So we currently have a chain of custody type certification with an organic customer whom we co-pack for (the facility and some documentation is audited, mass-balance, gmps, etc but the customer holds the certification) we have recently signed on a new customer that requires that we hold the full certification. We are currently in the application process, and Im having a little back and forth with the certification project manager. I'd like to add that the customer who we co-pack for, and the customer that we just signed on are under the same certifying body. SAME . CERTIFYING. BODY.
Our current (and until now accepted) practice for showing evidence that sanitizers that aren't on the
trainwreck National List are fully removed is to pull a final rinse sample. We titrate values and require that results are <1000ppm. Which is what we have always done... like for years!
The certif. project manager wants to know how <1000ppm ensures that all sanitizers are rinsed off the equipment. If we can illustrate that, it would be ok, If 1000ppm would still evidence that the sanitzer is on the equipment then the test is not sensitive enough...
So I asked "What is the lower minimum end ppm that is acceptable?" What if we tested pH on the final rinse water? What is an acceptable +/- variance on pH values for discharged final rinse sample and rinsing water sample?"
Essentially her answer was that she could not consult us on this.... great help lady.
Any suggestions? Do we just pH test both samples and require that they are equal to verify all sanitizers have been removed? If not equal, continue rinsing until they do??
I Eat Organic But Don't Understand Its Rules
Edited by it_rains_inside, 25 February 2015 - 02:16 PM.