Regulatory Considerations

Although the FDA has approved the use of aqueous ClO2 (3 ppm residual) to wash fruits and vegetables, it has not granted permission to use the gaseous form of ClO2 as a sanitizer for decontaminating produce. It is assumed that gaseous ClO2 treatment would be very similar to aqueous ClO2, producing similar oxychloro byproducts (chlorine, ClO2, chlorate, and chlorite) as an aqueous ClO2 treatment. Based on existing scientific literature and data related to exposure to drinking water containing 1 mg/kg of the oxidant species (chlorine, ClO2, chlorate, and chlorite), the use of aqueous chlorine dioxide is not likely to lead to chemical byproducts that are harmful to human health [10]. The research group at Purdue University has shown that residuals of ClO2 and chlorite on green peppers were not detectable after a 4-week storage period and after a 1-week storage period for strawberries [37,38]. However, in order to pursue regulatory approval for the use of ClO2 gas for decontamination of fresh and cut produce, more information and research are needed on production of byproducts on fruit and vegetable surfaces after ClO2 treatment.

In the food industry, ozone was first permitted by the FDA to disinfect bottled water [137]. In 1997 ozone was affirmed GRAS status as a disinfectant and/or sanitizer for broad-based food usage by an expert panel sponsored by the Electric Power Research Institute (EPRI) in the U.S. [57]. In 2001 the FDA approved the use of ozone as a direct food additive for the treatment, storage, and processing of foods in gaseous and aqueous phases. Acetic acid and hydrogen peroxide have been considered as GRAS food additives by the FDA; however, currently there are no regulations in the U.S. on the usage of their vaporous forms or of other natural plant volatiles (AITC, MJ, trans-anethole, carvacrol, cinnamic aldehyde, eugenol, linalool, and thymol) as antimicrobial agents for preservation or sanitation of fruits and vegetables. Regulatory approval of the usage of these antimicrobials for produce will depend upon many different factors. Certainly, treatment effectiveness and efficacy data, worker safety and human health exposure data, and industrial and commercial needs will all play very important roles as this technology moves forward.

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