Processing
NOP-Approved Sanitizers: Clearing Up
the Confusion on Peracetic/Peroxyacetic Acid
By Richard Theuer and
Jessica Walden
Within the USDA organic regulations, there are a few vague areas that re- quire in-depth clarification. One subject of confusion among many processors and
certifiers in the industry is the use of sanitizers—in particular, peracetic acid/peroxy-acetic acid (PAA). This sanitizer is an effective
alternative to chlorine and other harsher sanitation chemicals, and because it’s considered
benign for the most part, it can be used in a
variety of ways that other sanitizers cannot.
The National List permits the use of PAA
in organic food processing, with the following
cryptic annotation: “For use in wash and/or
rinse water according to Food and Drug Administration (FDA) limitations. For use as a
sanitizer on food contact surfaces.” This annotation appears to be very simple—until you
try to figure out exactly what it means. While
the FDA offers a list of generic formulas that
provide a good place to start, the fact is that
choosing the right PAA sanitizer may require
you to look deeper to address several factors,
including exactly how and at what stage the
sanitizer is being used. This article will attempt to provide some clarity on this complex
subject.*
ful sanitizer. While some processors may look
for a “pure” PAA solution, most stock commercial preparations usually contain a synthetic stabilizer such as HEDP (1-hydro-
xyethylidene-1, 1-diphosphonic acid) or dipi-colinic acid ( 2,6-pyridinedicarboxylic acid) to
slow the rate of oxidation or decomposition,
so that the PAA you buy still has potency when
you go to use it.
Background
PAA solution is an aqueous mixture of two
substances, acetic acid (the acid in vinegar)
and hydrogen peroxide. PAA is an unstable
oxidizing agent, which is why it is such a use-
Complex Regulatory Framework
The Organic Foods Production Act
(OFPA) of 1990 specifies that nothing in the
OFPA shall alter the authority of the secretary
of agriculture under the Federal Meat Inspection Act or under the Poultry Products Inspection Act, the authority of the secretary of
Health and Human Services under the Federal Food, Drug and Cosmetic Act, or the authority of the administrator of the
Environmental Protection Agency (EPA)
under the Federal Insecticide, Fungicide and
Rodenticide Act. As a consequence, at least
four federal agencies are involved in the processing and handling of organic foods, including postharvest handling, and each of these
agencies has a differing approach to exercising its regulatory authority. These agencies
are:
• The National Organic Program of the U.S.
Department of Agriculture (NOP)
• The Food and Drug Administration
• The Environmental Protection Agency
*Please note that this analysis is a result of much research. However, this is our interpretation and is meant
to assist certifiers and organic handlers in their assessment of peracetic acid formulas for NOP compliance.
We do not make any promises or assume any legal liability or responsibility for the accuracy, completeness
or usefulness of any information disclosed. In addition, we hope that the amateur and professional regulatory compliance people who read this article give us feedback, especially if you disagree. Valid arguments
will be posted with the online version of this article at www.organicprocessing.com.
