NSF Registration

The use of food-grade lubricants has revolutionised the food manufacturing process, making it possible to increase productivity, improve food safety and protect metal surfaces from corrosion and wear. They withstand extreme temperatures and can be designed for specialised applications. So what does the future hold for these Titans of the food production process?

Although the use of food-grade lubricants has greatly improved food production, they are not without their challenges. Manufacturers have to consider their processing environment, lubricant sourcing and implementing systems to minimise risks. Future regulations and certification from a third-party organisation are being highlighted to address the challenges of lubricants and help ensure the safety of their use.

Rising to the challenge

The food processing environment creates unique challenges for practical machinery lubrication. For instance, certain processing applications such as baking, frying, grilling, pasteurisation, sterilisation and packaging require extremely hot operating conditions. In contrast, techniques such as chilling, freeze-drying or flash freezing necessitate very low operational temperatures. In addition to extreme heat and cold, moisture and humidity are common elements in the food processing environment. Processing of perishable foods such as eggs, meat, fish, poultry, dairy, fruits and vegetables can introduce harmful bacteria and other indigenous biological agents into the manufacturing process. Each of these challenging environmental factors must be adequately addressed in order for equipment and machinery to operate efficiently and safely. Today, food grade lubricants play a critical role in helping to preserve the quality, integrity and safety of consumer food and beverage products and have a variety of common uses in the food manufacturing industry.

Managing risks, minimising harm

In selecting and sourcing lubricants, food facility operators must balance a multitude of equally important priorities including function and performance, regulatory compliance, worker safety and chemical risk management. In most food processing applications, the risk of the lubricant contacting the edible product cannot be entirely eliminated and some potential for exposure, contact or migration exists. Physical controls such as barriers, shields and sanitary equipment design help minimise the risk of lubricant exposure, but ultimately the operator is wise to proactively use food grade or ‘inci­dental contact’ lubricants as a logical alternative to traditional industrial products.

While awareness and use of food grade lubricants has increased significantly in the last 10 years, confusion remains surrounding the specific food safety standards and regulations that apply to these specialty lubricants. In many nations, government regulations for food grade lubricants and other food processing compounds are not clearly defined. Currently, few governments directly regulate the formulation, labelling and use of food grade or incidental contact lubricants and most formulators rely on criteria established in Title 21 of the U.S. Code of Federal Regulations (21 CFR), Section 178.3570, Lubricants with Incidental Food Contact.

NSF Registration

The question most frequently asked by food processing facility operators is: “How do I ensure the food grade lubricants I’m purchasing are safe and meet accepted food safety standards?” Today, an independent, voluntary registration scheme exists to address this need. For more than 10 years, NSF International, an inde­pendent non-governmental, not-for-profit organisation has managed a global Registration Program for evaluating food grade lubricants and other food processing compounds.

Today, NSF’s Registration Program is an internationally recognised resource for evaluating and registering food grade lubricants.

Under the NSF program, lubricants and greases are categorised as:

H1 – lubricants with incidental food contact
H2 – lubricants with no food contact
H3 – soluble oils for rust prevention which may contact food

In addition, two related categories for heat transfer fluids are:

HT1 – Heat transfer fluids with incidental food contact
HT2 – Heat transfer fluids with no food contact

Release agents are also categorised as:

3H – Release agents for food contact
M1 – Mold release agents for food packaging

In all, more than 75 individual product evaluation categories have been developed for lubricants, cleaners, laundry products, sanitisers, pest control agents, water treatment chemicals and other chemical processing compounds.

Before a lubricant, heat transfer fluid or release agent is listed in the NSF WhiteBookTM, NSF independently verifies that the formulation meets the requirements set forth by the U.S. Food and Drug Administration (FDA) in 21 CFR and in the NSF Registration Guidelines. In addition to formulary review, NSF products undergo a meticulous label screening to verify that product labels and data sheets are true and accurate and do not make misleading claims. NSF also verifies lubricant traceability back to the supplier by confirming company and trade name associations. This element of traceability is particularly critical given the current regulatory emphasis on raw material and supply chain traceability.

Once a lubricant is NSF approved, it bears the blue circle NSF registration mark, the category code for its approved use (ex. H1) and its unique NSF registration number on its package label or data sheet for easy identification by end-users.

The NSF WhiteBookTM

The NSF WhiteBookTM listing is a public health and safety resource for end-users and food safety inspectors. The WhiteBook’s web-based interface (www.nsfwhitebook.org) allows quick and conclusive verification of a product’s current NSF registration status and is freely available to any user, worldwide. The database is searchable by a variety of interactive fields including company name, product name, country of origin and lubricant category (ex. H1). The product information for thousands of NSF registered products is updated nightly, ensuring that the most current information is always accessible. Users can even view and download a product’s official registration letter, providing conclusive documentation to inspectors to support its use in their facility. Today, more than 4,700 food grade lubricants are registered and listed in the official NSF WhiteBookTM.

A global hygiene standard

In 2006, the International Organisation for Standardisation (ISO) developed a voluntary standard for lubricants used in food processing and other specialty processing applications. The standard, ISO 21469 – Safety of Machinery – Lubricants with Incidental Product Contact, is unique in that it addresses lubricants used in a variety of industries where hygiene is of particular concern including cosmetics, pharma­ceuticals, animal feed and food pack­aging. ISO 21469 establishes strict hygiene requirements for the formulation, manufacture and use of lubricants which may contact these product types during processing. The value of ISO 21469 certification for end-users is that it provides added assurance that the lubricant formula is safe, label information is true, accurate and traceable and lubricant manufacturing and packaging conditions are hygienic. Although ISO 21469 is a voluntary standard, the food industry has already recognised the value of these benefits and companies are proactively adopting ISO 21469 into their lubricant procurement specifications.

In order to be ISO 21469 certified, lubricant manufacturers must develop a strategy to preserve the hygiene of the lubricant product during all phases of production including formulation, blending, packaging and transport. In developing their hygiene plan, the manufacturer must consider and mitigate the introduction of all potential contaminants (physical, chemical and biological) through a documented risk assessment. A qualified, accredited third-party certifier, such as NSF International, then conducts a comprehensive facility inspection to verify risk management policies, verify batch records and collect production samples for laboratory testing.

Similar to the NSF WhiteBookTM resource, an official product listing of NSF ISO 21469 Certified companies and lubricants are publicly available on the NSF website at www.nsf.org.

Two of the leading issues facing the food processing industry today are food safety and government regulations. Earning regi­stration for lubricants can help addresses these concerns and helps manufacturers protect themselves, and their customers, against food safety risks.