[Editor’s Note: From time-to-time, we make a mistake. When we do, we like to admit it quickly, correct it, and then move on. Case in point, our recently published Fiscal Report article regarding the use of hand sanitizers which stated that “Senate Bill 1405 (Chapter 848/2014) required, beginning July 1, 2016, that local educational agencies (LEAs) using hand sanitizers must provide a one-hour training annually to employees.” That article has since been removed. According to the California Department of Pesticide Regulation, it is a common misconception that sanitizers regulated under the Environmental Protection Agency include hand sanitizers, which is not the case. School Services of California Inc. apologizes for contributing to this misconception.]
The California Department of Pesticide Regulation (CDPR) has clarified that under the law the term “sanitizers” has always meant surface sanitizers, not hand sanitizers. Sanitizer, in the context of Senate Bill 1405 (Chapter 848/2014), also known as the Healthy Schools Act, is an antimicrobial pesticide that sanitizes a surface. Antimicrobial pesticides are regulated by the Environmental Protection Agency (EPA). An easy way to determine if a product is an antimicrobial pesticide is to look for an EPA registration number on the label. If there is an EPA registration number, it is a pesticide.
Hand sanitizers do not have an EPA registration number. Hand sanitizers will include Drug Facts on the label because they are registered under the U.S. Food and Drug Administration. While the Healthy Schools Act requires annual training related to the use of sanitizers, it is specifically referring to surface sanitizers that are a registered antimicrobial pesticide. The CDPR has a useful Fact Sheet on this topic and the California Department of Education (CDE) provides guidance on its website on the use of hand sanitizers in California public schools.
In closing, the CDPH reports that the health risk to the general public in California from novel coronavirus (COVID-19) remains low, but schools can take common-sense precautions to prevent the spread of all infectious diseases. CDPH guidance on COVID-19 was sent to districts on February 7, 2020, and the CDE intends to provide more information to LEAs as it becomes available.