Traditionally, milk contact surfaces have been washed with hot water because the detergents used needed a minimum water temperature to be effective and to prevent bacteria problems in milk. However, detergents designed to wash milk contact surfaces with cold or warm water are now in the marketplace. This fact sheet describes how these products fit with the Food Safety program’s requirements.
What is a cold-water wash detergent?
There are two types of cold-water wash detergents that are available on the market. One type is a pure cold wash detergent, where you use cold water for every wash. The other type is a reduced temperature detergent (RTD). Some products are only intended for washing the pipeline, while others are intended for the pipeline and bulk tank.
Can I use cold-water wash detergents or RTDs and meet the Food Safety requirements?
Yes, you can use a cold-water wash detergent or a RTD and still meet the Food Safety program requirements. The Food Safety program requires you to:
1. Use approved products: make sure the products you use on milk contact surfaces are approved for use in food establishments or recommended by the manufacturer to clean dairy equipment.
2. Follow the Cleaning and Sanitizing Chart (Record 14) completed by your equipment dealer. The chart becomes even more important with cold-water wash products or RTDs, particularly if they require you to conduct a warm or hot wash at a specified frequency (e.g. once a week). Follow the directions carefully.
Do any Food Safety program requirements no longer apply if I use cold-water wash detergents?
Yes! Question 48 no longer applies. You do not need to monitor and record the temperature of your hot wash or your pre-rinse if you are only using cold water.
If, however, you use a RTD or your Cleaning and Sanitizing Chart states that you must conduct a warm or hot wash at a specified frequency (e.g. once a week), you must monitor the temperature of that wash and record it on Record 13, your Milking Equipment Sanitation Record. The minimum required frequency for recording is once a month.
How do cold-water wash detergents and RTDs affect my TTR?
At the time of publication of this fact sheet, the Time Temperature Recorders (TTRs) on the market may not have the capability to accommodate either cold-water washes or RTDs well, and may result in false alarms for wash temperatures. Table 1 outlines the different strategies you can try.
Do I have to record all of the false alarms related to my cold water or RTD washes?
Since TTRs are not well equipped yet to handle cold water or RTD washes, your TTR may alarm at every wash. Are you required to record every false wash alarm for the rest of Food Safety program history? No; however, you do need to be able to demonstrate to your validator that you are not ignoring real alarms. You need to be able to show how you are monitoring the temperature of a warm wash, if applicable, and how you ensure that you do not miss important milk temperature alarms. You should use your Standard Operating Procedures to explain how you are going to do this and then your Deviation and Corrective Action record should support it, showing what you have done whenever your TTR alarms for milk temperature problems.
What else do I need to know?
The Food Safety program does not advocate for one product or type of product over another. You are responsible to seek the best solution for your system, within the program guidelines of using approved products according to the professional advice of equipment dealers.
How can I find out more?
Talk to your equipment dealer to find out which products and associated water temperatures are best for your system, your water, and your management goals.