Dear Jessica Zeigler,
As per George, I can see no mention of “shall” regarding use of hot water for process cleaning in FDA Food Code. Other national regulations could depend on context, eg product.
SQF code7.1 seemingly not mandatory for process, text below is repeated multiply –
220.127.116.11 Supplies of hot and cold water shall be provided as required to enable the effective cleaning of the premises and equipment.
However hot water is mandated for lunch rooms in Code 7.1.
And, typically confusedly for SQF, their guidance manual for Code 7.1 states -
For small items of equipment such as tools, knives, tubs, cutting boards, etc., a wash area shall be provided with sufficient hot and cold running water, a suitable detergent and sanitizer for cleaning and when necessary, suitable racks for draining/drying equipment, utensils, and protective clothing. These areas shall be identified
Only SQF know the whole story perhaps.
Further, as already noted, specific regulations for yr locality / product / process may apply. No data supplied in OP to comment on this.
Rgds / Charles.C