Sanitizers

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

By Jennifer Ludwig

The National Organic Program (NOP) regulations include a “National List” of materials that are exceptions to the basic rules of what is allowed or prohibited in organic production. The National List is outlined in §§205.601–205.606. Within the scope of organic processing, materials are allowed as inputs for organic products if they are at least one of the following: certified organic; nonagricultural and present on the National List at §205.605; or agricultural and present on the National List at §205.606. All other materials are considered “non-National List materials,” and are typically prohibited for use in organic products. The NOP regulations at §205.272 permit the use of non-National List materials, provided that measures are taken to prevent the commingling of organic and nonorganic products, and to protect organic products from contact with prohibited substances.

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.

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, and the NOP advises that this rinse step should be sufficient to prevent contamination of organic products from prohibited cleaner residues.

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. To be allowed in organic production, persistent synthetic residues must be present on the National List, or else the use of an intervening event that removes the residue from the food contact surface is required.

A cleaner or sanitizer product that contains non-National List materials can be OMRI Listed®. OMRI policy requires that the product displays use instructions that end users can follow to prevent contamination with prohibited substances in or on organic foods. Examples of use instructions include a potable water rinse step or a system flush. Events such as drip dry are only acceptable when the materials will evaporate without leaving a residue (e.g., isopropyl alcohol). The OMRI Products List© uses two categories to list these product types: “Sanitizers, Disinfectants and Cleaners” and “Detergents.” Products listed in these categories carry an Allowed with Restrictions status, which communicates the regulatory requirements at §205.272.

This article was originally published in the Summer 2019 edition of the OMRI Materials Review newsletter.