Hi Audrey,
Thanks yr info.
I assume yr OP is primarily addressed to acceptability for SQF.
I assume yr operation is (SQF) Low Risk. (Is it?)
I assume no allergenic factors involved (as per previous post).
I assume the SQF cleaning requirements for a Low Risk, food ingredient operation are identical (unless Code stated otherwise) to that for a food. Seems logical since for GMP same module (11) is quoted in FSC 19.
Afai can see the relevant “cleaning” clause is 11.2.13.
The SQF Guidance material for this Clause in the section “What do I have to do” contains this text –
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A full description of the cleaning and sanitation procedures for each piece of equipment or area of the
operation. This should include:
° Physically remove solid particles by sweeping or wiping;
° Apply a suitable detergent in the correct concentration to remove grease and other food residues;
° Rinse off residual food residue and detergent;
° Apply a suitable sanitizer in the correct concentration to reduce or eliminate microbiological contaminants;
° Rinse to remove residual sanitizer, if indicated on product label;
° Dry, as indicated, in a manner that will prevent recontamination.
Etc, etc
To verify the effectiveness of sanitation, a visual pre-operational inspection of equipment and facility is to be conducted prior to the start of operations, after a sanitation activity or the beginning of a shift. For high risk operations and allergen cleaning verification (refer 2.8.2.1), a more thorough swabbing program shall be implemented to verify the integrity of the cleaning regime.
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The above implies that application of a sanitizer is mandatory.
I suggest that whether yr product could be regardable as a combined detergent/sanitizer (which certainly do exist) may depend, for example, on -
(a) how the product is formally described (and [2-way] cfia approved?) in its documentation
(b) a satisfactory verification of the cleaning efficiency. The last paragraph in above quoted text IMO is slightly ambiguous regarding the necessity for swabbing for a non-high risk operation (there is no mention of “swabbing” in the actual Code, eg clauses 11.2.13.[4,5]). However in the present case where use of only one detergent/”sanitizer” is envisaged, seems likely that an auditor would be relatively “rigorous” as far as verification is concerned.
There are at least 2 caveats in my above analysis –
(1) The SQF Guidance material is not an auditable document and is supercedable by the Code itself (and presumably by an auditor’s interpretation thereof),
(2) Based on other threads in this Forum, SQF auditors may simply interpret the Code in a different way to that given in the Guidance material and, IMO, occasionally to the Code also.
Accordingly since I am not a SQF user, the validity (or otherwise) of above analysis/opinions needs to be confirmed by actual SQF users.