Maintaining quality

As food safety rises to the top of the agenda of food and beverage manufacturers, regulatory bodies and governments again and again, Eduard Stempfel, Shell’s Food Sector Product Application Specialist discusses the lubricants industry’s response to these trends for food grade lubricants and the need for the new ISO 21469 certification.

Food and beverage product safety is an issue never far from the minds of anyone who works within the food industry. Any product contamination during the production or packaging processes could not only potentially have serious public health repercussions, but also hefty cost implications in terms of product recall and damage to the manufacturer’s brand.

So, if food safety is such a critical business consideration in the food sector, surely any new international certification that could help deliver greater assurances to manufacturers – and their customers – has got to be a good thing. While most food sector manufacturers would agree, many of their food grade lubricant suppliers wholeheartedly disagree, and for others the response is definitely a qualified maybe. So, what’s causing the dissent?

Setting a new standard

When the USDA stepped down from delivering its H1 registration programme for food grade lubricants a decade ago, the willingness of the NSF to step up to the mark and administer H1 registration in its place was universally welcomed by the food sector lubricants community. Indeed, at that time, there was a widespread enthusiasm for the idea that there should some day be an internationally recognised standard for food grade lubricants, based on the ISO model.

Cut to ten years later, and some now view the NSF’s recently introduced ISO 21469 certification as a cynical ploy to create a money making enterprise that will become, de facto, a must-have accreditation for any lubricant supplier that wants to do business within the food industry. Indeed, there is even a concern in some quarters that the NSF may be conspiring to keep the expense of gaining certification a secret so that companies that might aspire to accreditation won’t know how much it will cost until the process has begun.

These concerns are ill-founded. In reality, the story is more complex. Certainly gaining ISO 21469 will incur costs but really, the only surprise in this is that it should come as a surprise to anyone! The reason that the standard is so valuable – and, as some in the food sector might say, so overdue – is that it requires an extremely stringent certification process, involving a review of product information, a thorough site audit and laboratory testing. All of this will cost money to administer and, as every lubricant supplier is different, the level of work involved in assessing each for certification will be different too. Consequently, the NSF has very wisely chosen not to impose a flat fee, but to quote on a case by case basis.

Arguably, the costs involved in gaining ISO 21469 may ultimately be passed on to the food manufacturer but, as a proportion of the lubricant supplier’s total operational costs, how significant will this really be? Moreover, when it comes to food safety, the exhaustive assessment required to gain ISO 21469 will offer more peace of mind than any other registration programme or accreditation, and that is very valuable indeed.

Proving best practice

According to the NSF, the reason for introducing the ISO 21469 standard is that there was a demand for such a stringent certification from food manufacturers. Feedback from several lubricant suppliers supports this view, with many reporting that it has been well received, particularly amongst larger customers. While some lubricant suppliers continue to resist the new standard because qualifying for certification is an onerous and time-consuming task, surely the very fact that a lubricant company is willing to invest time and effort in proving that they can underpin high standards of food safety recommends them as a supplier.

In reality, certification is a four-stage process that can be completed in a matter of weeks. First, the lubricant company must supply the NSF with comprehensive product information so that a review of product formulas and labelling can be carried out. Next, an NSF representative undertakes an audit of the lubricant company at its manufacturing site, checking hygiene, verifying that the ingredients used on site are those that appear in the formula and collecting test samples for the third stage of the certification process – laboratory testing of products to verify their formula. Finally, a risk assessment is required, including identification of any risks on site and how the lubricant supplier would address them. The risk assessment also involves an appraisal of the steps taken by the lubricant supplier to ensure that its customers use the lubricants appropriately. Once certification has been awarded, annual surveillance audits are then required to maintain accreditation.

The process may seem complicated, and that’s certainly one of the criticisms levied by its opponents in the lubricants industry. However, what this thorough approach to verifying product formulas, manufacturing processes and risk assessment means for the food industry is that they no longer need to take it on trust that the actual product they are using in their machines is the same as the formula their supplier registered. That’s not to say that there was ever an issue with trust in this context, however, given the human and financial considerations involved in safeguarding food safety, ISO 21469 simply represents best practice due diligence.

Adding value

Ultimately, ISO 21469 remains a voluntary accreditation and, despite earlier talk of phasing out H1 registration, the NSF has now given its assurances that the two programmes will run in parallel, offering lubricants companies – and their customers – real choice about what level of assurances they need.

To date, NSF H1 registration, ISO 9001, and HACCP have proved perfectly adequate in safeguarding food safety where there is a risk of accidental contact with lubricants. However, most manufacturers would vehemently insist that they pursue continuous improvement in their own operations, and the same philosophy should surely be applied to maintaining food safety during the manufacturing and packaging processes. ISO 21469’s dissenters might argue that the availability of a new standard will create an unfair advantage for suppliers that opt for certification, making it, in commercial terms, mandatory for all. It’s possible. But realistically, if the food sector companies respond to ISO 21469 by making certified companies their preferred choice of supplier that would seem to confirm that there is a market-driven need for a standard of this kind. And if that’s true, lubricant suppliers must take the customer-focused approach and consider whether this really is just another administrative hurdle or a genuine way in which they can add value for their customers.