HACCP International’s certification requirements go beyond formulation
Within almost all food manufacturing processes there are opportunities for lubricants to come into contact with food and food packaging. Lubricants from compressor equipment can contaminate the compressed air that contacts food, conveyor chain lubricants can come into contact with food products as they move from place to place during manufacturing and gear boxes can release oils and greases. Lubricants are also deliberately made to contact food when used as release agents used to prevent food sticking to grills or baking pans.
Food manufacturers are required to use lubricants that are safe for their intended use. Lubricants for use in food processing areas are commonly marketed as ‘Food Grade’. Food grade lubricants are supposed to have a low level of toxicity and are usually formulated to be a pale or clear colour and have a low odour. However, to be truly safe for use around food, lubricants need more than just a low-tox formulation.
Contrary to popular belief, there are no formal, government-regulated rules or laws that specifically define an appropriate, low-toxicity, ‘food grade’ lubricant. In the absence of such rules, a commonly used means of designating a lubricant ‘food-grade’ is NSF registration. NSF is a private American product testing, inspection and certification company.
Commonly, a designation of ‘food-grade lubrication’ can be based on the completion of a formulation review, and a review of label contents. Unfortunately, while an appropriate formulation makes an important contribution to food industry lubrication, there is much more to food safety than just chemical toxicity. A review based only on chemical toxicity does not address biological hazards or physical hazards to food safety from lubricants used in critical areas.
With a focus on formulation as a means to designate a lubricant ‘food grade’, it is easy for some lubricant manufacturers to overlook the necessity to manufacture, pack and store lubricants such that they are hygienic and free from contamination which could lead to hazards in the foods with which they make contact.
A full assessment of the food safety profile of a lubricant should extend far beyond the traditional boundaries of checking formulations. According to the most widely accepted method for managing food safety, the HACCP protocols, which are codified by the World Health Organisation, food safety depends on the identification and minimisation or elimination of physical and biological hazards as well as chemical hazards. As such, formulation-based evaluations of ‘food-grade’ lubricants are missing two thirds of the story. Martin Stone, HACCP International’s Technical Director explains; “A food-safe lubricant is one that does not introduce chemical, physical or biological hazards to food processing areas.”
Beyond formulation; a holistic approach
HACCP International evaluates lubricants for their suitability for use by the food industry using HACCP International’s standard for food-safe equipment, materials and services. The standard utilises a risk analysis approach that considers food safety risks arising from chemical, physical and biological hazards that could be presented by materials such as lubricants when used in food handling facilities.
The HACCP International standard takes a holistic approach to food safety, considering both the intended applications of use for the material being assessed as well as possible consequences from unintended use or errors in use. Food safety risk assessments are conducted by expert food safety personnel who investigate the product thoroughly, performing a hazard analysis for chemical hazards (including allergens), physical and biological hazards.
An evaluation of a lubricant for use in a food manufacturing process typically includes an in-depth consideration of the points listed below.
Chemical hazards and controls
Is the lubricant formulation such that has low mammalian oral toxicity?
In the event of unintended or unexpected contamination of food in an error scenario what are the likely outcomes for consumers of the food?
Is the lubricant manufactured, stored and transported using systems that will effectively prevent contamination with non-ingredient chemicals during batching, blending, packing and storing processes?
Is the lubricant formulated to be free from common human food allergens?
Is the lubricant manufactured, handled and stored using systems that will effectively prevent inadvertent contamination with common human food allergens?
Is appropriate information about the presence and absence of human food allergens made available to food industry purchasers and users of the lubricant?
Is the lubricant designed, marketed and/or supplied with information available at the point of use such that it would be clear to the user about where and how it should be used within a food manufacturing facility?
Is the lubricant sold with instructions for use that reduce the likelihood that it will be over-applied such that excess product could be present in food handling areas?
Is the lubricant manufactured using systems such that it can be expected to be manufactured in a consistent manner to the appropriately controlled formulation?
Are compliant safety data sheets (SDSs) made available to purchasers of the lubricant?
Physical hazards and controls
Is the lubricant manufactured in such a way that it is protected from contamination with dust, dirt, swarf, wires, machine parts and other foreign objects during batching, blending and packing?
Is the lubricant packed and transported to adequately protect it from dust, dirt, hair and other foreign objects during transportation and storage?
Is the lubricant packaging free from small loose parts that could become a hazard in a food factory?
Is any dispensing and application equipment supplied with the lubricant free from small parts that could become physical contaminants in a food handling area?
Are packaging parts and dispensing accessories such as lids, tubes or straws brightly coloured and firmly affixed to reduce the likelihood of them getting lost in a food handling area?
Biological hazards and controls
Is the lubricant manufactured with components that are commercially sterile?
Are components, packaging materials, manufacturing equipment and work-in-progress products protected during manufacture, packing and storage from dripping condensate, birds, rodents, insects and workers hands?
Is the lubricant manufactured under conditions that protect it from the ingress of bacteria, viruses, yeasts, moulds and protozoa pathogens that could present a risk to human health?
Is the lubricant protected from biological hazards during packing, transport and storage?
Risk-based hazard identification
Stone explains: “Depending on hazards identified during the risk-based evaluation, we may send an experienced auditor to examine manufacturing processes such as batching procedures, manual handling activities or methods for cleaning of mixing vessels between batches.”
Beyond food safety there are other product characteristics that can affect a lubricant’s suitability for use in the food industry. For this reason, when evaluating lubricants for the purposes of certification, HACCP International also asks:
Is each unit of lubricate labelled with a lot Identifier to allow for full traceability in the event of a food safety problem?
For lubricants designed with direct food contact applications (such as pan release agents), is appropriate information about the components available to users?
Is the lubricant free from strong odours that could taint food?
Stone says: “We are concerned by the food industry’s reliance upon simple formulation reviews for food safety, since the process does not address all the potential food safety risks posed by lubricants. I’m pleased that the HACCP International certification programme does take these important risks into account and mandated by the HACCP methodology.”