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Sanitizer essential oils prerequisite program

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#1 AudreyB

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Posted 20 July 2016 - 01:05 AM

Hello all, 

 

My company manufactures essential oils and other aroma chemicals which do not support pathogenic growth (supported by literature and our industry). 

 

We are in the process of implementing an SQF system and are working on our cleaning/sanitation program. Currently, we wash our equipment (tanks, pumps, hoses) using a food grade degreasing soap. Our soap - Blizzard sold by Sani Marc - contains slight amounts of chlorine. Given these characteristics of the soap and our products, no sanitizing step was ever added to our past cleaning SOPs. 

 

Given our current staff, we would prefer to keep using only this degreaser soap if possible, without adding a sanitizing step.

 

Will this be acceptable to auditors / regulatory agencies? Are there any types of studies which we can complete to validate that our current cleaning is acceptable and no sanitizer is needed? 

 

Thank you all for any reponses. 

 



#2 redfox

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Posted 20 July 2016 - 01:33 AM

Hello Audrey,

 

After rinsing you can validate/verify your "how clean is clean" by checking the pH and ATP swabbing.

 

regards,

redfox



#3 Charles.C

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Posted 20 July 2016 - 04:25 AM

Hi Audrey,

Apologies for my ignorance but are the products you discuss regulated/approved as food additives or ?


Kind Regards,

 

Charles.C


#4 mgourley

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Posted 20 July 2016 - 09:05 AM

See if your chemical supplier has done any studies that show the level of chlorine is an effective sanitizer.

 

Marshall



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#5 AudreyB

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Posted 23 July 2016 - 01:48 AM

Charles, 

 

Our products are generally regarded as food ingredients / flavours, but we are not usually governed under any specific regulation and do not require regulatory audits. 

 

We are however subject to FSMA requirements. 



#6 Charles.C

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Posted 23 July 2016 - 04:51 AM

Hello all, 

 

My company manufactures essential oils and other aroma chemicals which do not support pathogenic growth (supported by literature and our industry). 

 

We are in the process of implementing an SQF system and are working on our cleaning/sanitation program. Currently, we wash our equipment (tanks, pumps, hoses) using a food grade degreasing soap. Our soap - Blizzard sold by Sani Marc - contains slight amounts of chlorine. Given these characteristics of the soap and our products, no sanitizing step was ever added to our past cleaning SOPs. 

 

Given our current staff, we would prefer to keep using only this degreaser soap if possible, without adding a sanitizing step.

 

Will this be acceptable to auditors / regulatory agencies? Are there any types of studies which we can complete to validate that our current cleaning is acceptable and no sanitizer is needed?

 

Thank you all for any reponses. 

 

Hi Audrey,

 

Based on info. in Post5 (thks !) it is rather unclear to me how yr product/process would be categorized/evaluated from SQF's (Food) POV, eg which Module  ?

 

Regardless i can offer 2 comments which would relate to food ingredient production process

 

(1) afaik, cleaning/sanitising products for food/food ingredient manufacturing processes in Canada are required to be approved/listed in an Official Compilation. But since the "food-related" status of yr product is itself unclear, such requirements may/may not be relevant/applicable.

 

(2) The effectiveness of any cleaning procedure for a food/food ingredient manufacturing process could be evaluated (by swabbing) via estimating  any residues of (a) chemical, (b) microbiological and (c) allergenic nature. Generic indicator limits for (b) exist but any testing/limits for (a,c) would likely depend on the specific products/hazards involved (if any). The caveat mentioned in (1) will presumably again apply.


Kind Regards,

 

Charles.C


#7 AudreyB

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Posted 23 July 2016 - 04:52 PM

Hi Audrey,

 

Based on info. in Post5 (thks !) it is rather unclear to me how yr product/process would be categorized/evaluated from SQF's (Food) POV, eg which Module  ?

 

Regardless i can offer 2 comments which would relate to food ingredient production process

 

(1) afaik, cleaning/sanitising products for food/food ingredient manufacturing processes in Canada are required to be approved/listed in an Official Compilation. But since the "food-related" status of yr product is itself unclear, such requirements may/may not be relevant/applicable.

 

(2) The effectiveness of any cleaning procedure for a food/food ingredient manufacturing process could be evaluated (by swabbing) via estimating  any residues of (a) chemical, (b) microbiological and (c) allergenic nature. Generic indicator limits for (b) exist but any testing/limits for (a,c) would likely depend on the specific products/hazards involved (if any). The caveat mentioned in (1) will presumably again apply.

 

Charles, 

 

We're covered in FSC 19 and 26, thus we are implementing Modules 2, 11 and 12. All our chemical products including our degreasing cleaner are approved by the CFIA. It is not an absolute requirement in our case, since our products are not a 'food' but rather a 'food ingredient', but it is par of our best practices to ensure we meet our clients' needs.

 

We do not purchase, manufacture or store any allergens, and as mentioned above our products are not a source of biological contamination, which leaves the only risk of chemical residues. 

 

If our cleaning procedure (using only the degreaser) is robust enough to eliminate this hazard without the use of a sanitizer (of course this will be verified and validated), we would not need to start using one? 



#8 Charles.C

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Posted 23 July 2016 - 06:15 PM

Hi Audrey,

 

Thanks yr info.

 

I assume yr OP is primarily addressed to acceptability for SQF.
I assume yr operation is (SQF) Low Risk. (Is it?)

I assume no allergenic factors involved (as per previous post).
I assume the SQF cleaning requirements for a Low Risk, food ingredient operation are identical (unless Code stated otherwise) to that for a food. Seems logical since for GMP same module (11) is quoted in FSC 19.

 

Afai can see the relevant “cleaning” clause is 11.2.13.

 

The SQF Guidance material for this Clause in  the section  “What do I have to do”  contains  this text –
---------------------------------------------------------------------------------
A full description of the cleaning and sanitation procedures for each piece of equipment or area of the
operation.  This should include:
°      Physically remove solid particles by sweeping or wiping;
°      Apply a suitable detergent in the correct concentration to remove grease and other food residues;
°      Rinse off residual food residue and detergent;
°      Apply a suitable sanitizer in the correct concentration to reduce or eliminate microbiological contaminants;
°      Rinse to remove residual sanitizer, if indicated on product label;
°      Dry, as indicated, in a manner that will prevent recontamination.
Etc, etc

To verify the effectiveness of sanitation, a visual pre-operational inspection of equipment and facility is to be conducted prior to the start of operations, after a sanitation activity or the beginning of a shift.   For high risk operations and allergen cleaning verification (refer 2.8.2.1), a more thorough swabbing program shall be implemented to verify the integrity of the cleaning regime.
-----------------------------------------------------------------------------------
The above implies that application of a sanitizer is mandatory.

 

I suggest that whether yr product could be regardable as a combined detergent/sanitizer (which certainly do exist) may depend, for example, on  -

(a) how the product is formally described (and [2-way] cfia approved?) in its documentation
(b) a satisfactory verification of the cleaning efficiency. The last paragraph in above quoted text IMO is slightly ambiguous regarding the necessity for swabbing for a non-high risk operation (there is no mention of “swabbing” in the actual Code, eg clauses 11.2.13.[4,5]). However in the present case where use of only one detergent/”sanitizer” is envisaged, seems likely that an auditor would be relatively “rigorous” as far as verification is concerned.

 

There are at least 2 caveats in my above analysis –

(1) The SQF Guidance material is not an auditable document and is supercedable by the Code itself (and presumably by an auditor’s interpretation thereof),
(2) Based on other threads in this Forum, SQF auditors may simply interpret the Code in a different way to that given in the Guidance material and, IMO, occasionally to the Code also.

 

Accordingly since I am not a SQF user, the validity (or otherwise) of above analysis/opinions needs to be confirmed by actual SQF users.


Kind Regards,

 

Charles.C






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