As a member of the public, anyone may choose to use hand sanitisers and surface disinfectants for your own and your family’s protection at home or elsewhere during the coronavirus outbreak. As an employer, you may also choose to provide hand sanitiser and surface disinfectants for your workers or others to use. These are biocidal products and are regulated by HSE. Whether you are a member of the public or also an employer, you should ensure that the products you use are suitable.
How hand sanitisers and surface disinfectants are regulated
Biocidal products, such as hand sanitisers and surface disinfectants, are beginning to be regulated in the UK under the Biocidal Products Regulation (BPR) to make sure that when they are used properly, they do not harm people, pets or the wider environment. BPR will require that both biocidal products and the active substances they contain have to be assessed and authorised or approved before they can be supplied and used.
Active substances (the ingredients that have the controlling effect on the harmful organism, such as bacteria) are currently undergoing a review process under the BPR, to assess their potential risks to people and the wider environment.
Once a review is completed and an active substance is approved, each individual product based on that active substance is then also assessed for authorisation under the regulations. However, until an active substance completes that review process, HSE does not carry out an assessment of the efficacy or risks from individual disinfectant products as they are not yet fully regulated under BPR.
Identifying suitable products
To find out which hand sanitiser and surface disinfectant products are suitable for your needs during the coronavirus outbreak, the HSEdatabase of authorised products might be a good place to start. Here you can find information about hand sanitiser and surface disinfectants products that have been authorised under BPR in the UK.
The database also contains information about hand sanitiser products that are using the Critical Situation Permit issued by HSE under Article 55(1) of the BPR for the WHO-specified formulation based on propan-2-ol or have been issued with their own permit for a different formulation.
Product manufacturers are responsible for ensuring that their products are suitably efficacious, including meeting any necessary testing standards, so it is recommended that you discuss your requirements with product manufacturers to determine if a product meets your needs.
Product manufacturers are also responsible for providing information and instructions for the user on the product label. You must always make sure that you read and understand the label before using a product and follow the label instructions carefully to ensure that you are using the product safely and effectively.
If a product does not appear on the HSE database, this does not necessarily mean it should not be used. The active substance could still be undergoing review and therefore products based on that active substance would not yet require authorisation. For example, ethanol, which is used in many hand sanitiser products, has not yet finished the review process. Therefore, ethanol products can continue to be used but they will not appear on the database as HSE will not have assessed or authorised them yet.
It remains the responsibility of the company supplying the product to maintain high levels of safety for the products they make available and to ensure their products are suitably effective. The product manufacturer or supplier named on the product label will be able to confirm if the active substance in their product has been supported for review under BPR and whether it has not yet finished that review process.
There is information about the supply and manufacture of hand sanitiser and surface disinfectants during the coronavirus outbreak.