The last few months have understandably been dominated by discussions on listeria in processed ready to eat meat and chicken products. The recent Listeriosis outbreak associated with polony has resulted in the amendment to the HACCP regulation and Regulation 607 of June 2018 now makes it compulsory for producers of ready-to-eat processed meat and chicken products to implement a certified HACCP system.
Does your hazard analysis include lubricants?
The last few months have understandably been dominated by discussions on listeria in processed ready to eat meat and chicken products. The recent Listeriosis outbreak associated with polony has resulted in the amendment to the HACCP regulation and Regulation 607 of June 2018 now makes it compulsory for producers ready to eat processed meat and chicken products to implement a certified HACCP system.
While there is a lot of focus on the biological hazards it is important to also consider chemical hazards. There are very few food industries that do not rely heavily on the use of moving equipment. Mixers, stirrers, conveyors, extruders, slicers and many more are part of our day to day activities. Moving parts require lubrication and lubrication means introducing a non-food compound into a food environment and this can result in contamination.
A lubricant used in the food industry is still essentially an industrial product and must perform the same technical functions as any other grease or oil. These include protection against wear and tear, friction, corrosion and oxidation, dispersion of heat and transfer of power. They must also be compatible with rubber and other sealing materials and in some cases even provide a sealing function.
In addition, another key aspect is different for food companies is that lubricants must resist degradation from food products, chemicals and water/steam. The lubricants must also not interact with plastics and elastomers and must also have the ability to dissolve sugars. These oils must physiologically inert, tasteless and odourless.
The environment in a food facility also poses challenges to the lubricant as there may be concentrated environmental pollutants such as dust and in a meat or chicken processing facility, there is an extremely high risk of water contamination due to cleaning programmes. Food-grade lubricants can even promote the growth of micro organisms.
The main concern with lubricants used in the food industry is the formulation and ingredients. Does the product contain any harmful substances that could harm the health of the consumer if your product was accidently contaminated?
The NSF nonfood compounds registration programme was designed to ensure that lubricants are safely formulated to manage this chemical risk. No registered lubricants may contain carcinogens, mutagens, teratogens, mineral acids or heavy metals. In addition, registeres lubricants are classified in terms of the uses and permitted formulations as follows:
NSF H1 lubricants
These are lubricants created for incidental food contact and used where contact may potentially occur. This contact is restricted to a trace amount with no more than 0.0001% permitted or the product will be considered unsafe for consumption. The formulation of H1 lubricants must comply with FDA 21 CFR, 178.3570 or other applicable CFR sections and may only contain certain types of base stocks, additives and thickeners.
NSF H2 lubricants
H2 lubricants are predominantly used on equipment in food processing facilities, but there must absolutely be no possibility of contact with food. Although most substances used to make lubricants are accepted in H2 formulations, there are restrictions due to the risks in toxicology and other considerations in regards to production and implementation.
NSF H3 lubricants
H3 lubricants are food-grade lubricants that are typically edible oils, used to prevent rust on hooks, trolleys and similar equipment. A key difference with these food grade lubricants and others is that these lubricants may only contain edible oils that satisfy FDA 21 CFR 172.860 (these include corn, soybean or cottonseed oils), types of mineral oils that meet FDA 21 CFR 172.878, and oils that are generally recognised as safe under either FDA 21 CFR 182 or FDA 21 CFR 184.
Make the right choice
Selecting whether to use an H1 or H2 lubricant can be challenging. A lubricant used on a conveyor system running over a food line must be an H1 category oil. H2 lubricants should not be used where there is any possibility for food contact.
In the design of your HACCP system, each lubrication point should be evaluated for where lubricant contamination might occur. Ensure you conduct a detailed survey and enlist the help of your supplier if necessary. One of the most effective ways to manage a potential hazard in your facility is to simply exclude it. By using the appropriate registered lubricants will go a long way to ensuring you do not inadvertently introduce chemical hazards into your product and process.
References:
https://www.machinerylubrication.com/Read/1857/food-grade-lubricants-basics
NSF International evaluates and registers lubricants, based on requirements originally developed by the U.S. Department of Agriculture. Today this registration has a global reach with products produced in over 50 countries (including South Africa) and continues to grow as food safety becomes increasingly important to consumers, producers and regulators. Be sure to ask your lubricant supplier if their products are NSF registered.
