Regulation > USDA

USDA Letter of No Objection

On December 19, 2018, using our FCN 1811 from the FDA, a letter of no objection was obtained from FSIS for the use of hypochlorous acid on meat, poultry and shell eggs at up to 50 ppm.

USDA National Organic Program
Letter from USDA Organic: Click Here

On June 9, 2014, the National Organic Program (NOP) published a policy memorandum (PM 14-3) on the status of electrolyzed water under the U.S. Department of Agriculture (USDA) organic regulations at 7 CFR Part 205. Following the release of PM 14-3, stakeholders provided additional technical and regulatory information on electrolyzed water to the NOP. Chlorine materials are allowed to be used in organic production and handling. The National Organic Program (NOP) Handbook includes guidance (NOP 5026) The Use of Chlorine Materials in Organic Production and Handling. This guidance clarifies the allowable uses of chlorine products under the USDA organic regulations. Chlorine materials are included on the National List of Allowed and Prohibited Substances (National List). In water, chlorine materials such as calcium and sodium hypochlorite form an equilibrium of related chlorine species, including hypochlorous acid (HOCl) and hypochlorite (ClO- ). Similar chlorine species are formed in the generation of electrolyzed water. Accordingly, the NOP considers hypochlorous acid generated by electrolyzed water to be an allowable type of chlorine material.

FSIS Directive: Table of Safe and Suitable Ingredients

The Table of Safe and Suitable Ingredients identifies the food grade substances that have been approved in 21 Code of Federal Regulations (CFR) for use in meat, poultry, and egg products as food additives, generally recognized as safe (GRAS) notices and pre-market notifications, and approved in letters conveying acceptability determinations.

National Organic Program
USDA Source: Click Here

The National Organic Program (NOP) is a regulatory program housed within the USDA Agricultural Marketing Service. It is responsible for developing national standards for organically-produced agricultural products. These standards assure consumers that products with the USDA organic seal meet consistent, uniform standards.

Potassium hydroxide (KOH) is currently allowed under the National Organic Program (NOP) regulations for use in in organic handling and processing as a synthetic nonagricultural (nonorganic) substance listed at 7 CFR 205.605(b) for use as an ingredient in or on processed products labeled as "organic" or "made with organic (specified ingredients or food group(s))" with the following annotation: "prohibited for use in lye peeling of fruits and vegetables except when used for peeling peaches." It is used as a direct food additive, formulation aid, pH adjuster, cleaning agent, stabilizer, thickener, and poultry scald agent.
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