Sanitizers

How are non-National List materials reviewed for compliance as sanitizers?

By Jennifer Ludwig

It is essential to clean and sanitize specific control points, equipment and tools used in the processing of food. Federal and local health authorities require such practices in commercial production. Producers use two types of products for this necessity:

Cleaners and detergents are substances used to remove dirt and foreign matter from food-contact surfaces. They are designed to be rinsed from food contact surfaces.

Sanitizers and disinfectants differ from cleaners, as they are substances used on clean surfaces to destroy microorganisms of significance to public health, and to substantially reduce other undesirable microorganisms. Sanitizers are designed to leave an anti-bacterial residue on food contact surfaces.

The National Organic Program (NOP) regulations include a “National List” of materials are allowed and prohibited in organic production. The National List is outlined at §§205.601–205.606. Within the scope of organic processing, materials are allowed as inputs for organic products if they are:

• certified organic;
• nonagricultural and present on the National List at §205.605; or
• agricultural and present on the National List at §205.606, when not commercially available in organic form.

All other materials are considered “non-National List materials,” and are typically prohibited for use in or on organic products. Any persistent residues that come into contact with organic products must be present on the National List. However, the use of non-National List materials may be permitted  provided that measures are taken to prevent their contact with organic products.

The NOP regulations at §205.272 outline the prevention practice standard, which state that  organic products must be protected from commingling and contact with prohibited substances. The use of an intervening event that removes the residue from the food contact surface, like a potable water rinse step or a system flush, can be sufficient to prevent contamination of organic products from prohibited cleaner residues. Events such as drip dry are only acceptable when the materials will evaporate without leaving a residue (e.g., isopropyl alcohol).

A cleaner or sanitizer product that contains non-National List materials is out of OMRI’s review scope. Only a certifying agent can evaluate on-site cleaning procedures and facility use conditions to determine if they sufficiently prevent contact with prohibited substances.

This article was originally published in the Summer 2019 edition of the OMRI Materials Review newsletter. It was revised and updated in October 2025 by Jacky Castañeda.