Food Safety: USDA NOP Update, Chlorine (6 of 6)

This is the final article in the series on food safety in the organic industry. It talks about the use of chlorine in clean-up and to sanitize equipment of organic food.

The draft guidance on the use of chlorine has been restricted to be:

“Allowed for disinfecting and sanitizing food contact surfaces. Residual chlorine levels for wash water in direct crop or food contact and in flush water from cleaning irrigation systems that is applied to crops or fields cannot exceed the maximum residual disinfectant limit under the Safe Drinking Water Act.”

Natural chlorine is simply an element, noted as CL on the periodic table, but when we think of chlorine it is usually in a chlorine compound. Ensuring the safety and protection of runoff is essential to organic food. Even organic food carries pathogens at times, and to ensure that there is no cross-contamination by farms that practice both conventional and organic farming, the use of chlorine is likely to be the most safety-minded measure.

There is already residual chlorine in municipal drinking water and of course, there are two valid arguments to condone and oppose its use. On one hand, says that drinking water treated with chlorine has helped promote healthy, clean drinking water for a world which battles diseases like typhoid, cholera and dysentery from polluted water. On the other hand, says that municipal drinking water treated with chlorine links to increased rates of cancer. In any case, the US Government allows a certain level of chlorine treatment to municipal water, currently currently 4mg/L expressed as Cl2. For more information on the Safe Drinking Water Act, visit the EPA's website on the subject.

Knowing that there is already a law in place to ensure water doesn't become over-chlorinated, the draft guidance for the use of chlorine seeks to enforce these rules while maintaining a quality of safety in organic food. Apparently, an oversight in the March 2000 documentation allowed for the possibility of flush water being used on crops: "The language used in the proposed NOP rule published in March 2000 did not include the terms 'in direct crop or food contact' and 'in flush water ... that is applied to crops or fields.'" The new draft guidance makes specific mention of this. In theory, using flush water is a great re-use of our most precious resource, assuming that the ppm of sanitizer is minimal to none.

It's easy to see how complicated the industrial food system can be, organic or not. And as people are always people, shortcuts in the system will be taken unless there is an overseeing force threatening some kind of fine. At the same time, it is imperative that the overseers are qualified to see the scope of an entire project, and that is why it is important that anyone with concerns about these six draft documents make the case better understood by commenting on them (deadline: December 13, 2010). It is in the interest of all consumers including you and your family to have access to clean, healthy, sustainable, safe food.