Issue View | Council III | 2020 Biennial Meeting

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PWWC- Issue 3: Amend Food Code to include Produce Wash Testing Devices

Inclusion of a new section: "4-302.15 Fruit and Vegetable Wash Solutions, Testing Devices" into the next edition of the FDA Food Code which would require establishments who utilize chemicals to wash fruits and vegetables to have a test kit for such chemicals available for use in the establishment.

2017 FDA Food Code section 3-302.15 (B) states, "Fruits and vegetables may be washed by using chemicals as specified under § 7-204.12." In the 2017 FDA Food Code Annex 3, 3-302.15, it explains that, "Toxic or undesirable residues could be present in or on the food if chemicals used for washing purposes are unapproved or applied in excessive concentrations. Unless otherwise stipulated in 21 CFR 173.315, chemicals used to wash or peel fruits and vegetables should not exceed the minimum amount required to accomplish the intended effect, need to be accurately tested for proper concentration, and must adhere to any indications as dictated on the product label."

Currently there is no FDA Food Code requirement to test or verify the concentration of chemicals used to wash fruits and vegetables when listed on the product label. Chemical produce washes which specify concentrations or ranges have been thoroughly reviewed and vetted by FDA and EPA for safety and efficacy. Concentrations exceeding or used at lower concentrations than listed on the product label, would not be appropriate for the intended use of the product. For EPA registered products, lower concentrations may not provide the desired and claimed product efficacy. Produce wash concentration verification is therefore necessary and recommended to prevent usage outside labeled use limits.

In order to assist both users of the chemical and regulators who want to verify proper use of the chemical as per label instructions, a method to verify concentrations for antimicrobial products used for fruit and vegetable washing should be available.

Amend the 2017 Food Code by adding a new section: "4-302.15 Fruit and Vegetable Wash Solutions, Testing Devices" as follows:

4-302.15 Fruit and Vegetable Wash Solutions, Testing Devices.

A test kit or other device that accurately measures the concentration of fruit and vegetable wash solution shall be provided if specified on the product label. ^Pf