Checking for cleaning chemical concentrations

Our facility uses a mixing station for automatic dilution of our cleaner and sanitizer. As usual, in the course of a recertification audit, Auditor C has issues that Auditors A & B (from prior years) did not have. This year Auditor C wants to know how we confirm that chemical concentrations are correct. QUESTION: How do you check cleaners that are automatically diluted for proper concentration? I see test strips for sanitizers but not for cleaners.

Furthermore, Auditor C stated that no information was available saying that the chemicals (we use) are approved for use. The chemicals that I am using are from a company that markets their product specifically for the food service. The supplier's product sheet clearly states that the product is for the food service. Auditor C says, " yes - but WHO told the supplier that it is ok for food use?"

Has anyone else had any experience with Audior C?

BTW our facility is considered low risk. We make a food contact product and have no food stored or processed in our facility.

-slim

I would advise first, you look at your cleaner's MSDS, you will see if it is a mild or a strong alkali, if it bears a pH above 7, let say 8.5, it will change colour of phenolphthalein from colourless to purple, so just take a sample during rinsing and at some drops to look for colour change, when you rinse water no more contains cleaner trace, there will be no more colour change, 

write a procedure and a check sheet for the above i think will be ok,

now for the  chemical, ask your supplier to request from his main supplier a certificate of analysis, an msds, and letter or certificate that the product is food grade basing on the certificate of analysis.

kind regards,

Michael G

Slim,

First off to IFSQN!

Now to your question.  You can't do some blind testing such as Michael has suggested.  The best way to proceed is to directly contact the chemical company that is selling you the chemical and find out how you are supposed to test the concentration of the cleaning chemical.  This may require titrations or some other set test they have.  In the yogurt plant I worked at we had the cleaning chemicals checked through titrations for the most part.  Whatever method you use should be one that is verified by the company as the appropriate way to test it and have documentation from the company on the test procedure and the frequency it should be checked.

They are your supplier they need to help you with this.

Hi, Mr Incognito,

you are right, i am trying to help and has been too brief in my description of my proposed idea, but i am sure that through the cleaner's msds at least we will start understanding what is in our hand and in front of us, 

as far as Slim's cleaner supplier is concerned, i am having the impression that they are distributors of main supplier. often very difficult to reach them,

thanks again for your idea,

Please accept my sincere apologies Slim 

kind regards,

Michael G

Well every system is different but sometimes being brief may not give all of the pertinent information that has to be considered.

We had foot foamers and a CIP system where we purchased all of our chemicals from Ecolab I believe.  The Ecolab rep would come and check on us now and then to make sure we had all of our titration chemicals in stock and that everything was working properly.  He provided us with the titration kit and instructions on how to properly perform all of the titration tests.

I don't know if Slim's system is at all the same but it gives him a good idea of things to look at.  Yes the MSDS (SDS) of a chemical should have information but the best practice, especially when working with a GFSI scheme if you are under one, is to have all of the pertinent test documentation from your supplier.

Is this a third party auditor or a customer?  First I agree with Mr. I.  Your chemical company needs to help you and they should be able to get the documentation that says this is okay for food use.  I am curious is this a well known brand or a smaller company?  If an unknown or unusual item then perhaps I can see the auditors point.  If this is a usual and/or known product then think the auditor is being a jerk. 

If this is a customer, not much to be done but try and unruffled their feathers get them the information they need.  But if this is a 3rd party audit, and this a known brand or product then I would possibly be inclined to say something to the company who sent them in. 

No apologies necessary Michael. I appreciate your input.

Thanks for the welcome Mr. I. I'm currently looking at a different product line (same local rep). Cleaner has a pH of 13.0 to 13.9 with a light soil dilution rate of 1:100. I'm not sure what the automatic dilution equipment is set for.

Thinking maybe I should find a supplier that can educate me rather than vice versa.

-slim

Now if only someone could quantify the definition of "PURE" compressed air.

-slim

No apologies necessary Michael. I appreciate your input.

 

Thanks for the welcome Mr. I. I'm currently looking at a different product line (same local rep). Cleaner has a pH of 13.0 to 13.9 with a light soil dilution rate of 1:100. I'm not sure what the automatic dilution equipment is set for.

 

Thinking maybe I should find a supplier that can educate me rather than vice versa.

 

-slim

Having a supplier that understands your environment and be of help is always a good thing.  This is sometimes the advantage of the some the bigger chemical companies, is that have all the necessary documentation and people who help deal with difficult auditors and regulators.  Very often these people will not want to argue with the big guns. 

Good chemical suppliers should be able to help you with this.  Was the automatic diluter supplied by your chemical company or did your company buy it themselves?  Typically the chemical company will install one for you and it will operate within the specifications they programmed it with.  And they should be able to tell you how to properly test the cleaning chemical coming out to ensure that it is at the proper dilution factor.

Thanks Mr I, your point is very helpful and obvious.

Slim with a pH 13.0 to 13.6, again I will give a brief Idea, to have a portable pH meter, know your rinse water pH then check with a simple procedure. but keep all records. in the mean time.

But  it urge you do as Mr I stated above.

so that to be precise 

Kind regards,

Michael G

1)here in Canada we require our supplier to be listed under CFIA Reference Listing of Accepted Construction Materials, Packaging Materials and Non-Food Chemical Products and, the listings are as to what the chemical is meant for. NSF also offers that service. That's means somebody else reviewed the chemical  because  having something  marketed for food doesn't necessarily mean it can be used on/ close to food.

2) usually in all chemicals there is a subcomponent that can  be tested - usually by titration- here we require our supplier to do a check every 2 weeks and offer us a  report and we also do a titration (internally)  every 2 weeks a. and, yes your chemical supplier must be a resource

3) checking the concentration (pH) of the undiluted chemical could also be a verification of your incoming product (chemical) and normally you do that once a year

Our facility uses a mixing station for automatic dilution of our cleaner and sanitizer. As usual, in the course of a recertification audit, Auditor C has issues that Auditors A & B (from prior years) did not have. This year Auditor C wants to know how we confirm that chemical concentrations are correct. QUESTION: How do you check cleaners that are automatically diluted for proper concentration? I see test strips for sanitizers but not for cleaners.

 

Furthermore, Auditor C stated that no information was available saying that the chemicals (we use) are approved for use. The chemicals that I am using are from a company that markets their product specifically for the food service. The supplier's product sheet clearly states that the product is for the food service. Auditor C says, " yes - but WHO told the supplier that it is ok for food use?"

 

Has anyone else had any experience with Audior C?

 

BTW our facility is considered low risk. We make a food contact product and have no food stored or processed in our facility.

 

 

-slim

Dear slim,

a little more context mght help.

cleaner = ?

business = ?

US jurisdiction = ?

method for estimation of concentration =  f ( chemical composition, etc)

unsure ?, > supplier

Auditor C is probably nit-picking unless yr documentation is unconvincing or yr unknown product/business  is "sensitive".  difficult to comment much more IMO without context.

Rgds / Charles.C

I'm kind of surprised auditors A & B missed it...but I guess like auditors our focus is all different.  You have to check concentration.  Like every day.  It's super easy though -

1.  As others have advised, get a test kit from your supplier.  If your supplier can't give this to you, get a new supplier.   They are easy to use, normally strips or titration.  Makes sure if you get strips they are within the range you need.  They should also have a letter from the NSF (or similar agency) stating safe use, and concentrations etc should be listed on a technical sheet.  Many suppliers offer free training. 

2. Spreadsheet with date, time, concentration, signature/initials by the sink.  Limits are the concentrations on the label.  Takes one employee 1 or 2 minutes a day. 

3.  If chemicals fall outside of range, stop the water, and don't use the sink until it is corrected.  Make sure to include in your HACCP plan as a chemical hazard & review the log. 

1)here in Canada we require our supplier to be listed under CFIA Reference Listing of Accepted Construction Materials, Packaging Materials and Non-Food Chemical Products and, the listings are as to what the chemical is meant for. NSF also offers that service. That's means somebody else reviewed the chemical  because  having something  marketed for food doesn't necessarily mean it can be used on/ close to food.

 

 

 

 

 

 

Unfortunately for us Canadians this is changing. As of this summer the CFIA will no longer be updating the Reference Listing, meaning that those of us who relied on covering ourselves by saying the product was on the list will not be able to do this anymore. Going forward purchasers will have to provide their own evidence of the acceptability of these materials, whether that be by referencing the old Reference Listing, requesting a Letter of Guarantee from the supplier, or receiving a Letter of No Objection/Acceptance from the CFIA.

 

 

 

 

 

"Auditor C says, " yes - but WHO told the supplier that it is ok for food use?"

You could audit your supplier's auditor.  I would also audit Auditor C's credentials.  Maybe I would audit Auditor C's knowledge of cleaning compounds.

Ok, I'm a bit surly this morning.  Letter of guaranty or statement on the technical data sheet has been sufficient for me thus far, and that's been through 3rd party, customer, FSSC22000 and SQF.  There's another thing too, it could be your systems are so well or over-designed and implemented, Auditor C is grasping at straws - they have to find *something* to put on their audit report.

One other thing, if you have a shady chemical supplier, that could prompt Auditor C's suspicions.  In that case, I can understand Auditor C shakin' you down.

It has always been my understanding that when an auditor talks about approved chemicals, they are looking for a list of chemicals that has been approved by me, Food Safety, Quality & Sanitation Manager.  We have a policy stating what requirements must be met in order to approve a chemical.  All of the documentation already mentioned are in these requirements.  There is also a seperate list of approved maintenance chemicals.  These are approved by the Maintenance Manager.   

You only need to verify concentrations of chemicals that will impact food safety.  For example, glass cleaner used in offices need not be verified. 

In regards to the second question, you can check whether the cleaning agent has an NSF registration (nsf.org). Chemical manufacturers can have their compounds assessed by NSF which will tell them whether it is a food grade chemical and it also states where it can and cannot be used and the conditions it must be used under. We found it very helpfull and only buy chemicals that are NSF registered.

It has always been my understanding that when an auditor talks about approved chemicals, they are looking for a list of chemicals that has been approved by me, Food Safety, Quality & Sanitation Manager.  We have a policy stating what requirements must be met in order to approve a chemical.  All of the documentation already mentioned are in these requirements.  There is also a seperate list of approved maintenance chemicals.  These are approved by the Maintenance Manager.   

 

You only need to verify concentrations of chemicals that will impact food safety.  For example, glass cleaner used in offices need not be verified. 

Dear Miss Tammy,

IMO, from an auditors POV, It's basically a question of validation.

And, after seeing an infinite number of  anon. cleaners, quite rightly so !

Rgds / Charles.C

PS -actually i thought there was an official approved list in USA ?

3.  If chemicals fall outside of range, stop the water, and don't use the sink until it is corrected.  Make sure to include in your HACCP plan as a chemical hazard & review the log. 

I agree with your post except it seems that more information and an assessment are required before including in the HACCP plan. It is more likely to be controlled by a prerequisite programme.

Regards,

Tony

I agree with your post except it seems that more information and an assessment are required before including in the HACCP plan. It is more likely to be controlled by a prerequisite programme.

 

Regards,

 

Tony

Touche - I should have said QMS - In my facility it is controlled by PRP (Chemical Control Program)

Does anyone have a sample of the log they use for this?