The Food Grade Lubricant Working Group within the European Lubricating Grease Institute (ELGI) is on a mission. Lately, some misconceptions have arisen in the marketplace regarding food-safe lubricants, and a few “food scares” have made the headlines. So in July, the working group released a position paper titled “The Selection and Usage of Food Safe Lubricants.” Andre Adam, chairman of the working group, who is sales director at Fragol GmbH & Co., hopes that the ELGI position paper will help educate both users and grease manufacturers.
Food-safe lubricants are used in facilities that make food products, pharmaceuticals, animal feed, cosmetics, tobacco and food packaging. Adam estimates that the total market size for food-grade lubricants is about 14,000 tonnes per year. He estimates that 7,000 products are currently registered as food-grade lubricants.
There are several categories of food-grade or food-safe lubricants. However, the only category that is truly food safe is known as H1. H1 lubricants are those that are approved for incidental contact with foodstuff. This means that, while it is not expected that machinery lubrication could leak into the foodstuff from gearboxes or other parts of machinery, this lubricant would be harmless to humans, up to a certain amount. One common misconception is that if a lubricant is food safe, then it does not matter how much gets into the food. This, Adam says, is not true. If fluid leaking into the food is discovered, that food should be thrown away.
“Some oil companies make claims like ‘our oil is so clean you can eat it,’” says Adam, “but we totally want to avoid the impression that oil is going into the food.”
The largest motivation for using H1 lubricants throughout a production plant is the Hazard Analysis of Critical Control Points (HACCP). Spearheaded in the 1960s when NASA was looking to ensure the safety of astronauts’ food, HACCP is the principle that every plant needs to conduct an analysis to look for and address potential points of danger. If a lubricant is in fact found in food, the plant will be at fault because it did not properly complete its HACCP.
“From a safety point, it is advisable and recommended to use H1 lubricants across all feasible applications,” the ELGI position paper reads. The working group recommends this both above and below the production line, and points customers toward resources for switching over to becoming an all-H1 facility. According to Adam, many companies implement H1 practices throughout the entire food chain, including packaging, to keep the food as safe as possible and to protect their brands.
Besides H1, there are other categories of lubricants that can be used in food production facilities, such as H2 and H3. The United States Department of Agriculture (USDA), which used to administer the registration of food-grade lubricants, created these designations. However, the USDA no longer certifies foodgrade lubricants. This has been left to private-sector companies such as NSF International based in Chicago, Ill., U.S.A., and InS Services UK Ltd. (InS) based in Staffordshire, U.K.
H3 refers to rust protective lubricants applied to hooks and knives that must be wiped off the equipment before it comes into contact with food. H2 and H3 lubricants are not approved for contact with food at all. Adam says that at times, commercial interest has led some companies to advertise H2 lubricants as food safe, which is misleading, because H2 lubricants are not to be part of any HACCP plan.
There is a different category of products, 3H, which are for mould release. They are in the category of food additives, not lubricants. However, these categories overlap, because 3H products are sometimes also registered as H1. This is necessary if the 3H product is used to lubricate a mechanical part. 3H products are permitted up to a certain amount, as outlined in the U.S. Food and Drug Administration’s (FDA) Code of Federal Regulations, Title 21. ELGI’s position paper makes clear that 3H products are not approved for incidental food contact unless they are also registered as H1.
“[T]hese are incidental contact products subject to limitations,” the ELGI position paper says. “Remember, the use
of the product has to be taken into account… if they are designed to be used as equipment lubricants they usually have H1 registration too.” A common misconception is that if a lubricant is designated as 3H, then it is safe. “Customers can be confused by the various categories that are being thrown around,” says Adam. To make matters worse, companies sometimes market their 3H products as food safe regardless of whether they have also been H1 approved, either due to “clever marketing” or lack of education, he says.
Registration as an H1 lubricant means that the product complies with the FDA’s 21 CFR 178.3570 criteria. To apply for registration, a manufacturer sends a letter with the components of the product, and NSF or InS checks to see if the list meets the requirements. Upon registration, the product receives new logos and registration certificates.
Certification is different from registration. It involves a yearly audit, the requirements of which come from ISO standard 21469, Safety of Machinery—Lubricants with incidental product contact—Hygiene requirements.
Adam calls the ELGI position paper the “first phase” of more education that the working group plans to put out on foodsafe lubricants. “We wanted to start with something that would get a buy-in from all the responsible food-lubricant producers,” he says, “and can safely say that this document is supported by all major players in the food lube business in Europe.”
There is support from beyond Europe as well. ELGI’s North American counterpart, the National Lubricating Grease Institute (NLGI), shares similar views as ELGI. At the NLGI Annual Meeting in June, the Food Grade Working Group agreed that both organisations should jointly issue the position paper to achieve the largest impact globally. At the time of this writing, the NLGI Food- Grade Working Group was still soliciting comments. The group plans to present its recommendations to the NLGI Board of Directors in September.
“As food safety is a globally reaching topic in today’s business, the working group feels it is necessary for education on the use of food-grade lubricants to be on top of the minds of all in the industry,” said a representative from the NLGI working group. Adam explains that the ELGI working group’s role is more focused on regulations than on the technical aspects of food grade lubricants, “because at the end of the day, food grade lubricants should be compatible with other lubricants in all ways except for an additional safety measure.”