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5.2.2 Daphnia magna Study A study was performed to research the toxicity of the active component of NEW on Daphnia magna, a water flea commonly used in toxicity studies on aquatic organisms. The study involved 21-day full life cycle testing measuring two endpoints, mortality and reproduction. The Daphnia clone used was of Finnish origin from the North Savo Regional Environmental Center in Kuopio, Finland. Results of the study showed that no significant differences were found in the reproduction of Daphnia magna in all tested media. The mortality of Daphnias during testing was <10%, with only one Daphnia dying during the study. There were no differences observed in the size and weight at the endpoint of experiments between Daphnia magna grown in the test samples and in the control. It was concluded that no chronic toxicity effects were observed for Daphnia magna grown in the presence of the active component of NEW. 6.0 NEW has an extended shelf life and is stable for longer than one month, although it is still highly recommended using freshly generated NEW. In contrast, many other super-oxidized waters are only stable for a few hours and are produced with electrolytic cells that are very limited in production capacity as well as limited in lifetime. In these products, free available chlorine is unstable and easily evaporates from the water, causing an immediate strong chlorine smell and complicating storage, transport and usage. The parameters that are measured in order to establish shelf life include pH, ORP and FAC. In addition, a commonly used method to determine stability revolves around the ability of NEW to kill spores of Bacillus subtilis, a bacterium known to be among the most resilient to chlorine. This is a useful measurement used in determining the shelf life of NEW, since it is ultimately this anti-microbial nature that is key to News’s action as a high-level disinfectant. A study was performed to compare the shelf life of NEW (446 mg/L of active chlorine) to a NaClO solution (334 mg/L of active chlorine) during a 54-day period under the following storage conditions: at 4oC under artificial light, and at room temperature (23 ± 2oC) in the presence of natural light in both open and closed containers. The pH, ORP and active chlorine concentrations were periodically measured during storage. Results showed that NEW exhibited better shelf life than NaClO in all of the evaluated conditions in terms of active chlorine degradation and bactericidal activity. The half-life of NEW was determined to be 21 days at room temperature, and more than 54 days at 4oC. 7.0 In data obtained from independent testing executed outside the USA by third parties, no evidence of toxicity in any form has been observed in any testing. Moreover, this claim is supported by the review of relevant literature, which has revealed that HOCl and OCl-, at the low doses occurring in NEW, do not produce toxic effects. Based on this information, it can reasonably be concluded that NEW is non-toxic and safe to use in the industries and applications considered by ChlorKing. 8.0 8.1 EPA Stability of NEW Toxicity of NEW Regulatory The EPA has approved the use of NEW in the raw food industry without the need for an additional processing, and has granted an “establishment number” (82060-FL-001) allowing the use of electrolyzed water that is produced on- site for the food industry. Because speciation studies from a variety of institutions have identified only chlorine in the mixed oxidant NEW solution, the U.S. Environmental Protection Agency (EPA) has determined that mixed oxidant customers need only to follow chlorine regulatory requirements, including use of chlorine CT values, limits on maximum chlorine allowed, and limits on total trihalomethanes (TTHM) and halo acetic acid (HAA5) formation. NEW is approved under 21 CFR 173.315 for direct contact with processed foods, and is approved for several indirect food contract applications under 21 CFR 172.892, 21 CFR 175.105, 21 CFR 176.170 and 21 CFR 177.2800. It is an approved sanitizer that meets 21 CFR 178.1010. The EPA has also given approval (40 CFR 180.1054) for washing raw foods that are to be consumed without processing. 14 | P a g ePDF Image | Neutral Electrolyzed Water
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