SQF 11.2.5.3 Mix concentration for dish soap

SQF Code section 11.2.5.3 states:

Detergents and sanitizers that have been mixed for use shall be correctly mixed according to the manufacturers’ instructions, stored in containers that are suitable for use, and clearly identified. Mix concentrations shall be verified and records maintained.

My facility uses a detergent that is very neutral and cannot be titrated to determine the concentration. It is diluted through a mixing station and used for manual cleaning on the line or in a wash sink. It is not used in a CIP system. 

The detergent is essentially the same as Dawn dish soap, but manufactured by a different chemical company and acceptable for use in a food plant. The chemical works well for us and is affordable so we we don't want to switch, but we aren't sure how we can meet the requirement to verify concentrations. Our chemical rep has attempted to determine concentrations through pH comparisons between our water and the diluted detergent from the dispensing system, but it's not a standard method nor is it something we could do frequently at the plant. Ultimately, the soap is safe at any concentration since it's rinsed afterwards and then sanitizer is applied. 

Has anybody used a similar detergent and written a risk assessment to skip concentration testing? 

You don't need to do concentration testing.

You get the info from the solution company that provided it and the type of tips or flow meter used at the mixing station that you mentioned, surely your chemical rep should have this readily available information.

Hi katiejopit,

:welcome:

Welcome to the IFSQN forums.

Would it be possible to put a meter in the water line? then you could record volume of detergent and water and confirm that you are using the correct concentration.

I am surprised your supplier hasn’t got a standard method to check the concentration. I mean, how do they expect you to set up a mixing station if you can’t check the station is dosing correctly? I would push them on this.

Kind regards,

Tony

 

Would it be possible to put a meter in the water line? then you could record volume of detergent and water and confirm that you are using the correct concentration.

 

I am surprised your supplier hasn’t got a standard method to check the concentration. I mean, how do they expect you to set up a mixing station if you can’t check the station is dosing correctly? I would push them on this.

 

My concern with adding a flow meter is that we would need to have calibration records for it, and we don't currently calibrate existing our flow meters (we are a bakery so all water that is metered into dough is baked out and so the amount isn't critical). I have considered developing a procedure where we turn off one side of the dilution station so we just pump detergent for X amount of time, and then do it with just water for the same amount of time and determine the ratio. We'd prefer to not do that if possible though since the detergent is acceptable at any concentration as long as equipment looks clean. 

We have pushed back at the supplier for a method, and they attempted to give us the pH comparison but they outright said that it's difficult to use accurately... They don't have another method since the detergent can be used at full strength and isn't for CIP so a visual check tells you if it's cleaning well enough. 

Might be missing something here, but here is another 2 cents - any known solution mixing machine has a metering tip or gate/ball built into it - it's there someplace.

I worked for Johnson Diversey, our metering tips were a really big thing - if there was ever an issue it always came down to the tip, all 28 of them - bit just 1 per unit.

I'm also kind of dumbfounded that the chemical supplier doesn't have any documentation to help with this:  something as simple as "this machine mixes in 1 part dish soap to 8 parts water" (or whatever dilution) would seem sufficient.  The soap itself isn't truly a hazard here as you've described it is safe to use undiluted, but when you've validated your cleaning of these utensils at whatever dilution the machine provides, that becomes the standard upon which you need to ensure all cleanings occur.  That is why you'll get a ding for not monitoring this dilution.

I've done hand monitored concentration validation in the past.  Bottles were marked or proper mixing cups were at the mixing station, with training and written instructions at the site stating "fill bottle to x, add y amount of cleaning solution."  Kept a form at the station so employees could initial and date they'd followed the instructions (marking what they made and how much solution to water they made the spray bottle with."  I monitored it once per week in an internal audit, checking that the pre-mixed bottle dates matched someone's entry on the log, and I'd watch an employee mix to verify effectiveness of training.  If I can get away with that method for verifying concentrations, having information for the titration machine with a procedure to verify the ratios should be cake.

Might be missing something here, but here is another 2 cents - any known solution mixing machine has a metering tip or gate/ball built into it - it's there someplace.

 

I worked for Johnson Diversey, our metering tips were a really big thing - if there was ever an issue it always came down to the tip, all 28 of them - bit just 1 per unit.

We do have a metering tip on the mixing unit. Does just having the right tip installed mean that we're getting the right ratio? Could we substitute a periodic verification that the tip is still the correct one?

How much should be dispensed per gallon of water (or whatever other unit makes sense)?  Your chemical company should know this.  They and/or you should be able to measure this and then document it to show that it is dispensing as it should and signed off.

We have a dispenser on on the bottles it says something like 1 ounce per 1/2 gallon of water.  dispense 1/2 gallon of water and measure that it pulled out 1 ounce to ensure it is working properly.  In the past I have had our chemical suppliers do this for us and provide a certificate.  They should definitely be able to do something like this for you.