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#26 Charles.C

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Posted 14 April 2017 - 12:02 PM

Hi Sarah,

 

Equipment surfaces treated with quat are typically inert to quat/chemicals so that removal by rinsing is effective.

 

However shrimp may also significantly absorb quat if the floor concentration is high thereby causing the subsequent rinse procedure for the dropped-shrimp to be inadequate.

 

Above only speculative of course. The easiest way to check the situation is to simply analyse some dropped-shrimp for quat residues, before/after rinsing (and maybe the floor if the paper works on such a "mixed" surface). (I note that quat indicator paper is available for approx measurement).

 

PS - i think yr attachment failed. You need to click the "more reply options" at bottom right hand side and follow instructions botttom left hand side. A successful upload is shown by the file name appearing under the message box. Then use "add" to position anywhere in the message box.


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Charles.C


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#27 sarah2014

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Posted 14 April 2017 - 12:16 PM

I am not able to attach the file  


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#28 Charles.C

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Posted 14 April 2017 - 12:22 PM

I am not able to attach the file  

 

Is it a pdf or ? (a few formats will not work but most do)

 

(sometimes its ifsqn's fault but the system seems to be working OK at moment for me)(using non-basic uploader)


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Charles.C


#29 sarah2014

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Posted 14 April 2017 - 12:41 PM

LIVA AlphaChemical"

 

 

 

 

 

 

 

 

 

 

 

 

 

ALPHA FLOOR GUARD

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

UNIQUE BEADED FLOOR TREATMENT

IN/QUATERNARY AMMONIA

DESCRIPTION:

This product is designed for use in industrial and institutional facilities; including food processing plants, cold or cool rooms, doorways, fork lift traffic lanes, or dry storage warehouses. In contains a special cationic detergent to clean and deodor­ize floor surfaces. It is one of the most unique products of its kind, and will provide benefits 24 hours a day. ALPHA FLOOR GUARD will also prevent ice from form­ing on floors and decks, which will improve safety.

INSTRUCTIONS:

For light duty use 1-2 lbs per 100 sq ft. For heavy traffic areas use 2-3 lbs per 100 sq ft. ALPHA FLOOR GUARD can be used on wet or dry surfaces. Spread uniformly on floor or deck using broadcast method. The unique bead shape will prevent clumping. Reapply as necessary and allow to remain on floor. In traffic areas the beads will easily crush and will transfer to shoes and tires, which will actually increase the efficiency of the ALPHA FLOOR GUARD. Rinse off or squee­gee the floor AT LEAST once or twice weekly, and broadcast a new layer as needed. Food contact equipment should be rinsed with potable water if exposed.


r INN                                  MIN =MI                    VIIM MEM NM 1MM                                    C:=3

I Warning

Causes serious eye irritation. Causes skin irritation. Hygroscopic. Keep out of reach of children. Avoid contact with skin, eyes and clothing.

Read label before use. Keep away from children. Wash hands thoroughly after handling. Wear protective gloves, eye and face protection, Do not eat, drink or smoke when using this product.

First Aid

Specific Treatment (See Section 4 on the SOS),

IF IN EYES: Possible eye irritation. Flush immediately with large amounts of water for at least 15 minutes. Eyelids should be held away from the eyeball to ensure thorough rinsing. Get immediate medical attention.

IF ON SKIN: Possible skin irritation. Flush immediately with large amounts of water while removing contaminated clothing. Wash contaminated clothing before reuse.

IF INHALED: Possible nasal irritation. Remove exposed person from source of exposure to fresh air,

IF SWALLOWED: Drink copious amounts of water. Seek medical attention. Do not induce vomiting unless directed by medical personnel.

Compositional Information

Contains: Water (CAS# 7732-15-5); Urea (CAS# 57-13-6).

Tech Info

PREMIUM INSTITUTIONAL PRODUCTS

 

0

 

 

Beaded Floor Treatment

 

FLOOR GUARD is a highly unique floor treatment and cleaner that is designed to relieve concerns of cleanliness and cross contamination on floors in production rooms, cool rooms, freezers, cold storage areas, and anywhere there is foot or forklift traffic. The beads are air-dried and light density, and the weight of the shoe or tire will burst the bead, releasing the active ingredients and coating the tire or shoe. Floors may be wet or dry before addition of FLOOR GUARD, depending on the conditions of its intended use. However, FLOOR GUARD is completely water soluble and dissolvable, and leaves no particulate residue after rinsing.

The active ingredients are a dual chain quaternary ammonia. The balance of FLOOR GUARD ingredients are inert and classified Generally Recognized As Safe (GRAS status), in accordance with 21 CFR part 184. Registered by NSF, Reg. No. 122923-(P1).

For 'normal' or medium use applications broadcast the FLOOR GUARD at the rate of 0.5-2 lbs per 100 sq ft. of floor. In high traffic areas, such as forklift lanes, broadcast FLOOR GUARD either manually, or by using a hand-held mechanical spreader (which yields a more uniform application) at the rate of 2-3 lbs per 100 sq ft. of floor area. Reapply 1-3 times per week or as needed.

FORM:                                                     white beads

ODOR:                                                     very faint

pH (10%):                                                 9-10

PHOSPHORUS:                                       none

ACTIVES:                                                 quaternary mixture

BIODEGRADABLE:                                  yes

Caution.         Keep out of reach of children.                   Contains an

appreciable amount of quaternary ammonia.                      Harmful if
swallowed. Eye irritant.

25, 100 and 300 lb drums. Modesto, CA

 

 


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#30 Charles.C

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Posted 14 April 2017 - 01:38 PM

Hi Sarah,

 

OK, well-"received". Thks.

It's certainly an unusual product IMEX.

 

So, as predicted, there could be a "sizeable" level of quat present at any one time on the floor. Or not.

 

This (static) quat floor treatment seems fine from a purely floor POV but, IMO, renders the shrimp reconditioning option "problematic". However I am unfamiliar with quats/their restrictions so may be being over-critical. In a way, the situation is analogous to using chlorinated water for (semi-continuous) floor washing except that afaik quat residues in shrimp after rinsing will not disappear over time (?).

(I deduce yr auditor's acceptability of reconditioning was based solely on the shrimp rinsing procedure).

 

I guess it all depends on the significance (if any) of quat residues (if any) in the shrimp after rinsing.

Some data would be useful.

 

Hopefully there are some quat users here to offer their direct experience/further input.


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Charles.C


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#31 FurFarmandFork

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Posted 14 April 2017 - 02:40 PM

From the information you uploaded sarah 2014:

"Food contact equipment should be rinsed with potable water if exposed."

 

Therefore, this sanitizer is not approved for direct food contact as Charles has already covered. So your inspector has a legitimate (if nitpicky) point about you exposing your product to a chemical hazard, and for your procedure to be acceptable, you need to provide some validation data (again, as Charles covered) to demonstrate that residual quat on/in the product will not pose a hazard. If you cannot scientifically demonstrate that the chemical cannot transfer to individual shrimp in the worse case scenario (e.g. several pellets were squeegeed up and placed in your re-conditioning bucket with the shrimp and they soaked in the solution).

 

The alternative solution would be to treat your floor in the processing room with chemicals approved for direct food contact to eliminate that risk, then I think your before-mentioned micro risk assessment/verification tools and any foreign material policy will cover the associated risks.

 

Note, you've also mentioned that you've "never had a recall" a few times as a justification for current practices. I wouldn't use that defense with auditors or customers, it's pretty weak all things considered. Anyone on this forum would immediately be able to pull up dozens of examples of companies tied to outbreaks that included in their press releases "never in our history have we had a recall...", its a stats game, you haven't had a recall yet. And if your company doesn't sell direct to consumer, customer "complaints" don't hold much water either for something like this that may be sporadic and not associated with classical FB illness.


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For discussions related to food safety, production, and agriculture. Check out my blog at http://furfarmandfork.com/.

 


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#32 sarah2014

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Posted 14 April 2017 - 03:09 PM

Corrective action :

 

so how about I use a food contact sanitizer on the floor that we can rinse and every day I check the concentration of the quat .plus I wash the  shrimp that was on the floor with a chlorine water . what do you think ?

 

please guys help


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#33 Charles.C

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Posted 14 April 2017 - 04:39 PM

Hi Sarah,

 

3F's previous post well-summarised what i was struggling to explain. :thumbup:

i am a little puzzled inasmuch as the supplier's documentation implies  (to me) that (a) the product is not suitable for direct food contact, (b) the product is appropriate to be permanently resident on floors in a production environment.

 

Seems to me that (a,b) are potentially contradictory, as you may have now demonstrated with respect to the dropped-shrimp reconditioning procedure.

 

As a comparison, consider the quat sanitizer described in attached file which is approved for use on food contact surfaces with  "no rinse" but has some very specific operational features/limitations. It illustrates the sensitivity of this topic.

 

Attached File  quat(1) sanitizer.pdf   177.26KB   8 downloads

 

You may need to do some careful thinking as to the inspector's precise requirements so as to accept yr dropped-shrimp reconditioning. For example -

 

(1) will he/she accept the presence of the quat on the floor at all ?

(2) if No, the options are obviously clear.

(3) if yes, under what conditions, ie "what" is required to be satisfactorily validated ?. = Probably that which has been already discussed, ie no significant chemical hazard due to possible presence/contamination by quat. chemical.

 

so how about I use a food contact sanitizer on the floor that we can rinse and every day I check the concentration of the quat .plus I wash the  shrimp that was on the floor with a chlorine water . what do you think ?

 

2 comments/queries -

 

(a) Above assumes that (3) above is viable (?) in which case, IMO, you will still need some more info./data for validatory purposes. One operational snag is that by immediate rinsing you may be losing the benefit of using quat. on the floor ?. Still cost effective ?

 

(b) Is, presumably, low-chlorinated water (X-ppm) acceptable to the inspector ?

 

JFI, here is a bit more quat. info from a text on fruit/vegetable processing -

 

Attached File  some quat possibilities-limitations.pdf   126.02KB   11 downloads


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Charles.C


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#34 sarah2014

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Posted 17 April 2017 - 01:27 PM

Thank you Charles


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#35 sarah2014

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Posted 18 April 2017 - 04:00 PM

I need you opinion, so this is what I come up with for salvage shrimp. ( corrective action )

 

 

We have 2 issues :

 

 

First is chemical issue : the floor Guard that we use is not  a food grade  and it contain an appreciable amount of quaternary ammonia. Harmful if we swallowed. So I decide to start using  a food grade  sanitizer on the floor and get rid of the floor guard.

 

Second issue is a micro issue: so I decide to add another step ,using a solution of acidified sodium chlorite (ASC) at up to 50 ppm for reconditioning the shrimp, ASC has approval from FDA for this purpose. They use it for poultry , meat, fruit, and sea food .

 

 

21CFR173.325

 

The additive is used as an antimicrobial agent in water and ice that are used to rinse, wash, thaw, transport, or store seafood in accordance with current industry standards of good manufacturing practice. The additive is produced by mixing an aqueous solution of sodium chlorite with any GRAS acid to achieve a pH in the range of 2.5 to 2.9 and diluting this solution with water to achieve an actual use concentration of 40 to 50 parts per million (ppm) sodium chlorite. Any seafood that is intended to be consumed raw shall be subjected to a potable water rinse prior to consumption.

 

 

 

 

For validation :   test the shrimp for quat residues and mico

what do you guys think


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#36 Fishlady

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Posted 18 April 2017 - 04:19 PM

I need you opinion, so this is what I come up with for salvage shrimp. ( corrective action )

 

 

We have 2 issues :

 

 

First is chemical issue : the floor Guard that we use is not  a food grade  and it contain an appreciable amount of quaternary ammonia. Harmful if we swallowed. So I decide to start using  a food grade  sanitizer on the floor and get rid of the floor guard.

 

Second issue is a micro issue: so I decide to add another step ,using a solution of acidified sodium chlorite (ASC) at up to 50 ppm for reconditioning the shrimp, ASC has approval from FDA for this purpose. They use it for poultry , meat, fruit, and sea food .

 

 

21CFR173.325

 

The additive is used as an antimicrobial agent in water and ice that are used to rinse, wash, thaw, transport, or store seafood in accordance with current industry standards of good manufacturing practice. The additive is produced by mixing an aqueous solution of sodium chlorite with any GRAS acid to achieve a pH in the range of 2.5 to 2.9 and diluting this solution with water to achieve an actual use concentration of 40 to 50 parts per million (ppm) sodium chlorite. Any seafood that is intended to be consumed raw shall be subjected to a potable water rinse prior to consumption.

 

 

 

 

For validation :   test the shrimp for quat residues and mico

what do you guys think

Hi, Sarah

This sounds like a good approach to me.


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#37 Charles.C

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Posted 19 April 2017 - 08:17 AM

Hi Sarah,

 

(1) I doubt that a food grade sanitizer exists.

(2) I would ensure that the literature with yr intended chemical validates that it/its SOP are FDA acceptable for shrimp treatment.

(3) i have no direct experience but handling Na chlorite looks highly unpleasant in various ways. I originally didn't use for this reason ( and cost). See attached files.

(4) I don't understand why you need to check shrimp for quats if usage discontinued ?

 

Regardless, Good Luck !

 

Attached File  Sodium Chlorite Handbook.pdf   710.13KB   8 downloads

Attached File  Regulatory Issues Regarding Food Applications of Sodium Chlorite.pdf   195.79KB   6 downloads

 

 


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Charles.C


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#38 sarah2014

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Posted 19 April 2017 - 12:38 PM

Hi Charles,

 

 I mean a food contact sanitizer

so you think using a solution of acidified sodium chlorite (ASC). it has a lot of risk


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#39 Charles.C

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Posted 19 April 2017 - 12:43 PM

addendum

 

Actually EPA proves my No.1 may be incorrect -

 

Directions for Use of Food-Grade Shell-Egg Sanitizers 
  • All formulations must be cleared under 21 CFR 178.1010 as sanitizing solutions for food contact surfaces or have a tolerance or exemption from the requirement of a tolerance in 40 CFR Part 180 that covers use as a sanitizing solution for food contact surfaces.
  • Any reference/directions for use for eggs intended for use as hatchlings is a drug claim and is regulated only by FDA. This type of claim is not allowed on FIFRA labels.
  • Only clean, whole eggs can be used for sanitizing. Dirty, cracked or punctured eggs cannot be sanitized.
  • If the product is intended for use as both a cleaner and a sanitizer, separate directions for use as a cleaner must be provided and followed by a potable water rinse, preceding the directions for use as a sanitizer with a fresh solution.

The directions for use in sanitizing eggs must be similar to the following:

 

[x] = company to provide amount/rate based on efficacy data.

To sanitize clean shell eggs intended for food or food products, spray with a solution of [x] ounces of product in [x] gallons of water (providing [x] ppm active). The solution must be equal to or warmer than the eggs, but not to exceed 130o F. Wet eggs thoroughly and allow to drain. (**Insert the applicable statement below, as appropriate). Eggs must be reasonably dry before casing or breaking. The solution must not be reused for sanitizing eggs.

  1. Eggs that have been sanitized with this quaternary ammonium compound shall be subjected to a thorough potable water rinse only if they are to be immediately broken for use in the manufacture of egg products.
  2. Eggs that have been sanitized with this chlorine compound may be broken for use in the manufacture of egg products without a prior potable water rinse.
  3. Eggs that have been freshly washed may be sanitized with this iodine compound only if the eggs are rinsed prior to application of the compound. A subsequent potable water rinse is not required.

So under certain conditions quats can apparently be referred to as food grade. Curious indeed.

 

https://www.epa.gov/...-egg-sanitizers

 

On the other hand -

EPA
Chemical sanitizers and other antimicrobials applied to food-contact surfaces are regulated by the US EPA, and must meet the requirements specified in FIFRA (Federal Insecticide, Fungicide, and Rodenticide Act). These products must go through an extensive testing, review, and registration process prior to being allowed for sale and will obtain a product specific EPA registration number indicating its approval under FIFRA. Refer to the link below for more information on the process used to register pesticide products under FIFRA:
https://www.epa.gov/...de-registration  
 
The 3M™ Sanitizer Concentrate is registered with the US EPA and is approved as a no-rinse food-contact sanitizer. It is not intended to be used directly on food, but is safe to use on food-contact surfaces without a water rinse when used as directed.

Disinfectant products are not intended for use in no-rinse food-contact applications and, like other cleaning products used on food contact surfaces, must be thoroughly rinsed from the surface with potable water after use. Some specified disinfectant products, when used according to label directions, can be appropriate for use in a food facility.  
This specific tolerance for no-rinse sanitizers granted by the EPA per 40 CFR 180.940 is only applicable “when used in accordance with good manufacturing practice as ingredients in an anti-microbial pesticide formulation, provided that the substance is applied on semi-permanent or permanent food contact surface with adequate
draining before contact with food.” In the case of the 3M™ Sanitizer Concentrate, the active ingredient (quaternary ammonium compounds) concentration, when present in ready to use form, must not exceed 400 ppm in order to remain compliant within the food contact antimicrobial parameters

 

It seems to me the 3M chemical above should also be able to called food grade but seemingly not.

 

Worst case ? -

 

Gastrointestinal Dangers

Food-grade hydrogen peroxide can damage the gastrointestinal tract. An article in the October 2007 issue of the "Canadian Journal of Gastroenterology" reviewed a case in which a man accidentally consumed 250ml of food-grade hydrogen peroxide, thinking it was water. Examination showed extensive caustic injury to the stomach lining, and some superficial erosions in the first section of the small intestine. The patient was able to leave the hospital on the third day with no complications. The study authors noted that keeping food-grade hydrogen peroxide on hand for alternative health purposes can lead to accidents such as this one. Ingesting this substance can also cause worse effects due to its caustic nature, including gastrointestinal ulceration and perforation.

 

The basic question is as to what (or who) defines "food - grade". A Name for Many Seasons


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Charles.C


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#40 Charles.C

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Posted 19 April 2017 - 01:08 PM

Hi Charles,

 

 I mean a food contact sanitizer

so you think using a solution of acidified sodium chlorite (ASC). it has a lot of risk

 

No recent experience unfortunately. Maybe someone here is using and can comment ?

 

I noticed this detailed description for brewing applications with a 2017 date at end (although refs are rather antique) -

http://www.birkocorp...xide-its-a-gas/


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Charles.C


#41 sarah2014

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Posted 19 April 2017 - 02:58 PM

we use Alpha BAC is an EPA registred , quaternary ammonia based sanitizer,designed for use in the food processing industry . is also USDA AUTHORIZED in produce processing plants, bakeries, seafood plants and beverages, meat and poltry plants


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#42 Charles.C

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Posted 19 April 2017 - 03:25 PM

we use Alpha BAC is an EPA registred , quaternary ammonia based sanitizer,designed for use in the food processing industry . is also USDA AUTHORIZED in produce processing plants, bakeries, seafood plants and beverages, meat and poltry plants

 

Hi Sarah,

 

Do you mean it's used for equipment/food contact surfaces ?


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Charles.C


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#43 sarah2014

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Posted 19 April 2017 - 04:12 PM

yes Charles


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#44 Scampi

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Posted 19 April 2017 - 04:59 PM

You need to look for a chemical that is specifically approved for direct food contact to be used as a microbial rinse-----not an off label application, I doubt that the quat you've mentioned is approved for DIRECT FOOD CONTACT, many many chemicals will be approved for incidental contact, but you must use an approved food contact product.

 

The problem with quats are that they are designed to stick--essentially industrial strength soap and are very stable  (we only use it for our boots dips because its efficacy is not affected by microbial load)

 

 

 

PPA's generally speaking do a great job, plus they can assist in shelf life as well as keep your product nice and white. And it is what we use (poultry)

 

IMVHO you get what you pay for in the chemical department----I would personally stay away from the big companies (ecolab etc) as you will not get the level of customer service you need or want.

 

My chemical company is a small, but very well educated company who has a combined 200+ years of food production sanitation experience. They are always more than happy to assist me with new problems technical issues

 

The floor guard chemical makes me very nervous particularly for a processing area, warehouse sounds great though.


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#45 Scampi

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Posted 19 April 2017 - 05:02 PM

"Alpha Bac 10 is a quaternary disinfectant sanitizer. Dilutions are 200 ppm QUAT for sanitizing.This liquid Sanitizer is for use in food service areas with no rinsing and can be used in the third compartment sink. Provides 200 PPM QUAT at one ounce per 4 gallons. Sanitizer strips available upon request."

 

Food service means restaurants not food processing for direct food contact. Quote above is from the website


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#46 Charles.C

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Posted 19 April 2017 - 05:18 PM

Hi scampi,

 

The surprising thing to me is that a quat may be approved for direct contact,

 

See my EPA link in post 39


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Charles.C


#47 Charles.C

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Posted 19 April 2017 - 05:45 PM

addendum

 

I totally agree with yr comment that it is necessary to find any options which are (EPA?) approved for direct food contact. Hopefully to include shrimp.

 

So is there a list of such chemicals anywhere ?

 

Or is Na chlorite the only entry (and presumably Na hypochlorite) ?


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Charles.C


#48 sarah2014

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Posted 19 April 2017 - 06:02 PM

we use a test strip , we test the sanitizer concentration to ensure that it has a concentration of < 200ppm (chlorine based) or < 400 PPM ( QUAT BASED ) if the concentration is over the targeted concentration, rinse the equipment before use and adjust the mixer to achieve the desired level


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#49 sarah2014

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Posted 19 April 2017 - 06:03 PM

oh my god I am getting confused :sleazy: .

I just trying to find corrective action for the shrimp that fall on the floor , but now I have more things to think about


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#50 Scampi

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Posted 19 April 2017 - 06:30 PM

Do not ever feel like you cannot ask your inspector for clarification----a good working relationship will pay dividends


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