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Using Clorox as a food surface chlorine sanitizer

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OrRedFood

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Posted 29 April 2022 - 08:02 PM

Hello - I was speaking with our chemical rep about the use of Clorox as our chlorine sanitizer.  We have used it for years, it is diluted properly, tested daily, and kept in a chemical storage cabinet.  We use a range of 50 - 100 ppm for food contact, and check it multiple times a day.    

 

We have years of ATP results for validation of this.  We have three SQF audits under the same auditor and this has been acceptable.  However, we are getting a new auditor this year and I'm wary of it not being acceptable - our past auditor did not pay much attention to our cleaning chemicals.  

 

Our chemical rep said that many food processing plants use it because it is inexpensive and effective, and the ppm usage for their "brand name" chlorine states a minimum of 50 ppm for its usage on the label is effective for food contact sanitizing without a rinse.  What we need is the documentation that Clorox is acceptable for food grade use at 50 - 200 ppm for food contact sanitizer use. It is difficult to justify to own owner changing to a different brand name chlorine sanitizer that costs more just to get paperwork, when what we are using is working perfectly and ATP validated.  

 

Does anyone in this situation have documentation that has been acceptable for SQF? I am looking , but thought I'd reach out to you all at the same time. Thank you so much!



Scampi

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Posted 29 April 2022 - 08:11 PM

I have not doubt that your ATP results are good, but they do not measure whether something is sanitized or not, but merely the absence or presence of cells, they could be dead, they could also still be viable

 

 

Couple of things re: commercial sanitizers

 

A) Undiluted sodium hypochlorite is ALWAYS going to be cheaper than off the shelf chlorox

 

B) Your auditor will have an issue, as off the shelf chlorox is NOT for institutional/commercial use. it doesn't come with SDS or is buffered to adjust for your water conditions

 

The piece your missing is initial concentrations

 

Chlorox (that you'd use at home) is anywhere between 5 and 7%

 

Commercial sodium hypochlorite can be purchased at concentrations up to 50% (you're not paying for water)

 

You are to follow the label/manufacturers instructions for chemicals in a food processing facility, residential chlorox makes no such label claims


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OrRedFood

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Posted 29 April 2022 - 08:31 PM

Yes, I expected that would be the case.  I'm going to price it out against commercial food grade chlorine.  Clorox says it is 6.08% on its website.  But as you said, no documentation, i.e. manufacturers instructions for a food processing facility. This plant is new to SQF, has been using Clorox for 40 years, and their only SQF auditor was not very strict on a lot of items that I've put in place or plan to put in place, in anticipation for a "real" audit.  

 

Any other thoughts are appreciated!

 

Thanks. 



Spidey

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Posted 29 April 2022 - 08:47 PM



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OrRedFood

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Posted 29 April 2022 - 09:06 PM

This is very helpful!  I will work with our chemical rep to put together my own dilution and usage sheet, from their information, then get some more input.  I must say that Clorox has the most polite customer service, ever :)



kingstudruler1

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Posted 03 May 2022 - 05:26 PM

Some Clorox products are acceptable for food manufacturing.   They are usually the "pro" and "commercial" ones.  You can make these work if needed.  

 

Listing Category Search Page | NSF International

I couldn't readily find the label of these, but i'm sure it is out there somewhere.    

 

 

I agree with scampi - it is probably easier and less expensive to purchase something else.   


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Charles.C

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Posted 04 May 2022 - 06:09 AM

Hello - I was speaking with our chemical rep about the use of Clorox as our chlorine sanitizer.  We have used it for years, it is diluted properly, tested daily, and kept in a chemical storage cabinet.  We use a range of 50 - 100 ppm for food contact, and check it multiple times a day.    

 

We have years of ATP results for validation of this.  We have three SQF audits under the same auditor and this has been acceptable.  However, we are getting a new auditor this year and I'm wary of it not being acceptable - our past auditor did not pay much attention to our cleaning chemicals.  

 

Our chemical rep said that many food processing plants use it because it is inexpensive and effective, and the ppm usage for their "brand name" chlorine states a minimum of 50 ppm for its usage on the label is effective for food contact sanitizing without a rinse.  What we need is the documentation that Clorox is acceptable for food grade use at 50 - 200 ppm for food contact sanitizer use. It is difficult to justify to own owner changing to a different brand name chlorine sanitizer that costs more just to get paperwork, when what we are using is working perfectly and ATP validated.  

 

Does anyone in this situation have documentation that has been acceptable for SQF? I am looking , but thought I'd reach out to you all at the same time. Thank you so much!

Hi ORF,

 

Post 6 link offers a route to alternative sanitizers although I'm unclear as to the approval mechanism of NSF (eg D2) listed chemicals (?).

 

Based on previous threads on this Forum I seem to recall that (possibly for defined products) there is an official list (EPA ??) of Sanitizers approved for Food Contact applications in USA with/without subsequent water rinsing ??

 

(JFI, the terminology "Food Grade" is maybe best avoided in current context unless Validatable, eg Chlorox  is presumably not a categorised food ingredient?)


Kind Regards,

 

Charles.C


OrRedFood

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Posted 04 May 2022 - 03:48 PM

Hello, Charles - Thanks for following up with me, I appreciate it. 

 

I did some cost comparison of the Clorox Pro germicidal bleach to established food processing chemical companies, and found that for our usage rate, the gallons purchased from a restaurant supply are the least expensive route.  A 5 gallon jug of sodium hypochlorite will expire before we can use it all.  So, by purchasing the Clorox pro we are saving in the neighborhood of 0.03 cents per gallon.  

 

I've attached all the documentation we have to back up our use of the chemical, and added the NSF approval that kingstudruler1 so kindly provided.  NSF does not provide proof of food contact approval by FDA, but with the other information, it does help.  From prior experience, I believe the documentation covers us to use the product.  If you have time, I'd be interested in what you think of the attached. TIA! 

Attached Files


Edited by OrRedFood, 04 May 2022 - 03:52 PM.


OrRedFood

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Posted 04 May 2022 - 03:49 PM

Here's the NSF document, forgot to attach it to my last reply.  

Attached Files


Edited by OrRedFood, 04 May 2022 - 03:50 PM.


kingstudruler1

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Posted 04 May 2022 - 05:40 PM

Hello, Charles - Thanks for following up with me, I appreciate it. 

 

I did some cost comparison of the Clorox Pro germicidal bleach to established food processing chemical companies, and found that for our usage rate, the gallons purchased from a restaurant supply are the least expensive route.  A 5 gallon jug of sodium hypochlorite will expire before we can use it all.  So, by purchasing the Clorox pro we are saving in the neighborhood of 0.03 cents per gallon.  

 

I've attached all the documentation we have to back up our use of the chemical, and added the NSF approval that kingstudruler1 so kindly provided.  NSF does not provide proof of food contact approval by FDA, but with the other information, it does help.  From prior experience, I believe the documentation covers us to use the product.  If you have time, I'd be interested in what you think of the attached. TIA! 

The FDA does not "approve" cleaners and sanitizers.  Somewhat ironically, the EPA regulates sanitizers on "inanimate" objects as antimicrobial pesticides.   A EPA number and NSF cert is all  need.   

With the NSF document, a copy of the label (indicating epa number and approved dilutions for what you are using it for/ (see nsf comment), and the SDS, you should be fine.     


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Charles.C

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Posted 05 May 2022 - 11:05 AM

Hello, Charles - Thanks for following up with me, I appreciate it. 

 

I did some cost comparison of the Clorox Pro germicidal bleach to established food processing chemical companies, and found that for our usage rate, the gallons purchased from a restaurant supply are the least expensive route.  A 5 gallon jug of sodium hypochlorite will expire before we can use it all.  So, by purchasing the Clorox pro we are saving in the neighborhood of 0.03 cents per gallon.  

 

I've attached all the documentation we have to back up our use of the chemical, and added the NSF approval that kingstudruler1 so kindly provided.  NSF does not provide proof of food contact approval by FDA, but with the other information, it does help.  From prior experience, I believe the documentation covers us to use the product.  If you have time, I'd be interested in what you think of the attached. TIA! 

Hi ORF,

 

afaik a typical requirement is a demonstration/validation/statement that the chemical when used as stated can be categorised as "food grade" or perhaps more appropriately as "food safe".

 

Just for clarity, is the product being directly used on food contact surfaces plus the food itself ? With rinsing ? (I was unable to find yr "no-rinsing" label option quoted in OP ?)(the D2 no-rinse option mentioned in NSF document was not intelligible to me).

 

IIRC there is a previous, analogous, lengthy thread here (location unsure) on another sanitiser and whether its evaluation documentation (similar to present) was appropriate. From memory only, the conclusion was "uncertainty".

 

Note that the NSF document everywhere uses the term "acceptable".  Meaning precisely what ?

 

FWIW, IIRC, Food Codex offers a purity requirement for ("straight") sodium hypochlorite in respect to heavy metal impurities.

 

I suppose the SQF "acceptability" depends on what documentation/content they (minimally ?) require (never used SQF myself). Personally I find the NSF attachment "unclear" but perhaps its introductory cross- referenced items would enhance the intelligibility (for me). I am curious as to the meaning of EPA's designated number (if any).


Kind Regards,

 

Charles.C


OrRedFood

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Posted 05 May 2022 - 04:27 PM

Charles - We do not use chlorine sanitizer on the food it self, ever. It is an equipment sanitizer.  We use at a maximum of 200 ppm without rinsing.  This is the same process that has been used at food plants over the years.  The only difference is that it is brand named "Clorox-Pro germicidal" instead of "Ecolab" or another chemical company.  The information I attached prior has a statement from Clorox Co. stating it is suitable for food contact surface at the strength we are using it at.  

I believe the EPA reg. number and NSF approval are nice to have, but the key piece of information is what Clorox sent over confirming that it is safe for food contact surfaces up to a maximum of 200 ppm, no rinse.  



Charles.C

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Posted 05 May 2022 - 09:13 PM

Charles - We do not use chlorine sanitizer on the food it self, ever. It is an equipment sanitizer.  We use at a maximum of 200 ppm without rinsing.  This is the same process that has been used at food plants over the years.  The only difference is that it is brand named "Clorox-Pro germicidal" instead of "Ecolab" or another chemical company.  The information I attached prior has a statement from Clorox Co. stating it is suitable for food contact surface at the strength we are using it at.  

I believe the EPA reg. number and NSF approval are nice to have, but the key piece of information is what Clorox sent over confirming that it is safe for food contact surfaces up to a maximum of 200 ppm, no rinse.  

Hi ORF,

 

Thks yr reply.

 

IMO, there is an abundance of queries regarding the attachments in Posts 8, 9 .

 

Re ^^^(red) - Can you point out the location of this claim in Clorox attachment ?. This aspect may overlap EPA's domain.

 

Frankly, I was rather astonished by the second paragraph of the attachment in Post 9 hence my "clarity query" in Post 11.

 

i suggest a look at the informative U-tube video provided on the Clorox website in respect to the starred caveat comment on Page 4 of attachment Post 9.

 

I also suggest to determine the specific significance of the EPA classification.


Kind Regards,

 

Charles.C


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OrRedFood

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Posted 06 May 2022 - 12:32 AM

EPA  - "PPD PUMA (EPA Reg. No. 67619-32) [REGISTERED AS Insert Registered Alternate Brand Name] FOR SANITIZING SOLUTIONS FOR EQUIPMENT AND UTENSILS It is a violation of Federal law to use this product in a manner inconsistent with its labeling. Labeling must be in possession of user at time of application. Read and follow label affixed to the container. Refer to container label for use precautions and further information. This product is authorized for use as a sanitizing solution in official establishments operating under the USDA meat, poultry, shell egg grading and egg products inspection programs. Before using this product, food products and packaging materials must be removed from the room or kept protected. Before they are treated with a bleach solution, the food processing equipment and utensils must be thoroughly washed and then rinsed with clear, cold water. The bleach solution used for sanitizing must not exceed 200 ppm (parts per million) available chlorine. (Use chlorine test strips to adjust to 200 ppm available chlorine.) -or- Use the Dilution Table to make the desired dilution. [Use chlorine test strips to quantify the available chlorine. If the available chlorine is less than desired, add a small amount of product slowly and carefully to the dilution and determine the available chlorine with a fresh chlorine test strip. Repeat these steps, as needed, until the desired concentration of chlorine is achieved.] The bleach solution must be applied by spraying, soaking or scrubbing. Treated surfaces must remain wet for at least 2 -or- two min[utes]. A potable water rinse is not required, provided the equipment and utensils are adequately drained before they come into contact with food. Little or no residue must remain to adulterate or otherwise affect edible products."

 

Above is the EPA reference, stating no rinse necessary on food equipment at the recommended dilution ppm.  Sodium hypochlorite at 200 ppm or less is standard in the food industry for no rinse for hard surface food processing equipment. I was not able to determine which video on the Clorox website you are pointing me towards.  The technical services department at Clorox has told me that the specific item we are using, and the ppm recommended, is the only product they will recommend for the food industry, in teh manner we are using it.  I also have a list of the ingredients for the product, and it doesn't contain fragrance, if that was a concern?  I'm unsure of the meaning of your last post.  



Charles.C

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Posted 06 May 2022 - 07:05 AM

EPA  - "PPD PUMA (EPA Reg. No. 67619-32) [REGISTERED AS Insert Registered Alternate Brand Name] FOR SANITIZING SOLUTIONS FOR EQUIPMENT AND UTENSILS It is a violation of Federal law to use this product in a manner inconsistent with its labeling. Labeling must be in possession of user at time of application. Read and follow label affixed to the container. Refer to container label for use precautions and further information. This product is authorized for use as a sanitizing solution in official establishments operating under the USDA meat, poultry, shell egg grading and egg products inspection programs. Before using this product, food products and packaging materials must be removed from the room or kept protected. Before they are treated with a bleach solution, the food processing equipment and utensils must be thoroughly washed and then rinsed with clear, cold water. The bleach solution used for sanitizing must not exceed 200 ppm (parts per million) available chlorine. (Use chlorine test strips to adjust to 200 ppm available chlorine.) -or- Use the Dilution Table to make the desired dilution. [Use chlorine test strips to quantify the available chlorine. If the available chlorine is less than desired, add a small amount of product slowly and carefully to the dilution and determine the available chlorine with a fresh chlorine test strip. Repeat these steps, as needed, until the desired concentration of chlorine is achieved.] The bleach solution must be applied by spraying, soaking or scrubbing. Treated surfaces must remain wet for at least 2 -or- two min[utes]. A potable water rinse is not required, provided the equipment and utensils are adequately drained before they come into contact with food. Little or no residue must remain to adulterate or otherwise affect edible products."

 

Above is the EPA reference, stating no rinse necessary on food equipment at the recommended dilution ppm.  Sodium hypochlorite at 200 ppm or less is standard in the food industry for no rinse for hard surface food processing equipment. I was not able to determine which video on the Clorox website you are pointing me towards.  The technical services department at Clorox has told me that the specific item we are using, and the ppm recommended, is the only product they will recommend for the food industry, in teh manner we are using it.  I also have a list of the ingredients for the product, and it doesn't contain fragrance, if that was a concern?  I'm unsure of the meaning of your last post.  

Hi ORF,

 

Thanks for the quotation.

 

As I initially suspected (feared?), this topic seems to be a highly complex area particularly in respect to EPA's involvement.

 

I was unable to locate the EPA extract as quoted above, is there a  link available ?

 

I have done a little digging into the product under discussion with some seemingly rather surprising results. (I include the "seemingly" since I make no claim to be an expert in this area and the following should be regarded as speculative).

 

The attachment in yr Post 8 may not be the latest Product Information for item under discussion (?). I attach a seemingly more detailed document below (Cx1). The information within is in some respects significantly different to that in the attachment of Post 8. (See Comments below).

Attached File  Cx1.pdf   5.5MB   1 downloads

 

This encyclopedic document (Cx2) is the latest (2020)  EPA Registration confirmation/description of  Product I could find.

Attached File  Cx2.pdf   964.48KB   1 downloads

 

The Regulatory control for sanitizers in USA appears quite "subtle"  eg -

 

Do chemical sanitizers used on surfaces in direct contact with food (food contact surfaces) have to be FSIS approved for use in the establishment?

No. Food Safety Inspection Service (FSIS) no longer approves or lists approved sanitizers. Sanitizers are reviewed and approved by Environmental Protection Agency (EPA) and Food and Drug Administration (FDA). Prior to approval and registration, the EPA reviews efficacy and safety data and product labeling information. FSIS relies on manufacturers and distributors to provide information to establishments regarding the antimicrobial activity or efficacy, safety of residues on food contact surfaces, environmental safety, and conditions of use. See 9 CFR 416.4©. The FDA is primarily involved in evaluating incidental residues or food additives from sanitizer use which may enter the food supply. Thus, any antimicrobial agent and its maximum usage level for direct use on food or on food product contact surfaces must be approved by the FDA. Approved no-rinse food contact sanitizers and non-product contact sanitizers and their formulations and usage levels are listed in the Code of Federal Regulations (21 CFR 178.1010). In 1999, the National Sanitation Foundation started to maintain the "White Book™ - Nonfood Compounds Listing Directory".

https://ask.usda.gov...urfaces-have-to

 

This is an extract from Cx2

Attached File  Cx2 - extract.PNG   421.8KB   0 downloads

 

A few Observations/Comments

 

(1) Above Cx2 extract basically agrees your "no rinse" quote (ie see "air dry") but your quoted text appears to include additional text (USDA? NSF?). I have no idea as to how one could evaluate the "Little or no residue etc" comment. Seems designed for "back-covering".

 

(2) The choice of contact times involved may relate to target species as illustrated in the substantially "modified" attachment Cx1 (also see Cx2 regarding species).

 

(3) There seems to be a quantitative discrepancy in the dilution procedure given for sanitizing FCS in the attachment in Post 8. Basically 1 tbsp (Pg4) does not equal 2 tsp (Pg3), the latter as also given in Cx1, Cx2 (in fact 1 tbsp = 3 tsp)(It is possible that Pg4 is referring to a Clorox bleach of different, ie lower, % concentrate than Pgs 1-3)

 

(4) Note the surfaces in Cx1 (Pg8) where product can be "safely" used.  Also this "miscellaneous"  comment in Cx2 - [DO NOT USE ON NON-STAINLESS STEEL, ALUMINUM, SILVER OR CHIPPED ENAMEL.]

 

Video mentioned in Post 13  is here and yes, my comment was directed to fragrance.

 

My last comment in Post 13 reflected my deduction that in this specific case NSF are only a Secondary source regarding Product Safety whereas EPA, (and perhaps USDA, FDA ) are the Primary Agents. This contributed to my "surprise" at the apparent  NSF support for direct use of this Product on food (albeit with subsequent rinsing). 

 

I have various reservations over the NSF document however when appropriately implemented, the product seems well supported/documented by EPA. for use on FCS. I would like to know what the other 90% of non-active materials in the product are though.


Kind Regards,

 

Charles.C






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