Other Sanitizers, Disinfectants, or Chemicals

Other sanitizers, disinfectants, or chemicals used must: 1) Be U.S. EPA-REGISTERED under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and, 2) Not create a hazardous condition or compromise disinfectant efficacy when used with required bromine or CHLORINE concentrations, and 3) Not interfere with water quality measures meeting all criteria set forth in this CODE.

The MAHC has opted to not include lists of disinfectants that should not be used in AQUATIC VENUES versus just saying that they must not pose a hazardous issue with the CHLORINE or bromine disinfectants in use and that all water quality criteria must be met. PHMB Polyhexamethylene biguanide hydrochloride (PHMB) is a polymeric antimicrobial that has been used as an alternative to CHLORINE and bromine. PHMB is often referred to as biguanide in the industry. The formal name for PHMB on US EPA accepted labels is “Poly (iminoimidocarbonyliminoimido-carbonyl iminohexamethylene) hydrochloride”. The U.S. EPA has registered PHMB for use in POOLS and SPAS as a “SANITIZER” with label directions requiring that the concentration be maintained between 30 and 50 PPM (mg/L) as product (6 to 10 PPM (mg/L) of active ingredient). PHMB is not an oxidizer and must be used in conjunction with a separately added product. Hydrogen peroxide is the strongly preferred oxidizer. The vast majority of the PHMB used in POOLS and SPAS is in private residences but a limited number of public facilities have used PHMB. Because of its limited use in public AQUATIC FACILITIES, there are few independent studies on the efficacy of PHMB in recreational water. Studies report that the rate of kill of bacteria is slower than that of CHLORINE under laboratory conditions. However, the U.S. EPA found that manufacturer’s generated data demonstrated adequate efficacy under the EPA guideline DIS/TSS-12 to grant registration under the Federal Fungicide, Insecticide and Rodenticide Act (FIFRA) and without regard to whether the facility is public, semi-public, or private. As part of their registration process, the US EPA does not distinguish between public and private facilities. The efficacy data analyzed by the U.S. EPA is company confidential and has not been reviewed as part of the development of the MAHC. There are no known published studies of the efficacy of PHMB against non-bacterial POOL and SPA infectious agents (e.g. norovirus, hepatitis A, Giardia sp., Cryptosporidium spp.), under use conditions. PHMB is generally compatible with both UV and ozone, but both UV and ozone will increase the rate of loss of PHMB. Since SECONDARY DISINFECTION SYSTEMS require the use of a halogen as the primary disinfectant, the use of PHMB, even with a secondary system is problematic. PHMB IS NOT compatible with CHLORINE or bromine. POOLS using PHMB have a serious treatment dilemma for control of Cryptosporidium after a suspected outbreak or even a diarrheal fecal accident. The addition of a 3 PPM (mg/L) of CHLORINE to a properly maintained PHMB-treated POOL results in the precipitation of the PHMB as a sticky mass on the POOL surfaces and in the filter. Removal of the precipitated material can be labor intensive. Testing for PHMB requires special test kits. Conventional kits for halogens are not suitable. PHMB test kits are readily available at most specialty retail POOL stores and on-line. Hydrogen Peroxide Hydrogen peroxide is not registered by the U.S. EPA as a disinfectant for recreational water. Since it is not registered, the use of hydrogen peroxide as a recreational water disinfectant, or any market claims that implies hydrogen peroxide provides any biological control in recreational water is a violation of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). Hydrogen peroxide has been granted registration by the U.S. EPA as a hard surface disinfectant and several other applications. The U.S. EPA Registration Eligibility Document (RED) on hydrogen peroxide is available from the EPA website at www.epa.gov/oppsrrd1/REDs/old_reds/peroxy_compounds.pdf. The U.S. EPA posts PDF copies of accepted product labels on the National Pesticide Information Retrieval System website (http://ppis.ceris.purdue.edu/#.) Product claims for uses and concentration may be verified by reading the PDF of the U.S. EPA stamped and accepted copy of the product use directions at this website. When used as a hard surface disinfectant, hydrogen peroxide is normally used at around 3%. When used in recreational water, hydrogen peroxide is used at 27 to 100 ppm (mg/L), which is 1111 and 300 times, respectively, more dilute than that used on hard surfaces. Borgmann-Strahsen evaluated the antimicrobial properties of hydrogen peroxide at 80 and 150 ppm (mg/L) in simulated POOL conditions.³⁷⁴ Whether 150 ppm (mg/L) of hydrogen peroxide was used by itself or in combination with 24 ppb of silver nitrate it had negligible killing power against Pseudomonas aeruginosa, E. coli. Staphylococcus aureus, Legionella pneumophila or Candida albicans, even with a 30 minute contact period. In the same tests, the sodium hypochlorite controls displayed typical kill patterns widely reported in literature. Borgmann-Strahsen concluded that hydrogen peroxide, with or without the addition of silver ions, was, “no real alternative to chlorine-based disinfection of swimming pool water from the microbiological point of view.”