Is there a ‘master list’ of cleaners and sanitizers we can use to clean equipment prior to Organic processing?
–A Curious Manufacturer
Dear Curious Manufacturer: Unfortunately no, there isn’t! Such a list would be impossible to maintain since it would involve tracking and evaluating every new cleaner and sanitizer product that comes out on the market. There are, of course, organizations like OMRI that review substances for use in organic production, but the OMRI list only includes those products containing ingredients that are already on the National List. We’ll explain what that means below.
Evaluating cleaners and sanitizers for use in organic production is based upon 1.) How & where the substance will be used in the organic facility, and 2.) The formulation of the cleaning or sanitizing agent. When considering a new cleaner or sanitizer, remember that your certifying agent (OneCert!) must evaluate all new cleaners or sanitizers prior to use by looking at a label and Safety Data Sheet and reviewing other information you provide about its ingredients and how it will be used in your facility.
There are substances on the National List (205.605) that are allowed for applications where the sanitizer may have minimal “food contact.” Substances on the National List for these purposes include hydrogen peroxide, peracetic/peroxyacetic acid, and chlorine materials. These substances are allowed for use as equipment sanitizers without a “removal event” (such as a rinse) occurring prior to organic production. Be aware of the restrictions noted in the National List for use of each of these materials. There are other cleaners on the National List which do require removal events, like phosphoric acid. Manufacturers’ instructions for the use of materials must be followed with regard to removal of these substances prior to organic production.
Other than those substances on the National List, cleaning agents must be removed from food contact surfaces via some method (either a rinse or evaporation in the case of ethanol/isopropyl alcohol) prior to organic products contacting the equipment. This is because cleaning agents can’t be permitted to contaminate the organic product with residues. In most cases, a rinse is sufficient to remove sanitizing substances from a food contact surface, however, some substances–like quaternary ammonia compounds–leave residues with persistent germicidal action even after the equipment is rinsed. In those cases, a protocol for removing the substance completely from the equipment must be developed by your facility and residue testing using “quat strips” must be implemented to prove that the surface is free of residual cleaning compounds.
So, cleaners and sanitizers fall into four basic categories depending upon their formulation:
1.) those on the National List which do not require a removal event
2.) those on the National List which do require a removal event
3.) those not on the National List which require a removal event
4.) those substances with residual antimicrobial action which require a removal event and residue testing (such as quaternary ammonia compounds [quats]).
We hope this helps you clarify how to choose the appropriate cleaners and sanitizers for your particular application.
Best Wishes,
–OneCert