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Issues related to formulation/use of product

As far as the products themselves are concerned, a number of issues have become apparent. Somewhat related to the issue of reliable taxonomic designation mentioned above is the issue of consistency in quality control (QC) and quality assurance (QA) methods applied during the production of the micro-organisms and/or the end products. There are indications from previous studies (Spok and Klade, 2009), as well as from past experiences of the New Substances Program in Canada, that there is a wide variation in how QC/QA methods are applied in the production of these products. This includes procedures in place to monitor for potential contaminants. Currently, no broadly recognised standards for the QC and QA of cleaning products exist. However, in Canada, the EcoLogo Program, a voluntary third-party certification programme for environmentally preferable products, requires that all biologically based cleaning and degreasing products be manufactured in a facility that has a documented QC/QA system (EcoLogo, 2011).

As well, there are currently no regulatory requirements for specifically identifying microbial ingredients in these products in Canada. Since many of these types of products appear to be imported into Canada, and because the active ingredients are very often considered confidential business information, importers, distributors and end users very often do not know what micro-organisms are present in these products. There also do not appear to be any specific labelling requirements for these products in the European Union or in the United States. However, as of April 2011, the United States Environmental Protection Agency’s voluntary programme “Design for the Environment” requires that all non-trade secret ingredients be listed for all products that carry the Design for the Environment label, including cleaning products. Non-trade secret ingredients also need to be described as specifically as possible without revealing trade secret information (United States Environmental Protection Agency, 2011).

Considering the way in which microbial-based cleaning products would typically be used, human exposure to the micro-organisms contained within them is likely to some extent. Dermal exposure is the most obvious route; however, spray applications and powders can create aerosols leading to inhalational exposure as well. To a lesser extent, oral ingestion may also be possible, particularly if these products are applied anywhere near surfaces used for food preparation. Long-term exposures may also be possible since many of these products appear to contain spores that can remain viable for long periods of time. All of these exposures may also be enhanced by the fact that many of these products will be used in indoor settings where proper ventilation may not always be in place. There currently appears to be a significant lack of information in the scientific literature on the nature and magnitude of potential human exposures to micro-organisms through their use in these products, thus making any attempt to more precisely assess human health risks from such products somewhat difficult.

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