Finding Your Way Around the Food-grade Lubricants Maze
Tribology & Lubrication Technology, Nov 2007 by Profilet, Rob
Feel like you're in a maze without a map when you are trying to figure out the regulations and registrations that impact nonfood compounds such as lubricants? Here are some tips to help you find your way around.
Background
Historically, the U.S. Department of Agriculture (USDA) approved incidental food contact lubricants used in meat and poultry facilities. Approval relied on the Food and Drug Administration (FDA) guidelines that define approved components for use in incidental food contact lubricants. These approvals became industry-accepted and carried over to other food industry segments. Although the USDA evaluated product formulations and reviewed labels, it seldom conducted testing. For products in compliance, the USDA issued a letter of authorization. Typically, both manufacturers and suppliers obtained authorization before marketing their food-grade lubricants.
For the most part, lack of resources ended the USDA authorization program in February 1998. There was a gap until 1999, when NSF International stepped in to meet the risk management needs of food product manufacturers, processors and regulators. Relying on the FDA guidelines, NSF manages a registration process for nonfood compounds, including lubricants used in and around food-processing.
Registration and Certification
Registration is neither ominous nor obligatory. In fact, the United States has no legal requirements for registering-with NSF or anyone else-a lubricant used in food processing. However. NSF registration is becoming an industry standard in the U.S. and globally. In addition to NSF. ISO 21469 is being developed for incidental food contact lubricants. There is significant debate in the industry about the value of imposing this additional standard, which appears to only add cost.
On top of NSF registration, some food plants require kosher and/or halal certification. In Yiddish, kosher means sanctioned by Jewish law. Kosher certification means ritually fit for use, according to Jewish law. Halal is Arabic for permissible. It means sanctioned by Islamic law and ritually fit for use. according to Islamic law. Both halal and kosher have specific certification processes.
To minimize risk exposure, food companies and lubricant blenders should make every effort to comply with food grade guidelines. Additionally, additive component and lube suppliers must follow good manufacturing practice protocols while manufacturing these lubricants. These protocols include having a dedicated plant (vessels, piping, and storage and packaging equipment) so there is no risk of contamination from nonfood approved lubricants.
NSF Lubricant Categories
There are three main categories of lubricants used in the food industry.
1. H1 - Lubricants that could have incidental food contact when used on food-processing equipment as a protective antirust film, as a release agent on gaskets or seals of tank closures, or as a lubricant for machine parts and equipment in locations where the lubricated part is potentially exposed to food.
2. H2 - Lubricants with no possibility of contacting food. These compounds may be used as a lubricant, release agent or antirust film on equipment and machine parts or in closed systems in locations where there is no possibility of the lubricant or lubricated part contacting edible products.
3. H3 - These soluble oils may be applied to hooks, trolleys and similar equipment to clean them and prevent rust.
Market Trends
Estimates are that 60% or more of U.S. food and beverage companies are not using incidental food contact lubricants. Companies that comply tend to use both HI and H2 lubricants in their plants, increasing the possibility of using the wrong lubricant for the application. One reason these companies may use both lubricants in a location is because they have performance concerns or are not knowledgeable about the requirements. One accomplishment of the NSF program is that it has heightened industry awareness about using HI lubricants.
Certain food equipment manufacturers (OEMs) offer their own branded H1 lubricants, which they recommend for use in their machinery to maintain the warranty. ISO 21469 may become effective in early 2008 or 2009 creating new requirements.
Finally, growing affluence in countries such as India and China is increasing demand for prepared foods. Accordingly, global companies are setting up shop in these countries. Localized, manual food operations are turning into large, mechanized operations. So far, food processors in these countries tend not to use H1 lubricants. But that will change as Asia's food processors invest in new plants and equipment and want to use the appropriate lubricants. Once food manufacturers have invested in quality equipment, they'll also want to ensure that it runs efficiently. That means using the right lubricant. The growth in Asia is an emerging trend, and we may not see its impact for two or three years.
The Lubricant's Role
The food industry uses lubricants ranging from hydraulic fluids, gear oils, oven chain oils, compressor oils, and vacuum pump oils to specialty lubricants such as can seamer oils. Due to the diversity, plant managers realize that a single lubricant cannot handle all these needs.
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