It goes without saying that there is plenty of conjecture and disagreement in the disinfection arena. Disinfection or Sanitise? Clean surfaces or just mist it all?
Well I’ve done some preliminary research and taken a mini deep dive into how this could work for your business here are some key points:
1. Defining Your Service
Jay Turner recently highlighted a probable legal issue around the definitions applicable to different words like “Disinfection”, “Sanitise” and “Sterilise” and warned we should be careful about what we use and how.
It goes without saying that we should be across all of this and I would warn that we should not define our service as a “Disinfection Service” – at least not in any official way. In marketing law I have learned that we can use words that have broader meanings to consumers comfortably so having on your website or Facebook page that you are now offering ‘Disinfection Services’ is not something that would ordinarily end up in any trouble.
But you should, for an abundance of clarity, provide a well produced and defined service agreement of sorts – almost like a pre inspection agreement in the PPI world. This document should define what it is you are doing and perhaps it would be a good idea to remove any mention of “disinfection” and instead use “sanitise”.
I’d suggest that you use products with Therapeutic Goods Administration (TGA) approval. Any product that makes a claim to kill micro-organisms is regulated and subject to TGA approvals. See here for more info. This might offer you some protection against any claims you might make provided they are in line with label claims, that your procedures follow labels and so on.
You will want to scope your service with reasonable claims so perhaps you’ll say you are going to apply a disinfectant but you won’t say you’ll actually disinfect the place! You can probably say it kills viruses and bacteria as well as fungi etc – Be sure it’s on the label of your products thought and that your service procedures cover the prerequisites listed there. You could even say it’s non-toxic, environmentally friendly etc. These would be reasonable, justifiable claims.
DO NOT SAY you can disinfect / kill / control COVID-19!
Interestingly there is a way in which products manufacturers could make a claim – the TGA has issued an alert allowing products with surrogate claims for Human Coronavirus to be justified for claims against COVID-19 by surrogate. I DO NOT recommend you do this and I would, at minimum seek written confirmation of surrogate claims from the product manufacturer and confirmation the product is registered with the TGA.
You might position your service as a peace of mind, demand driven offering and while I’m confident there is strong demand for these services I would ensure that every potential customer signs a disclaimer. Be sure you don’t claim to be applying disinfectants to kill Coronavirus. The sample I produced is provided here – adapt to your needs.
2. Scoping Your Service
Once you have a solid understanding of what you want to actually offer to the consumer you’ll need to know what you’ll use and how you’ll use it, including the techniques, work practices, PPE and risk management considerations that go along with effecting the service. It’s not that different from pest control with LABEL IS THE LAW – apply the same thinking here.
Obviously this step is quite interchangeable with step 1. Perhaps you select a product and equipment first? Either way this should all be looked at holistically.
Select a product, examine it’s label for claims and assess if it is fit for purpose. Some popular products include: Netbiochem DSAM, DeoSan Plus, Forcefield, Steri-7 among others.
Your Standard Operating Procedure / Service Instructions will be very much determined by the products you choose to use. I have seen companies make claims consistent with claims made on product labels and I think it is reasonable to make those claims, especially if it’s TGA approved. Be sure your SOP’s cover all aspects relevant for all claims. Eg: Some labels require 30min no rinse or removal for full virus eliminating effect – if your SOP doesn’t allow this then don’t claim it kills viruses.
The label usually includes information about the surfaces that it can be safely used on – be sure your label supports the kinds of environments you are to work on. Another important factor in scoping a service is labelled requirements including:
- pre-cleaning advice, i.e. cleaning the surface to remove other contaminants or debris before applying the disinfectant;
- dilution of the product;
- the application method;
- contact time (how long the product needs to be on the surface being disinfected to inactivate or kill micro-organisms).
Assess the SDS and label for PPE requirements and then consider the risks beyond products (this bit isn’t like pest control) – should your staff be required to use disposable coveralls (tyvek etc), respirators etc?
Maybe you create a pre appointment requirement for the client to fully clean the property, especially high contact / frequently touched and other soiled areas.
This will all form part of your SOP – the how to for your technicians – so if there are prerequisite requirements there should be a check-list for a technician to use.
I would recommend that you base your SOP’s and overall service offering on the principles within the official government advice. In particular I quite like the Victorian Dept. Health guide that provides a much more reasonable guide to disinfectant use – unlike the Australian Gov guide which allows just bleach.
EDIT: Recently come across this guide out of the USA – well cited and offers some good ideas for developing a complete SOP. Be cautious that it is very USA based – CDC is not Australian and therefore products won’t be approved here!