Certification, the future of food-grade lubricants

According to a recent research survey by Gantz Wiley Research, two of the leading issues facing the food processing industry today are regulations and food safety. As economies continue to grow, the need to move and supply safe food will also increase. With this said, regulations and programs must evolve to reflect those changing needs.

One area of concern for food and beverage processors is lubricant contamination from production equipment. To help decrease the possibility of contamination, increasing numbers of processors are replacing non-food grade lubricants with NSF H1 food-grade lubricants.

As regulations and food safety programs become more stringent, food and beverage processors are looking for ways to ensure the products they use in their facility will reduce the likelihood of contamination. Certification of food-grade lubricants would help in this respect. This article addresses the past, present and future standards for food-grade lubricant regulations used in the food and beverage processing industry.

Past: USDA

Lubricants used in the food and beverage-processing industry must perform the same basic technical functions as other lubricants, such as to protect against wear, friction, corrosion and oxidation.

They must also resist degradation from food products, chemicals and steam:

• Exhibit a neutral behavior when in contact with elastomers and plastics
• Have the ability to dissolve sugars
• Be physiologically inert, odourless, tasteless, non-toxic and harmless – to name a few

In addition to these requirements, incidental food contact lubricants in the United States and many other countries must comply with the U.S. Code of Federal Regulations (CFR), Title 21, Section 178.3570 and other sections referenced therein.

Originally, the Food Safety and Inspection Services (FSIS) under the United States Department of Agriculture (USDA), required meat and poultry plants to only use products that had been approved for use under the USDA authorisation program. These included pre-processing products (proprietary substances), such as hog scalds, marking agents and fruit and vegetable washing products, as well as nonfood compounds, such as cleaning and sanitising products, lubricants and hand care products. Under this program, H1 lubricants were identified as those that may come in contact with food during processing.

With the introduction of the Hazard Analysis and Critical Control Points (HACCP) food safety program, the FSIS altered their facility inspections from prescriptive regulation to performance-based reviews. This action removed the burden of responsibility from the regulating body and placed it back on the processors. As a result, in 1998 the FSIS eliminated the pre-approval requirement and provided a compliance guide, the Sanitation Performance Standards Compliance Guide, to address the appropriate use of proprietary substances and nonfood compounds in meat and poultry establishments.

Under this guidance, a Letter of Guaranty can be provided to any interested party in place of third-party registration. The major disadvantage of the Letter of Guaranty is that it requires divulging the chemical ingredients in a product in the event of food contamination. For food and beverage processors, they can request to know the chemical ingredients in the products they use in their facility. For food-grade lubricant manufacturers, they would need to provide these ingredients.

Present: NSF ‘White Book’

Recognising the need to continue this service, NSF International, in December 1999, began the Nonfood Compounds Registration Program. This voluntary registration program, which mirrors the former USDA evaluation program, involves the confidential scrutiny of formulation, label and use requirements against established guidelines for proprietary substances and nonfood compounds by highly trained review toxicologists. To stay abreast of the regulatory and technology changes within the food and beverage processing industry, NSF toxicologists interact regularly with the FDA, USDA and the EPA. The NSF registration guidelines are currently in their fourth revision, which will soon be available online: http://www.nsf.org/business/nonfood_compounds/nonfood_guidelinesform.asp?program=NonFoodComReg.

Upon successful completion of the NSF review, a Registration Letter is issued and posted in the ‘White BookTM’, which is located on the NSF website at www.nsf.org/usda/psnclistings.asp. The NSF Registration process is complete when the registration number, category code and Registration Mark appear on the label of the NSF registered product. The ‘White Book’, which is updated as new products and companies are registered, is a one-stop shop for manufacturers, regulators and end-users to peruse more than 4000 NSF registered H1 lubricants for more than 400 companies located in 31 countries.

Therefore, a major benefit of using NSF H1 lubricants in food and beverage processing facilities is that they provide a proactive step in meeting HACCP food safety standards. In addition, NSF’s program provides formula confidentiality to the manufacturer as well as an unbiased product evaluation to the food and beverage processors.

Future: ISO 21469 certification

In order to meet industry’s changing needs and concerns, NSF continually monitors its practices to maintain quality standards in all of its endeavors. By utilising steering committees and industry involvement, NSF seeks to provide current and concise practices that are effective and that satisfy current regulatory requirements. As an industry leader, NSF is able to provide these services competitively and conveniently throughout the United States and abroad, thereby increasing and ensuring a customer’s products positioning in today’s world market.

As of February 15, 2006, the first edition of the International Standard 21469 – Safety of Machinery-Lubricants with Incidental Product Contact-Hygiene Requirements – became a published standard. This standard is a type-B standard in the field of machinery and specifies hygiene requirements for formulation, manufacture, use and handling of H1 lubricants. NSF is currently pursuing accreditation from the American National Standards Institute (ANSI) for its certification program. In contrast to the present registration program by the Nonfood Compounds Program, the certification program for Standard 21469 compliance will be developed and accredited as all other NSF certification programs – it will include formulation and label review, as well as periodic facility auditing and product testing.

What does this mean to food and beverage processors? This certification program will address both the regulatory and food safety issues plaguing the industry. It will ensure the following:

1. That manufacturers of food-grade lubricants continue to formulate and manufacture a safe product according to industry standards
2. That the ingredients used to make these lubricants, as well as the manufacturers’ suggested use, are in accordance with federal regulations.

In short, the NSF certification program will ensure that the food-grade lubricant is formulated, manufactured and its use and handling performs and will continue to perform as prescribed by the manufacturer.

NSF will hold their sixth Annual Nonfood Compounds Steering Committee Meeting on Tuesday, October 24, 2006. This meeting will encourage networking and fellowship in the nonfood compound industry; provide information on issues that may impact the industry, as well as the benefits and updates of the registration program. An update on the progress of the ISO 21469 certification program will also be given.