Global listing program

With increased interest from food manufacturers to apply sanitary equipment design principles to their processes, many food processing equip- ment manufacturers now design and construct equipment with food safety in mind.

Some of these considerations include the following:

• Making food processing equipment easier to dismantle for improved cleanability and sanitation
• Developing equipment that is compatible with other plant systems, such as electrical, hydraulic, steam, water and oil filtration systems
• Designing equipment using construction materials that are compatible with the facility’s environment; the product produced and the cleaning and sanitising agents and methods used

These advances in sanitary equipment design arise from the food industry’s need to reduce micro­biological, chemical and physical contaminants in the plant environment. One area that is receiving increased attention is the application of food-grade lubricants for sanitary design.

All food and beverage processing equipment needs lubrication and should be designed in a manner that minimises lubricant contamination during processing, although this will not eliminate the potential of incidental food contact. This is why it is critical to apply food-grade lubricants on all types of processing equipment – to ensure public health and safety protection. The use of food-grade lubricants also supports the quality assurance/quality control (QA/QC) processes throughout the meat, poultry, fruit, vegetable and other food processing industries and serves as insurance against plant shutdowns.

Global food-grade lubricants listing

It has been five years since NSF International (see panel) launched its Nonfood Compounds Registration Program to re-introduce the previous U.S. Department of Agriculture (USDA) authorisation program, which was terminated in 1998. Not only has the NSF program successfully re-instated the central compounds registration system, but NSF expanded the program’s scope to include food/beverage processing industries worldwide. As a result, more than 570 nonfood compound manufacturers and private labelers from 29 countries, including 14 European and nine Asian countries, have chosen to participate in this NSF program to expand their marketing.

The NSF White Book website (www.nsfwhitebook.org) currently lists more than 6200 nonfood compounds. Among these are 3200 food-grade lubricants manufactured worldwide. These food-grade lubricants are categorised under the H1 category. This means that these lubricants are formulated using indirect food additives that have met the U.S. Code of Federal Regulations Title 21 (21CFR), Food and Drugs, Section 178.3570. The U.S. Code of Federal Regulations establishes the requirements for incidental food contact lubricants. Section 178.3570 also references Generally Recognized As Safe (GRAS) substances under parts 182 and 184 of 21 CFR.

NSF worked with the USDA to establish H1 criteria when developing the NSF Registration Guidelines. The guidelines are available on the NSF website (www.nsfwhitebook.org). The NSF Registration Guidelines are periodically reviewed by the USDA staff and track the most current USDA, U.S. Food and Drug Administration (USFDA) and U.S. Environmental Protection Agency (USEPA) requirements related to nonfood compounds.

Web-based product listing

The prior USDA program updated its product listings once a year in print. NSF’s web-based product listing is designed to meet the global needs of the food/beverage processing industry when selecting food-grade lubricants. The NSF website (www.nsfwhitebook.org) contains a product search engine enabling advanced searches by manufacturer name, product name, end use category code and/or a product’s 6-digit registration number. All listed product names on the site are hyperlinked to the readily viewable/printable NSF Registration Letter specifying the intended end use of the product. The web listing provides an up-to-date product validation tool for product users and inspectors and a global marketing tool for manufacturers.

2004 E-White Book

In addition to the search engine, the NSF website also publishes the Electronic White Book Listing of Nonfood Compounds in a PDF format which is updated daily (www.nsfwhitebook.org). This printable listing replaces the previous annual hardcopy publications.

Proposed certification scheme for food-grade lubricants

The 10/21/2003 NSF Steering Committee meeting and the subsequent 4/22/2004 NSF Steering Committee Working Group conference call discussed an industry proposal to develop an optional certification program for H1 lubricants. The current NSF H1 registration program (a re-introduction of the previous USDA H1 authorisation program) relies solely on a one-time verification of formulations. As such, NSF registration letters that are posted online with the original registration issuance dates are not routinely updated.

The ISO65 Guide defines product certification as having surveillance activity in standard conformity evaluation. Periodic sample assay and formulation review, for example, can be added to verify that products marketed are consistent with the registered formulations (product certification). Product certification will enhance customer reassurance about product quality; confidence of a quality management system used by the manufacturer (e.g. ISO9000) and market differentiation by using a certification logo. At the above meetings, concerns were also expressed for potentially elevated certification costs. Differences in end user demands for certification between the U.S. and foreign markets were also discussed. Taking all these concerns into consideration, NSF developed a draft proposal for certification outlining all possible options and submitted it to the NSF Steering Committee on October 8, 2004. The NSF proposal can be viewed on the NSF website (www.nsfwhitebook.org).

At the 10/28/2004 NSF Steering Committee meeting, participants expressed both support and concerns for the draft proposal. The proponents of the NSF proposal stated that the USFDA was already reviewing a proposal to introduce random checks on food-grade lubricants by a third party and the proposed certification could be beneficial in the near future. Companies marketing in Asia and Europe also mentioned that users in these regions are increasingly demanding more stringent criteria for product quality, while recognising that such demands are less in the US. The opponents of the NSF proposal stated that food-grade lubricants are not always used properly in food/beverage processing and suggested that end user awareness should be prioritised above product certification. The 10/28/04 meeting thus concluded with a recommendation that NSF conduct a global market survey to analyse the end user needs for certification and awareness regarding the proper use of food-grade lubricants. An NSF Steering Committee Work Group for Food-grade Lubricants will also be formed, to design the survey and table the NSF proposal until the next meeting.

ISO21469 standard and international harmonisation

The work of the committee ISO TC 199 toward the completion of Document ISO/CD 21469, Safety of machinery – Lubricants with incidental product contact – Hygienic requirements, was discussed at the 2004 ELGI meeting in Nice, France. The current target date for completion is September 2005.

Already acting as the U.S. representative on the ISO Technical Committee Work Group, NSF recently requested to be the standards development organisation to administer the U.S. adoption of the standard. There are countries that have not yet developed rules for incidental food contact lubricants (e.g. Japan) that may be interested in adopting this ISO standard as their national standard. On the other hand, countries such as the United States may prefer to adhere to their own existing national regulations (e.g. USFDA 21 CFR). To satisfy various domestic and international conformity needs, NSF is prepared to provide registration service to the traditional H1 criteria as well as to the new ISO21469 standard.

NSF is actively developing collaborative relationships with international regulatory authorities in efforts to facilitate the global marketing of food-grade lubricants. For example, the Australian Quarantine Inspection Agency (AQIS) has approved nearly 50 products based on NSF H1/H2 registration and the Canadian Food Inspection Agency (CFIA) has introduced a fast track review option for NSF Registered food-grade lubricants, significantly decreasing the review turnaround time to within a few weeks.