant in one but require different dilution ratios or dwell time for each use. The product label on chemicals is legally enforceable and all contain the statement: “It is a violation of federal law to use this product in a manner inconsistent with its labeling” (EPA, 2021a).
Failure to follow pesticide label instructions can render your cleaning and disinfecting processes ineffective, waste product, be dangerous, have very serious and devastating consequences, and result in legal liability. Never mix chemicals together, and do not attempt to alter a chemical’s intended purpose. Always follow label instructions.
Chemical Training
The importance of training on the use of chemicals can never be overstated. Training is an important part of any effective cleaning and disinfecting program. OSHA Standard 29 CFR 1910.1200, Hazard Communication states, “Employers shall provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area. Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemical-specific information must always be available through labels and safety data sheets” (OSHA, 2013).
In addition to training for employees, anyone participating in cleaning and disinfecting tasks, including the use of chemicals must be trained as well—including inmates. I most often find that inmates are given little-to-no training on cleaning and disinfecting practices, the use of chemicals, and safety precautions. Most inmates have no idea what Safety Data Sheets (SDSs) are nor do they know where the SDSs are located.
It is advisable to create an inmate training package for cleaning and disinfecting processes, use of chemicals, information available from SDSs, and the use of PPE for all inmates who are assigned cleaning and disinfecting tasks.
For disinfecting in the facility against COIVD-19, use a disinfectant product that is on the EPA’s List N (EPA, 2021b). EPA’s List N contains products that the “EPA expects to kill all strains and variants of the coronavirus SARS-CoV-2 (COVID-19) when used according to the label directions.” In most cases, the same disinfectant approved for use against COVID-19 can be used for general disinfecting in your facility as well. Food service and medical areas will have additional requirements. Therefore, ensure that chemical products are used for their intended purpose.
It is a best practice to utilize auto dilution and dispensing systems for cleaning, disinfecting, and sanitizing chemicals throughout the facility, including for laundry operations, food service, and general housekeeping. Auto dilution and dispensing systems can be set to provide the proper dilution ratio for dispensing into secondary containers, such as trigger spray bottles, thus avoiding dilution errors.
The facility must ensure that each secondary container of hazardous chemicals in the workplace is labeled in accordance with OSHA Standard 29 CFR 1910.1200, Hazard Communication (OSHA, 2013). Chemical suppliers can provide either pre-screened bottles or labels with the appropriate information to meet the OSHA standard.
What Are the Differences Between Cleaning, Disinfecting, Sanitizing, and Sterilization?
Understanding the differences between cleaning, disinfecting, sanitizing, and sterilization can assist the facility staff in writing the Sanitation Plan and is an important part of determining the appropriate processes required for a healthy environment.
• Cleaning is defined by the Centers for Disease Control and Prevention (CDC) as, “the removal of visible soil (e.g., organic and inorganic material) from objects and surfaces and normally is accomplished manually or mechanically using water with detergents or enzymatic products” (CDC, 2016). Cleaning should always be completed first before any disinfecting or sanitizing tasks, as microorganisms can hide behind dirt, debris, and organic materials impeding the effectiveness of the disinfecting and sanitizing process.
• Sanitizing lowers the number of germs on a surface to a safe level in accordance with public health standards and requirements. This process is commonly used in food service areas.
• Disinfecting eliminates many or all pathogenic microorganisms, except bacterial spores, on inanimate objects (CDC, 2016). Disinfecting does not clean a surface or remove germs. However, after proper cleaning, disinfecting will kill germs on the surface.
• Sterilization destroys or eliminates all forms of microbial life and is carried out in healthcare facilities by physical or chemical methods (CDC, 2016).
Equally important to the use of appropriate chemicals is the use of correct supplies for the tasks, such as mops, mop buckets, brushes, PPE, etc. Chemical labels can be a good source for the type of supplies needed to complete tasks. Chemical suppliers can also provide pertinent information concerning what supplies are appropriate for use with a specific chemical. The type of supplies should also be included in the step-by-step instructions in the Sanitation Plan for the cleaning, disinfecting, and sanitizing processes in your facility.
Always follow chemical label instructions concerning the type of PPE to be worn when using a chemical. This is important for staff as well as incarcerated persons. If the facility utilizes inmates for cleaning and disinfecting tasks, they must be equipped with the proper PPE.
Safety Data Sheets Safety Data Sheets (SDSs), formerly known as Material Safety Data Sheets (MSDSs), contain important information about a chemical, such as the physical, health, and environmental health hazards; safety precautions; emergency measures; and first aid information. SDSs are required to be presented in a consistent format containing 16 sections. All SDSs follow the same format, with each numbered section being the same category.
For example, all SDSs have First-Aid Measures as Section 4. Requirements for SDSs are covered by OSHA Standard 29 CFR 1910.1200, Hazard Communication. This standard requires that employers “have a safety data sheet in the workplace for each hazardous chemical which they use” and “the employer shall maintain in the workplace copies of the required safety data sheets for each hazardous chemical, and shall ensure that they are readily accessible during each work shift to employees when they are in their work area(s)” (OSHA, 2013). The facility must ensure that SDSs are continually updated and available to everyone who utilizes chemicals. This includes both staff and inmates.
Other Disinfection Methods COVID-19 has given all of us a lot to think about. How do we reduce the spread of this virus? Will there be an outbreak in the facility where I work? Will I be infected? Do staff take the virus seriously enough or too seriously? What cleaning and disinfecting protocols are needed in my work environment?
All of these are very important subjects to give serious consideration. Given the events with COVID-19 in the past two years, many facilities have inquired about alternate means of disinfection in their facility. Two subjects that are frequently mentioned and have gained some popularity are the use and effectiveness of UV lights and fogging, misting, or electrostatic spraying to reduce the spread and to inactivate or “kill” the virus.
UV Lights UV disinfection has been a validated technology for the disinfection of pathogens on surfaces and in air and water for several decades (Raeiszadeh & Adeli, 2020). UVC light causes cellular damage, which renders the pathogen unable to replicate or survive. Therefore, it is said to inactivate a pathogen instead of killing it. The effectiveness of the UVC light is measured in wavelength, dose, and duration in inactivating a virus.
Some studies have shown UV light—especially UVC lights—to be effective in the reduction of pathogens in hospital environments; however, it is also important to know that the CDC has stated that UV radiation against the virus that causes COVID-19 has not been fully established. This is because there has been limited testing of this mechanism specifically with SARS-CoV-2.
The U.S. Food & Drug Administration (FDA) states, “There is limited published data about the wavelength, dose, and duration of UVC radiation required to inactivate the SARS-CoV-2 virus” (FDA, 2021). In addition, there are limitations to how effective UVC radiation can be due to the need for the virus to have direct exposure to the radiation, which means anything on a surface (such as dust, cracks, scratches) can block the UVC radiation from direct exposure with the virus. It is also important to note that UVC radiation only acts upon a surface; there is no penetration of effectiveness beyond the surface.
Fogging, Misting, and Electrostatic Spraying Fogging, misting, and electrostatic spraying delivers disinfectants as an aerosol suspending the product in the air. Electrostatic sprayers change the disinfectant into “charged” aerosols that are attracted to surfaces. This process can improve the surface coverage and make disinfecting in hard-to-reach areas easier. Disinfecting via foggers, misters, or electrostatic sprayers should only be used with chemical products that are approved by the EPA for these types of equipment and application methods.
A disinfectant’s label contains the instructions for the types of equipment and application methods if the products have been approved for those methods. In addition, remember to clean surfaces first before attempting to disinfect/sanitize them. The CDC states they neither recommend or not recommend the use of foggers, misters, or electrostatic sprayers for disinfecting. Instead, they warn that these devices should be used with extreme caution.
In addition, the CDC (2021) warns that when foggers or electrostatic sprayers are used, they should be handled: • only by trained personnel; • with disinfectants approved for the method of application; • according to manufacturer instructions for safety, use, and contact time; • with appropriate PPE and other safety measures to ensure safety for the operator, others nearby, and people who could use the room afterward; • when rooms are not occupied; and • with extreme caution if using around food preparation or areas where children play.
If UV and/or fogging, misting, or electrostatic type systems are being considered for your facility, take the time to do your homework. Inquire about these systems with manufacturers or reputable vendors, and talk with other facilities that are using a system similar to what you are considering.
Understand what you want to use the equipment and delivery method for and the capabilities of the system. Ask questions about the system—i.e., ask about health and safety risks, what health/safety precautions need to be followed, what type of maintenance is needed for the equipment and how maintenance needs are accomplished. You want to purchase the safest, most reliable, and easy-to-use system that meets your facility’s needs.
Conclusion Environmental health requires assessing and mitigating environmental factors that influence human health. Therefore, a facility should work toward promoting health and a healthy environment for all who are in contact with the facility. A well-thought-out Sanitation Plan ensures that the facility is promoting environmental health and can be a strong factor in reducing infection rates and the spread of disease. Implementation of the Sanitation Plan, monitoring, inspections, and corrective actions can ensure that the facility is taking appropriate steps to establish and maintain a healthy environment.
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Debbie Graham is a Registered Environmental Health Specialist/Registered Sanitarian and a Registered Dietitian. She spent 32 years in county government, with more than 28 of those years in corrections, retiring as a Division Chief in Miami, Florida. She can be contacted at fsbcmdrdebbie@yahoo.com.
References
Centers for Disease Control and Prevention. (2016). Introduction, methods, definition of terms, guideline for disinfection and sterilization in healthcare facilities, 2008. Retrieved from cdc.gov/infectioncontrol/guidelines/disinfection/introduction.html
Centers for Disease Control and Prevention. (2021). Safety precautions when using electrostatic sprayers, foggers, misters, or vaporizers for surface disinfection during the COVID-19 pandemic. Retrieved from cdc.gov/coronavirus/2019-ncov/php/eh-practitioners/sprayers.html
Environmental Protection Agency. (2021a). Introduction to pesticide labels. Retrieved from epa.gov/pesticide-labels/introduction-pesticide-labels
Environmental Protection Agency. (2021b). About list N: disinfectants for coronavirus (COVID-19). Retrieved from epa.gov/coronavirus/about-list-n-disinfectants-coronavirus-covid-19-0
Occupational Health & Safety Administration. (2013). 1910.1200-Hazard communication. (78 FR 9313, Feb. 8, 2013). Washington, DC: U.S. Department of Labor. Retrieved from www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200
Raeiszadeh, M., & Adeli, B. (2020). A critical review on ultraviolet disinfection systems against COVID-19 outbreak: Applicability, validation, and safety considerations. ACS Photonics Journal, 7(11), 294–2951.
U.S. Food and Drug Administration. (2021). UV lights and lamps: Ultraviolet-C radiation, disinfection, and coronavirus. Retrieved from fda.gov/medical-devices/coronavirus-covid-19-and-medical-devices/uv-lights-and-lamps-ultraviolet-c-radiation-disinfection-and-coronavirus