Cleaning up our disinfectants: usage of antimicrobial biocides in direct-to-consumer products in Australia
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In supermarkets and chemists worldwide, consumers are faced with an array of antimicrobial domestic cleaning and personal hygiene products purporting to kill germs and keep people safe. Many of these proven active ingredients (biocides) encourage the development of antimicrobial resistance (AMR) in microbes and microbial populations, in turn increasing the likelihood of AMR infections. In order to understand and address the selective pressure towards AMR posed by the unrestricted use of biocides, it is necessary to understand which biocides are most frequently found in consumer products and the current regulatory framework that governs their use. In this research we survey the biocidal active ingredients in the major categories of cleaning and personal care products available from supermarkets and pharmacies in Australia, and comment on the regulations that dictate how these products are tested and marketed. Benzalkonium chloride and ethanol were the two most prevalent antimicrobial biocides in this study, while triclosan, which is banned in several jurisdictions, was found in a small number of products. In Australia, many antimicrobial consumer products are regulated for efficacy and safety under the Therapeutic Goods Act, but the potential to drive microbial adaptation and AMR is not considered. Overall this survey underscores the broad use and light regulation of antimicrobial biocides in products available to the general public in Australia, and provides an information resource to inform further research and stewardship efforts.
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Thank you for taking onboard the comments from reviewers, I hope you found them useful. We are now happy to accept this version of your manuscript with associated data as Supplementary Material.
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Comments to Author
Dear author, This manuscript presents an important study describing the variety of biocides in consumer products available in Australia, and makes some very important discussion points. Overall, i think this manuscript is certainly worthy of publication following some amendments that might help make the paper a little easier to follow. Please find comments/suggestions below: Introduction L51 - you describe that biocides have been included in a number of products - can you describe why? Whilst their use needs to be carefully considered, they do provide benefits to consumers (increase shelf life etc). Figure 1 - 'Manufacture' in the top left corner should probably say 'Manufacture of biocides' or something more specific? L100 - 'in what context they are being used' - can you clarify that this is from a …
Comments to Author
Dear author, This manuscript presents an important study describing the variety of biocides in consumer products available in Australia, and makes some very important discussion points. Overall, i think this manuscript is certainly worthy of publication following some amendments that might help make the paper a little easier to follow. Please find comments/suggestions below: Introduction L51 - you describe that biocides have been included in a number of products - can you describe why? Whilst their use needs to be carefully considered, they do provide benefits to consumers (increase shelf life etc). Figure 1 - 'Manufacture' in the top left corner should probably say 'Manufacture of biocides' or something more specific? L100 - 'in what context they are being used' - can you clarify that this is from a consumer product point of view? For example you are not studying the inclusion of biocides in paint cans. L103 - you describe the most frequent biocides in surface and laundry products - where is this? globally? Australia? L108 - in this sentence you mention the US banning triclosan amongst others, could you mention in the introduction other international regulatory processes? You describe the EU Biocidal products regulation (BPR) in the discussion, perhaps allude to it here? Methods Overall comment - can you make the methods easier to follow. Its a bit vague in places, and its difficult to understand exactly what happened. A particular point here is what exactly you were assessing? Products that were known to contain biocides? or products in the catagories you describe (wipes etc) that may or may not contain biocides? L116 - you say that you look at websites, but you dont say why! L118 - consumer products most likely to contain biocides - how was this defined? Was this author knowledge or is there a list of these somewhere? L123 - why have you excluded ear drops? Why not include the 5 products? L124 - line starting 'The consumer products...' can be removed - repetition in the next sentence L134 - Paraben cosmetic preservatives removed from analysis - why? What about other cosmetics? L134 - 'Up to 4 antimicrobial additives were recorded for each product' - was this the max? it may read like some had more than 4 and you arbitrarily cut off at 4? L140 - 'Some consumer products were accessed...' - move to part of methods describing searching websites L142 - The searching of the regulatory info should be its own seperate section of methods - not tacked onto the end here. Its a very important part of your manuscript. Perhaps consider two subheading under Methods - (i) review of biocides and (ii) understanding the regulation (or something to that effect) Results L146 - what is meant by non-redundant biocide-containing products? Figure 2 - can we have the n= for each of them? either on the figure or in the caption text? L161 - this is confusing and vague. Can you be really specific. The first sentence reads like 8 catagories of cleaning and hygiene products (when in fact there was 6 and 8 catagories of biocides). Be really specific when describing the elements of data. L171 - what is a smaller product category? L240 - out of interest, did you find any antibiofilm claims? might be interesting to note even if the answer is no. L305 - im not sure stating that the use of biocides was previously unknown, perhaps previously not assessed and available in one location? L346 - there is an extra space after QAC that needs removing.
Please rate the manuscript for methodological rigour
Good
Please rate the quality of the presentation and structure of the manuscript
Good
To what extent are the conclusions supported by the data?
Strongly support
Do you have any concerns of possible image manipulation, plagiarism or any other unethical practices?
No
Is there a potential financial or other conflict of interest between yourself and the author(s)?
No
If this manuscript involves human and/or animal work, have the subjects been treated in an ethical manner and the authors complied with the appropriate guidelines?
Yes
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Comments to Author
The authors outline the current use of biocides in consumer products in an Australian context, stating the need for additional care due to biocide resistance and cross-resistance. Additionally, the current framework of regulation surrounding biocide use in Australia is explored with recommendations for updates and provides a foundation for further research. While the methodological analysis, presentation of results and drawn conclusions appear to be consistent, scientifically sound, and easy to understand, a number of comments should be addressed before a recommendation for publication can be made: Line 54-55: While biocide use can indeed cause resistance and cross-resistance, in some settings it has been shown that the concentrations aren't high enough to induce a stress response from the …
Comments to Author
The authors outline the current use of biocides in consumer products in an Australian context, stating the need for additional care due to biocide resistance and cross-resistance. Additionally, the current framework of regulation surrounding biocide use in Australia is explored with recommendations for updates and provides a foundation for further research. While the methodological analysis, presentation of results and drawn conclusions appear to be consistent, scientifically sound, and easy to understand, a number of comments should be addressed before a recommendation for publication can be made: Line 54-55: While biocide use can indeed cause resistance and cross-resistance, in some settings it has been shown that the concentrations aren't high enough to induce a stress response from the microorganisms (as stated in Abbood, Hijazi and Gould, 2023). It is of benefit to form a rounded view of the literature here and/or specify the context of the sentence. Line 58: While it is clear the $ is referring to AUD, it would be preferable to specify. Line 58: ."The five most common AMR pathogens", please specify them. Additionally, the ESKAPE pathogens are considered to be those of particular concern surrounding AMR, it is recommended to include these in the introduction. Lines 65-68, 80-82: There is no mention throughout the paper of the effects of bioaccumulation on AMR development in the environment despite the claim here that AMR development occurs in the environment (additionally stated in Figure 1). The authors claim that environmental concentrations of biocide through wastewater is sufficient, whereas Chukwu et al 2023 state that environmental concentrations of antibiotics and biocide is not sufficient to induce a stress response in E. coli. Bengtsson-Palme et al also attributes bioaccumulation as a factor in resistance development. Line 71: What is the specific efflux system? Figure 1: Although it becomes clear throughout the paper that an agricultural and industrial context is not within the scope of this work, the use of the word "commercial" and the lack of explicit statements of scope before this point lead to the belief that Figure 1 was stating the only possibility of biocides reaching the environment is through drainage systems. Either a greater clarity of the figure or statements of scope specifically excluding agriculture and industry (possibly in the figure caption) at or before this point is required. Line 116- Which supermarkets and pharmacies were explored? Line 134- Why is it only a maximum of four antimicrobial additives per product? No change to the manuscript is required if a justifiable reason is stated. Line 267-280: This paragraph outlines the claims relating to antimicrobial activity, but there is no mention of any of the actual standards (i.e., ISO, ASTM, etc) or lack there of that have been used to generate these claims. Line 317-320: While it is fair that the concentrations of biocidal components in some products cannot be accessed, it would still be interesting and informative to the reader to include whether the concentrations used in the products that were listed are high enough to induce a stress response and/or be sub-inhibitory, with appropriate literature to support this. Line 341-346: It may be interesting (but not required) to add here that QACs were once thought to be impervious to AMR build-up, which may have led to their widespread use. Line 378: Is a 3-log reduction (99.9%) considered "low-level", this seems like a significant reduction. It may be more appropriate to phrase it as "Since broad claims of antibacterial activity…". Line 403: The EU/GB has an Article 95 list of all approved biocides. Is this the case with the TGA and is this recommendation of the authors to opt for an EU like framework based around this idea? General: There are many comments throughout the paper listing specific claims of biocidal activity. However, there's no references to any actual standards that are being used or that are required by the TGA to approve a potential biocide. It would be of great benefit to the reader to understand the methodological processes currently in place and whether these are insufficient to address the needs of biocide approval in Australia in order to build the necessary foundations for meaningful change to the regulation.
Please rate the manuscript for methodological rigour
Very good
Please rate the quality of the presentation and structure of the manuscript
Good
To what extent are the conclusions supported by the data?
Strongly support
Do you have any concerns of possible image manipulation, plagiarism or any other unethical practices?
No
Is there a potential financial or other conflict of interest between yourself and the author(s)?
No
If this manuscript involves human and/or animal work, have the subjects been treated in an ethical manner and the authors complied with the appropriate guidelines?
Yes
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