Installing a generator is the easy part. What decides whether the programme holds is the work around it: the task list, the water and ice systems, the written procedures, the training, and the verification that proves it is being done. This page is the implementation plan we use in a seafood plant, in the order it happens.
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.
1. Site survey
- Water: hardness, iron, manganese, chlorine demand, pressure and flow; the softening and filtration the system needs. In coastal plants, test rather than assume.
- Ice and chill systems: daily ice production, machine type and feed point, ice store, slurry systems, CSW or RSW circuits and their volumes.
- Demand: measured chlorine demand in each water use, with product in it — a slurry carrying whole fish behaves nothing like a fillet rinse.
- Location: a ventilated area with drainage, power and clearance, as close as practical to both the line and the ice plant.
- Distribution: the route to each point of use — tank, pumps, drops, hose stations, ice-machine feed.
- Constraints: landing patterns and season, production windows, wash-down zones, raw/RTE segregation, and anything the shellfish control authority has approved.
2. Task inventory and classification
List every sanitation task and every water use with its area and zone, surface or volume, current product and concentration, method, contact time, frequency and owner. Then classify each one: move to generated solution, keep on a registered product because a claim must be documented, or fix with cleaning rather than chemistry. In a seafood plant, record which rule covers each item as you go — water and ice under FCN 1811, surfaces under 178.1010 — because that classification carries straight into the SSOP.
3. Install and commission
- Water treatment, generator, tank, pumps, outlets, ice-plant feed and labelling.
- Commission: set output for each area, measure free available chlorine and pH at the generator, at the farthest outlet and in the water in use, and record all three as the baseline.
- Confirm strength at the point of use matches the set point once demand is in play; if it does not, fix the dose or the distribution before writing the SOP around it.
- Record the commissioning readings, the set points, and who signed them off.
4. Write the SOPs
One page per task. Each answers seven questions:
| Question | What goes in the SOP |
|---|---|
| What and where? | Surface, equipment or water system; area and zone |
| When? | Frequency: between batches, at changeover, end of shift, per landing |
| Cleaned how? | Detergent, mechanical step, rinse — the step that matters most in this plant |
| Which solution? | Generated solution at the set point, or the registered product and its label directions |
| Applied how? | Spray, wipe, foam, flood, dose into water or ice |
| How long? | Contact time, and whether a drain, rinse or air-dry follows |
| Verified how? | Strength and pH check, visual, ATP or swab frequency, and where it is recorded |
5. Build the schedule
| Frequency | Tasks |
|---|---|
| Every shift | Pre-op strength and pH per outlet and per water system; zone 1 clean and sanitise; drains; footbaths; tote turnaround |
| Daily | Zone 2 surfaces; floors; ATP on rotating points; salt or brine level; ice-store check |
| Weekly | Disassembly cleaning of nominated equipment — slicers, injectors, skinners; chill-room surfaces; environmental swabs to plan |
| Monthly | Filter check or change; ice machine deep clean; deep-clean rotation; review of strength logs and verification trends |
| Quarterly / per season | Service; test-equipment calibration; SOP and training review; re-run the ROI against actuals |
6. Train the people who will run it
- What the solution is, and why it is never mixed with other chemicals.
- How to draw solution, test strength and pH in water and at outlets, and what to do when a reading is out of range.
- The sequence that matters: clean first, apply at strength, keep wet for the contact time, drain or dry.
- Which rule covers which use, and why the water limit and the surface limit differ.
- Storage, container labelling and tool segregation by zone — particularly raw versus RTE.
- Handling brine or acid inputs, for whoever refills the system.
- Where the SDSs are and what they say; first aid; who to call when the generator faults.
Record the training, with names, date, topics and signature, and repeat it for seasonal staff before the season rather than during it.
7. The verification plan
Agree, before the change, what will show it worked: baseline ATP and environmental swabs in the pilot area, water and ice results, the same points afterwards, acceptance criteria, and who signs off. Keep monitoring (strength and pH) separate from verification (ATP, swabs, water testing, record review) in the paperwork, because auditors ask about both. In an RTE plant, hold the environmental monitoring plan steady through the change so the trend stays comparable.
8. The first 90 days
| Milestone | What to check |
|---|---|
| Week 1 | Strength at every outlet and in every water use against set point; staff confidence; anything that does not fit the SOP |
| Week 2–4 | Verification results in the pilot area versus baseline; salt, water and power use; any material or equipment concerns |
| Day 30 | Roll-out decision by area; SOP updates; first review of logs and corrective actions; shelf-life comparison under way |
| Day 60 | Full roll-out progress; training gaps; distribution issues; where the incumbent product is still needed |
| Day 90 | Trend review; ROI against actual salt, water, power and service; update the HACCP plan, SSOPs and chemical list |
Troubleshooting
| Symptom | Usual cause | First action |
|---|---|---|
| Strength collapses as soon as product goes in | Chlorine demand from slime, blood and protein — normal in seafood | Measure demand with product present; adjust dose or improve the pre-clean; do not simply raise the set point |
| Strength lower at the outlet than at the generator | Long runs, storage time, light on a tank or line, or line contamination | Shorten storage, shade the tank, clean the line, re-test at both points |
| Output drifting over weeks | Feed-water hardness scaling the cell | Check softener and filters; service the cell per the manual |
| Environmental results worse after the change | Cleaning step weakened, contact time cut, or set point too low for the soil | Re-check the sequence before changing the chemistry |
| Ice results inconsistent | Machine hygiene, ice-store handling or reuse on the floor | Clean the machine and store; walk the floor at end of shift to see what actually happens |
| Staff not testing | Test point inconvenient, or the log is awkward at speed | Move the kit to the draw point; simplify the log |
| Corrosion or discoloration | Prolonged contact on sensitive materials in a wet building | Check compatibility; add a wipe or rinse step for those surfaces |
The document set
- Task and water-use inventory with its rule classification.
- SSOP per task, with set points and contact times.
- Commissioning record and set-point change control.
- Strength and pH logs; water and ice records; ATP and swab records; corrective actions.
- Training records; maintenance records for generator, softener, filters and ice plant.
- SDSs for solution and inputs; HOCl-AS200 label; FCN 1811 where relied on; shellfish authority approvals; generator manual.
- Validation evidence for the change.
Printable templates for most of these are in the free HOCl Compliance Pack.
Designing distribution in a wet plant
The most common reason a good system underperforms is that solution is inconvenient to get. If the nearest draw point is two rooms away, people carry buckets, reuse solution and skip the test. Plan the drops with the sanitation team rather than from a drawing: one at each wash-down station, one at the filleting line, one near tote washing, one at the ice plant, one in the chill and cold store, and a fill point for sprayers and foamers. Keep runs short, shade any tank, and label every outlet with its contents and set point.
A holding tank buys peak capacity from a smaller generator, which suits a plant with lumpy landings — but it adds storage time, and hypochlorous acid decays. Size it for the peak you actually have, not the largest tank that fits, and test at the outlet rather than at the generator. Published work on how these solutions hold their strength over time is indexed as stability of electrolysed oxidising water.
Frequently asked questions
How long does the whole implementation take?
A survey and install can be done in days; a controlled roll-out with pilot, verification and SOP rewrite usually runs 30 to 90 days. Plan it outside peak season if you can.
Do we have to stop production?
Installation is normally scheduled into a maintenance or sanitation window. Roll-out happens area by area during normal operation.
Who should own the programme?
Whoever owns sanitation — usually QA or the sanitation manager — with trained operators and controlled set points.
What if a task does not transfer?
Leave it on the incumbent product and record why. A programme that is honest about its exceptions survives audits better than one that is not.
Can you write the SSOPs for us?
The audit produces a written recommendation including draft procedures for the tasks it covers; your team owns and approves the final documents.