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?