Is IPA a Registered Sanitizing Solution?

[buckeye gold]

It is not a matter of what is safe alone it is a matter of what is an approved use. The EPA established allowable residue levels, if a product has been labeled and manufactured legally in another country then you can apply to import it. It is subject to inspection and testing, but that does not mean it always is. See regs below

Imports:
The requirements of section 402 of the FFDCA apply equally to domestically produced and
imported food and feed found to contain pesticide residues. Therefore, even though the use of a
pesticide in a foreign country is not subject to EPA registration requirements under FIFRA, a
pesticide residue in imported food or feed must be in conformity with a tolerance, tolerance
exemption, or food additive regulation established by EPA or, if the pesticide residue is
unavoidable, an action level established by FDA.

Many substances are considered generally safe. The issue is it has never been approved for manufacturing use in the US, not if it is safe. EPA and FDA both accept that syrup produced in Canada is safe. Again it is not about that is about complying with our laws. Below is a list of sanitizing used for IPA, maple syrup is not on there

Isopropanol, isopropyl alcohol - SOLV, REG, <250 ppm as residue in modified hop extract - 172.560; <50 ppm as residue - In mfr of spice oleoresins - 173.240; 6 ppm - In mfr of lemon oil - 173.240; 2% by wt - In hop extract as residue from extraction of hops in mfr of beer - 173.240; AF, REG, GMP, Comp of defoaming agent for processing beet sugar and yeast - 173.340; SANI, REG, GMP, Adequate drainage - May be used on food processing equip and on food-con-tact surfaces - 178.1010(b)(17); SANI, REG, < 40 ppm Adequate drainage; May be used on food processing equip and on glass containers for holding milk - 178.1010(b)(7)

There are pages on pages of regs, I just tried to post enough to kind of help understand....it is by no means complete

I have to say the simplest thing is to just do what you know is right. When people in the know like Dr. Tim and your Dept of Ag representative tells you what is ok and what is not, why argue...just do what is approved. If you want to change law then go see your congressman, but if you go you better have done your homework. They don't change laws on I want to be different.

[Louie]

Wish I could find the approved list of cleaners for maple. The only thing I came up with was the last Maple News video of the guy cleaning with Zappit swimming pool cleaner.

[johnallin]

Wish I could find the approved list of cleaners for maple. The only thing I came up with was the last Maple News video of the guy cleaning with Zappit swimming pool cleaner.

Kind of what I'm thinking, does such a list even exist?

[buckeye gold]

I think it would be great if someone like Dr. Tim or USDA/FDA would print such a list. A public service document from an ag extension office or something. All I know is what I have been told by Dept. of Ag and extension agents, I have never seen a document spelling it out. Maybe state Maple producer Associations could work on this.

[n8hutch]

I've got my own concerns about using swimming pool cleaner. Understand that it dissolves and the residue left over is not harmful but I'm not certain that even that would be considered an approved use. Or at the minimum might be hard to sell to your customers. No doubt in my mind that 3/16 tubing is going to need to be cleaned somehow but until they figure out the best and approved way I'm just going to continue to cut out the bad spots and keep on going with uncleaned lines.

That was a great video they put out on what they ate trying to do but it was in no way a (Best Practice) or a seminar on how to clean Tubing. It is a trial ,at best.

[johnallin]

Nate, those are my sentiments exactly. I'm beginning to think that none of the cleaners/sanitizers that have been suggested as approved, list Maple Syrup individually on any kind of list, and that after all of the stern warnings, there is nothing to back them up.

We know that IPA is approved and registered as an ingredient in certain sanitizers for use in dairy and other food processing applications, and I'm fine with the fact that it's not specifically listed for use with Maple Syrup and therefore not a legal use. Although, using that logic, It would seem imperative that Hydrogen Peroxide does list tubing for use in collecting maple sap as an approved use of the product.

Not trying to be "different" or difficult, but as buckeye gold said, " I have never seen a document spelling it out. Maybe state Maple producer Associations could work on this." It would sure clear the air on this one.

[dsaw]

I've never used IPA, however, here's a hypothetical: Can I use IPA to clean my lines of water/dark spots? It's all in the use. In a past life, I purchased biocides for a major company that supplied the oilfield and became somewhat familiar with the rules regulating them. There was one biocide that only one company owned the registration to use it as a biocide in the oilfield, so they charged something like $20/lb for it. However, the chemical was actually duel use and also acted as a corrosion inhibitor. You could buy the same chemical from China for about $2/lb and legally use it in the US, as long as you only advertised it as a corrosion inhibortor and didn't mention it was a biocide. So is there another legitimate use for IPA that isn't as a sanitizer (regulated), like a cleaner (I'm not an expert, but guessing not regulate)?
This also brings up why no one has bothered to register IPA in the US. Let's say company A jumps through the hops and gets it registered. That registration only applies to company A's IPA. So obviously, company A is going to charge ? times the normal price for their product. Just because they have it registered doesn't mean you can use anyone's IPA, the registration is only for that company's product or someone who pays a fee for access to their approval research (not likely in what is already a generic product). But after you buy one container from the registered company, who's to know if you aren't refilling it with generic stuff at 1/? the price? That's probably why no one has bothered to do it in the US.

[buckeye gold]

dsaw, I have done similar things with sanitizers my past career, but when the EPA and FDA come looking they will frown real big and shake their head no. It might get you off with a warning, but ultimately your wrong. You need to show a regular approved need and maintenance plan. Positive side effects are good, and in your case, in the oil field, there was a regular commonly accepted practice of using the compound in approved applications. IT's a hard nut to crack when there is no accepted regular use of a product within the industry. I really struggle with why we as people have to constantly push the limits. It's like children always testing their parents, until they get their hind end spanked or some other form of discipline. The common response in our house was we all got in trouble when one of us pushed mom and dad too far. Just do what we know we can, it works just fine.

[johnallin]

dsaw, ... Just do what we know we can, it works just fine...

I agree with your thinking regarding doing what "we know" we can do....but has a list of approved/registered sanitizers specific to Maple been found? If not, do we really know what we can and cannot use?

[buckeye gold]

I'm still waiting on that official document too. All we can do is go by what we are told and hold people to that word. I don't think anyone is going to make an issue of what we are using if it is in line with what Dept of ag and accepted authorities have verbally stated. There are too many witnesses for a rebuttal. At worse it would be a stop use from this point on warning.