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Volume XI, Number 269

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US EPA Issues Best Practices for Cleaning and Disinfecting Public Spaces, Workplaces, Businesses, Schools and Homes

On April 29, 2020, US EPA and the CDC issued guidance on how best to disinfect and clean workplaces, schools, and other public spaces as the US economy begins to re-open during the COVID-19 pandemic. The guidance, mainly directed to employers, facility managers, and public school officials, is part of the larger federal “Guidelines for Opening Up America Again.” However, EPA adds that this particular guidance can be applied to individuals’ households as well.

In the guidance, US EPA outlines three main steps for success and the corresponding best practices:

  • Develop Your Plan

    • Determine what needs to be cleaned

    • Determine how areas will be disinfected

    • Consider the resources and equipment needed

  • Implement Your Plan

    • Clean visibly dirty surfaces with soap and water prior to disinfecting

    • Use the appropriate cleaning or disinfectant product

    • Always follow the directions on the label

  • Maintain and Revise Your Plan

    • Continue routine cleaning and disinfection

    • Maintain safe practices

    • Continue practices that reduce the potential for exposure

In more detail, US EPA then outlines the resources it has developed over the last few months, including its list of approved disinfectants (discussed here), along with the current science on the effectiveness or need for certain cleaning practices. EPA ultimately recommends following the CDC’s guidelines on cleaning particular surfaces, but offers some specific recommendations. For example, US EPA proposes alternatives to using approved disinfectants, such as a 1/3 cup to 1 gallon bleach-water solution. EPA also discusses the need to keep certain outdoor areas clean, such as school playgrounds versus the lack of a need to disinfect pools or hot tubs already treated with chlorine or bromine.

Notably, for facilities or schools that have been completely unoccupied for 7 days or more, US EPA recommends normal cleaning routines because the virus has been shown to not survive on surfaces longer than that timeframe. Moreover, while EPA claims there is no need to clean ventilation systems, regularly-used hard surfaces should be routinely cleaned / disinfected (toys at schools, seating, desks, computers, doorknobs, light switches, toilets, etc.). Conversely, carpets or soft surfaces at offices that are not regularly touched should be normally cleaned, while other soft materials like clothing, uniforms, seating cushions, etc. should be laundered using the appropriate warmest setting.

US EPA also sets out some general reminders:

  • Coronaviruses on surfaces and objects naturally die within hours to days. Warmer temperatures and exposure to sunlight will reduce the time the virus survives on surfaces and objects. . . .

  • Normal routine cleaning with soap and water removes germs and dirt from surfaces. It lowers the risk of spreading COVID-19 infection.

  • Disinfectants kill germs on surfaces. By killing germs on a surface after cleaning, you can further lower the risk of spreading infection.

  • Store and use disinfectants in a responsible and appropriate manner according to the label. Do not mix bleach or other cleaning and disinfection products together–this can cause fumes that may be very dangerous to breathe in. Keep all disinfectants out of the reach of children.

  • Do not overuse or stockpile disinfectants or other supplies. This can result in shortages of appropriate products for others to use in critical situations.

  • Always wear gloves appropriate for the chemicals being used when you are cleaning and disinfecting. Additional personal protective equipment (PPE) may be needed based on setting and product.

  • Practice social distancing, wear facial coverings, and follow proper prevention hygiene, such as washing your hands frequently and using alcohol-based (at least 60% alcohol) hand sanitizer when soap and water are not available.

Finally, US EPA lines out all of its and the CDC’s resources and interim guidance geared towards specific facilities, including healthcare settings, schools, universities, community organizations, businesses, restaurants, and mass transit (such as buses or airplanes). It will be important for businesses in these identified sectors to refer to this specific interim guidance as well.

Though not expressly required in this guidance, it seems that EPA and the CDC are urging employers, schools, and other owners/operators to document such best practices in a comprehensive plan and/or communicate that plan clearly to employees or staff. This mirrors prior CDC and OSHA guidance to conduct hazard assessments, implement infections disease and preparedness and response plans, and to clearly communicate COVID-19 policies and procedures and train employees on the same. Ultimately, while individual states either have already or will likely provide guidelines on this topic as well, following these US EPA best practices will help ensure that businesses and workplaces operating in multiple jurisdictions can be prepared for a smooth re-opening.

© Copyright 2021 Squire Patton Boggs (US) LLPNational Law Review, Volume X, Number 129
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About this Author

Danelle Gagliardi Environmental Attorney Squire Patton Boggs Columbus, OH
Associate

Danelle Gagliardi represents a wide variety of clients in complex environmental transactions, litigation and regulatory compliance, including those in the metals, mining, iron and steel, oil and chemical industries, as well as real estate developers and shipping and logistics companies. She has a strong background in the Clean Air Act (CAA), Clean Water Act (CWA), Toxics Substances Control Act (TSCA), Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) and California’s Proposition 65 (Prop 65).

Danelle has a multistate, global practice involving all aspects...

614-365-2820
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