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Regulatory Affairs Hypochlorous Acid

FDA Guidance for Industry: Guide to Minimize Microbial Food Safety Hazards of Fresh-cut Fruits and Vegetables.

The antimicrobial activity of a chlorine-based disinfectant depends on the amount of hypochlorous acid (also called “free chlorine”) present in the water. The amount of hypochlorous acid in the water depends upon the pH of the water, the amount of organic material in the water, and, to some extent, the temperature of the water. If the amount of hypochlorous acid is not maintained when the amount of organic material increases, the antimicrobial agent may lose effectiveness in maintaining water quality. If a fresh-cut processor uses a chlorine containing compound as a disinfectant, we recommend that the processor monitor the processing water for free chlorine or hypochlorous acid concentrations. Visit Source at FDA Website.

EPA: Food-Contact Surface Sanitizing Solutions – Allowance of Hypochlorous Acid at up to 200 ppm The following chemical substances when used as ingredients in an antimicrobial pesticide formulation may be applied to food-contact surfaces in public eating places, dairy-processing equipment, and food-processing equipment and utensils. When ready for use, the end-use concentration of all hypochlorous acid chemicals in the solution is not to exceed 200 ppm determined as total available chlorine. Visit Source at EPA Website.

EU Chemical Agency
The Biocidal Products Committee of European Chemicals Agency documented positive opinion on the approval of the active substance active chlorine generated from sodium chloride by electrolysis.

USDA - National Organic Program

USDA Organic This memorandum clarifies that electrolyzed water (hypochlorous acid) is a type of chlorine material that is allowed in organic production and handling.

On June 9, 2014, the National Organic Program (NOP) published a policy memorandum (PM 14-3) on the status of electrolyzed water under the USDA organic regulations at 7 CFR Part 205. Following the release of PM 14-3, stakeholders provided additional technical and regulatory information on electrolyzed water to the NOP. Chlorine materials are allowed to be used in organic production and handling. The National Organic Program (NOP) Handbook includes guidance (NOP 5026) The Use of Chlorine Materials in Organic Production and Handling. This guidance clarifies the allowable uses of chlorine products under the USDA organic regulations. Chlorine materials are included on the National List of Allowed and Prohibited Substances (National List). In water, chlorine materials such as calcium and sodium hypochlorite form an equilibrium of related chlorine species, including hypochlorous acid (HOCl) and hypochlorite (ClO-). Similar chlorine species are formed in the generation of electrolyzed water. Accordingly, the NOP considers hypochlorous acid generated by electrolyzed water to be an allowable type of chlorine material.


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