Sanitization for Food Safety: Using Sanitizer Test Strips

National Environmental Health Association, 2026.

Hydrion ® pH and sanitizer test kits since 1934

Sanitization for Food Safety Using Sanitizer Test Strips

Melissa Vaccaro, MS, CP-FS NEHA Sr. Food Safety Program Specialist

Sanitization for Food Safety

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1: Title Slide

2: Learning through Partnerships

3: Welcome

Sanitization for Food Safety

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4: Why Sanitize?

5: Heat Sanitizing

6: Chemical Sanitizing

Sanitization for Food Safety

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7: Chlorine

8: Chlorine cont.

9: Chlorine cont.

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10: Chlorine and Dishwashers

11: Quaternary Ammonia Compounds (Quats)

12: Quaternary Ammonia Compounds cont.

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13: Quaternary Ammonia Compounds cont.

14: Quaternary Ammonia Compounds cont.

15: Quaternary Ammonia Compounds cont.

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16: Do you know what “Quat Binding” is?

17: Video

18: Quats

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19: Comparison - Pros

20: Comparison - Cons

21: Iodine-Based Sanitizers (Iodophors)

Sanitization for Food Safety

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22: How many different sanitizer test kits do you carry?

23: Test Kits

24: Test Kits cont.

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25: Test Kit cont.

26: Test Kits cont.

27: Test Kits cont.

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28: Test Kits cont.

29: Test Kits cont.

30: Test Kits cont.

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31: Test Kits – pH for Sushi Rice

32: EPA Label

33: Resources

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34: How to Use Test Strips

35: How to Use Test Strips cont.

36: How to Use Test Strips cont.

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37: The Lot Number and The Color Pad

38: Expiration

39: How to Use Test Strips cont.

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40: How to Use Test Strips cont.

41: How to Use Test Strips cont.

42: Quat Testing

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43: Quat Testing cont.

44: Quat Testing cont.

45: Chlorine Testing

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46: Chlorine Testing cont.

47: QAC Test Strip

48: Demonstration Video

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49: Thank You & Contact Information

50: NEHA Training Newsletter

51: NEHA Membership

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Resources

Slide 33 Links: • NSF: Registered Cleaner: Disinfectants, Sanitizers, and Cleaners for the Food Industry • EPA: Selected EPA-Registered Disinfectants • EPA: List N (Covid-19) • EPA: List G (Norovirus) • EPA: How to Search for Information about Pesticide Ingredients and Labels • Active Pesticide Product Registration Informational Listing (APPRIL)

Video Links:

• How to Use Sanitizer Test Strips • Cómo Usar las Tiras de Prueba de Desinfectante • Shore Manufacturing Quat Binding Demo (Shore Quat Compatible Foodservice Towels)

Spanish Resources and Handouts on NEHA.org : • Sanitization for Food Safety: Using Sanitizer Test Strips

TECHNICAL BULLETIN Requirements for Surface Sanitizers to be FDA Food Code Compliant

1. Federal and State Registration: The product must be registered with the EPA and have an EPA registration number. The product must also be registered in the state that it is being used in. a. FDA does not review and approve food contact surface sanitizers. b. Jurisdiction for antimicrobial substances used to sanitize or disinfect food-contact surfaces was transferred to the EPA under the Food Quality Protection Act (FQPA) passed by Congress in 1996 (http://npic.orst.edu/reg/laws.html). c. EPA must review the product formulation, acute toxicity, and efficacy data as well as approve/ prescribe product labeling i. In order for EPA to permit labeling for Food Contact Surface Sanitizing with no rinse required EPA must check that the active ingredient and any inert ingredients are acceptable for this use per 7-204.11 Sanitizers, Criteria of the 2013 Food Code (referencing 40 CFR 180.940, 950, or 960). The 2005 - 2013 FDA Food Code recognizes this.

ii. EPA must review the efficacy data and assure that the product kills 99.999% of bacteria within 30 seconds (Staphylococcus aureus and E. Coli). Note: Even though a product has proven to kill 99.999% of bacteria in 30 seconds or less and FDA Food Code requires a contact time of at least 30 seconds for other chemical sanitizing solutions, EPA requires that a product's directions for use indicate 60 seconds for sanitizing food contact surfaces.

2. Test Device: A test kit or other device that accurately measures the active concentration level of sanitizing solutions must be available as per 4-302.14 Sanitizers, Criteria of the 2013 Food Code.

3. Follow Directions for Use: If a sanitizer other than chlorine, iodine, or a quaternary ammonium compound is used, it shall be applied in accordance with the EPA-registered label use instructions. a. As identified above within Federal Registration, EPA will approve as well as prescribe product labeling. b. An area that is prescriptive is the 'directions for use' for EPA registered food contact surface sanitizers. EPA requires food contact surface sanitizers to indicate a 60-second dwell time even if the product has data that proves 99.999% reduction of bacteria in 30 seconds or less.

PURELL® Foodservice Surface Sanitizer Complies with FDA FOOD CODE

1. Federal and State Registration: a. PURELL Foodservice Surface Sanitizer is an EPA registered surface sanitizer/disinfectant (EPA Reg. No. 84368-1-84150) approved for use on food-contact surfaces with no rinse required and is currently registered in all 50 states. b. All ingredients in PURELL Foodservice Surface Sanitizer have been reviewed by EPA and found to meet requirements for use on food contact surfaces and not requiring a rinse. i. NOTE: Food Code does not prohibit the use of ethanol as active ingredient. The Food Code requires that the registration holder demonstrate to the regulatory authority (EPA) that the solution achieves sanitization. c. PURELL Foodservice Surface Sanitizer is approved by EPA with the level of ethanol active ingredient in the range of 28.5 to 30.3%, however there is no upper limit for amount of ethanol that can be used on a food contact surface per 40 CFR 180.940. d. Product quality is verified before shipping to ensure the level of ethanol active ingredient and since the product is ready to use there is no risk of mixing incorrectly.

2. Test Device: to support the use of this product, specifically in back-of-house on food contact surfaces, test strips to measure active ingredient concentration are available to the end user as specified by the 2013 FDA Food Code.

3. Follow Directions for Use: The PURELL Foodservice Surface Sanitizer product is acceptable for use in foodservice establishments as long as it is used in accordance with the EPA-registered label use instructions.

ANSWERS TO COMMON QUESTIONS:

• WHAT ARE THE APPROVED USES FOR THE PRODUCT? PURELL Foodservice Surface Sanitizer is EPA-approved for surface sanitizing and cleaning in both Front of House and Back of House. It is approved for use on both non-food contact surfaces and food contact surfaces with no rinse required. Facilities should always follow Food Code guidance for cleaning and sanitizing food contact surfaces. In order to effectively clean and sanitize food contact surfaces, where and when required to satisfy the requirements in Parts 4-6 and 4-7 of the Food Code, the surface must be first cleaned properly to remove organic material. o For Food Contact Surfaces, PURELL Foodservice Surface Sanitizer may be used for both the pre-clean steps as well as the sanitization steps and no rinse is required. For example: 1. Scrape: Scrape excess/visible food away from surface. 2. Wash: Spray PURELL Foodservice Surface Sanitizer on surface; then, wipe with a dean towel. No rinse is required. 3. Sanitize: Spray PURELL Foodservice Surface Sanitizer on surface again and allow to air dry. o For Non Food Contact Surfaces, PURELL Foodservice Surface Sanitizer may be used to sanitize and clean in one-step. For example: 1. Sanitize: Spray PURELL Foodservice Surface Sanitizer on surface and allow to remain wet for 60 seconds. Wipe or allow to air dry. • WHAT ARE THE ACCEPTABLE LOW AND HIGH LEVELS OF THE PRODUCT? PURELL Foodservice Surface Sanitizer is approved by EPA with the level of ethanol active ingredient in the range of 28.5 to 30.3%, however there is no limit for amount of ethanol that can be used on a food contact surface per 40 CFR 180.940. Test strips accurately measure ethanol levels and ensure levels meet EPA approved specifications.

• WHERE SHOULD YOU STORE THE PURELL FOODSERVICE SURFACE SANITIZER AND ASSOCIATED TEST KIT? Always store PURELL Foodservice Surface Sanitizer and Test Kit materials in a designated chemical closet.

Chlorine and pH How to apply FDA Food Code 4-501.114(A) - S pecifically the table that shows how chlorine sanitizer effectiveness depends on concentration, pH and temperature . What the provision says Section 4- 501.114(A) sets requirements for chemical sanitizing solutions used on food - contact surfaces in manual or mechanical operations (e.g., sinks, warewashing machines). It states that a sanitizer (like chlorine) must meet these parameters: concentration , temperature , pH , and contact time . ( U.S. Food and Drug Administration ) For chlorine solutions, the table (as adopted in some jurisdictions) looks like this:

Chlorine concentration (mg/L or ppm)

Minimum temperature required at pH ≤10

Minimum temperature required at pH ≤8

25- 49 ppm

120 °F (49 °C)

50- 99 ppm

100 °F (38 °C)

75 °F (24 °C)

100 ppm

55 °F (13 °C)

(Note: the “pH ≤8” column shows a lower temperature requirement when the pH is more favorable.)

A few things to note: • Concentration refers to how many milligrams per liter (mg/L) of free chlorine are in the sanitizing solution. • pH is the acidity/alkalinity of the solution: higher pH means more alkaline. • Temperature is the minimum water/solution temperature that must be reached (or exceeded) for the sanitizer to be effective under those conditions. • There is also a required contact time (how long the sanitizer must stay in contact with the surface) but that is covered in other parts of the Code (or in local adoption) — many sources say at least ~7 – 10 seconds for chlorine in these conditions.

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Why this matters The table reflects how sanitizer efficacy is influenced by multiple variables:

• Higher pH (more alkaline) reduces the antimicrobial effectiveness of chlorine. So if the pH is high (e.g., pH ~10), you need higher temperature (or more concentration) to get the same effect. • Lower temperature also reduces the rate of chemical sanitization. So if temperature is low, you need higher concentration (or lower pH) to compensate. • Concentration : At lower concentrations of chlorine, you must compensate with higher temperature (and/or favorable pH) to ensure the necessary kill or reduction of microorganisms. In other words: If conditions are less favorable (higher pH, lower temperature, lower concentration), the sanitizing solution may not reliably sanitize surfaces. The Code table gives the “minimum” conditions under which chlorine is considered acceptable for manual/mechanical sanitization operations. How to apply it When you’re in a food - service or retail establishment (or any regulated food environment) you would use this table to ensure your sanitizing solution meets all the required conditions. For example: • Say you mix a chlorine sanitizing solution at 50 ppm free chlorine, and the pH of the solution is measured at 9.0 . o That falls into the “50 - 99 ppm” range, and the pH is “pH ≤10” column. According to the table, minimum temperature must be 100 °F (38 °C) . o If your solution is only at 70 °F, that would not meet the requirement (unless local code variation says otherwise). • If instead you keep the solution at pH 8.0 (more favorable) at 50 ppm, then the “pH ≤8” column applies — the table says minimum temperature 75 °F (24 °C) . So you’d be good if temperature is ≥75 °F. • If you use 25 ppm chlorine (lower concentration), you need temperature 120 °F regardless of whether pH is ≤8 or ≤10 (in the table they show 120 °F for both). • You also must measure and track pH, temperature, and concentration of the sanitizing solution periodically (depending on your local jurisdiction) to make sure the solution is within spec.

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Important caveats & local variation • The table and the exact numbers may vary slightly depending on which edition of the Food Code your jurisdiction has adopted, or if the local health department has additional or more stringent requirements. • The solution must also be used in accordance with the EPA - registered label and manufacturer’s instructions for that chemical sanitizer. The Code acknowledges this . • Contact time: Even if concentration, pH and temperature are correct, you still must ensure the sanitizer stays in contact for the required minimum time (often 7 –10 seconds for chlorine manual, as many training sources say). • Hardness of water, presence of organic soil, and other sanitation factors may affect efficacy — so this table is part of the “ideal condition” baseline, but good practice includes cleaning surfaces thoroughly before sanitizing and verifying the solution frequently.

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