Washing produce with conventional soap is harmful, I agree! But what about fragrance-free, dye-free, preservative-free, hypo-allergic, non-toxic, eco-friendly, bio-degradable, ALL natural (even organic!) dish soap? These soaps look safe because they are free from
toxins like 1,4-dioxane + phthalates + cocamidopropyl betaine.
First and foremost, I believe you need to take a look at how regulatory bodies actually define and qualify terms such as "harm" and "safety". I'll go ahead and quote one of my own answers (source), just keep in mind this is a generalization that aims at brevity and ease of reading for the average layperson:
...First of all, a bit of the fundamentals and clarification on terminologies: what is "harm"? We define harm as any unintended, adverse health impact that results from the ingestion of foods containing hazards; and likewise, we define "hazards" as the unintended presence of potentially harmful elements or substances. These hazards are traditionally grouped into three major categories: physical, chemical, and biological (note: radiological and allergenic hazards have been consolidated under the chemical hazards category post-FSMA). The sciences and disciplines involved with the prevention, reduction, and control of such hazards as what is known as food safety, and just like any other branch of science, there are systematic, evidence-based methodologies deployed in the interest of mitigating aforementioned hazards. Of the existent systems, the USDA and FDA in particular enforce what is known as Hazard Analysis and Critical Control Points (HACCP) — and in more recent years in light of the Food Safety Modernization Act (FSMA), we now incorporate the more robust Hazard Analysis and Risk-based Preventative Controls (HARPC). In short, the principles and practices in these sets of methodologies allow us to quantify health hazards, and once quantified, we are able to manage undesirable outcomes based upon principles of risk management. And what is "risk"? We define risk as the product of likelihood and severity [of potential harm]. Employing such principles, each and every individual processing step (and beyond) is analyzed and potential hazards are systematically addressed. This is enforced on the federal, local, and most of all, the retail spaces; surprising as it may seem, the driving force of food safety in the past few decades has in fact been the major retailers and international consortiums. Why? Because food recalls cost money, it's as simple as that...
Now, in regards to your question, here are some contradictions I believe we need to address in order to arrive to an objective answer:
How does one define "conventional soap"? If we are to narrow down the vernacular usage of "soap" here by application, I would presume one might be referring to "detergents" or "surfactants" intended and approved (when abiding by the validated labeling instructions and dilution/concentration ratios) for use on direct food contact surfaces. However, this still leaves a myriad of candidates, making the qualifying term "conventional" difficult to apply in any ubiquitous fashion. On the otherhand, the lack of an "umbrella" gating sieve is not actually too much of an issue; if the manufacturer is reputable and abides by industry and regulatory standards, then the label will have provided CAS (Chemical Abstracts Service) Registry Numbers where applicable, and an SDS (Safety Data Sheet) should be made available upon request (many corporations actually have them readily accessible on their website, or sometimes a standalone file server.
You question the safe use of the subject soap, but then you list the following supporting characteristics: fragrance-free, dye-free, preservative-free, hypo-allergic, non-toxic, eco-friendly, bio-degradable, ALL natural (even organic!). Of these, fragrance-free, dye-free, and preservative-free are redundant, as they are all covered under the product's hypo-allergenic labeling claim (there may be some exceptions where additives have been classified as, e.g., carcinogens, but for the most part they are GRAS but include sensitizing agents). The remainder of the claims, non-toxic (absurdly redundant), eco-friendly, bio-degradable, all natural and organic; none of these claims actually address the safety of the soap in question (besides the non-toxic I suppose, but I don't exactly see an abundances of toxic soaps on the shelves).
The article you reference regarding the antimicrobial claim having an adverse long-term impact on the end consumers does not include any citation or reference source. Unless supporting documentation is provided to support such a case, I would presume that they are referring to anti-microbial soap being used imroperly, i.e., without rotating out at validated frequency, thus causing microbial resistance to develope. They also might possibly be referring to the FDA ruling (backup) back in 2016 where several additives were disqualified from being utilized for an "anti-microbial" labeling claim due to lack of supporting evidence to validate it's efficacy or demonstrate that they are GRAS.
You may be confusing the standard sanitation process flow. The traditional validated procedural flow involves 1) clean water rinse, which removes a majority of soil, debris, particulates, etc., 2) use of a surfactant, which then removes a majority of toxins and pathogens that still remain, and then lastly 3) disinfectant, which achieves lethality for the majority of what pathogens potentially remain. This order is important because pathogens can cause illness via three distinct modes: 1) infection, 2) intoxication, and 3) infection-mediated intoxication. Achieving lethality only eliminates half of the hazards of concern, which is why the use of surfactants has become so ingrained and ubiquitous. Recent marketing callouts may be taking advantage of the general publics' fears, lack of knowledge/training, and demand for convenience.
In industry, each establishment contends with their own hazard analyses, risk assessments, draft plan, implementation, and the validation/annual revalidation, as a generalization for the decision-making process for what chemical additives (if any) are utilized in fresh produce or fruit wash. They take into consideration factors such as: will this product be ready-to-eat (RTE) or will it undergo further processing/lethality? What is the inherent quantified risk assignment associated with this material? Does the nature of the material reqire a distinct wash procedure or additional steps to be applied (e.g., dehydrated mushrooms, etc)?
As for the selection of the additive of choice, this is often based upon cost effectiveness, ease of handling/storage, efficacy, safe handling, etc. On the regulatory end, the chosen additive needs to meet the following requirements:
- Regulatory status of sodium hypochlorite and other substances used to treat wash water in contact with fresh-cut leafy vegetables Any substance that is reasonably expected to become a component of food because of its intended use in wash water used during the production of fresh-cut produce (e.g., by migrating from the wash water into food) must be lawful under sections 402(a)(2)(C) and 409 of the FD&C Act, e.g., because the substance: Is covered by a regulation, listed in 21 CFR, that provides for its safe use; Satisfies the criteria (in 21 CFR 170.30) for eligibility for classification as “generally recognized as safe” (GRAS); Is the subject of a prior sanction issued by FDA or the U.S. Department of Agriculture prior to September 6, 1958 (section 201(s)(4) of the FD&C Act; see the definition of “prior sanction” in 21 CFR 170.3(l)); Is covered by a Threshold of Regulation (TOR) exemption in accordance with 21 CFR 170.39; or Is covered by an effective Food Contact Substance Notification (FCN) (21 CFR part 170, subpart D).
Just for your reference, a very common industry choice is sodium hypochlorite 12.5% @ 200PPM ±15PPM and 6.5 pH ±0.5pH with contact time of 60 seconds and hourly verification via titration.
Good ANDA Submission Practices Guidance for Industry (backup)
Guide to Minimize Food Safety Hazards of Fresh-cut Produce: Draft Guidance for Industry (backup)
Preventive Control Measures for Fresh & Fresh-Cut Produce
Guide to Washing Fresh Produce (Colorado State University)(backup)
CFR TITLE 21 CHAPTER I.B PART 173 SUBPART D - § 173.315 Chemicals used in washing or to assist in the peeling of fruits and vegetables(backup
