Revisions to the Guidelines

1. Revisions to the Guidelines Revisions to be made to version 3.0

2. Revisions to the GuidelinesSection 3.2.1 Formulation Submission • The guidelines currently require that the following formulation information be submitted for each ingredient: • The complete chemical name • The Chemical Abstract Service Registry Number (CAS Number) • The name of the supplier • The regulatory reference which allows the ingredient to be used in contact with food

3. Revisions to the GuidelinesSection 3.2.1 Formulation Submission • “Proprietary fragrances must be identified by trade name and manufacturer. Essential oils may be identified by common or chemical names.” • This requirement will be removed.

4. Revisions to the GuidelinesSection 3.2.1 Formulation Submission • Reasoning • NSF wishes to identify each ingredient in a product by chemical name and CAS number so we can determine the suitability of each ingredient to the guidelines.

5. Revisions to the GuidelinesSections;4.5 Hog Scald Agents (3B)4.6 Tripe Processing Substances (3C)and 4.7 Fruit and Vegetable Washing Products (3D)

6. Revisions to the GuidelinesSections 4.5, 4.6 and 4.7 • The current requirements read: • “Products containing one or more of the substances listed in Table [XX] may be acceptable.” • The change will be: • Replace the phrase “may be acceptable” with “are acceptable”.

7. Revisions to the GuidelinesSections 4.5, 4.6 and 4.7 • Reasoning • The phrase “may be” is confusing, and makes it appear that compounds other than those on the lists in these sections are acceptable, which unless otherwise noted is not the case.

8. Revisions to the GuidelinesSection 5.8.6 Boiler Treatment Products (G6) • The current requirement indicates that “products shall comply with 21 CFR 173.310.” • NSF is considering the addition of GRAS substances (21 CFR sections 182 and 184) to the list of acceptable ingredients for products of this category.

9. Revisions to the GuidelinesSection 5.8.6 Boiler Treatment Products (G6) • Reasoning: • Many of the guidelines currently in place for products that contact food indicate GRAS (section 182 and 184 of 21 CFR) substances as being acceptable.

10. Revisions to the GuidelinesSection 5.8.6 Boiler Treatment Products (G6) Suggestions and/or comments

11. Heat Transfer Fluid Issue • Several companies have applied for registration as a lubricant with incidental food contact (H1) and as a heat transfer fluid under the miscellaneous category (P1). • In the past the USDA listed these products as both H1 and P1.

12. Heat Transfer Fluid Issue • NSF’s position: • The labeling of heat transfer fluids is not consistent with the use as a lubricant. • A possible option for companies would be to create a new label/trade name for the product and submit one as a lubricant and one as a heat transfer fluid.

13. Heat Transfer Fluid Issue Suggestion and/or comments

14. Revisions to the GuidelinesSection 5.2 - Cleaning Products • The current requirement reads: • “Products shall have an expected human single oral LD50 greater than 10 mg/kg.” • The change will be: • Replace “expected human single oral LD50” with “expected animal single oral LD50.”

15. Revisions to the GuidelinesSection 5.2 - Cleaning Products • Reasoning • After consulting with the USDA, we were informed that the USDA used animal LD50 when necessary.

16. Request for the formation of a working group • Many issues arise throughout the year which require input from the steering committee. • Available to respond to requests for opinions on guideline changes throughout the year.

17. Request for the formation of a working group • As issues arise • The issue will be emailed to the working group. • The working group will then have 2-3 weeks to respond with their opinion. • No specific number of people requested with as many representatives from as many industries as possible.