We are writing regarding the article in the May 2009 issue of the Journal oj Environmental Health titled, "Efficacy of 'Green' Cleaning Products with Respect To Common Respiratory Viruses and Mold Growth," by Ed Light. The main premise of this paper, that green cleaning products should be evaluated as if they were disinfectants, is flawed. First of all, antimicrobial products are registered as pesticides under Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the U.S. Environmental Protection Agency does not currently allow third party organizations, such as Green Seal, to certify "green" or "safe" claims about pesticides. It is not surprising that Mr. Light found Green Seal-approved products that "do not claim antimicrobial capability." The previous version of Green Seal's GS-37 standard, which Mr. Light references in his paper, stated in the definitions for general purpose, carpet, and glass cleaners, "This category does not include any products required to be registered under FIFRA, such as those making claims as sterilizers, disinfectants, or sanitizers." The current version of the GS-37 standard, released in August 2008, states in its scope: "The standard does not apply to ... enzymatic or microbially active products, or products required to be registered under the Federal Insecticide, Fungicide, and Rodenticide Act, such as those making claims as sterilizers, disinfectants, or sanitizers." We think this is quite clearly stated and should have raised a red flag among those reviewing the manuscript prior to publication. Secondly, cleaning and disinfecting are not the same thing. Proper (and effective) disinfection takes place only after thorough cleaning. For example, New York State's Office of General Services states it very clearly in their Guidelines and Specifications for the Procurement and Use of Environmentally Sensitive Cleaning and Maintenance Products for all Public and Nonpublic Elementary Schools: "Clean first, then disinfect or sanitize only when and where necessary Surfaces must be cleaned thoroughly, whether or not disinfectants are used." In addition, the Centers for Disease Control and Prevention (CDC) states in its Guideline for Disinfection and Sterilization in Healthcare Facilities, 2008: "Because maximum effectiveness from disinfection and sterilization results from first cleaning and removing organic and inorganic materials, this document also reviews cleaning methods." Many of the ingredients found in disinfectants are hazardous to health. Some are known to cause asthma, a health endpoint for which there is usually no known exposure threshold, in which case OSHA-permissible exposure limits are not protective. Therefore, limiting the use of disinfectants to only when they are necessary and finding the least toxic alternatives among disinfectants are essential exposure prevention strategies. In addition, finding the least toxic alternatives among general cleaners is also desirable to protect health. Unfortunately, there are many unregulated "green" claims being made to sell cleaning products. One way that consumers, including employers, can find safer alternatives is to seek out products that have been certified by thirdparty organizations that issue openly published standards. As an example, criteria for GS-37 certification include a prohibition of ingredients known to cause allergic-type asthma, toxicity and corrosivity limits, limits on ingredients that can cause indoor air pollution, and limits on chemicals that can be absorbed through the skin. These are valuable and relevant attributes to consider in choosing products. This paper would have been useful had it compared antimicrobial pesticides to each other or compared "green" versus conventional cleaners. Because it takes the illogical leap, however, of evaluating green cleaning products for something that they very clearly are not designed to do, it confuses the consumer, adds nothing valuable to the discussion about cleaning products and practices, and, worst of all, may increase the number of unnecessary hazardous chemical exposures.