Item No. 4: Table 4 lists two germicides that essentially have been banned or restricted since the 1970s: mercuric chloride, an environmental hazard, and hexachlorophene, a toxic antiseptic. The listing of these toxicants, even as informational material, should include a statement of their restricted status, lest someone in the future ascribe USP sanction to these agents. Better examples are available. Furthermore, mercurials are cited as attacking either "-SH groups" or "thiol" groups, but they are both the same. Any compound that contains a functional group consisting of a sulfur and hydrogen atom (R-SH) traditionally is known as mercaptan.

Item No. 5: Chapter ‹1072› in the section entitled "Theoretical Discussion of Disinfectant Activity" presents an intriguing but, in context, useless series of mathematical equations for the purpose of "... picking the use-dilution of different disinfectants." In legal and regulatory terms, the use-dilution is simply what the Environmental Protection Agency allows on the label after a manufacturer provides data or whatever the user decides to use based on in-house experiments with organisms isolated in the plant. Q-10 values, rate constants, and discussions of first-order reactions and linear or sigmoid plots are not required to sanitize, disinfect, or sterilize a pharmaceutical plant.

USP has at its service some of the finest microbiologists and chemists in the world. It has been honored by the scientific, regulatory, and legal communities. These comments on the work of a single chapter are not meant to diminish the classic writing in the chapters about sterility, antibiotics, microbial limits, or any others. We merely point out a series of questionable scientific statements in a USP chapter that reflect a proofreading or revision process that requires adjustment and that, if not corrected, could lead to serious problems in the future. There is an old saying: "What you tolerate becomes your standard." USP must not allow incorrect or misleading statements to become its standard.

*To whom all correspondence should be addressed.

Reference

1. United States Pharmacopeia 29—National Formulary 24, Chapter ‹1072› (US Pharmacopeial Convention, Rockville, MD, 2006).