HOCl for Dairy programme

Compliance & Audits — Dairy

The regulations, standards and audit criteria that apply, and the documentation that satisfies them.

What applies to this sector

  • Pasteurised Milk Ordinance requirements where applicable
  • FDA 200 ppm food-contact limit
  • HACCP and preventive controls documentation
  • Residue considerations for organic certification

The distinction that causes most arguments

Generated solution is used as a cleaner and sanitiser. HOCl-AS200 is an EPA-registered disinfectant, Reg. No. 101112-1, carrying specific public-health claims on its label. Registration governs what may be claimed, not what the chemistry does. Where a rule, an auditor or an insurer specifies a registered disinfectant, use the registered product — and use generated solution for the volume work around it.

Limits worth memorising

Application Limit Source
Food-contact surfaces 200 ppm total available chlorine, ready to use FDA food-contact provisions
Potable water 4 mg/L EPA National Primary Drinking Water Regulations
Registered disinfection Per label — 5-minute contact time EPA Reg. No. 101112-1

The documentation package

  1. System specification and commissioning records
  2. Written SOPs by application and by zone
  3. Concentration verification logs at the frequency your scheme requires
  4. Baseline and ongoing environmental monitoring results, trended
  5. Training records for everyone who operates the system
  6. Safety data sheets and, where applicable, the registered product label
  7. Supporting research citations from the sector collection

What auditors actually check

Not the chemistry. They check whether the concentration you specified is the concentration present, whether the records exist, and whether the results are trending in the right direction. All three get easier when the solution is machine-produced at a set concentration.

Get this written for your facility

Send your volumes, applications and current chemical spend. You will get a sized system, a written protocol and a payback model — free.