Hand Sanitizers

How does the Canada Organic Regime (COR) standard apply to hand sanitizers?

By Jimmy Trasport

During the course of the COVID-19 pandemic, people became very familiar with hand sanitizer products. Under the Canada Organic Regime (COR) standards, there are special considerations for using such products in organic processing and handling.

Hand sanitizers most commonly use ethyl alcohol (ethanol), isopropyl alcohol or benzalkonium chloride as their active ingredients. Some products contain ethanol and water as primary ingredients, and glycerine as an inert ingredient. Many also contain additional inert ingredients, such as aloe vera, propylene glycol, carbomers (synthetic polymers), triethanolamine, and fragrances, including botanical essential oils. 

CAN/CGSB 32.310 8.1.2(a) identifies hand sanitizer products as “incidental additives” if used in direct contact with organic products, and requires that they be composed of substances appearing on Table 7.3 of the Permitted Substances List (PSL) for use without a mandatory removal event. In this way, ingredients used in hand sanitizers that make direct contact with organic products are held to the same standards as other sanitizers used on food contact surfaces, such as cutting boards, augers or conveyer belts without a removal event.

No-rinse hand sanitizers are technically within OMRI’s scope of review, although there are currently no hand sanitizers listed by OMRI. In terms of compliance criteria, all ingredients in a hand sanitizer must appear at PSL Table 7.3, and must meet any annotations regarding their source or manufacture. Ethanol and isopropyl alcohol appear at Table 7.3 as materials permitted on food contact surfaces. Glycerin sourced from vegetable or animal fats and/or oils, produced using fermentation or by hydrolysis, is also an allowed material appearing at PSL Table 7.3. Conversely, no-rinse hand sanitizers containing benzalkonium chloride, carbomers, or botanical substances such as essential oils and aloe vera gel are prohibited from making contact with organic produce in Canadian organic production, because Table 7.3 does not have an entry explicitly allowing their use. 

CAN/CGSB 32.310 also allows the use of cleaners, disinfectants and/or sanitizers for which a removal event is mandatory. These materials are found at PSL Table 7.4 and include soaps. Hand and equipment cleaners whose labelled use instructions include demonstrably effective methods to prevent contact between organic food and prohibited substances, and contain ingredients identified in Table 7.4, are within the scope of OMRI review. On the other hand, OMRI does not review or list cleaners, disinfectants and/or sanitizers not appearing at PSL Tables 7.3 or 7.4, although such products may be allowed in Canadian organic production under CAN/CGSB 32.310 subclause 8.2.3. A certification body must determine if and how these materials may be used. 

In addition to the COR standards and OMRI standards, other national, federal, state and local laws and regulations may apply to the use of materials in organic operations. OMRI makes no representation that OMRI Listed® products comply with any of these other requirements. It is the user’s responsibility to determine the compliance of a particular substance with all applicable laws and regulations. As always, a certification body must approve the use of any substance in an organic operation.

This article was originally published in the winter 2021 edition of the OMRI Materials Review newsletter, and was revised in December 2022 by Senior Bilingual Technical Coordinator Tina Jensen Augustine.