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Ethanol for surface cleaning?


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Thanks to all the hard work we've all been doing over the past month, I'm starting to see hand sanitizer reach its saturation point. However, the product I've found to be in demand now is ethanol that can be used for sanitizing surfaces. I've been getting quite a few requests lately. I understand that packaging ethanol and labeling it for surfaces makes it a pesticide and requires EPA approval. Has the EPA or another federal agency removed any of the roadblocks that currently prevent us from doing this? I saw a document recently that talked about labeling denatured spirits - I thought it was one of the FDA advisory documents but I don't see it now. Can we just denature ethanol with the 40B formula and bottle it up in jugs?

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On 5/2/2020 at 12:58 PM, CalwiseSpirits said:

Thanks to all the hard work we've all been doing over the past month, I'm starting to see hand sanitizer reach its saturation point. However, the product I've found to be in demand now is ethanol that can be used for sanitizing surfaces. I've been getting quite a few requests lately. I understand that packaging ethanol and labeling it for surfaces makes it a pesticide and requires EPA approval. Has the EPA or another federal agency removed any of the roadblocks that currently prevent us from doing this? I saw a document recently that talked about labeling denatured spirits - I thought it was one of the FDA advisory documents but I don't see it now. Can we just denature ethanol with the 40B formula and bottle it up in jugs?

Another option you might consider:

Submit for a new TTB label with minimal info for 140 proof neutral spirits (labels are going very quick these days).  Bottle the 140 proof and pay the excise tax (excise tax is cheap enough at the moment to be a minimal factor in pricing).  Let people know its basically very strong, very bad vodka, but what they do with it is their decision.  Point them to the following info from the CDC:

The US Centers for Disease Control and Prevention recommends daily disinfection for frequently touched surfaces such as tables, doorknobs, light switches, countertops, handles, desks, phones, keyboards, toilets, faucets, and sinks. The CDC also recommends the use of detergent or soap and water on dirty surfaces prior to disinfection. Solutions of 70% alcohol should ideally be left on surfaces for 30 seconds. Containers of 70% alcohol should be sealed to prevent evaporation. But unlike bleach solutions, they will remain potent as long as they are sealed between uses. A 70% alcohol solution with water will be very harsh on your hands and should not be used as a substitute for handwashing and/or hand sanitizer. 

 

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We have also identified this need because our hand sani is being used to spray disinfect ambulances, I got to thinking what a waste of glycerine. Anyways surface disinfectants are regulated by the EPA and they are being much more stringent than the FDA was w sani. We are working with a legal team and a lab to develop a formula that in an emergency could be made by proper permit holders. But legally you don’t have the right or permission to manufacture at this time. 

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as for a packaged product: Marketing is going to be your downfall here. You are welcome to sell an alcohol based solution at 70% or 80% concentration (I think in all states but maybe not at least mine yes) but legally, that is not a registered sanitizer product with the EPA (who regulates all pesticides, which sanitizing sprays fall under the purview of). However you are not legally allowed to tell people it can be used as a sanitizer because it is not registered, even if you are making an approved formula that someone else owns and is literally just alcohol and water at the approbate concentration (even if it is infact adequate for killing the corona virus or stronger viruses). Without you yourself getting your product with your formula and your data approved by the FDA in order to be an approved manufacturer of that registered product you are in violation US law if you tell anyone that product is a surface disinfectant. 

 

I am not telling you that this isn't a need or that the above isn't ridiculous. But I am telling you the legal opinion of multiple super high powered corporate attorneys. if you have any questions let me know, otherwise I will update once we get further along on our project. We are trying to get this done for all of us, idk wtf DISCUS or ACSA hasn't advocated more for this yet but it looks like we may be getting a reasonable path to expedited approval done, which is a big win in comparison to the current reality.

 

 

Dr 😧Ambulance ran out of rural fire department in WI. We found out about their use after they had already done it. Using a denatured product for what they are doing has complications, as well the application of topical sanitizer is wasteful not only of ingredients because of the nature of the products use but from the standard point of volume, which is why they use foamers for exterior surface cleaning of equipment in many industries. Foams stick where you apply them to maintain action over needs amount of time, liquids run off and pool else where. 

These are wild times, but at some point in time we all have to agree it is an undue burden to expect distilleries to supply sanitizing products for free to big business for profit hospitals regardless of their situation. This hospitols have huge operating budgets and payment for raws keeps the supply chain active and intact.For isntance: we are able to provide free buckets of sanitizer to every first responders who contacts us because we are selling consistently large scale weekly orders for the same corporations; but if we didn't have that and we pussy footed about getting our costs covered, we would have ended up donating in magnitudes of less. Thousands of gallons of finished product vs maybe dozens of gallons? Charging honest and moderate prices for ingredients/overhead also helps control market gouging, and can keep us as an industry from going out of business. "Yeah I could've donated a barrel of ETOH to this hospital, which is for profit and not inundated with cases. Or, I can sell them the alcohol for a moderate profit knowing full and well hand sanitizer is a regular operating expense for them, and take that cash and make more finished sanitizer to donate to every independent nursing home that calls. To every fire station that calls. To every ambulance operator. To (insert great cause here).

 

Sorry I'll get off my soap box. Hope everyone is staying in biz!

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Mostly for the sake of argument....  

 

16 hours ago, SlickFloss said:

as for a packaged product: Marketing is going to be your downfall here.

If like the original poster mentioned they are receiving requests, then there is no need for marketing.  People call or email asking for alcohol for disinfecting; you reply that you have 140 proof beverage alcohol that you have an approved TTB beverage alcohol label and that you have paid the federal excise tax on.  "Its 70% alcohol and 30% water; is that what you want to buy from me?"

Its a product that we are legally allowed to sell (high strength beverage alcohol) that is materially the same as a product we are not allowed to sell (denatured disinfecting alcohol solution).

17 hours ago, SlickFloss said:

However you are not legally allowed to tell people it can be used as a sanitizer because it is not registered, even if you are making an approved formula that someone else owns and is literally just alcohol and water at the approbate concentration

So is it only illegal for someone selling 70% beverage alcohol to say it could be used as a surface disinfectant, or is it illegal for everyone to say that? :)

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10 hours ago, HedgeBird said:

Mostly for the sake of argument....  

 

If like the original poster mentioned they are receiving requests, then there is no need for marketing.  People call or email asking for alcohol for disinfecting; you reply that you have 140 proof beverage alcohol that you have an approved TTB beverage alcohol label and that you have paid the federal excise tax on.  "Its 70% alcohol and 30% water; is that what you want to buy from me?"

Its a product that we are legally allowed to sell (high strength beverage alcohol) that is materially the same as a product we are not allowed to sell (denatured disinfecting alcohol solution).

So is it only illegal for someone selling 70% beverage alcohol to say it could be used as a surface disinfectant, or is it illegal for everyone to say that? :)

 

10 hours ago, HedgeBird said:

Mostly for the sake of argument....  

 

If like the original poster mentioned they are receiving requests, then there is no need for marketing.  People call or email asking for alcohol for disinfecting; you reply that you have 140 proof beverage alcohol that you have an approved TTB beverage alcohol label and that you have paid the federal excise tax on.  "Its% alcohol and 30% water; is that what you want to buy from me?"

Wink wink nudge nudges are what they are, questionable around the boundaries of regulations. I just pointed out the delineation of the regulation so to speak. Also said they could sell alcohol at that proof for sure 

10 hours ago, HedgeBird said:

Its a product that we are legally allowed to sell (high strength beverage alcohol) that is materially the same as a product we are not allowed to sell (denatured disinfecting alcohol solution).

I would like LOOSELY quote/paraphrase myself where I said “I I am not telling you .... this isn’t ridiculous” In case t wasn’t clear this was a reference to this technical foul. 

10 hours ago, HedgeBird said:

So is it only illegal for someone selling 70% beverage alcohol to say it could be used as a surface disinfectant, or is it illegal for everyone to say that? :)

It’s illegal for anyone not approved by the epa to manufacture and distribute finished surface disinfecting sprays. As you and I both mentioned, he is likely able to sell alcohol at that proof. 

 

 

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  • 3 months later...

SlickFloss, any update on your disinfectant formula and registration effort?  

On 5/12/2020 at 6:03 PM, SlickFloss said:

if you have any questions let me know, otherwise I will update once we get further along on our project. We are trying to get this done for all of us, idk wtf DISCUS or ACSA hasn't advocated more for this yet but it looks like we may be getting a reasonable path to expedited approval done, which is a big win in comparison to the current reality.

 

 

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  • 1 month later...

Hi All,

I am also interested in making a Surface Disinfectant from GNS, I reached out to the EPA and they claim that it is a complicated process and they suggest we find a consultant to help us go threw this process,

Has anyone gone threw this process?

I would greatly appreciate if anyone has more info to shear regarding this matter, or if anyone can recommend us a consultant. 

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