[compost_tea] CTTF Questions

From: Kirk Leonard <kirk_at_oregonatural.com>
Date: Sun, 13 Jun 2004 13:36:59 -0700
Help!  I don't know enough chemistry to understand what CTTF recommendation
#2 is doing by referencing 21 CFR 178.1010 "sanitizing agents" for cleaning
tea equipment.  Would someone who does please take a look and sanity check
it?

Googled 21 CFR 178.1010 and found from top link in search, don't have
original pointer.  It's about restaurant and food processing sanitizers, and
it sure seems like overkill to me.  Also looks like a list including a lot
of things not allowed by NOP...

I see hydrogen peroxide, several chlorines ("oxychloro species"), but no
plain natural soap (at least that I can recognize), which is probably
what most people use - and is sufficient. (I find plain water, little
pressure and rubbing sufficient, but...)  Are we gonna be hamstrung or
sidetracked by this - e.g., not commonly available or only thru industrial
distributors? Are all the "agents" commonly used for cleaning tea equipment
actually there?

Finally, all the stuff referenced there is subject to this:

"(d) Sanitizing agents for use in accordance with this section will
bear labeling meeting the requirements of the Federal Insecticide,
Fungicide, and Rodenticide Act."

Are these things a problem or not?  I can't tell.  I don't know if my best
soaps are labeled that way, and they probably don't have the same
formulations in this CFR, but they work.  Please help if you can translate
the CFR.  If it needs changing we should point it out.  We could recommend a
short, discrete list of common (and recognizable) cleaning agents instead.

Other question:  Poking up CTTF report to check CFR number again, I re-read
recommendation #5 where test requirements are, noticed something different
than was stuck in my head.  First sentence says "same compost batch,
additives, and equipment" implying every combination has to be tested twice.
But then, 4th sentence: "Each new batch of compost would require that the
system quality assurance pre-test be conducted again as indicated."

NOT all combinations.  That would reduce number of potential tests,
especially if you kept just one batch of super compost or blend for teas you
could lean the way you want with nutrients, and got all of them included in
two tests, including activation, hmm?

I like the idea of testing tea machines rather than tea batches but this
could be simpler...  Best of course would be to test compost - once - but
CTTF doesn't go there, nor does NOP anywhere else, so I won't either.

What about this 21 CFR 178.1010 sanitizing stuff?

Kirk

There, I didn't even say rawmanureheads!  And only suggested how totally
goofy it could be if you included a CFR reference in your requirements that
contained mostly substances disallowed under yer program, and plain old soap
and a little elbow grease does the job...





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Received on Sun Jun 13 2004 - 18:48:45 EDT

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