
In brief: ASTM A967 makes no recommendation on which treatment or acceptance criteria suit a particular application, so the buyer has to specify them. Before hiring a passivation service provider, agree the standard, the treatment, the tests and the pass marks in writing. Under 21 CFR 211.22, the plant's own quality unit approves or rejects the procedure, and the full record set should come back with the job.
Many plants choose a passivation service provider the way they buy spares. They get three quotes, pick the lowest price and raise a purchase order. Then the auditor asks which method was used, which test proved it worked, and who signed the result. Often no one can find the answers. This guide covers the questions to ask before you sign, so you have those answers on paper from day one.
Ask which standard and which method they will use, and get the answer in writing. The rest follows from it. A vendor who only says "we passivate to ASTM" has not told you what you are buying. They still need to name the standard, the treatment and the tests. Vague quotes like that leave room for an argument later.
For pharma and food plants, two ASTM standards do most of the work. ASTM A967 covers chemical passivation of stainless steel parts. ASTM A380 covers cleaning, descaling and passivation of new parts and equipment, including systems fixed in place. It says it does not cover the cleaning of systems that have been in service. For older plant, ask the vendor how they adapt it. The 2025 edition of each is the current one.
The method matters as much as the standard. A967 names three kinds of treatment, which are "immersion treatment using nitric acid solutions, immersion treatment using citric acid solution, and electrochemical treatment." A quote that does not say which one you are getting is not finished. Our guide to choosing a passivation chemical compares citric and nitric acid.
Ask the vendor to put the standard and method in the quote itself, where they are easy to find later. When the job is done, you will want to hold the quote up next to the results and see that they match. If the quote was vague, there is nothing to hold them to.
Because ASTM says so, in plain words. The A967 scope says it "makes no recommendations regarding the suitability of any grade, treatment, or acceptance criteria" for any particular use. So the standard gives you the options, but it does not pick one for your plant.
That one line changes how you buy the service. The choice of treatment and pass marks belongs to you, the buyer. If you leave it to the vendor, you hand over a decision the standard expects you to make.
This matters in practice, because a WFI loop in a Baddi pharma unit and a dairy tank in Ahmedabad need different proof. Your written specification should say what fits your system, and why. Our page on passivation for pharma plants covers that kind of work in more detail.
The tests you agree before the job starts. A967 includes "several alternative tests, with acceptance criteria." Its summary names five of them: water immersion, high humidity, salt spray, copper sulfate, and potassium ferricyanide-nitric acid. Separately, it names a free iron test, which checks for loose iron left on the surface.
The scope calls these alternative tests, so pick the ones that fit your system and leave out the rest. Write them into the purchase order, with the pass mark beside each one.
A pass mark is simply the result that counts as a pass, written down before the work begins. For a visual check it might be no rust spots on the rinsed surface. For a ferroxyl test it is no blue marks. If nobody writes these down in advance, the result can be argued either way after the job, and QA has nothing firm to sign against.
ASTM A380 adds its own cleanliness checks. Its summary lists "Visual inspection; wipe tests; residual pattern; water-break test" as basic checks. It lists the ferroxyl test among the more precise ones. Our guide to passivation testing methods explains what each test shows.
| Question to ask | What a good answer includes | Why it matters |
|---|---|---|
| Which standard and method? | A967 or A380, and the treatment, by name | You know what you are buying |
| Which tests, and what pass mark? | Named tests with written pass marks | A967 leaves the choice to you |
| Who approves the procedure? | Your quality unit, before work starts | Expected under 21 CFR 211.22 |
| What records come back? | Procedure, test results, sign-offs | Auditors often ask for these |
| Can they work onsite? | Teams and kit for installed systems | Fixed loops often cannot move |
| How fast can they respond? | A stated response time | Shutdown windows are short |
| How is used chemistry handled? | A written disposal method | It is part of the job |
In a plant that follows US FDA drug rules, your own quality unit does. Under 21 CFR 211.22, the quality control unit has "the responsibility for approving or rejecting all procedures or specifications" that affect the drug product. A passivation procedure for product-contact steel counts, in our reading, so QA should approve it.
So the vendor's procedure should reach your QA team before the job starts, well ahead of the invoice. QA approves the method, the tests and the pass marks. After the work, QA checks the results and makes the final call.
Here is a scene, and it is fictional. The QA team at a formulation plant in the Vapi-Ankleshwar belt gets a passivation certificate after the April shutdown. It names no test and no pass mark, and QA never saw the procedure. QA has nothing to sign against, so the line waits.
A good provider expects this step, so they will send the procedure early and ask who in your QA team signs it.
Enough for your QA team to defend the job to an inspector without calling the vendor. That often means the approved procedure, the chemistry and batch details, the test results, and signed records of who did what. If a record is missing, an auditor has little proof the job was done properly.
Agree all of this in writing before work starts. FDA has guidance on contract manufacturing quality agreements. It says the parties "can use quality agreements to delineate their manufacturing activities to ensure compliance with CGMP." The guidance is written for contract manufacturing, but the same idea helps with a passivation vendor: write down who does what, before anyone starts.
Qualifications belong in the file too. 21 CFR 211.34 covers consultants. It says they must have "sufficient education, training, and experience" for the work they advise on. It also asks for records of their qualifications. Asking a passivation vendor for the same is a sensible habit.
Keep these papers with the equipment log for that system, so the history of each loop or vessel sits in one place. Our guide to passivation documentation for audits covers what an auditor opens first.
Ask this early, because most installed systems cannot go to a workshop. A WFI loop, a CIP skid or a jacketed reactor often has to be treated where it stands. A provider with no onsite teams will quote only for the parts they can take away. The rest of your system is left for someone else to treat.
Speed matters during a shutdown, because a window such as April or after the monsoon is short. A slow start eats into the time you need for testing. Ask for a stated response time and a named team for your region.
At Rouging Solutions, we work onsite across India through our West, South and North teams, and we respond within 24 hours. Our passivation service page explains what we cover.
Ask one more thing while you are at it: what happens to the used acid. Rinse water and spent solution have to go somewhere, and your site's own rules apply to them. A good provider will tell you how they neutralize and remove it, and put that in writing too. If the answer is vague, the job is not fully planned.
A few answers should make you pause before you sign. None of them proves bad work on its own. Together, they often mean the paperwork will be thin when an auditor asks for it. Here are five worth watching for.
The standard lets you choose the treatment and the proof, so choose them yourself, in writing, before anyone arrives on site. That one habit protects your plant at audit time, and it costs you nothing but an hour with the purchase order and your QA team.
Take your next passivation quote and check three things. Does it name the standard and method? Does it name the tests and the pass marks? Does it say your QA team approves the procedure first? If any answer is no, ask for it before you sign.
If you would like to talk through a specification, our team in Ahmedabad is happy to help.
No. Its scope says it "makes no recommendations regarding the suitability of any grade, treatment, or acceptance criteria" for a particular use. You choose the treatment and the pass marks, and you should write both into the purchase order.
Agree them in advance. A967 offers several alternative tests, including water immersion, high humidity, salt spray, copper sulfate and potassium ferricyanide-nitric acid tests. Pick the ones that suit your system, with a written pass mark for each.
Not in a plant that follows US FDA drug rules. Under 21 CFR 211.22, your quality control unit approves or rejects procedures that affect product quality. The vendor supplies the records, and your QA team makes the decision.
The approved procedure, the chemistry details, the test results and signed records of who did the work and who checked it. Agree this list before the job starts, so nothing is missing when an auditor asks.
Sources. ASTM International, ASTM A967/A967M-25 product page, for the three treatment types, the list of alternative tests and the line that the specification makes no recommendations on treatment or acceptance criteria · ASTM International, ASTM A380/A380M-25 product page, for the cleanliness acceptance checks and its scope of new parts, equipment and installed systems · 21 CFR 211.22 and 211.34, read on the Cornell Legal Information Institute copy of the regulation · US FDA, Contract Manufacturing Arrangements for Drugs: Quality Agreements (November 2016). Every quotation was read on the source page. The questions, the table and the example are ours, and the example is fictional.