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.
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).
This encyclopedic document (Cx2) is the latest (2020) EPA Registration confirmation/description of Product I could find.
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".
This is an extract from Cx2
Cx2 - extract.PNG 421.8KB
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.