I read the comments documents provided and determined whether or not they were a match to the main points I raised about the EPA draft lab protocol for assessing antimicrobial potency of copper- and copper-alloy surfaces.  Briefly, I and some of these commenters focused on the issue of needing a lab method to measure continuous potency (the current method revision does not address this).  With regards to the abrasive testing part of the protocol, I can agree with the substitution of a quaternary ammonium compound for the EDTA-phosphoric acid, but I do question the labor-intensive and time-intensive aspects of this part of the protocol.  Two of the reviewers conducted the highly detailed critique of the protocol, raising good questions.  From the information and directives provided to me, I didn't apply that level of scrutiny but rather focused on addressing the general questions posed to us.

Basically, I'll stick with the vast majority of my original comments with the departures noted above and in the attached document.

Best regards,
Lynne
