United States Chemical Safety June 2011 Environmental Protection and Pollution Prevention Agency (7510P)



# Glycolic Acid And Salts Summary Document: Registration Review : Initial Docket

June 2011Docket Number: EPA-HQ-OPP-2011-0422
www.regu lations .gov



## Glycolic Acid And Salts Summary Document Registration Review: Initial Docket May 2011

Case # 

## 4045

Ap pro ved By:



# -

Dan arrigan-Farrelly Director, Antimicrobials Division

Date:

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### TABLE OF CONTENTS

Glycolic Acid And Salts Registration Review Team

................................ .......................... 4 I. Preliminary Work Plan

................................ ................................ ................................ ..... 5 II. Fact Sheet

................................ ................................ ................................ ...................... 11 III. Summary of Anticipated Data Requirements

................................ .............................. 15 IV. Appendix A

................................ ................................ ................................ .................. 16

________________________________________ Please Note

This Preliminary Work Plan and Fact Sheet summarize the Environmental Protection Agency's current position based on the following documents:

1. Summary of Product Chemistry, Environmental Fate, and Ecotoxicity Data for the Glycolic acid Registration Review Decision Document

. J une 7 , 2011

2. Summary of Human Health Effects Data for the Glycolic Acid Registration Review Decision Document

. May 31 , 2011
Additional supporting documents for the Glycolic Acid And Salts Case may be found in the registration review do cket EPA

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4 of 19 Glycolic Acid And Salts Registration Review Team

Human Health & Environmental Effects Nathan Mottl Srinivas Gowda

Risk Management Seiichi Murasaki Lance Wormell

Office of General Counsel Philip RossDocket Number: EPA

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5 of 19 I. Preliminary Work Plan

-- Glycolic Acid And Salts

Introduction:
The Food Quality Protection Act (FQPA) of 1996 mandated a registration review program

. All pesticides distributed or sold in the United States generally must be registered by the U.S. Environmental Protection Agency (USEPA, EPA, or the Agency) based on scientific data showing that they will not cause unreasonable risks to human health or the environment when used as directed on product labeling

. The registration review program is intended to make sure that, as the ability to assess risk evolves and as policies and practices change, all registered pesticides continue to meet the statutory standard of no unreasonable adverse effect s to human health or the environment

. Changes in science, public policy, and pesticide use practices will occur over time

. Through the registration review program, the Agency periodically reevaluates pesticides to make sure that as change occurs, products in the marketplace can be used safely

. Information on this program is provided at http://www.epa.gov/oppsrrd1/registration_review/

. The Agency is implementing the registration review program pu rsuant to Section 3(g) of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and will review each registered pesticide every 15 years to determine whether it continues to meet the FIFRA standard for registration

. The Agency will consider benef its information and data as required by FIFRA

. The public phase of registration review begins when the initial docket is opened for each case

. The docket is the Agency’s opportunity to state what it knows about the pesticide and what additional risk analys es and data or information it believes are needed to make a registration review decision

. After reviewing and responding to comments and data received in the docket during this initial comment period, the Agency will develop and commit to a final work plan and schedule for the Glycolic Acid And Salts C ase.
The Glycolic Acid and Salts case (Case 4045) contains two active ingredients, glycolic acid (PC Code 000101) and sodium glycolate (PC Code 000103). Glycolic acid is the only active ingredient in the case with registered products. The last product contain ing sodium glycolate was canceled in 1989. There are no registered pesticide products containing s odium glycolate and therefore sodium glycolate will not be addressed in this registration review at this time

. The first product containing glycolic acid ( PC Code 000101 ) as an active ingredient was registered in the United States in 2001

. Currently
, there are eight product s registered with EPA. Glycolic acid is registered as a disinfecting cleaner and a disinfectant/sanitizer for non

- food contacting, hard n on

- porous surfaces in residential and public access premises. There are no tolerances, exemptions from tolerances, or tolerance petitions for this antimicrobial pesticide

. Glycolic acid is approved by FDA as an indirect food additive for use in food packag ing adhesives (175.105). Furthermore, human dietary exposure to residues of glycolic acid pesticidal sources is expected to be minimal compared to cosmetic uses and naturally

- occurring residues (especially in sugar cane, sugar beets, and several fruits). T he only expected labeled use pattern that could potentially lead to dietary exposure is indirect food contact from countertops in residential homes. During applications on countertops, formulations are typically diluted and the label states that all food must be removed prior to application, and surfaces must be rinsed with potable water following application. Although residues of glycolic acid on countertops after potable water rinses are not expected to concentrate on food products and exposure will beDocket Number: EPA

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6 of 19 minimal, EPA will perform risk assessments to determine if tolerances or exemptions from tolerances will be needed to support the existing registered uses of glycolic acid.

. A Reregistration Eligibility Decision (RED) was not completed for glycolic acid be cause it was registered after November 1, 1984.
Documents associated with the registration review of Glycolic acid and salts can be viewed at www.regulations.gov in docket EPA

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. Below is a summary of the issues relevant to this registration review case.
Anticipated Risk Assessment and Data Needs:
The Agency does not anticipate the need to conduct an ecological risk assessment. The Agency anticipates the need to conduct a human h ealth risk assessment. The Agency anticipates needing additional data to conduct the registration review for glycolic acid.
Ecological Risk:

Based on the low hazard and exposure, the Agency conclude s that the registered uses of glycolic acid will have 'no effect' (NE) on endangered or threatened terrestrial or aquatic species, or their designated critical habitats, as listed by the U.S. Fish and Wildlife Service (USFWS) and the National Oceanic and Atmospheric Administration's (NOAA) National Marine Fisher ies Service (NMFS). EPA anticipates conducting no further analysis of potential risks to endangered or threatened species unless public comment provides data or information that would otherwise inform the Agency's determination.

The Agency does not antici pate the need to require additional ecological data for th is registration review at this time.

The Agency does not anticipate the need to require additional environmental fate data for th is registration review at this time.

F or more information
, please r efer to Summary of Product Chemistry, Environmental Fate, and Ecotoxicity Data for the Glycolic acid Registration Review Decision Document , located in the docket

.
Human Health Risk:

The most recent human health assessments for glycolic acid were completed in 1997 to support the initial registration based on the proposed use as a toilet bowl disinfectant.

The Agency anticipates the need to require the following additional human health data for use in the registration review of all registered uses of glycoli c acid.

870.3465

-- 90

- day inhalation toxicity (rat) 875.1200

-- Dermal indoor exposure 875.1400

-- Inhalation indoor exposure 875.1600

-- Application exposure data reporting and calculationsDocket Number: EPA

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875.1700

-- Product use information 875.2300

-- Indoor surface residue dissipation 875.2800

-- Description of human activity 875.3000

-- Nondietary ingestion exposure

F or more information
, please refer to Summary of Human Health Effects Data for the Glycolic Acid Registration Review Decision Document
, located in the docket

. Product Chemistry:

The Agency does not anticipate the need to require additional product chemistry data for this registration review at this time.

F or more information
, please refer to Summary of Product Chemistry, Environmental Fa te, and Ecotoxicity Data for the Glycolic acid Registration Review Decision Document
, located in the docket

. Endocrine Disruptor Screening Program
As required by FIFRA and FFDCA, EPA reviews numerous studies to assess potential adverse outcomes from exposu re to chemicals

. Collectively, these studies include acute, subchronic and chronic toxicity, including assessments of carcinogenicity, neurotoxicity, developmental, reproductive, and general or systemic toxicity. These studies include endpoints which may b e susceptible to endocrine influence, including effects on endocrine target organ histopathology, organ weights, estrus cyclicity, sexual maturation, fertility, pregnancy rates, reproductive loss, and sex ratios in offspring

. For ecological hazard assessme nts, EPA evaluates acute tests and chronic studies that assess growth, developmental and reproductive effects in different taxonomic groups

. As part of its most recent registration decision , EPA reviewed these data and selected the most sensitive endpoints for relevant risk assessment scenarios from the existing hazard database

. However, as required by FFDCA section 408(p), glycolic acid is subject to the endocrine screening part of the Endocrine Disruptor Screening Program (EDSP).
EPA has developed the ED SP to determine whether certain substances (including pesticide active and other ingredients) may have an effect in humans or wildlife similar to an effect produced by a “naturally occurring estrogen, or other such endocrine effects as the Administrator

ma y designate.” The EDSP employs a two

- tiered approach to making the statutorily required determinations. Tier 1 consists of a battery of 11 screening assays to identify the potential of a chemical substance to interact with the estrogen, androgen, or thyroi d (E, A, or T) hormonal systems

. Chemicals that go through Tier 1 screening and are found to have the potential to interact with E, A, or T hormonal systems will proceed to the next stage of the EDSP where EPA will determine which, if any, of the Tier 2 te sts are necessary based on the available data. Tier 2 testing is designed to identify any adverse endocrine

- related effects caused by the substance, and establish a dose

- response relationship between the dose and the E, A, or T effect.

Under FFDCA section 408(p), the Agency must screen all pesticide chemicals. Between October 2009 and February 2010, EPA issued test orders/data call

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8 of 19 the group of 58 pesticide active ingredients on the initial list to be screened under the EDSP. Accordingly, as part of registration review, EPA will issue future EDSP orders/data call

- ins, requiring the submission of EDSP screening assays for glycolic acid

. For further information on the status of the EDSP, the policies and procedures, the list of 67 chemicals, future lists, the test guidelines and the Tier 1 screening battery, please visit our website: http://www.epa.gov/endo/

.
Timeline
EPA has created the following estimated timeline for the completion of the Glycolic acid and salts registration review:
Anticipated Schedule Activities Estimated Month/Year Phase 1: Opening the docket Open Public Comment Period for Docket June 2011 Close Public Comment Period for Docket August 2011 Phase 2: Case Development Develop Final Work Plan (FWP) December 2011 Issue DCI December 2012 Data Submission December 2014 Open Public Comment Period for Preliminary Risk Assessments June 2016 Close Public Comment Period for Preliminary Risk Assessments September 2016 Phase 3: Registration Review Decision Open Public Comment Period for Proposed Reg. Review Decision December 2016 Close Public Comment Period for Proposed Reg. Review Decision March 2017 Final Decision and Begin Post

- Decision Follow

- up 2017 Total (years) 6

Guidance for Commenters:
The public is invited to comment on EPA’s P reliminary W ork P lan and rationale

. The Agency will carefully consider all comments as well as any additional information or data provided in a timely manner prior to issuing a final work plan for the Glycolic acid and salts registration review case.

Trade Irritants:
Through the registration review process, the Agency intends to solicit information on trade irritants and, to the extent feasible, take steps toward facilitating irritant resolution

. Growers and other stakeholders are asked to comment on any trade irritant issues resu lting from lack of Maximum Residue Limits (MRLs) or disparities between U.S. tolerances and MRLs in key export markets, providing as much specificity as possible regar ding the nature of the concern.Docket Number: EPA

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9 of 19 Water Quality:
Glycolic acid is not identified as a caus e of impairment for any water bodies listed as impaired under section 303(d) of the Clean Water Act, based on information provided at http://iaspub.epa.gov/tmdl_waters10/attains_nation_cy.cause_detail_303d?p_cause_group_id=88 5. In addition, no Total Maximu m Daily Loads (TMDL) have been developed for glycolic acid
, based on information provided at http://iaspub.epa.gov/tmdl_waters10/attains_nation.tmdl_pollutant_detail?p_pollutant_group_id =885&p_pollutant_group_name=PESTICIDES.
More information on impaired w ater bodies and TMDLs can be found at http://www.epa.gov/owow/tmdl/

. The Agency invites submission of water quality data for this pesticide

. To the extent possible, data should conform to the quality standards in Appendix A of the OPP Standard Operating Procedure: Inclusion of Impaired Water Body and Other Water Quality Data in OPP’s Registration Review Risk Assessment and Management Process (see: http://www.epa.gov/oppsrrd1/registration_review/water_quality_sop.htm ), in order to ensure the data can be used quantitatively or qualitatively in pesticide risk assessments.

Environmental Justice:
EPA seeks to achieve environmental justic e, the fair treatment and meaningful involvement of all people, regardless of race, color, national origin, or income, in the development, implementation, and enforcement of environmental laws, regulations, and policies. To help address potential environme ntal justice issues, the Agency seeks information on any groups or segments of the population who, as a result of their location, cultural practices, or other factors, may have atypical, unusually high exposure to glycolic acid compare d to the general popu lation. Please comment if you are aware of any sub

- populations that may have atypical, unusually high exposure compared to the general population.
Structure Activity Relationships:
EPA must rely upon information of appropriate quality and reliability for each decision made by the Agency

. In the Office of Pesticide Programs (OPP), the evaluation process for a pesticide chemical traditionally begins with the applicant’s submission of a set of studies conducted with the specific pesticide chemical of interest

. The use of the results of such testing (measured data) is a logical, scientifically rigorous process that identifies the physical, chemical, and environmental fate properties of the pesticide, as well as the dose and endpoints at which an adverse effect can occur in various animal species.
Today, there is significant interest in alternative techniques, i.e., techniques other than data generation that could significantly inform the Agency’s decision

- making process

. Recently, OPP has made increasing use of structure activity relationship (SAR) as part of its regulatory decision

- making process

. In the SAR process, a chemical's molecular structure is compared to that of other chemicals for which data are available

. These structural similarities are then used to make predictive judgments about a chemical’s physical, chemical, and biological properties

. Thus, the chemical’s physical, chemical, and biological properties are a function of (or directly related to) the chemical’s molecular structure

. Quantitative SA R is referred to as QSAR

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10 of 19 develop a QSAR, a selected set of measured data on a single physical, chemical, or biological property is used to derive a model (an equation) to predict the value of that property

. Since SAR assessments and QSAR modeling are another set of tools that are available to Agency scientists, OPP has begun a process shift that envisions shifting from the current study

- by

- study approach to an approach in which the use of predicted data, generated using validated models, is considered along with information from open literature and studies specifically generated under Part 161 requirements

. All relevant information would be considered as part of a weight

- of

- the

evidence evaluation

. At this time, EPA believes that for certain endpoints, especially physical/chemical and fate properties, that SAR and QSAR might be effectively utilized to fulfill these data requirements for many antimicrobial pesticide chemicals

. When considering biological properties, at this time, EPA believes that SAR an d QSAR can be most effectively utilized in the evaluation of chemicals that exhibit lower toxicity for human health and/or ecotoxicity parameters

. This is appropriate because the risk assessment for lower toxicity chemicals can be stream

- lined, i.e., a

scr eening

- level assessment procedure rather than multiple tiers of assessments with progressively more data requirements.

If stakeholders believe that submission of predicted data can fulfill one of the data needs for the Glycolic Acid And Salts C ase, then th e Agency invites submission of this information

. The submitter would be expected to supply a rationale describing the utility of the information and provide documentation on the scientific validity of the information

. The determination that the predicted d ata fulfills the data requirement would be at the sole discretion of the Agency

. Pre

submission consultation with the Agency is encouraged.

Additional Information:
Stakeholders are also specifically asked to provide available information and data that will assist the Agency in refining its risk assessments , including any species

- specific ecological effects determinations. The Agency is interested in receiving the following information:

1. Confirmation on the following label information:

a. Sites of application b. Fo rmulations

c. Application methods and equipment d. Maximum application rates

e. Frequency of application, application intervals and maximum number of applications f. Geographic limitations on use 2. Use or potential use distribution 3. Use history 4. Usage/use information for non

- agricultural uses (e.g., materials preservation) 5. Typical application interval 6. State or local use restrictions 7. Ecological incidents (non

- target plant damage and avian, fish, reptilian, amphibian and mammalian mortalities) not already reported to the AgencyDocket Number: EPA

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11 of 19 8. Monitoring data

Next Steps:

After the 60

- day comment period closes in August 2011 , the Agency will review and respond to any comments received in a timely manner, and then issue a Final Work Plan for the Glycolic Acid And Salts C ase

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12 of 19 II. Fact Sh eet

Background Information: Active Ingredient: glycolic acid C ase number: 4045 PC Code: 000101 CAS number : 79

- 14

- 1 Technical registrants: E. I. du Pont de Nemours and Company First approved for use in a registered product: 2001 There are no tolerances, ex emptions from tolerances, or tolerance petitions for this antimicrobial pesticide . Glycolic acid is approved by FDA as an indirect food additive for use in food packaging adhesives (175.105). Furthermore, human dietary exposure to residues of glycolic acid pesticidal sources is expected to be minimal compared to cosmetic uses and natu rally

- occurring residues (especially in sugar cane, sugar beets, and several fruits). Antimicrobials Division Chemical Review Manager (CRM): Seiichi Murasaki
, murasaki.seiichi@epa.gov Antimicrobials Division Product Manager (PM): Wanda Henson
, henson.wand

a@epa.gov Chemical Structure:

Use & Usage Information:
Glycolic acid is registered as a disinfecting cleaner and a disinfectant/sanitizer for non

food contacting, hard non

- porous surfaces in residential and public access premises.
Ecological Risk Assessment Status:

Please refer to Summary of Product Chemistry, Environmental Fate, and Ecotoxicity Data for the Glycolic acid Registration Review Decision Document , located in the docket, for a detailed discussion of the ecological risk assessments.

Base d on available environmental fate and ecotoxicity data for glycolic acid, EPA believes that the currently registered use pattern of glycolic acid as a disinfectant/sanitizer for hard non

- porous surfaces in homes will not cause unreasonable adverse effects on the environment, and is not anticipated to cause adverse effects on fish, invertebrates, plants or other wildlife.

Human Health Risk Assessment Status:
The following are key findings of the recent human health risk assessments for Glycolic acid and salts . Please refer to Summary of Human Health Effects Data for the Glycolic Acid RegistrationDocket Number: EPA

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13 of 19 Review Decision Document
, located in the docket, for a detailed discussion of the human health risk assessment.

Hazard Characterization:

Acute dermal, dermal irritation, and eye toxicity studies were waived during registration based on a low pH (<2) and the expected corrosivity of the product; these three default to Toxicity Category I.

Oral toxicity was assigned Category III, and acute inhalation toxicity was assigned Category IV, based on studies in mice.

Glycolic acid was determined not to be a dermal sensitizer based on a modified Draize
test.
Dietary (Food and Water):

A dietary risk assessment was not conducted during the intial registration since the Agency did not expect dietary exposure to glycolic acid resulting from the proposed toilet bowl disinfectant use.

Glycolic acid is approved by FDA as an indirect food additive for use in food packaging adhesives (175.105). Furthermore, human dietary exposure to residues of glycolic acid pesticidal sources is expected to be minimal compared to cosmetic uses and naturally

occurring residues (especially in sugar cane, sugar beets, and several fruits).

The only expected label ed use pattern that could potentially lead to dietary exposure is indirect food contact from countertops in residential homes. During applications on countertops, formulations are typically diluted and the label states that all food must be removed prior to application, and surfaces must be rinsed with potable water following application. Although residues of glycolic acid on countertops after potable water rinses are not expected to concentrate on food products and exposure will be minimal, EPA will cond uct a dietary food assessment for this use.

According to the environmental fate data, glycolic acid is expected to be readily biodegradable in the environment. Glycolic acid is also expected to be diluted when it is flushed down the drain and resulting c oncentrations in drinking water are not expected to be above background levels found in the environment.

Residential:

A residential risk assessment was not conducted during initial registration because exposure was expected to be minimized based on the proposed use as a toilet bowl disinfectant.Docket Number: EPA

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14 of 19 With additional uses (e.g., countertop disinfectant and laundry use) there is a potential for short

- term dermal and inhalation application exposure to homeowners while using aerosol sprays and trigger pump sprays and while open

- pouring and mopping.
Aggregate:
The Agency has not conducted an aggregate risk assessment for glycolic acid.
In examining aggregate exposure, EPA takes into account the available and reliable information concerning exposures to glycolic aci d residues in food and drinking water, and non

- occupational pesticide exposures. Only residential risks associated with aerosol spray, trigger pump spray, open pouring, and mopping dermal and inhalation exposures as well as possible dietary exposure and p ost

- application hand

- to

- mouth exposure from treated countertops and mouthing treated fabrics are expected to be aggregated.
Occupational:

An occupational risk assessment was not conducted during initial registration because exposure was expected to be min imized based on the proposed use as a toilet bowl disinfectant.

With additional uses (e.g., hard surface disinfectant and laundry use) there is a potential for short

- term dermal and inhalation application exposure to occupational worker while using aerosol sprays and trigger pump sprays and while open

- pouring and mopping.

Cumulative:

EPA does not have, at this time, available data to determine whether glycolic acid has a common mechanism of toxicity with other substances or how to include this pesticide in a cumulative risk assessment. For the purposes of this Registration Review, EPA has assumed that glycolic acid does not have a common mechanism of toxicity with other substances when used as an antimicrobial as registered.

Incidents:
Ecological:

No glycolic acid ecological incidents have been reported in the Ecological Incident Information System (EIIS), maintained by the Environmental Fate and Effects Division (EFED) of the Agency

.
Human Health:

No glycolic acid human poisoning incidents have been r eported in the OPP Incident Data System (IDS)

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15 of 19 Tolerances and International Harmonization:
There are no tolerances, exemptions from tolerances, or tolerance petitions for this antimicrobial pesticide

. Glycolic acid is approved by FDA as an indirect food additive for use in food packaging adhesives (175.105). Furthermore, human dietary exposure to residues of glycolic acid pesticidal sources is expected to be minimal compared to cosmetic uses and natural ly

occurring residues (especially in sugar cane, sugar beets, and several fruits).

The only expected labeled use pattern that could potentially lead to dietary exposure is indirect food contact from countertops in residential homes. During applications o n countertops, formulations are typically diluted and the label states that all food must be removed prior to application, and surfaces must be rinsed with potable water following application. Although residues of glycolic acid on countertops after potabl e water rinses are not expected to concentrate on food products and exposure will be minimal, EPA will perform risk assessments to determine if tolerances or exemptions from tolerances will be needed to support the existing registered uses of glycolic acid

.
Data Call

- In Status:
There are no outstanding data call

- in (DCI) requirements for glycolic acid.

Labels:
Registered products, including EPA registration numbers are provided in Table 1 below

. For future reference, during registration review a list of pr oduct registration numbers will be included in the docket. Product registration labels may be obtained from the Pesticide Product Label System (PPLS) website at: http://oaspub.epa.gov/pestlabl/ppls.hom e

.
Table 1

. Registered Products

– Glycolic Acid

Registration # Registration Name Company Name Formulation Type % A.I.

5813

- 80 Clorox Patch The Clorox Company Soluble Concentrate 1.5

5813

- 86 CBW The Clorox Company Impregnated Materials 11.185

5813

- 87 X

- Men The Clorox Company Ready

- to

- Use Solution 3.07

5813

- 93 Show The Clorox Company Impregnated Materials 11.185

5813

- 101 Tuck 3 The Clorox Company Ready

- to

- Use Solution 1.75

71654

- 1 DuPont Glyclean AM E.I. du Pont de Nemours and Company Formulation Intermediate 68

71654

- 2 DuPont Bowl Cleaner E.I. du Pont de Nemours and Company Ready

- to

- Use Solution 9.5Docket Number: EPA

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16 of 19 Registration # Registration Name Company Name Formulation Type % A.I.

71654

- 5 DuPont KleanIt E.I. du Pont de Nemours and Company Ready

- to

- Use Solution 5.0Docket Number: EPA

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17 of 19 III. Summary of Anticipated Data Requirements

– Glycolic Acid And Salts

The table below summarizes anticipated data needs for the Glycolic Acid And Salts Case in Section I of this document (Preliminary Work Plan), Summary of Product Chemistry, Environmental Fate, and Ecotoxicity Data for the Glycolic acid Regis tration Review Decision Document , and Summary of Human Health Effects Data for the Glycolic Acid Registration Review Decision Document

. Table 2. Summary of Anticipated Data Requirements

– Glycolic Acid

Guideline Number Anticipated Data Requirement Test Material Est imated Timeframe (Measured in months from DCI Receipt)

875.1200 Dermal indoor exposure TGAI 24

875.1400 Inhalation indoor exposure TGAI 24

875.1600 Application exposure data reporting and calculations TGAI 12

875.1700 Product use information TGAI 12

875.2300 Indoor surface residue dissipation TGAI 24

875.2800 Description of human activity TGAI 12

875.3000 Nondietary ingestion exposure TGAI 24

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18 of 19 IV. Appendix A : Use Patterns

– Glycolic acid and salts

EPA Reg. # Treatment Site Method of Application Application Rate/

No. of applications Use Limitations

Use Category

– Residential and Public Access Premises Use Site

– Hard, Nonporous Surfaces

5813

- 80 Sinks, stovetops,

refrigerator exteriors, range hoods, kitchen appliance exteriors
, b aby furniture, toilet bowl exteriors, urinal exteriors, tubs, diaper pails, high chairs (non

food contact areas) Spray spray until wet, 30 second contact time to sanitize, 10 minutes to disinfect Do not use on floors, do not use on

cookware

5813

- 86 Sinks, stovetops,

refrigerator exteriors, range hoods, kitchen appliance exteriors
, b aby furniture, toilet bowl exteriors, urinal exteriors, tubs, diaper pails, high chairs (non

food contact areas) sponge, wipe wipe until wet, 5 minutes contact time to sanitize, 10 minutes to disinfect Do not use on flo ors, do not use on

cookware. Moisten impregnated pad to release end use product.

5813

- 87 Toilet bowl interiors spray Apply under and around rim of toilet bowl, 5 minute contact time.

5813

- 93 Toilet bowl interiors sponge, wipe Scrub entire bowl below water line, 5 minute contact time.

5813

- 101 Sinks, stovetops,

refrigerator exteriors, range hoods, kitchen appliance exteriors, baby furniture, toilet bowl exteriors, urinal exteriors, tubs, diaper pails, high chairs (non

food contact areas) sponge, wipe wipe until wet, 10 minutes to disinfect If used on food preparation

surfaces, the application must be followed by a potable water rinse

. Do not use on marble
, aluminum
, or wood that is unfinished
, unsealed, unpainted
, waxed, oiled or worn.

71654

- 1 F or use in the

formulation of liquid antimicrobial cleaning products For formulation of antimicrobial cleaners for use in household, industrial, institutional, commercial, & agricultural p remis es, and on food processing facilities and equipment, use up to 20% glycolic acid by weight (100% basis) in an aqueous solution. Formulation should be performed using a closed system.

71654

- 2 Toilet bowl interiors spray Apply at least two ounces under andDocket Number: EPA

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19 of 19 EPA Reg. # Treatment Site Method of Application Application Rate/

No. of applications Use Limitations

around rim of toilet bowl, 10 minute contact time.

71654

- 5 Sinks, stovetops,

refrigerator exteriors, range hoods, kitchen appliance exteriors
, b aby furniture, toilet bowl exteriors, urinal exteriors, tubs, diaper pails, high chairs (non

food contact areas) Spray spray until wet 10 minute contact time to d isinfect If used on food preparation

surfaces, all food must be removed prior to application and the application must be followed by a potable water rinse

Use Category

– Residential and Public Access Premises Use Site

– Fabric and Upholstery

5813

- 101 Laundry Pour Rub in full strength on grease spots or heavily soiled areas before washing; for extra cleaning, add 1/2 cup to load. Use only on white or colorfast

fabrics

.