Food Grade Lubricants: Invest now, save in the future

On 4 January 2011, United States President Barack Obama and Congress passed the Food and Drug Administration Food Safety Modernisation Act into law. This measure reflects a significant change in the United States food safety laws. This legislation mandates preventive measures by growers, processors and distributors, providing for increased inspections and gives the FDA greater regulatory authority. The specific areas of focus will be hazard analysis, validation and ensuring verification systems are in place.

This new U.S. regulation will have far-reaching implications for the global food supply chain. In addition to stricter measures for U.S. processors, the regulation establishes new requirements for labelling, import, supplier qualification programmes and mandatory recall authority.

 The U.S. Food Act also expands the jurisdiction of the FDA and increases penalties for companies that distribute products that are harmful or unsafe. It is now more critical than ever for food facilities to effectively manage risks in their processes and supply chain. The most effective way to do this is through implementa tion of an effective HACCP plan. HACCP (Hazard Analysis Critical Control Point) is an approach that identifies where potential contamination can occur and strictly manages and monitors these areas, ensuring the process is in control and that the safest product possible is being produced. HACCP-based food safety programmes place the responsibility on food processors to prevent – rather than catch – potential hazards.

Designing your hygiene plan

Too often, lubricants and other maintenance chemicals are overlooked during hazard analysis, or plant operators and process engineers don’t realise they have options when it comes to selecting appropriate lubricants. Stringent regulations, harsh environmental conditions and rigorous plant operations are making it increasingly important to research the source of food grade lubricants used on equipment and machinery to maximise performance and longevity. Today, these products 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. Product contamination from equipment using lubricants is a significant concern. A food grade lubricant that is specially formulated for use in food processing facilities is less harmful and reduces the risk of having to conduct a product recall associated with an inappropriate lubricant. NSF International is a third-party organisation that registers these products by conducting a stringent review of the label and formulation to ensure compliance with the FDA requirements stated in 21 CFR Section 178.3570.

The importance of having these products evaluated by a third party is becoming more evident as focus on traceability in the food supply increases. Using NSF-Registered products to demonstrate that a lubricant formulation has been independently evaluated reduces the burden on the processor and provides the necessary documentation to support the traceability and safety of these food grade lubricants. Processors must couple the use of approved products, such as NSF-Registered lubricants, with a well-designed lubricant maintenance plan.

NSF Registration

 NSF International launched its voluntary Nonfood Compounds Registration Programme in 1999 to re-introduce the previous authorisation programme administered by the U.S. Department of Agriculture (USDA). The scope of this programme is to evaluate products for compliance to the former USDA Guidelines for Obtaining Authorisation of Compounds to be Used in Meat and Poultry Plants. By registering these products, NSF is upholding its mission to protect public health and safety. Once a product has been approved, the applicant includes the NSF Mark on its product label that includes the category code and registration number. The category code highlights the product’s intended use and the registration number is established to create a designating factor for traceability and verification purposes.

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

To register a product such as a lubricant with NSF, the lubricant formulation, including ingredients and percentage composition, and the finished product label is essential in order for NSF to complete an independent review against the requirements of 21 CFR. Product labelling must be true and accurate, make no inappropriate claims and outline appropriate use instructions. Product labels must also be traceable to the registered company and bear the NSF Registration Mark, including the appropriate category code and unique product registration number. The registration number assigned to each product allows for straightforward searching and traceability. NSF’s registration programme is designed to complement the HACCP programmes developed by food facilities by providing assurance for food processors that the necessary information has been reviewed and found to be acceptable, therefore preventing the possibility of product contamination.

Sourcing with the NSF WhiteBook™

An easy-to-use online list of registered products allows companies to quickly determine if a product is acceptable for use in their processing facility. The product list, also known as the NSF White Book™, is searchable by various factors such as trade name, company name, NSF Registration number and/or NSF category code. The NSF White Book™ can be reached through the website www.nsfwhitebook.org. Once a product is found, a copy of the registration letter can be downloaded. The registration letter details what end use the product has been registered for and any limitations associated with its use. This document is an essential tool to help support your lubricant sourcing decisions and demonstrate third-party approval of the products used in your facility.

 ISO 21469: taking safety one step further

A trend on the upswing is lubricant manufacturers taking a more stringent approach to demonstrating the safety of their products by going the extra step of considering the manufacturing process and the storage requirements for the lubricants they sell. Several manufacturers have recently chosen to adopt ISO 21469 certification. In 2006, the International Organisation for Standardisation (ISO) published ISO 21469 – Safety of Machinery – Lubricants with Incidental Product Contact. ISO 21469 is a voluntary standard which specifies hygiene requirements for the formulation, manufacture and use of lubricants, which may contact products during manufacturing or processing. The standard applies beyond food applications and includes lubricants used for processing cosmetics, pharmaceuticals, animal feed and food packaging, where hygiene is of particular concern. Although voluntary, the food industry has already taken notice and some global food companies are now adopting ISO 21469 as their minimum requirement for sourcing lubricants.

To achieve certification to ISO 21469, lubricant manufacturers must develop a strategy to specifically preserve the hygiene of the lubricant product during all phases of production, including formulation, blending, packaging and transport. In developing a hygiene strategy, the manufacturer must consider and mitigate the introduction of all potential physical, chemical and biological contaminants through a documented risk assessment process. In addition, a qualified, accredited third-party certifier, such as NSF International, conducts a comprehensive facility inspection to verify risk management policies, verify batch records and collect production samples for testing analysis. Product certification to the ISO 21469 standard provides end users with the assurance that the quality, safety and hygiene of the lubricant formula have been independently verified by a qualified certification body, such as NSF.

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. NSF currently has more than 300 products certified in this programme. Visit www.nsf.org to access the most current list of these certified products.

Don’t forget the water

Food grade lubricants are definitely a main product category to consider when protecting the safety of materials that a facility is processing in the food industry. A component that is often overlooked when evaluating a quality system is in place for sourcing materials is water treatment products. Since water can also be a source of contamination, the ability to ensure the cleanliness of water used in a food facility is an essential critical control point. Water treatment products are used to improve the condition of the water and since they are not food ingredients, they are considered nonfood compounds. There are two types of water used in food processing facilities; process water for boilers, steam, washing and rinsing that are not intended to be used in the food, and there is also ingredient water, which needs to meet FDA CFR requirements (which references EPA standards for potable drinking water at a minimum). Water treatment products are used in both of these categories.

 There are several different types of water treatment products. In general, phosphate, silicate and chlorine products or used in addition, there are water treatment products used in specific systems, such as boiler and steam lines or cooling and retort water systems. General water treatment products include pH adjusters and water softeners. Phosphate and silicate products are used to control water quality problems resulting from inorganic contaminants such as lead and nitrates/nitrites. These products are typically corrosion and scale inhibitors. Chlorine products are used to control bacteria in the water. Products used to treat cooling and retort water or boiler water systems are also corrosion and scale inhibitors, antimicrobials, pH adjusters, etc. These products are designed for specific systems.

Many countries do not have regulations that cover water treatment products, so companies look to the regulations put in place by the United States. In the U.S., products used in water that will come into contact with food are regulated by the FDA. These products must consist of substances that are Generally Recognised as Safe (GRAS). Boiler water treatment products have a slightly wider range of acceptable ingredients and can include substances listed in the U.S. FDA Code of Federal Regulations Title 21 Section 173.310 (21 CFR 173.310) in addition to GRAS substances. When a facility chooses to use water treatment products that are registered by a third-party organisation, like NSF International, it will provide them with the added assurance that the formulation and labels have gone through a stringent review and can be incorporated into their sourcing decisions. To view the products that NSF currently registers, please visit www.nsfwhitebook.org and look for the water treatment products.

Are you prepared?

In the coming months, new legislation will test food processing facilities and the systems they have in place to protect the safety of the consumer. Preventing foodborne illness outbreaks like those that have occurred in the past will continue to be a primary focus. Companies will devote more resources to the inspection of their facilities to ensure that the necessary controls are in place to protect consumer health. Many of the leading global retail and foodservice companies already require suppliers to comply with international food safety standards through independent, third-party inspection to the Global Food Safety Initiative (GFSI). GFSI promotes the exchange of information across the retail environment to educate suppliers about the safety requirements of the food industry. GFSI-benchmarked food safety standards include Safe Quality Food (SQF), British Retail Consortium (BRC), GlobalGAP, Food Safety System Certification (FSSC) and International Food Standard (IFS), among others.

What can companies do to prepare for increasingly stringent safety and hygiene requirements? Choose products such as lubricants, water treatment chemicals, heat transfer fluids, pesticides, cleaners, etc., for use in your facilities that have undergone a third-party approval process, to minimise the risk of contamination and to complement your existing HACCP plans. This proactive approach will save you time and money in the long run and will support you in producing a quality product for your customers.

About NSF International

NSF International is a not-for-profit, non – governmental organisation. Founded in 1944, NSF (www.nsf.org) is a world leader in standards development, product certification, education and risk management for human health and safety. While focusing on food, water, indoor air and the environment, NSF develops national standards, provides public health education and conducts third-party conformity assessments while representing the interests of all stakeholders. The primary stakeholder groups include industry, the regulatory community and the public at large.

About the Author

Recently appointed to Manager of the NSF Nonfood Compounds Registration programme, Jessica Evans has worked at NSF International for nearly 10 years serving in many leading positions, including Group Leader for the NSF Dietary Supplement Certification programme. Her expertise in the NSF registration process will help continue NSF’s mission to deliver a programme that provides product manufacturers, food producers and regulatory/inspector groups with a proven method to determine product acceptability.

In her new role, Evans oversees all aspects of NSF’s Nonfood Compounds Registration programme, which includes a complete product formulation and label review to ensure NSF Listed products meet food safety standards and NSF Registration Guidelines (formerly USDA Guidelines for Obtaining Authorisation of Compounds to be Used in Meat and Poultry Plants). She leads the Nonfood Compounds team in developing new service offerings, improving existing processes, accommodating unique customer projects and representing NSF International at industry events and conferences. Evans also will work closely with NSF Registered companies and regulators, assuring that the NSF Nonfood Compounds Registration programme continues to utilise the most up-to-date regulatory requirements and industry best practices. Evans earned her bachelor’s degree in supply chain management from Michigan State University.