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#1 Dahmun

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Posted 07 September 2017 - 02:12 PM

Hi All,

 

Upper management is considering the idea of filling both liquid detergent (dishwashing liquid) and beverages in the same filling line and ensuring complete rinsing and validation of rising so as one will not contaminate the next.

​I know HACCP requirements speaks to the use of approved chemicals in approved concentrations.

 

Can anyone weigh in on this, whether it is a good or bad idea for food safety or process flows based on gravity fill equipment (tribloc filler) and the difference between viscosity of beverages and liquid detergents?

 



#2 Gerard H.

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Posted 08 September 2017 - 12:35 PM

Dear Dahmun,

 

Theorically it is possible. You can rinse the system, until there is no more detergent rest in it anymore.

 

There are good indicators on the markets to detect low detergent rests, so that you can carry out your line release.

 

However, the idea is scary (probably the reason, why you have asked it here). 1 miss is sufficient to find yourself in a recall situation, which is probably more expensive than to invest in an extra filling unit.

 

Kind regards,

 

Gerard Heerkens



#3 CMHeywood

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Posted 13 September 2017 - 09:48 PM

Recently there was a company in Wisconsin that was doing the same thing.  I believe they got a warning letter from the FDA - possibly a cease and desist type order.



#4 jdpaul

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Posted 08 May 2018 - 01:27 PM

Late to the party

 

We run a sodium hydroxide solution through our CIP aparatus; the same we use for making sparkling beverages. A rinse out verification can be fairly straight-forward:

 

1. Take a scoop of barium chloride into a mortar and pestle

2. Add a few drops of phenolphthalein

3. Take a sample of the rinse water and mix with the aforementioned 

 

If the solution turns pink this is an indication you still have sodium hydroxide in your piping. Electronic Instrumentation can be introduced to be more quantitative, but this is just to give you a general overview of a qualitative pH verification method.



#5 Scampi

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Posted 08 May 2018 - 02:37 PM

wouldn't touch this idea with a 10 foot pole. Period


Because we always have is never an appropriate response!


#6 jdpaul

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Posted 08 May 2018 - 02:42 PM

Scampi,

 

What are you making reference to; the sanitation of running NaOH through a CIP system or the method of testing for residual NaOH?



#7 Scampi

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Posted 08 May 2018 - 03:25 PM

Running laundry detergent and food through the same filler.  I understand what upper management is thinking....its about ROI for the equipment. There is too much room for error. If the detergent ingredients aren't approved for food contact surfaces as the cleaning step with a potable water rinse, I don't want to eat it.

 

For heavens sake, I won't let our jar/sealed product on the same truck as chemicals in sealed containers.............why would anyone ever suggest this is a good idea. I smell a recall. Sorry, I happen to think this is the most horrific idea I have ever heard

Clearly not a regularly inspected location....CFIA would never allow this, and would probably issue a license suspension and a find for "intentional adulteration" regardless of what your swab/test results show

 

 

Please keep food in food and chemicals in chemicals


Because we always have is never an appropriate response!


#8 jdpaul

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Posted 08 May 2018 - 03:37 PM

Scampi,

 

It is very common practice in the beverage industry to use a detergent or soap to clean piping, storage tanks, filler bowls, etc. 



#9 Scampi

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Posted 08 May 2018 - 04:28 PM

To clean yes, of course. But those are products approved for use in a food processing sanitation program; the original question was about using the same system TO FILL detergent into bottles.....that is a different animal altogether

 

I've been in the food processing business for 20+ years and have never heard tell of using food processing equipment to pack NON FOOD


Because we always have is never an appropriate response!


#10 jdpaul

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Posted 08 May 2018 - 04:39 PM

Oh I missed that part. You're right, after revisiting the original post it appears they want to run a beverage for human consumption and a detergent on the same line. 

 

I would be curious to know what the legislation states for this; if there is any? I don't know

 

 

Anyways, theoretically employing this idea. You would probably plan to run all of your beverage product at the beginning of the week (similar to an allergen).Your cleaning and sanitation PRPs would have to be very robust and extensive to determine any trace amount of detergent residue. I would look at investing in an HPLC and looking at doing an analysis on a sample of the rinse water. You could look at the analyte with the lowest molecular weight in the detergent; if it is not present then you are probably safe on your cleaning. You would just need to have a very good system in place and it could be done. It's risky if aren't confident and don't understand the control measures you are employing to control it, but it can be done I believe. 



#11 Scampi

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Posted 08 May 2018 - 05:42 PM

I would think/hope most inspectors would use this to stop that kind of nonsense, like PP, FDA issued an order to stop in a facility that thought you could just go ahead and run non food chemicals in food processing equipment....not ok   21 U.S. Code § 342 - Adulterated food
food shall be deemed to be adulterated—
(a)Poisonous, insanitary, etc., ingredients
(1)
If it bears or contains any poisonous or deleterious substance which may render it injurious to health; but in case the substance is not an added substance such food shall not be considered adulterated under this clause if the quantity of such substance in such fooddoes not ordinarily render it injurious to health.[1] (2)(A) if it bears or contains any added poisonous or added deleterious substance (other than a substance that is a pesticide chemical residue in or on a raw agricultural commodity or processed food, a food additive, a color additive, or a new animal drug) that is unsafe within the meaning of section 346 of this title; or (B) if it bears or contains a pesticide chemical residue that is unsafe within the meaning of section 346a(a) of this title; or © if it is or if it bears or contains (i) any food additive that is unsafe within the meaning of section 348 of this title; or (ii) a new animal drug (or conversion product thereof) that is unsafe within the meaning of section 360b of this title; or (3) if it consists in whole or in part of any filthy, putrid, or decomposed substance, or if it is otherwise unfit for food; or (4) if it has been prepared, packed, or held under insanitary conditions whereby it may have become contaminated with filth, or whereby it may have been rendered injurious to health; or (5) if it is, in whole or in part, the product of a diseased animal or of an animal which has died otherwise than by slaughter; or (6) if its container is composed, in whole or in part, of any poisonous or deleterious substance which may render the contents injurious to health; or (7) if it has been intentionally subjected to radiation, unless the use of the radiation was in conformity with a regulation or exemption in effect pursuant to section 348 of this title.
(b)Absence, substitution, or addition of constituents
(1)
If any valuable constituent has been in whole or in part omitted or abstracted therefrom; or (2) if any substance has been substituted wholly or in part therefor; or (3) if damage or inferiority has been concealed in any manner; or (4) if any substance has been added thereto or mixed or packed therewith so as to increase its bulk or weight, or reduce its quality or strength, or make it appear better or of greater value than it is.

Because we always have is never an appropriate response!


#12 jdpaul

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Posted 08 May 2018 - 06:07 PM

It is unlikely any trace residues would cause a significant health risk. In reality, routine quality monitoring and organoleptic sensory would pick up any detergent fragrances/odors which means you would need to dramatically beef up your sanitation. If you are following a thorough rinse out verification, it is unlikely you would face any health risk other than quality issues. If you run the beverages at week start up you allow for a larger period where you can clean and sanitize the line following next weeks start up. It's like an allergen, just not as severe. There are no pathogens. 

 

 

 

paragraph (b) is just talking about economically motivated/adulterated food-stuffs. I don't think that part applies. 



#13 redfox

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Posted 11 May 2018 - 05:59 AM

Hello,

 

IMO, that really a very dangerous idea. Though in bottling company uses caustic soda, rinse the line and bottles, verify the rinsing by using phenolpthalein indicator. But the contact time is very different when your run a filling of liquid detergent with the same line of the food product.

 

What the risk? non-food grade residues, synthesizers, allergens other harmful chemicals that would stick on the bends and elbows on your piping line.

 

regards,

redfox



#14 melsm57

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Posted 18 July 2018 - 06:01 PM

Running laundry detergent and food through the same filler.  I understand what upper management is thinking....its about ROI for the equipment. There is too much room for error. If the detergent ingredients aren't approved for food contact surfaces as the cleaning step with a potable water rinse, I don't want to eat it.

 

For heavens sake, I won't let our jar/sealed product on the same truck as chemicals in sealed containers.............why would anyone ever suggest this is a good idea. I smell a recall. Sorry, I happen to think this is the most horrific idea I have ever heard

Clearly not a regularly inspected location....CFIA would never allow this, and would probably issue a license suspension and a find for "intentional adulteration" regardless of what your swab/test results show

 

 

Please keep food in food and chemicals in chemicals

I agree, the risk is appalling. It's bad enough risk when the intended cleaning chemicals for a CIP system are not rinsed properly, the risk when you are including a cleaning product in your product mix beggars belief






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