Swabs of processing surfaces, a standard procedure in any plant, take on added significance in an organic one. Photo: PSSI
The choice of cleaning and sanitizing chemicals is determined by how they’ll be applied. The two terms are often used interchangeably, but strictly speaking, cleaning refers to the removal of dirt, residue or other extraneous material from a surface; sanitizing means applying a biocide like bleach or acid to a clean surface to keep it free of microorganisms like bacteria.
In general, there is a wide leeway for which cleaning chemicals can be used in organic plants, because cleaning chemicals are almost invariably rinsed off. That is not, however, always the case with sanitizers.
“Chemistry made from materials not on the NOP national List are not allowed to come in direct contact with organic food, so these can only be used if there is an effective means to prevent the [chemicals] from coming into contact with organic food,” Stokes says. Rinsing them away before food contact is allowed would be one means.
To rinse or not?
The FDA’s document on organic cleaners and sanitizers explicitly states that “the cleaning agent itself is not required to be organic” and that “unlike sanitizers...cleaners and detergents are designed to be rinsed off, and a subsequent rinse step is sufficient to prevent contamination of organic foods from synthetic cleaner residues.”
Sanitizers are another story. “Some commonly used sanitizers in food production are considered prohibited,” says Shannon Murphy, a consultant with The Organic Consulting Firm, a certification agency for organic status. “An operation may still use the material but there must be an intervening step between the use of the material and organic production.”
That intervening step is rinsing. If sanitizers are to be used in an organic plant, they fall into two basic categories under FDA regulations: those that must be rinsed off, and those that don’t need to be.
Both kinds include commonly used varieties of sanitizers. In the no-rinse category are peracetic/peroxyacetic acid, chlorine (in proper concentration), hydrogen peroxide, phosphoric acid and other substances. In the must-rinse category go acetic acid, ethyl or isopropyl alcohol, quaternary ammonia, vinegar, citric products and more.
“An operation may choose to use quat [quaternary ammonia], but prior to organic production will need to rinse the equipment to remove any remaining quat from the food contact surfaces,” Murphy says.
It’s a consequential decision. Using a sanitizer that has to be rinsed off increases both labor and water use. In addition, most sanitizers are intended not to be rinsed off; the point is that they leave traces behind that combat microbial contamination on an ongoing basis. Rinsing them off can compromise their effectiveness in this regard.
Pesky pest control
Pest control is an ongoing concern in keeping plants clean. The problem can be especially acute for certain kinds of organic ingredients, because they can’t be treated with pesticides and so are especially liable to infestation.
The approach to pest control is generally the same for an organic plant as for any other: use of non-chemical means first, like traps, improved sanitation and removal of situations or areas where pests can accumulate. If those don’t do the trick, then it’s time to resort to chemicals.
“For those facilities following organic rules, there is an order in which control tools are used,” says Patricia Hottel, technical director at McCloud Services. “This will be different and more restrictive in regard to pesticides. Following the prescribed hierarchy or order in which control tools are deployed, will help drive some of the non-chemical control techniques such as improved sanitation, pest exclusion and traps.”