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Water Activity & pH Control Checklist

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Control product safety through water activity and pH, covering formulation limits, measurement, calibration, and monitoring to prevent pathogen growth and toxin formation.

21 CFR 117FDA Food Code

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Formulation Limits

  • Are documented water activity (aw) and pH limits established to control the growth of pathogens? *
  • Is the product classified as non-TCS where aw is 0.85 or below or pH is 4.6 or below? *
  • Are the critical limits supported by a scientific study or process authority letter? *
  • Is a hurdle approach documented where aw and pH are combined to control safety?

Measurement & Instrumentation

  • Is water activity measured with a calibrated aw meter under controlled temperature conditions? *
  • Is pH measured with a calibrated pH meter or validated method for the product type? *
  • Are representative samples taken from each batch or lot for testing? *
  • Measured finished product water activity (aw)

Calibration

  • Are aw meters verified with saturated salt standards before use? *
  • Are pH meters calibrated with certified buffer solutions at the required frequency? *
  • Are calibration records maintained and traceable? *
  • Measured finished product pH

Monitoring & Corrective Action

  • Is each batch monitored against the established aw and pH critical limits before release? *
  • Are corrective actions taken and documented when aw or pH is outside the critical limit? *
  • Are monitoring and verification records maintained for the required retention period? *

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