Smooth running: a guide to food-grade lubricants
With many processors still confused about how to follow regulations surrounding food-grade lubricants, Elly Earls asks Fragol’s Andre Adam and the NSF’s Ashlee Breitner how the issues can be cleared up.
Lubricants may be unseen, but they play a critical role in the operation of food and beverage processing plants, reducing wear and tear and minimising energy consumption. Not only do lubricants need to ensure that machinery - which ranges from hydraulic systems and compressors to conveyor belts and high-temperature ovens - performs to its maximum capacity, they must also achieve this using ingredients that will not cause adverse effects if they are accidentally consumed in trace amounts by a customer.
There are many points in a food and beverage processing plant where lubricants could make accidental contact with a food or drink product. Compressors could blow out small amounts of oil with the compressed air, chains of conveyor belts could drip lubricant onto underlying machinery or production machine gears might lose lubricant while close to the product. While such incidences would just be an inconvenience in another industry, the consequences of a lubricant-contaminated product in the food and beverage sector are much more acute, particularly given the increasing focus on safety.
As such, the regulations surrounding the lubricants used in food and beverage processing equipment, applications and plants go well beyond the requirements and protocols for typical industrial lubricants.
Food-grade lubricant regulations explained
There are currently three classes of lubricant that can be used in food and beverage processing plants - H1, H2 and H3 lubricants - and these are chosen depending on the likelihood they will come into contact with food.
H1 lubricants are food-grade lubricants used in food and drink processing environments where there is some possibility of incidental contact with consumables. Lubricant formulations may only be composed of one or more approved basestocks, additives and thickeners listed in the FDA's 21 CFR 178.3750.
H2 lubricants are used on equipment and machine parts in locations in the plant where there is absolutely no possibility that the lubricant or lubricated surface will come into contact with food. Because of this, H2 lubricants do not have a defined list of acceptable ingredients, although they cannot contain heavy metals such as arsenic, lead or selenium, or carcinogens, mutagens, teratogens or mineral acids. They are not food-grade lubricants.
H3 lubricants, or soluble or edible oils, are used to clean and prevent rust on hooks, trolleys and other similar equipment. These are food-grade lubricants, but must be wiped off prior to use of the equipment.
Lubricant manufacturers can register their lubricants, as H1, H2 or H3, through either the National Sanitation Foundation (NSF) in the US or InS in Europe. These bodies review the products to verify they are within the FDA list of permitted substances and, if they are, add them to their list of approved lubricants. On the NSF website, the list, which now includes over 14,000 different incidental or no food contact lubricants, can be viewed at www.nsfwhitebook.org while InS' register is at www.insservices.eu.
NSF also has an ANSI-accredited ISO 21469 Certification Program (Safety of Machinery-Lubricants with Incidental Product Contact - Hygiene Requirements) that provides independent, third-party assessments of products' conformity to the hygiene requirements for the formulation, manufacture, use and handling of lubricants that may come into contact with food products during processing.
Confusion over lubricants in the food industry
Sounds pretty simple, right? Well, actually, there is a surprising amount of confusion across the food and beverage processing industry regarding which lubricants (food-grade or non-food-grade) should be used where and how these products should be used.
The first factor causing confusion is the term 'food-grade'. Despite the widely accepted use of the term 'food-grade' in the industry to mean suitable for direct contact with food, drinks or other edible products, 'food-grade' when it comes to lubricants means the product is suitable only for incidental contact. Indeed, the FDA limits lubrication contamination to 10 parts per million, or 0.001%, which means that if more than trace amounts of lubricant come into contact with the food or drink produced, it is no longer suitable for commercial purposes whether the lubricant conforms to H1 standards or not.
This means that food processing plants still need to take measures to ensure that food products are not directly exposed to food-grade lubricants. This can be achieved by implementing an effective hazard analysis and critical control points (HACCP) plan, where exposed lubrication points are addressed as critical control points (CCPs). However, many stakeholders - largely local, rather than international processors - do not recognise the importance of lubrication surveys within their HACCP plans.
"Stakeholders are aware of the regulations, but the challenges in the industry seem to be more on educating the end-users on the proper use of techniques and applications applicable for the products to be used effectively," confirms Ashlee Breitner, business unit manager of the NSF Nonfood Compounds Registration programme. "The current challenge in the industry is the education of the long standard industry term of 'food-grade' and that it does not imply that it is safe to be put into/onto foods for consumption."
The second major factor causing confusion within the industry is the difference between H1 and H2 lubricants. While H1 lubricants can be used at points in a processing plant where it is possible they will come into contact with food or drink, H2 registered products are 'no food contact' lubricants, so they can only be applied in locations where there is absolutely no possibility of cross-contamination.
But, according to Andre Adam, global sales director at food-grade lubricants manufacturer Fragol and chairperson of the H1 Food Lubricants Working Group, under the European Lubricating Grease Institute (ELGI), this is not understood by everybody and, even in cases where it is understood, the rules are not necessarily followed. "It gives the industry excuses," he remarks. "Stakeholders will say they are using H2 lubricants for the food industry, but H2 is absolutely not for food contact. For this reason, a large part of the industry feels that H2 should be banned, thrown out, not used."
Education on H1, H2 and H3 lubricants is needed
So what can be done to reduce confusion and ensure that food and beverage processing industry stakeholders are following regulations to the letter, therefore ensuring the safety of their customers? For both Breitner and Adam, it's all about education.
"The industry is working hard to educate others about the term 'food-grade'," Breitner emphasises. "This education of how these products are intended to be used in the processing facilities is a major industry undertaking."
Adam agrees. "Training on how lubricants should be used is the most important thing," he says. "In fact, we are actually writing two flyers now - one for the workshop floor so the people operating the machines and lubricating the equipment understands what they're doing, and one for the management, detailing the rules, guidelines and regulations."
According to Adam, though, lubricant manufacturers need to take some responsibility too. "The lubricant industry should take a responsible role by not misleading customers," he stresses. "H2, for example, basically misleads the customer because you give them a feeling of food safety, but actually these products have nothing to do with food safety. They don't fit into an HACCP plan."
Moreover, an all-encompassing international standard for food-grade lubricants could significantly improve matters, Adam believes. "Food is a global thing, so you have to control it globally," he notes.
In the meantime, however, Breitner believes things are improving. Not only is the number of food-grade lubricants fast increasing because of a growing demand from food and beverage processors that want to maintain the highest possible level of food safety (there are now 14,000 registered products on the NSF's safe list, compared to only 10,000 in 2009), knowledge about the correct procedures to follow is on the up too.
"With the Food Safety Modernization Act (FSMA) on the minds of food manufacturers and the suppliers of non-food compounds, the growing need to ensure that the products they are producing and the processes they are using are creating safe and effective products, is a growing trend," she concludes. "Companies will continue to devote more resources to the inspection of the facilities to ensure that the necessary controls are in place to protect the health of the consumer."
Safe and high-performing: the latest H1 food-grade lubricants
Food-grade lubricants didn’t used to be as high-performing as their traditional counterparts due to the fact that they had to be made from ingredients specified on the FDA’s 21 CFR 178.3750. However, with growing demand as well as advances in technology and chemistry, this is no longer the case, and food-grade lubricants can now both increase users’ productivity and meet the industry’s stringent regulations.
An example of this is Fragol's line of H1 lubricants, which includes compressor and vacuum pump oils, gear oils, hydraulic fluids and greases, and is produced in an ISO 21469 certified plant, is H1 registered with InS and is certified Kosher and Halal. Another example is Rocol's FOODLUBE solutions, which improve operating efficiency, are NSF H1 registered for absolute food safety and are supported by a proven lubrication management strategy, which is easily integrated into any HACCP plan.
Exxon Mobil, too, offers a range of NSF H1 registered food machinery oils and greases to help food and drink manufacturers increase productivity and reduce their energy consumption while ensuring food safety. "Our Mobil SHC Cibus Series lubricants are expertly formulated to help food and beverage processors meet their application-specific goals and provide valuable sustainability-related benefits, such as enhanced energy efficiency and extended oil drain intervals," says Rainer Lange, Mobil SHC brand advisor - EAME, ExxonMobil Fuels & Lubricants. These NSF H1-registered lubricants are produced in facilities that have earned ISO 22000 certification.