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International registration for your cleaning products – now a reality in South Africa.

| Legislation

Ever wonder if the cleaners you are using in your food or production facility are safe? This article will help you understand what to look for when sourcing chemicals.

We explain product registration (how it works and why it is an important component of a food safety program), the prominent cleaner categories and their end-use applications.
Who Seeks and Grants Registration?
Whether in food processing, manufacturing or food service, cleaning and sanitation is an essential pre-requisite programme. Unfortunately, there is the potential for the chemical products used for cleaning prior to, during and after processing to come into contact with the food itself. The potential for nonfood materials to have incidental contact with a food product is a hazardous cross-contamination risk and must be controlled as part of a facility’s overall HACCP approach. With the potential for contamination of the foodstuff, to minimise the risk, it is vital that these compounds adhere to strict standards of safety and quality. Registration of the cleaning chemicals by a competent authority can give food processors’ confidence that their selection has included this critical criterion.
NSF International evaluates and registers cleaning chemicals, based on requirements originally developed by the U.S. Department of Agriculture. Today this registration has a global reach with products produced in over 50 countries (including South Africa) and continues to grow as food safety becomes increasingly important to consumers, producers and regulators.
What Are Registration Categories?
Product registration category codes consist of a letter and number identifier and ensure that a product is reviewed against the appropriate criteria based on its intended end use. The criteria are based on current regulations as well as toxicological data to determine whether the ingredients within the product are safe for that particular end use. Something as simple as a letter code may not seem extremely important, but the impact of using the incorrect product could lead to a significant risk potential and possible food contamination.
There are a number of product categories for cleaning chemicals used in the food industry, which designate the intended end-use applications. These are shown in the table below:

Cleaning Products

*A1    General cleaners

A2 Soak tank, steam/mechanical cleaners

A3 Acid cleaners

A4 Floor and wall cleaners

A5 Freezer floor and wall cleaners

A6 Scouring cleaners

A7 Metal cleaners and polishes – nonfood contact

*A8    Degreasers/carbon removers

AX Ingredients for use in Cleaning Products

*Use of this product in food processing or handling facilities requires all food products and packaging materials to be removed or protected prior to product use. A potable water rinse of cleaned surfaces is required after use of this product. When used according to manufacturer instructions, the cleaner shall neither exhibit a noticeable odour nor leave a visible residue.

Other cleaning product categories available for registration
K1, K2 and K3 are for solvent cleaners. These products typically consist of hydrocarbon, chlorinated hydrocarbon, or other water immiscible solvents, for nonfood processing areas, electronic instrument cleaning and adhesive removers respectively.
L category cleaners are for drain cleaning. L1 products are used to clean sewers and drains and typically consist of strong acids or strong alkalis. L2 products are used to clean sewers and drains and contain bacteria or enzymes and typically requires Salmonella testing.
How Are Cleaners Registered?
Cleaning chemical manufacturers are required to provide full formulary disclosure and these are reviewed against applicable regulations or toxicological safety data. Once submitted to a registration body, the formulation goes through an independent review against the requirements for each individual end use. 
The finished product label is also reviewed to ensure it is accurate, makes no misleading claims and includes appropriate end-use instructions. Product labels must be traceable to the registered company and bear the registration mark, including the category code.
The Importance of Using Registered Cleaners
The recent Listeriosis outbreak in South Africa should have provided a trigger for a full review of your HACCP programme to ensure it provides you as a food processor with sufficient protection. As effective cleaning and sanitation is critical for the control of pathogens, the use of the correctly registered products for the different applications in facilities provides a reliable prerequisite approach to complement a HACCP plan. While HACCP plans tend to focus on the handling of the actual ingredients and products, manufacturers also need to consider seemingly peripheral aspects such as cleaning chemicals tainting products. What may seem to be a minor issue could have a massive impact on a product, a company’s reputation and public health.
A master cleaning schedule should clearly define which products are used in various parts of the facility and the simple use of a letter and a number can assist cleaning staff in recognising the correct chemicals for the correct application, thereby further reducing the potential for cross contamination.
The use of NSF registered cleaning chemicals and other nonfood compounds as part of a strong HACCP plan that looks at both the chemical and physical risks associated with food processing is an important and critical step toward completing certification to the Global Food Safety Initiative (GFSI) benchmarked standards.
The registration of cleaning chemicals has always been a retail supplier food safety requirement in South Africa. Although certification against South African national standards has been the historical choice, NSF non-food compound certification can provide cleaning chemical manufacturers and food processors, with a trusted alternative for product registration. This can ensure “business-as-usual” at despite recent disturbing media disclosures. Understanding what product categories are, and the value of sourcing and appropriately applying internationally registered products, should be considered very closely by those involved in retail supplier food safety audits.

 Are you a cleaning chemical manufacturer needing certification?

For assistance in obtaining non-food compound certification for your cleaning chemicals, contact Uli Gerntholtz: This email address is being protected from spambots. You need JavaScript enabled to view it. 

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