[compost_tea] CTTF Comment
Another public comment. Please send yours, too.
No answers on chemistry here made me confess my ignorance but I hope I
made a set of sound points about compost tea, and a better suggestion.
Kirk
Sent this today to NOSB.crops_at_usda.gov and Katherine.Benham@USDA.gov.
> Dear NOSB members:
> I have a comment on the Compost Tea Task Force report you received
4/29/04. It is about sanitizing agents for compost tea machinery.
> Recommendation #2 requires sanitizing per 21 CFR 178.1010. Why?
I believe it would be both more appropriate and more clear if the
recommendation simply stated that appropriate dilutions of hydrogen peroxide
or chlorine or a few kinds of soap were required, preferably natural soaps.
> Additionally, many of the substances in the CFR reference seem to be
materials that are hazardous to both people and the biology of compost tea.
Residues could easily wreak havoc with teas. It also seems to me that many
of the substances in the reference are not allowed by NOP. Not being a
chemist I may be wrong, but if that is the case it does not seem
appropriate.
> The cleaning of compost tea equipment should not, and does not require
restaurant-level sanitizing, and most of the substances specified in 21 CFR
178.1010 are unnecessary, potentially even counterproductive.
> Hydrogen peroxide or chlorine dilutions are often used in cleaning tea
equipment, but there are many other natural cleansers used which are quite
sufficient and equally safe. Well-designed and maintained tea equipment can
often be adequately cleaned simply using pressure washing with clean water,
and tea itself is a good cleaning agent in combination with a little rubbing
or light brushing.
> The key here is the principal cleaning problem, which is biofilm buildup,
not pathogens. Clean tea equipment does not harbor pathogens - nor does
good compost tea, for that matter.
> I support the report, but this provision seems inappropriate. A short
list of acceptable, common cleaning agents would be much better for both
users and certifiers.
> R. Kirk Leonard
> P. O. Box 249
> Aurora, OR 97002
> 503-678-5990
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Received on Wed Jun 16 2004 - 22:37:55 EDT
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