9 replies to this topic

[hannahharo]

I work for a beverage manufacturer that makes several different types of mixer concentrates. We were approached by a customer who is interested in purchasing a beverage line cleaner through us (we currently only manufacture food products) because their supplier is unable to keep up with demand. This beverage line cleaner is made up of three ingredients: water, citric acid, and a surfactant. I am curious to see if there are any companies out there that do this sort of thing: manufacture both food and chemical products? I feel like this is a much larger undertaking than just mixing those three ingredients in a tank and filling containers and I'm not really sure where to start my research other than this forum!

 

My initial thoughts to make this happen:

-need to revamp our food safety programs to include this new process (we would be using the same equipment for both food products and the new cleaning product)

-need to verify and validate that the new cleaning solution is effective in cleaning 

-need to verify and validate that this new process will not contaminate our food products: RMs and FGs. 

-need to register new product with NSF 

-need to update our registration with FDA 

 

Any insight would be appreciated. Thank you!

 

 

 

[Scotty_SQF]

I'm not in the beverage industry, however I have worked in food and I can't imagine ever considering making a line cleaner product on the same lines as my food product.  It just make the waters muddy so to speak as far as all of your programs and such and makes extra work.  

 

The only advice I could provide is do your due diligence on this line cleaner.  You have to make sure this can in no way effect your equipment, is toxic, etc.  Looks like you have already started on that avenue.  Are you currently certified under a GFSI scheme? 

[hannahharo]

Thank you for your response! We are SQF certified. 

 

 

I'm not in the beverage industry, however I have worked in food and I can't imagine ever considering making a line cleaner product on the same lines as my food product.  It just make the waters muddy so to speak as far as all of your programs and such and makes extra work.  

 

The only advice I could provide is do your due diligence on this line cleaner.  You have to make sure this can in no way effect your equipment, is toxic, etc.  Looks like you have already started on that avenue.  Are you currently certified under a GFSI scheme? 

[jdpaul]

I tend to take more of an apologist approach to these sort of things. Some questions I think about for this are:

 

• If you can run a non-allergen product on a dedicated allergen line why couldn't you have an effective changeover procedure for this? What is different about this that makes the risk greater than the allergen scenario?
   
• What are your biggest risks? Residual carry-over - but by what? water and citric acid are both widely used in food - what about this surfactant? What is its makeup/composition? 
   
• Do you have a CIP Skid? If so, do you believe it will be effective at removing residual? Do you have internal test methods you can use to verify the changeover as effective?

[Scampi]

NO NO NO

 

Someone here once asked the same question, but the non food was laundry detergent and they received the same response. NO

 

how are you ever going to prove that all the surfactant has been removed from your line

 

How would you ever get ALL the ingredients from the manufacturer?  They are all they have, and would never part with the list (nor do they have to) so you wouldn't even be able to validate, because you wouldn't know what you're dealing with

 

The FDA determination of "adulterated" is quite broad-------------would you be able to defend your self?????

[hannahharo]

I am interested in your response. We are obviously not dealing with laundry detergent    this product that we are looking to duplicate is used in restaurants and bars and connects to bar guns to flush and clean the system. If we are trying to duplicate a "food safe" cleaner what is the difference in using our equipment to manufacture this vs. a normal clean and sanitize step between our beverage concentrate batches? Isn't there the same risk associated with potential sanitizer in our finished products as there could be with this new beverage cleaner potentially in our finished products? 

 

What is the difference? Genuinely curious.

 

 

NO NO NO

 

Someone here once asked the same question, but the non food was laundry detergent and they received the same response. NO

 

how are you ever going to prove that all the surfactant has been removed from your line

 

How would you ever get ALL the ingredients from the manufacturer?  They are all they have, and would never part with the list (nor do they have to) so you wouldn't even be able to validate, because you wouldn't know what you're dealing with

 

The FDA determination of "adulterated" is quite broad-------------would you be able to defend your self?????

[Scampi]

Concentration is the problem (along with optics)

 

I'm assuming the product your wanting to make would be diluted by the end user

 

AND if you're using approved chemicals to clean and sanitize, they will have jumped through some hoops (NSF etc.) to get some sort of recognition that there product is approved for use on food contact surfaces at the prescribed concentrations

 

FDA should be asking you to see the product spec sheets for what you are using to clean and sanitize (in every food manufacturing facility)   and I'm pretty sure if you read all the fine print regarding your FDA registration, this won't be allowed

 

and if I follow your line of thinking, I should be ok buying juice from a chemical manufacturer because they manufacture chemicals to be used in food processing?

 

 

If you think you do not fall under this category below, then the choice is yours

7. When is a food considered adulterated under Section 402 of the FD&C Act?

Section 402 of the FD&C Act includes many reasons a food may be adulterated including:

• If the food bears or contains any poisonous or deleterious substance which may render it injurious to health; consists in whole or in part of any filthy, putrid, or decomposed substance, or is otherwise unfit for food; or has been prepared, packed, or held under insanitary conditions whereby it may be rendered injurious to health;

• If the food is a dietary supplement or contains a dietary ingredient that presents a significant or unreasonable risk of illness or injury under the conditions of use recommended or suggested in labeling; is a new dietary ingredient for which there is inadequate information to provide reasonable assurance that such ingredient does not present a significant or unreasonable risk of illness or injury; or is a dietary supplement declared by the Secretary to pose an imminent hazard to public health or safety.

[SHQuality]

My first question would be: what is the surfactant that is used? 

If I were to do this, I would keep this process separated from all other processes to avoid any risk of contamination.

It sounds like too much of a cost and hassle to do for just one customer...

[hannahharo]

We are still in verrrry preliminary stages of this so right now I'm unsure. But I agree, it does seem like a lot of work for only one customer. I am thinking if we were to move forward, we would need a dedicated tank and hoses/fillers/etc. for this process to eliminate possible contamination hazards.

My first question would be: what is the surfactant that is used? 

If I were to do this, I would keep this process separated from all other processes to avoid any risk of contamination.

It sounds like too much of a cost and hassle to do for just one customer...

[SHQuality]

By the way, I thought about contamination of your own beverage product, but that works the other way too. You don't want the cleaner to be contaminated with beverage syrup either.