Smooth solutions to risk management

Mention the word lubricant in whatever context and you will most likely be greeted by a raised eyebrow or giggle. Food-grade lubricants may not be sexy, but they are a vital part of a food
manufacturer’s food safety and risk management armoury. Product recall is a nightmare scenario that manufacturers go to great lengths to avoid through risk evaluation and implementation of strict hygiene measures – and yet they can often overlook the need to use the right food-grade lubricants in their equipment. Accidental contamination of food by the wrong lubricant may not always involve a full product recall but might well lead to costly product disposal and/or destruction of the batch involved.

A review by the UK Food Standards Agency of food withdrawal and recall processes published in September 2017 reported that in the period 2013-2016 about half (50 per cent) of food alerts were associated with allergens. Almost a quarter of the alerts (23 per cent) related to microbiological and hygiene issues, including pathogenic and non-pathogenic microorganisms and problems related to poor or insufficient controls implemented in food businesses. A further 18 per cent of food alerts were associated with physical contamination of food.

Food-grade lubricants address HACCP requirements

Nowadays lubricants are increasingly recognised for the important role they play in HACCP (Hazard Analysis and Critical Control Point) evaluation. The handling, preparation, processing and packaging of food products of all types inevitably involves the use of equipment and machinery with lubricated moving parts that come into contact with foodstuffs. Machines also need to be cleaned and maintained, involving the use of other chemicals such as those contained in cleaning products and anti-rust agents.

Using registered food-grade lubricants reduces the risk of cross-contamination by harmful chemicals. They are formulated to be innocuous and not pose a significant health risk should incidental food contact occur. Processors are increasingly recognising that using these registered products is a logical, practical solution to addressing critical control points.

H1 category registered lubricants are the only comprehensively established food-grade lubricants

Only H1 lubricant category registration (as defined in the U.S. Code of Federal Regulations or CFR) is formulated and therefore acceptable for incidental food product contact and can be pursued as a food-grade lubricant. Any other category registration is not appropriate. Independent third-party verification of the lubricant formulation is available only through NSF International in the US but is recognised worldwide. NSF’s nonfood compounds programme was established specifically to evaluate the risk of contamination of chemical compounds used in and around food processing facilities.

Products eligible for registration include lubricants, cleaners and water treatment products.

An H1 lubricant is intended for use in applications where there is potential for incidental food contact, for example in the case of anti-rust agents or release agents on gaskets or seals of tank closures. Although this category encompasses the possibility of incidental food contact, it is still recommended that use of the lubricant is kept to the minimum amount needed for it to be effective for its purpose. Overuse can make the unwanted transfer of the material onto food, or the build-up of residual lubricant, more likely. For example, when a lubricant is applied as an anti-rust film, the application instructions usually recommend that residual material be removed by washing or wiping the equipment before going back into production.

H1 is the only category registered for incidental food contact. Sometimes H2 is cited as also being suitable, but this is not the case as H2 lubricants are acceptable only in non-contact applications, where there is a physical barrier or other measures in place to ensure cross-contamination is not possible. H3 is a more limited-use category in which certain oil ingredients are classified as safe. H3 lubricants are typically used to clean and prevent rust on hooks, trolleys and other similar equipment.

The easiest way to check if a lubricant is registered, and under what category, is to visit www.nsfwhitebook.org, which provides a list of all registrations.

Using food-grade lubricants does not, however, absolve manufacturers from any of their full food hygiene responsibilities. The term incidental contact means that the lubricant is not intended to come into direct contact with food under normal use conditions, but that in some instances, accidental contact with foodstuffs may occur. This means that production facilities must still take measures to ensure that the food product is not directly exposed to, and as a result becomes contaminated by, thelubricant. The most effective way to ensure this is to have a fully implemented HACCP plan in place, where exposed lubrication points are addressed as critical control points, together with detailed records of equipment cleaning and maintenance, as well as tracking and controlling the amount of lubricant consumed in processing operations and sourcing appropriately registered products from reputable suppliers.

International certification is well recognised and fast growing

The establishment of an ISO standard for lubricant use has given impetus to the growth of registered products, as it provides internationally recognised assurance of safety and quality and offers a standard that is readily accepted in most global markets.

The ISO 21469 standard builds on the basic H1 registration. Certified lubricants not only meet the formulation requirements established in 21 CFR, but they are also required to undergo risk assessment, testing, auditing and labelling review by an independent qualified third party such as NSF International. One of the key reasons that more lubricant manufacturers are certifying
their products to ISO 21469 is that this broader international standard applies to lubricants used in sectors beyond food processing, including food packaging, pharmaceuticals and animal feed. Moreover, once a manufacturer has achieved H1 registration, it is relatively easy to progress to certification under the full ISO standard.