Cleaning Verification Activities
Greetings.
Like most others, my team verifies C&S by swabbing. Will this be enough to exempt testing the concentration of diluted chemicals? (We test the concentrations of sanitizers only currently).
A past auditor highlighted our failure to verify the sanitizer concentration in the past, but not the cleaning chemicals. Oversight perhaps?
Any thoughts is much appreciated.
Ideally you are testing both
the best reason to test is effectiveness-----sanitizers cannot work through leftover cleaning chemicals
the second best reason to titrate cleaning chemicals is cost, cost of the chemical for using too much and labour costs for either too much manual scrubbing OR too long rinsing a chemical that was applied too heavy
I understand the idea of only verifying the sanitizer titrations if your argument is that you rinse the cleaners off and under diluted soaps pose no risk to product. But depending on which GFSI code you're under, you're required to use all cleaning chemicals per manufacturer's instructions. In SQF for example, requirement 11.2.5.3 states "Detergents and sanitizers that have been mixed for use shall be correctly mixed according to the manufacturers’ instructions, stored in containers that are suitable for use, and clearly identified. Mix concentrations shall be verified and records maintained."
Beyond any GFSI requirement, allowing cleaning chemicals to be used in stronger than recommended concentrations puts your employees at physical risk for fumes and skin irritation or burns. Lawsuits for eye damage if they're injured by using a chemical mixed incorrectly. And you'll spend more money on chemicals mixed too strongly. And when mixed under recommended concentrations, any pathogen reduction claims made by that chemical are invalidated and surviving microorganisms might not be spotted by your chosen swab verification method.
I understand the idea of only verifying the sanitizer titrations if your argument is that you rinse the cleaners off and under diluted soaps pose no risk to product. But depending on which GFSI code you're under, you're required to use all cleaning chemicals per manufacturer's instructions. In SQF for example, requirement 11.2.5.3 states "Detergents and sanitizers that have been mixed for use shall be correctly mixed according to the manufacturers’ instructions, stored in containers that are suitable for use, and clearly identified. Mix concentrations shall be verified and records maintained."
Beyond any GFSI requirement, allowing cleaning chemicals to be used in stronger than recommended concentrations puts your employees at physical risk for fumes and skin irritation or burns. Lawsuits for eye damage if they're injured by using a chemical mixed incorrectly. And you'll spend more money on chemicals mixed too strongly. And when mixed under recommended concentrations, any pathogen reduction claims made by that chemical are invalidated and surviving microorganisms might not be spotted by your chosen swab verification method.
Thanks for your response. We have a stringent dispatching/authorization use for the chemicals. I really wanted to ensure there are no loopholes especially since the auditor did not point it out (I anticipate some resistance from management for the test kit purchases). Wish me luck!
Bit late but Standard = ??!
Due the total absence of Product/Process/Sanitizer Information all comments are surely speculative .
It also depends upon the chemical supplier and the service contract that you have signed with them.
Some large reputable companies charge more for the same or similar chemicals, but they also supply a lot of service as well, like monthly monitoring/titration of the chemical concentration, both detergents and sanitizers. This is very nice to both keep your sanitation SOP consistent and your sanitation crew stable and happy with the performance of the chemicals. QA will still need to check sanitizer concentration daily, and also periodically validate the detergent concentrations in-house through titrations, but much less often. You can often call upon the Rep to come out and retest if you think your usage levels have changed.
Some more budget chemical supply companies do the bare minimum, basically dropping off the chemicals and maybe monitoring usage. The cost much less, but your QA and/or Sanitation department then needs to do the testing/monitoring and validation, and they will need the related testing kits and the training to properly use them.
So management will have accept paying for it is some way, either the service or the equipment and training to do it in-house. One of the biggest tools I had was the SSOP that was written by me but approved by management. What they had approved in writing, we had to show proof that we carried it out to the auditors satisfaction. If management wanted to change it, I had to rewrite it and get it reapproved by management on a procedure change form. That way I had it in writing no matter what.
If the auditor suggested a change, I might review your Risk Assessment program in that area to see if you are missing a possible hazard.
Verifying the Sanitizer concentration is always advisable, feasible & reliable.