Onsite Hypochlorous Acid Generation in Food Processing. FCN 1811, PNC 2800, what the research actually supports, and what switching costs. Ten pages. September 2026.
Written for plant QA and food safety managers, sanitation leads and plant controllers. It answers the two questions that stall most food-safety technology decisions — is this authorised for use on my product, and what will getting that authorisation cost me — and then sets out what the published research supports at the authorised concentrations, including the studies that found little or no effect.
What is inside
| Section | What it covers |
|---|---|
| 1–2. FCN 1811 | FCN 1811 has been effective since 13 October 2017, and the FDA’s 2022 correspondence records the Manufacturer/Supplier as EcoloxTech, Inc. The four authorised uses, the 60 ppm ceiling under the FCN and the tighter 50 ppm that FSIS Directive 7120.1 sets for meat and poultry, and which uses carry a drain-or-rinse condition — including ready-to-eat meats, which summaries often miss. |
| 3. PNC 2800 | What a Pre-Notification Consultation is, and what it is not. The FDA’s signed letter of 6 June 2022 is quoted verbatim: the substance is “already authorized by effective FCN 1811” when generated on site by an EcoloxTech machine, and a customer using one “may market this FCS for the intended use … without further authorization under an FCN.” The same letter records the Manufacturer/Supplier as EcoloxTech, Inc. Also: what that coverage avoids, being a review period of up to 120 days on top of a multi-year data package. |
| 4. Two authorities | FCN 1811 for food contact versus 21 CFR 178.1010 for food-contact surfaces. One site-wide ppm figure is wrong somewhere by definition. |
| 5. The research | Meat and poultry, seafood, produce and shell eggs — studies selected because they test at or below the authorised ceiling rather than above it. |
| 6. Where it does not work | Chlorine demand of 1,000–2,000 ppm in a loaded poultry chiller; no significant reduction on heavily soiled pork bellies; under 0.3 log in one field trial. The conditions that decide whether any of section 5 transfers to your plant. |
| 7. The economics | What contamination costs the industry, and EcoloxTech’s field-reported cost categories — chemical spend, water and effluent, PPE, corrosion, sanitation labour, failed swabs. |
| 8–9. The wider position | The EPA tolerance exemption, organic acceptance, FSIS Directive 7120.1 — and where HOCl-AS200 fits and, importantly, where it does not. |
| 10–11. Limits and questions | What on-site generation does not fix, and seven questions to put to any supplier, including us. |
What this paper claims, and what it does not
An EcoloxTech system is a device that produces a hypochlorous acid solution on site, regulated by the EPA as a device, and we make no efficacy claims for it or for the solution it produces. Regulatory authorisation and efficacy are different things — a Food Contact Notification authorises a use, it is not a performance claim, and the paper does not present it as one. Research is reported as findings under the conditions the authors tested, and deliberately includes the work that found little or no effect. Cost figures are EcoloxTech’s own field-reported data, labelled as such. We do not claim that our equipment prevents outbreaks or recalls.
Related reading
The sector programme is at food processing, with companion pages on pathogens, applications and compliance and audits. Closely related sectors: seafood and agriculture. The registered product referenced in section 9 is HOCl-AS200, and the published literature is indexed in the research library.