[Valerie Smith]

Hi Francesca,

I looked up the label to see what it says and there are no directions for using it as a sanitizer, nor the EPA number, so I’d ask more questions. I’d look at how they are using it compared to the risk level of that procedure. What is the crop? If there does not appear to be an uncontrolled hazard, I’d probably let it pass. If it’s to control something pretty risky, I would ask for a change to an EPA approved product. Unless that is totally unallowed by certification requirements.

My two cents.

Valerie Smith, NM

[Francesca Scola]

Thanks Valerie!

I need to talk with the producer more to see what they are intending to sanitize/ if there is an uncontrolled hazard. They also have bleach listed as a sanitizer for food contact surfaces so im not sure what situations they would use the vinegar for v.s. the bleach.

[Humberto Maldonado]

Hi, Francesca. I did a little research on this topic, and hopefully it helps. EPA considers vinegar a household substance and it is not regulated. Here are some references:

https://www.epa.gov/coronavirus/can-i-use-common-household-substances-kill-novel-coronavirus

https://www.nsf.org/blog/consumer/reliable-scientific-tips-cleaning-with-vinegar

Even when it is not as effective as other sanitizers (for example, it has little effect on viruses), and strictly won’t be called as that, it has some bactericidal effects. I am sharing a couple of references I found:

https://www.extension.purdue.edu/extmedia/FS/FS-34-W.pdf

https://www.sciencedirect.com/science/article/pii/S0362028X22066686

Humberto

[Francesca Scola]

Thanks Humberto!

<font face=”inherit”>These links are helpful 🙂 Looking </font>forward<font face=”inherit”> to discussing more with everyone on the next call. </font>

[Billy Mitchell]

Morning all,

Sorry to chime in so late and I hope this is helpful and I recognize some of it is a little redundant. Also, just my two cents. : )

Francesca, I think you’re right that the first step is finding out what the vinegar is used to be sanitizing. I spoke with someone who works at a company that does NOP certification and food safety audits. They shared that often vinegar is used to sanitize drip irrigation and other non-food contact surfaces. I don’t see a food safety auditor having an issue with that.

If the the vinegar was being used for food contact surfaces, there is the potential for an issue. From a FSMA PSR perspective, the rule doesn’t require growers to use an EPA-labeled sanitizer. The EPA label does let the grower know that the product is labeled for its intended use (for example, to control human pathogens.) If it isn’t labeled, like vinegar, the grower should be able to prove that vinegar is suitable for sanitizing food contact surfaces and reducing contamination risks. I’m not convinced that a grower would be able to prove that. I believe a majority of auditors/Extension would tell you that vinegar is not an acceptable sanitizer because their view is that it does not adequately sanitize food contact surfaces.

It’s tough because not all sanitizers are created equal and not all sanitizing agents have the same efficacy. Some are not approved for food contact surfaces and some are. Some will get you the log reduction you need and some won’t. From an audit perspective, and I think a best food safety practice, I would encourage the grower to use an EPA-labeled sanitizer for food contact surfaces.

Last thing – In the preamble to Organic Foods Production Act, it says that ? “We have consistently maintained that the NOP is for marketing, not food safety, purposes.“ While there is a lot of overlap between NOP and GAP, they do not always align.

I hope this is helpful and everyone is well – I’ve missed being able to attend the calls!

[Valerie Smith]

Thanks Billy and Humberto for your responses, very informative. I get that question a lot. Thanks for posting Francesca!

Valerie Smith

[Billy Mitchell]

Hey y’all,

After our last call, I reached out to the USDA and an auditing company.

<font face=”verdana, sans-serif”>This one from the USDA – “It is important for the auditee to determine the right cleaners and sanitizers for their operation. There are many different vinegar products on the market. The best thing for the grower to do is to read the label on the vinegar to determine if it is appropriate for use. Acetic acid is the active ingredient for Vinegar and percentage of acetic acid in the mixture varies from product to product. The grower will want to look for language that shows the efficacy of the product towards human pathogens, or pathogens of public health concern. If the product does show use for sanitizing or disinfecting then following the directions based on the label to meet that efficacy.”</font>

<font face=”verdana, sans-serif”>This one from the auditor (who was not GLOBAL GAP) – “GLOBAL G.A.P. does not approve sanitizers and the Environmental Protection Agency has not approved vinegar as a sanitizer.”</font>

<font face=”verdana, sans-serif”>My guidance for a grower would still be use an EPA labeled sanitizer </font>for sanitizing food contact surfaces.

<font face=”verdana, sans-serif”>Thanks!</font>