This page walks the plant from the dock to despatch and sets out where generated solution is used, how it is applied and what is recorded. Set points are deliberately described as decisions rather than numbers: the right strength depends on your chlorine demand, your surfaces and your verification data, and the applicable limits differ between water and surfaces.
About claims on this page
EcoloxTech generators produce a hypochlorous acid solution on site. They are regulated by the EPA as devices, are not registered disinfectants, and we make no efficacy claims for them or for the solution they produce. The only EcoloxTech product with disinfection claims is HOCl-AS200 (EPA Reg. No. 101112-1), used according to its label. Research cited here describes published studies of hypochlorous acid and electrolysed water under their own test conditions; it is not a claim for any product.
Two different rules, two different limits
Process water and ice that contact the product sit under FCN 1811 — free available chlorine not exceeding 60 ppm, with a drain step or potable rinse for product consumed raw. Food-contact surfaces sit under 21 CFR 178.1010 — up to 200 ppm available chlorine, followed by adequate draining. Quoting one limit for the other job is a common audit finding.
Reception, totes and crates
Everything that comes into the plant arrives in something, and that something goes back out again. Tote and crate washing is the most under-managed application in most seafood operations: the wash is often hot water alone, the turnaround is rushed at peak, and the containers then carry spoilage flora directly back onto fresh product.
The sequence that works is the ordinary one — remove debris, wash with detergent, rinse, then sanitise at the SOP set point and drain. Where a crate washer exists, a dosed final stage is straightforward; where washing is manual, a dedicated station with the solution on tap is what makes the step actually happen. Hoppers, chutes, elevators and grading equipment follow the same pattern.
Ice and chilled water
This is usually the largest volume of treated water in the plant and the application with the clearest authorisation behind it.
| Use | How it is done | What to watch |
|---|---|---|
| Flake and slurry ice | Treated water feeds the ice machine within the FCN limit | Demand in the slurry once product is in it; machine hygiene and ice-store cleanliness |
| Chilled and refrigerated seawater | Dosed into the circuit by design after measuring demand | High chloride and high demand; contact time in a moving system |
| Flume and transport water | Dosed at make-up, monitored in the flume | Organic load climbs through the shift; top-up strategy matters |
| Thaw water | Dosed within the limit; drain or rinse where product is consumed raw | Protein load and temperature |
| Line rinse and wash water | Dosed at the point of use | Strength measured in the water, not at the generator |
| Glaze water for frozen product | Treated water used for glazing | Contact is brief; water quality is the point |
Two practical notes. Ice is often reused in practice even when the SOP says otherwise — walk the floor at the end of a shift rather than reading the procedure. And melt water is a sample worth taking: it tells you what the ice was carrying. Published work on treated ice includes sanitised ice on fish fillets and in the melt water and electrolysed water ice and the quality of shrimp.
The filleting and trimming line
Belts, tables, skinning machines, pin-bone removers, graders, saws, knives, gloves and aprons. This is high-touch, high-soil, food-contact work, and the sequence matters more than the chemistry: fat and protein must come off first, or the oxidiser is spent on soil.
- Through the shift: tool and glove stations, hand-contact surfaces at breaks and changeovers, knife stations.
- At changeover: clean down, sanitise and drain between species or batches, particularly where allergen or quality segregation applies.
- End of shift: full disassembly cleaning to the schedule, then sanitise at the set point and allow to drain and dry.
- Belts: seams and the underside are where the problem lives. Belt cleaning systems are worth the investment in any plant with a persistent environmental finding.
Research on belt and raw fish surfaces is indexed as Listeria monocytogenes and Morganella morganii on conveyor belt and raw fish surfaces, and on seafood processing surfaces generally as Listeria monocytogenes on seafood processing surfaces and electrolysed oxidising water and bacterial contamination on seafood.
Shellfish handling
Graders, washers, shucking benches, knives and hand-contact surfaces are ordinary food-contact work. Tank water is not.
Depuration and wet-storage water for molluscan shellfish is governed by the National Shellfish Sanitation Program and administered by your state shellfish control authority. Treating that water is a decision the authority has to approve, and the approval will specify what may be used and how it is monitored. Design the conversation with them first; the plant’s own HACCP plan does not settle it.
RTE: brining, smoking, slicing and packing
In a cold-smoke or cooked-and-peeled operation, this is the zone that justifies the whole programme, because nothing downstream removes a contaminant introduced here.
| Equipment | The specific risk | Practice |
|---|---|---|
| Brine injectors and brine tanks | Salt-tolerant organisms; needles and manifolds are hard to reach | Strip-down cleaning to schedule, then sanitise; single-use or validated brine handling |
| Kiln trolleys and racks | Wheels travel between zones; racks carry residue | Dedicated trolleys per zone where possible; wash and sanitise on a fixed cycle |
| Slicers | The last contact before pack; complex geometry | Disassembly cleaning, sanitise, drain and dry; dedicated tools |
| Packing surfaces and conveyors | Direct product contact, high frequency | Sanitise at changeover and end of shift; verify with ATP |
| Hands, gloves, aprons | The most mobile vector in the room | Solution on tap at stations that people actually pass |
Drains, floors and the environment
Zone 3 is where a Listeria problem is won or lost, and it is also where a per-litre chemical cost quietly limits what gets done. Generated solution changes that arithmetic: flooding a drain properly, or foaming a floor–wall junction on a real schedule, stops being an expensive decision.
Work drains last, with dedicated tools, and never move from a drain back onto a food-contact surface. Footbaths and boot washes are worth running properly or not at all — a dilute, dirty footbath is a transport mechanism. Hose stations, forklifts, trolley wheels, walls and condensate points all belong on the schedule.
Vessels and the first cold chain
Where a business owns its vessels, the programme can reach further back: holds, boxes, deck surfaces, RSW systems and the ice put aboard. The constraints are space, power and water quality, so this is usually a dockside operation — treated ice and cleaned boxes going out rather than a generator going to sea. It is worth including in the survey, because quality won or lost in the first six hours is not recoverable in the plant.
Cold store, despatch and transport
The last few metres get less attention than they deserve. Cold-store floors, racking, pallet trucks and door seals are zone 3 surfaces in a room where everything is wet and nothing dries; condensate above stored product is a recurring audit finding. Despatch bays, dock levellers and vehicle interiors sit between your control and someone else’s, and returnable packaging comes back from a customer having been somewhere you cannot see.
Put them on the schedule explicitly: chill and cold-store surfaces on a weekly cycle, door seals and drip points on the same visit, dock and vehicle interiors before loading, and returnable packaging through the same wash and sanitise route as your own totes rather than a quick rinse.
Water re-use and top-up strategy
Water re-use is normal and sensible in a plant using this much of it, but it changes the arithmetic. A flume or wash tank accumulates organic load through a shift, so the strength that was right at start-up is not right four hours later. Decide in advance whether the tank is dosed continuously, topped up on a schedule, or dumped and refilled at fixed points, and write that decision into the SOP with the measurement that supports it. Measuring at the water, on a schedule, is what turns re-use from a risk into a controlled practice.
Frequently asked questions
What strength should we use?
It depends on the task, the soil and the applicable rule — and on what your verification data shows. The audit sets initial set points per area, and they are adjusted on evidence.
Can we dose the ice machine directly?
Treated water into ice is what FCN 1811 covers. The engineering — where the dose goes, how it is monitored — is a design question answered in the survey.
Do we rinse after sanitising a surface?
Under 178.1010 the requirement is adequate draining at or below 200 ppm. Follow your SOP and the applicable rule rather than habit.
Can it replace our detergent?
No. It has minimal surfactant action. In a plant this greasy and this high in protein, the detergent step is what makes everything else work.
What about fogging the chill rooms?
Fogging is sometimes used for environmental work between shifts. Treat it as an addition to cleaning, not a substitute, and manage occupancy and ventilation.