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Canadian Organic Standards
Final Questions & Answers

Cleaners, disinfectants and sanitizers

Updated on May 28, 2024
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Cleaners, disinfectants and sanitizer #

Conformity of a cleaning product #

Manufacturers of concentrated sanitation products may provide Safety Data Sheets (SDSs) showing the ingredients of both the concentrated form and the diluted form (as used) on the same document, or they may provide two distinct SDSs – one specific to the concentrated form and another specific to the diluted (as used) form. Which SDS should be used to evaluate the conformity of a cleaning product to the PSL if the ingredient listings are different? (437-539) – 13 December 2021
If using a diluted version, either purchased or diluted on-site, the SDS pertaining to the diluted substance applies. In the event that no SDS was issued for the diluted version – the SDS of the concentrate applies. Further, if used without a removal event (PSL Table 7.3), the label of the concentrated product is referred to for both the concentrated and diluted version PSL 7.1.3.

Chlorine to disinfect poultry carcasses #

Can chlorine be used to disinfect livestock carcasses? Are there alternative substances or processes? (254, 476) -24 March 2021
Yes. Livestock, including poultry, carcasses, may be disinfected with chlorinated water, provided the concentration of chlorine does not exceed the maximum limits applicable under regulations for safe drinking water. See Table 7.3 – Chlorine compounds. As an alternative peracetic acid can be used at disinfecting rates (Table 7.3). Alternative physical processes such as steam, hot water or High-Pressure Processing (HPP) are allowed.

*Water quality falls under the jurisdiction of provincial and territorial governments. Health Canada’s Guidelines for Canadian Drinking Water Quality indicates “Free chlorine concentrations in most Canadian drinking water distribution systems range from 0.04 to 2.0 mg/L”. The US Centers for Disease Control and Prevention (CDC) state “chlorine levels up to 4mg/L (4ppm) are considered safe in drinking water”.


Detergent as a cleaner #

Is a detergent considered a cleaner under clauses 7.1.2 and 7.1.3 of CAN/CGSB-32.311 (PSL)? What differentiates a detergent from a cleaner? (558) 19 December, 2022

Per PSL 7.1.1, any substance used to remove dirt, filth and foreign matter from organic products and organic product contact surfaces is a cleaner. A cleaner is only a detergent if specifically formulated for cleaning through the process of detergency as defined by ISO 862:1984(en) – Surface active agents https://www.iso.org/obp/ui/#iso:std:iso:862:ed-1:v1:en. Detergency is result of the action of several physico-chemical phenomena and a detergent is a combination of many components including surfactant, chelating agent, enzyme, and dispersant.


Assessment of detergent biodegradability #

Does each component (e.g., surfactant, chelating agent, enzyme, and dispersant) of a detergent need to be assessed individually for its biodegradability? (444) – 21 June 2019
No. The purchased “detergent” product must be rated as biodegradable.

Is the manufacturer of a detergent required to test the biodegradability of its product based on the definition of “biodegradable” in clause 3.11 of the Canadian Organic Standard (CAN/CGSB 32.310)? (515.1) 1 July 2021

In the 2020 version of CAN/CGSB-32.310, the definition of “biodegradable” (3.11) applies specifically to inputs and production aids in crop and livestock production. For detergents, biodegradability shall be assessed based on OECD definitions and standards; refer to Detergents, Table 7.4 of the PSL. Therefore, the manufacturer shall demonstrate that the biodegradability of the detergent meets or exceeds the guidelines defined by the OECD when assessing conformity to CAN/CGSB-32.3210.

Can a so-called biodegradable detergent contain non-listed or restricted substances such as phosphoric acid, whose use is only permitted for dairy equipment? (515.2) 29 Apr 2024

Yes. If the detergent meets the biodegradability requirement as outlined in Table 7.4 of Section 32-311, there are no other restrictions.

Elimination of a detergent #

Regarding the annotation for the Detergents listing in Table 7.4 of the PSL, how can you determine that a detergent is “readily eliminated during wastewater treatment such that harm to the environment is minimized”? (559) 22 March 2023

The annotation is not about the quality of the detergent or the manufacturer’s ability to demonstrate that it is “readily eliminated…” ; this annotation requires that wastewater treatment be in place to eliminate potential environmental harm when a non biodegradable detergent is used. The ingredients of any non-biodegradable detergent must comply with 7.1.3 (32.311) or the conditions of 8.2.3 (32.310) must be met.

Anti-stick film after rinsing #

Is a detergent used on organic product contact surfaces that leaves an anti-stick film after rinsing permitted? (596) December 13, 2023

Yes, if the remaining anti-stick substance is listed in Tables 6.3, 6.4 or 6.5 (32.311) per 8.1.2 c) (32.310).

Substances for egg cleaning #

Can substances listed in Table 7.4, with a removal event, be used to clean eggs? Is potable water required to wash eggs? (351)
Only substances listed in Table 7.3 as permitted for direct contact with organic products may be used to clean eggs. Water used for egg washing must be potable. See CFIA ‘Shell Egg Manual’ requirements. Take note, however, that organic vegetable oils, or other appropriate non-organic processing aids in PSL Tables 6.5 such as, e.g., silicon dioxide, could be used as defoaming agents during egg washing.

Non-food Contact Surface Cleaning #

Do clauses 7.3 and 7.4 apply to the cleaning of: dedicated and non-dedicated spraying equipment; of irrigation systems; and non-food contact surfaces such as floors, windows, staff toilets etc.? (21.1, 10)
Tables 7.3 and 7.4 of the Permitted Substances Lists generally apply to products (7.3) and product contact surfaces (7.3 and 7.4). While the cleaners listed in these tables may be used in other applications, and are preferred, cleaning of non-product contact surfaces is not restricted to these cleaners. In the case of the use of substances not listed in 7.3 & 7.4, the operator is responsible for ensuring that no residual contamination occurs on land and crops.

Substances used as cleaners #

Can substances listed as food additives (PSL 6.3) or processing aids (PSL 6.5), such as tartaric acid, be used as cleaners in facilities where organic product preparation takes place? (319)
If substances listed in 32.311 7.3 & 7.4 have been shown to be ineffective, substances listed in Tables 6.3 and 6.5, such as tartaric acid, or any other non-listed substance, can be used to clean organic product contact surfaces in facilities where organic product preparation occurs, as per criteria stated in 310 8.2.3.

Botanical compounds as cleaners #

Can essential oils be used to clean organic products or organic product contact surfaces? (366)
Essential oils compliant to the restrictions described in the new Essential oils listing in Table 7.4 may be used to clean surfaces in contact with organic products. But they cannot be used to clean organic products as they are not listed in Table 7.3.

Surfactant, spreaders, stabilizers, foaming agents #

Must formulants, such as surfactant, spreaders, stabilizers, foaming agents, contained in commercial cleaning products be listed on 7.3 and 7.4, or only the active ingredients? (453, 610.1) – 29 Apr 2024 

a) Without a removal event, all the non-organic ingredients listed on the Safety Data Sheets (SDS) must be listed in PSL Table 7.3. All other active and non-active ingredients, including    formulants, must be listed in PSL Table 7.3 or be chemicals used to treat drinking water, or serve as product stabilizers. For example, HEDP listed on the SDS would not be allowed since it does  not appear in Table 7.3, while it would be allowed if listed as a non-active ingredient on the label.

b) When used on product contact surfaces followed by a removal event, all the non-organic ingredients on the SDS, and active ingredients on the label, must be listed in Table 7.3 and/or 7.4.

If a cleaner/sanitizer SDS and label do not list ingredients, is the product allowed under Tables 7.3 and 7.4? (610.2) 29 Apr 2024

No. Active and non-active ingredient lists are needed from the manufacturer to assess compliance to Table 7.3 for substances used without a removal event. An active ingredient list is needed from the manufacturer to assess compliance to Table 7.3 and 7.4 when substances are used with a mandatory removal event.

Cleaning of dairy equipment #

Is sodium phosphate tribasic dodecahydrate permitted for use as a cleaner, disinfectant and sanitizer on dairy equipment as a derivative of phosphoric acid? (493) – 18 August 2020
No. Cleaning substances, including derivatives, must be listed in Tables 7.3 or 7.4. (7.1.3 in CAN/CGSB-32.311, SIC Final Questions and answers -Q&A 453) unless the derogation in 8.2.3 of CAN/CGSB-32.310 is pertinent.

Colloidal silver #

Can colloidal silver be used as a cleaning product for food contact surfaces? (274)
Use of colloidal silver as a cleaning product must comply with 8.2.3 and 1.4 of 32.310.

Neem oil and diatomaceous earth #

Can neem oil (listed in Table 8.2) be permitted in direct contact with organic food products? (310)
Yes. While the title of 8.2 is “Facility pest management substances”, there is no restriction on the use of diatomaceous earth, carbon dioxide or neem oil in relation to food contact post-harvest.

Peracetic Acid #

Peracetic Acid (peroxyacetic acid) is listed on table 7.3 PSL. Are all forms of this substance allowed, regardless of method of production? (221)
Yes. There are no restrictions on the method of production in the annotation for peracetic acid

Peracetic acid containing synthetic acetic acid #

Is peracetic acid that contains synthetic acetic acid permitted? (390)
Yes. Commercially, peracetic acid is produced by reacting synthetic acetic acid and hydrogen peroxide and residues of both reactants will more than likely be present. As there is no restriction in the peracetic annotation in PSL Table 7.3, peracetic acid products containing residual amounts of hydrogen peroxide and acetic acid are permitted for use in direct contact with organic products without a removal event.

Electrolyzed water #

Is electrolyzed water allowed by the Canada Organic Standards? (290, 491) – 18 August 2020

As of 2020, electrolyzed water is listed under Chlorine compounds, Tables 7.3, 7.4, PSL: ‘c) hypochlorous acid generated via electrolyzed water’.

Sanitizing in apple packing lines #

Can a calcium hypochlorite product containing additional components not included on Table 7.3: sodium chloride, calcium carbonate and calcium hydroxide, be used in apple packing lines? (513) 24 March 2021
Yes. Calcium hypochlorite is listed on table 7.3 for use in direct contact with food, and these three secondary ingredients – sodium chloride, calcium carbonate and calcium hydroxide – are permitted as they are used to treat drinking water as per 32.311 7.1.3 (“Other non-organic ingredients … shall be limited …. to compounds used to treat drinking water”). Concentration of the calcium hypochlorite shall not exceed maximum levels for safe drinking water when in direct contact with organic products such as the apples.

*Water quality falls under the jurisdiction of provincial and territorial governments. Health Canada’s Guidelines for Canadian Drinking Water Quality indicates “Free chlorine concentrations in most Canadian drinking water distribution systems range from 0.04 to 2.0 mg/L”. The US Centers for Disease Control and Prevention (CDC) state “chlorine levels up to 4mg/L (4ppm) are considered safe in drinking water”.

Use of detergents to wash clothing of employees #

Must laundry detergents used to wash clothing of employees comply with the Canadian Organic Standards when they work in an operation manufacturing organic products? (489) 18 August 2020
When clothing is in direct contact with organic food intentionally (i.e., fabric gloves), laundry detergents must comply with clause 8.2 of CAN/CGSB-32.310. Otherwise, the clothing is not considered a food contact surface, and is outside the scope of the standard.

Use of piperonyl butoxide #

Are pyrethrin products containing piperonyl butoxide as a synergist permitted for use in organic facility pest management programs? The annotation in 8.2 of CAN/CGSB-32.311 specifically prohibits piperonyl butoxide as a carrier. (490) – 18 August 2020
No. The annotation for pyrethrin is to prohibit its use if it contains piperonyl butoxide. When used as a synergist, piperonyl butoxide is considered an active ingredient under the Pest Management Regulatory Agency and would need to be listed in CAN/CGSB-32.311 to be acceptable in organic production.

Mint oil as sprout inhibitor #

Clove oil is permitted as a post-harvest sprout inhibitor for potatoes (Table 8.3). Can other plant oils, such as mint oil, be used for this purpose? (514) 1 July 2021
Although only clove oil is specified in Table 8.3, following consultation with the PSL Preparation Working Group, the SIC has clarified that oils from three plant families, specifically Lamiaceae (mint family), Apiaceae/Umbelliferae (celery family) and Myrtaceae (clove family), may be used as post-harvest sprout inhibitors for potatoes.


Use of unlisted substances #

If an organic product is treated under a mandatory government program (such as exports of potatoes to the US) with a pest control substance not listed under Table 8.2 of 32.311, does the organic product maintain organic status? (593) October 13, 2023

No. The only exception provided to substances listed in 32.311 Table 8.2 is described in 32.310 clause 8.3.3, which specifies that there shall be no risk to organic product status or integrity and that contact of organic products with unlisted substances was avoided. The treatment of an organic product with an unlisted substance would not comply with these requirements, as is also specified in 1.5 and 8.4.3 (32.310).

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