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Response of Antimicrobial Regulators in the United States to the COVID-19 Pandemic

Seth Goldberg


The COVID-19 pandemic has challenged industry and regulators to ensure that adequate supplies of effective antimicrobial products for use on environmental surfaces and as skin sanitizers remain readily available to the public in times of unprecedented supply chain disruption. Regulators around the globe have responded by facilitating the authorization and distribution of antimicrobial supplies, while at the same time, ensuring that the safety and efficacy of these products remains a priority – consistent with national rules. While manufacturers typically supply to many jurisdictions, the regulatory requirements in each jurisdiction may differ. These differences necessarily affect the types of raw materials and finished formulations that may be manufactured, as well as how these products may lawfully be made available for sale and distribution. In the United States (U.S.), for example, the Environmental Protection Agency (EPA) and the Food and Drug Administration (FDA) coordinate to ensure that adequate supplies of environmental and dermal antimicrobials remain available. Policy decisions made early in the course of the pandemic by both agencies ensured that manufacturers and distributors were able to adapt to rapidly changing consumer demand patterns while continuing to ensure safety.

Seth Goldberg is a Washington D.C.-based partner in Steptoe & Johnson LLP and Co-Chair of its Chemicals and Life Sciences Practice. His practice focuses on pesticide and chemical regulation, with a particular focus on antimicrobials. E-mail:


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