15 replies to this topic

[hacksalot]

All,

 

We were given a minor NC for having household dish soap in our production area.  We use it to wash equipment.  I'm not sure what the specific problem is with having something like this in our production area.  It was well away from actual production and sitting on a wash station.  The auditor was not specific in why this was an NC.  He also mentioned scented hand sanitizer was not allowed.  

[SQFconsultant]

Was it at a sink that is specifically for washing equipment?

 

The only thing you need for it is to have it on your inventory and have an SDS sheet for it.

 

If it as at a hand wash station then that would be no no.

 

Unscented only.

[Scampi]

residential soap is not chemically formulated to deal with industrial organic build up. You should be ONLY using cleaning and sanitizing chemicals specifically designed for the food industry and your type of product

 

what works for protein build up doesn't always work for fat etc etc etc

 

IMHO you got off easy

 

Scented hand sanitizer???  of course this isn't allowed.........the scent can transfer and ruin your product

[hacksalot]

Was it at a sink that is specifically for washing equipment?

 

The only thing you need for it is to have it on your inventory and have an SDS sheet for it.

 

If it as at a hand wash station then that would be no no.

 

Unscented only.

 

 

Yes, it was at a cleaning station, not a hand washing station.

[Scampi]

This is why you cannot use household dishsoap

 

v. Methods used to confirm the correct concentrations of detergents and sanitizers, 

 

How are you going to check concentrations?  And you don't know if it leaves a residue and yes, you can get SDS for household products, but that's it......you cannot get any documentation that says it's appropriate for your facility

[QA-Tech]

Was this a 3rd party audit or FDA/State? 

 

Agree with SQFConsultant that you need an SDS and that it should not be at a hand washing sink.

 

Do you currently have an equipment washing policy/procedure that also includes a validated sanitizer or dishwasher? 

 

I would be asking for further explanation or specific code reference as to why they gave the NC. 

 

Definitely ditch the scented hand sanitizer though. 

[Scampi]

Please please please stop using residential dish soap for food processing!  This is why SQF is asking for demonstrated concentrations and you cannot do that with product purchased at the retail level

 

http://ucfoodsafety....files/26501.pdf

[QA-Tech]

We use Dawn dish soap in our facility, basically the same formula as Ulines industrial dish detergent. Its a nationally recognized branded product that is clearly intended to clean food contact surfaces, and it saves adorable baby seals. We would never use it for CIP, but for cleaning removable equipment, its purpose is to remove soil so that our validated sanitizer can effectively do its job. All detergents/soaps should be completely rinsed off whether they are from Dawn or from EcoLab. 

 

If you have proper sanitation procedures in place (wash, rinse, sanitize) and can validate that those procedures are effective, I don't see the problem. 

 

In the case of this auditor, simply having dish soap in your facility doesn't seem appropriate cause for an NC unless you failed to provide an SDS or were storing it inappropriately.  

[Scampi]

and how do you verify concentrations or get around that requirement?????

[QA-Tech]

As per the SQF Guidance for module 11, anything that is mixed on site is verified to be within the manufacturer's recommended concentration and that gets recorded daily and we use our sanitation verification schedule to monitor efficacy of our sanitation program. 

 

I don't think an auditor would expect me to use test strips on EcoLabs pre-moistened alcohol wipes, since they come ready to use and from a reputable supplier. I don't think it should be any different for a ready to use detergent that I am then rinsing and following with sanitizer when I have data to support that the procedure is consistently effective. 

[Scampi]

alcohol is known to evaporate completly once dry, but I take your meaning....

 

I can tell you this would never fly in Canada.....not even in a restaurant kitchen.............so imagine my surprise!!!!!!!!!!!

[MsMars]

I will add to this conversation that I have been at a facility in the past that used Dawn in their regular cleanup.  They maintained an SDS for it and only used it for cleaning utensils and never had a question from an auditor.  I will also say that in the past I have used an "industrial grade" product that was basically dish soap to clean utensils and equipment parts that we simply maintained an SDS for and never had questions from any auditor or inspector about mixing concentrations. In both cases, the items were washed with the soap, rinsed, then sanitized with a sanitizer of known concentration that was verified with strips. 

 

Now that's not to say that an auditor or inspector COULDN'T raise questions about these soap products, but IMO if they get to that point during your audit they are either trying to find SOMETHING or they've seen reckless or irresponsible (non-common sense) use.

 

Just my 2 cents. 

[hacksalot]

We use Dawn dish soap in our facility, basically the same formula as Ulines industrial dish detergent. Its a nationally recognized branded product that is clearly intended to clean food contact surfaces, and it saves adorable baby seals. We would never use it for CIP, but for cleaning removable equipment, its purpose is to remove soil so that our validated sanitizer can effectively do its job. All detergents/soaps should be completely rinsed off whether they are from Dawn or from EcoLab. 

 

If you have proper sanitation procedures in place (wash, rinse, sanitize) and can validate that those procedures are effective, I don't see the problem. 

 

In the case of this auditor, simply having dish soap in your facility doesn't seem appropriate cause for an NC unless you failed to provide an SDS or were storing it inappropriately.  

 

In the written NC from the auditor, he states "domestic use" cleaners were observed in the processing area.  Think I pretty much figured out what we got the NC for.  The employees were using it to clean removable small parts from equipment.  Funny thing, we have another industrial cleaner we're using that's almost the identical chemistry as Dawn. 

[Charles.C]

In the written NC from the auditor, he states "domestic use" cleaners were observed in the processing area.  Think I pretty much figured out what we got the NC for.  The employees were using it to clean removable small parts from equipment.  Funny thing, we have another industrial cleaner we're using that's almost the identical chemistry as Dawn. 

 

It's basically, usually, simple.

You are typically expected by auditors to be able to show evidence that chemicals used in production are "suitable" for food processing.

I anticipate that you had/have none. ??

[hacksalot]

It's basically, usually, simple.

You are typically expected by auditors to be able to show evidence that chemicals used in production are "suitable" for food processing.

I anticipate that you had/have none. ??

 

Honestly, I have not a clue why they brought Dawn into the facility when they have an equipment cleaner that the manufacture claims is for food processing equipment.  Unfortunately, I have had an extremely difficult time getting a TDS from this manufacture to prove. 

[Charles.C]

Honestly, I have not a clue why they brought Dawn into the facility when they have an equipment cleaner that the manufacture claims is for food processing equipment.  Unfortunately, I have had an extremely difficult time getting a TDS from this manufacture to prove. 

 

My sympathies having experienced both problems.

 

I found that merely trialling a new supplier generated a rapid change in documentation offers. And a cost reduction. Word of mouth can do wonders sometimes.

 

PS - IMEX a TDS, per se, is not always  mandatory but It depends on the audit Standard of course. And possibly the auditor.